17 Q Who was in charge of the Chris Wolf

18 investigation?

19 A There was no one particular person in

20 charge of the Chris Wolf investigation. It was a

21 team effort.

22 Q Of all --

23 A There were different aspects that people

24 would be involved in.

25 Q Of the entire Ramsey team?

69

1 A Um-hum.

2 Q Who were the members of the Ramsey team,

3 then, the detectives by name?

4 A Well, it's varied over a period of five

5 years and I don't even know if I could name all of

6 them for you. Certainly Tom Wickman, Steve Thomas,

7 Ron Gosage, Jane Harmer, Cary Weinheimer, Mike

8 Everett, Kim Stewart. And this was in October of

9 '97. But there were a whole lot of other people

10 involved at various times. Then, of course, you had

11 Mitch Morrissey, Bruce Levin, Mike Kane that came in

12 later. You had investigators with the DA's office

13 prior to that.

14 Q Had Chris Wolf been removed from under the

15 umbrella of suspicion prior to the time that Michael

16 Kane and Bruce Levin and Mitch Morrissey came into

17 the picture?

18 A I can only tell you to the best of my

19 recollection. I believe Mike Kane came on in spring

20 of '98. So no.

21 Q Would one of the factors in removing Chris

22 Wolf from under the umbrella of suspicion be the fact

23 that the Boulder Police Department had concluded that

24 it was probable that John Ramsey and Patsy Ramsey

25 were involved in the death of their daughter?

70

1 A No, I don't think so.

2 Q For example, if you as the chief of police

3 or as the commander in charge of the Ramsey

4 investigation state to your investigator or

5 investigators, members of your detective team, I

6 believe Patsy Ramsey killed JonBent, would you

7 expect that to have an impact on how that

8 investigator or detective would approach another

9 possible individual under suspicion such as Chris

10 Wolf?

11 A Would I expect it to? No.

12 Q Well, why not? I mean when the chief says

13 I believe Patsy Ramsey did this, how could that not

14 impact the efforts to investigate others?

15 MR. MILLER: Object to the form of the

16 question. Misstates testimony.

17 Q (BY MR. WOOD) Well, maybe I didn't lay

18 the foundation. Have you ever made that statement to

19 another detective in this case?

20 A I don't know, to be honest with you,

21 whether I have said that.

22 Q Well, Steve Thomas says in his book that

23 you did.

24 A Well, I don't know that I have.

25 Q Well, do you deny that?

71

1 A No. I don't know whether I have or not.

2 Q Well, does it sound like something that

3 you would have said to another detective?

4 A It may have been something that was said.

5 We've had, you know, hundreds of conversations about

6 hearings about this case. Maybe, I don't know. I

7 don't recall saying that specifically.

8 Q Well, I mean, Chief, that's not an

9 insignificant statement to come from the chief of

10 police or from the commander of the investigation. I

11 mean is it possible that you may have made similar

12 comments about other individuals?

13 A Sure.

14 Q That you believe some other person other

15 than John or Patsy might have been involved?

16 A Sure.

17 Q Do you have a recollection of doing that?

18 A I have a recollection of challenging

19 detectives in terms of some of the evidence and what

20 it means, sure.

21 Q But I'm really looking more for the

22 specific statement. I mean maybe that's the way, if

23 Thomas is accurate and says that Mark Beckner said I

24 believe Patsy Ramsey killed JonBent, would that have

25 been -- should that be interpreted as a statement of

72

1 your actual belief or is that a way that you might

2 challenge some findings or some information from a

3 detective? I'm not sure I'm following you.

4 A Yeah, because to this day I haven't come

5 to any conclusions on that. So what I would say is

6 it would probably be in the context of discussing

7 different theories about the case.

8 Q Because to this day, you have not

9 concluded yourself that Patsy Ramsey killed JonBen t?

10 A That's correct.

11 Q And would you expect then because the

12 question is how other detectives if they hear you

13 make statements like that, would you have expected

14 them to understand the context in which you would

15 make such a statement if you made it?

16 A I would --

17 MR. MILLER: Objection to the form of the

18 question.

19 Q MR. WOOD: Let me go back. I think the

20 chief answered, but would you have expected your

21 detectives if they heard you make a statement that

22 you believed Patsy Ramsey did this or you believed

23 that John Doe did this, that that would have been in

24 the context of discussing different theories about

25 the case as opposed to your stating your conclusion

73

1 based on the evidence?

2 MR. MILLER: Do you understand the

3 question?

4 THE DEPONENT: I think so.

5 A Hypothetically, yes.

6 Q (BY MR. WOOD) Hypothetically?

7 A Well, you're creating a hypothetical

8 situation --

9 Q Yeah, because you don't remember --

10 A I'm --

11 Q I'm creating --

12 A -- answering hypothetically.

13 Q I'm asking you because you don't recall

14 the situation as to whether that was actually said to

15 Steve Thomas?

16 A (Deponent nods head.)

17 Q But if said hypothetically about Patsy or

18 any other person, you would have fully expected

19 Detective Thomas or any other individual on the force

20 that you were talking to to understand you were

21 simply talking about one of many theories of the case

22 as opposed to making a statement of accusation or

23 conclusion, true?

24 A True.

25 Q And therefore, because of that, that's why

74

1 you would not have expected any such statement about

2 Patsy Ramsey or John Ramsey or John Doe or Jane Doe

3 to have impacted the detectives' degree of

4 investigative efforts toward other individuals under

5 suspicion, true?

6 A Correct.

7 Q Okay. Would the sexual orientation of

8 Chris Wolf have been a factor to be considered, that

9 is to say whether he was heterosexual, homosexual or

10 bisexual or I guess we could include, not with Wolf,

11 but we could throw in the category of asexual?

12 A That's not something you would throw out.

13 I mean, I'm not sure I understand.

14 Q If --

15 A You consider all information you get.

16 Q Right. But if hypothetically I ask you to

17 assume that Chris Wolf had confessed to one of the

18 detectives that he was a homosexual but no one in his

19 family or his friends had known that fact, would that

20 information have been viewed as exculpatory as it

21 related to the murder or death of JonBent Ramsey?

22 A I don't know why that would be seen as

23 exculpatory.

24 Q I don't either but that's the -- you

25 wouldn't view as it as exculpatory?

75

1 A No.

2 Q You would just view it as just one

3 additional bit of -- piece of information about a

4 person under suspicion, it may or may not have

5 relevance?

6 A Correct.

7 Q I mean there was no working theory that

8 this act could not or was not committed by a

9 homosexual, a male homosexual, was there?

10 A Are you asking me whether there was a

11 theory?

12 Q Right. Was there any working theory that

13 this was not the act of a male homosexual?

14 A No.

15 Q Okay. The background of Chris Wolf, did

16 you all obtain his criminal record, the Boulder

17 Police Department?

18 A I can't specifically remember that.

19 Q Would you have expected the detectives to

20 go back and pull his criminal record history?

21 A I would expect that.

22 Q Do you have any knowledge of Mr. Wolf

23 being arrested for public indecency and masturbation

24 prior to the death of JonBent Ramsey?

25 A No, we've looked at so many people I can't

76

1 remember -- distinguish to that detail.

2 Q Was Chris Wolf ever under suspicion in

3 connection with the death of Susannah Chase?

4 A I don't know that I would say he was under

5 suspicion for that.

6 Q How would you describe your department's

7 investigation of Chris Wolf in connection with

8 Susannah Chase --

9 A It may have been a lead that we would

10 follow up on to make a determination but I don't

11 believe he ever came under serious consideration.

12 Q Did he ever come under consideration?

13 A As a lead to follow up on.

14 Q Would that have been as a result of

15 information from Jackie Dilson or information gained

16 independent about Mr. Wolf and a possible

17 relationship with Susannah Chase?

18 A Again, just based on recollection, I

19 believe that also came from Jackie Dilson.

20 Q Did the department ever ascertain whether

21 in fact Chris Wolf acknowledged that he had and did

22 know Susannah Chase and perhaps had made overtures to

23 her about trying to go out with her on a date?

24 A I believe -- that sounds familiar. I

25 believe we knew that.

77

1 Q Would a given individual under suspicion,

2 the lack of or the fact of cooperation with

3 authorities factor in in terms of your assessment of

4 the person's status in the investigation?

5 A Repeat again.

6 Q With respect to an individual under

7 suspicion, obviously I take it that under the

8 umbrella of suspicion, there might be different

9 levels of suspicion; is that right?

10 A Certainly.

11 Q Would an individual's lack of cooperation

12 with authorities, for example in terms of being

13 interviewed, or the fact of cooperation with

14 authorities, for example on being interviewed, factor

15 in in the Boulder Police Department's assessment of

16 the individual's status under the umbrella of

17 suspicion?

18 A Yeah, it would be a factor.

19 Q Chris Wolf initially refused to cooperate,

20 didn't he, sir?

21 A To the best of my recollection, yes.

22 Q He refused to give a handwriting exemplar

23 in January of 1997?

24 A I believe so.

25 Q He refused to be interviewed in January of

78

1 1997?

2 A Again, to the best of my recollection,

3 yes.

4 Q He actually got physical and had to be

5 hobbled by Detective Thomas and I think Detective

6 Gosage; are you familiar with that?

7 A Yes.

8 Q You were aware that he had been brought

9 into the Boulder -- well, you learned that he had

10 been brought into the Boulder Police Department under

11 a ruse traffic stop in order to be interviewed?

12 A Well, I wouldn't agree that it was a ruse.

13 My understanding was he did have a traffic warrant

14 out for his arrest.

15 Q I don't want to quibble over the word

16 ruse. My understanding is they used the traffic, the

17 outstanding traffic citation to specifically and

18 intentionally bring him in to talk about the JonBent

19 Ramsey case?

20 A Correct.

21 Q Not to pick him up and by happenstance in

22 the process of so that -- I don't mean to have been

23 implying with ruse but clearly there was a plan

24 developed to use the outstanding traffic ticket to

25 bring him into police headquarters to question him

79

1 about the JonBent Ramsey case?

2 A That's my understanding.

3 Q And again we're assuming that was January

4 of 1997 and he was totally uncooperative; that's your

5 understanding, right?

6 A I don't know whether I could say totally.

7 I don't know whether I have enough knowledge of that

8 time frame to say that.

9 Q Do you have any knowledge that would

10 indicate that he in any way cooperated when he was

11 first brought in to the Boulder Police Department to

12 talk about the JonBen t Ramsey case?

13 A That would be something I would have to

14 review. I don't know.

15 Q But based on your recollection, you recall

16 that he was uncooperative in the sense that he would

17 not give a handwriting exemplar, he would not give an

18 interview --

19 A That's my --

20 Q -- he would not discuss his whereabouts?

21 A That's my understanding.

22 Q Was that publicly discussed by you or any

23 other member of the Boulder Police Department about

24 his level of uncooperation, failure to cooperate?

25 A I don't recall.

80

1 Q There was -- you know who Steven Pitt is?

2 A Yes.

3 Q What was his role?

4 A He was a forensic psychologist that

5 assisted us in the case.

6 Q What would a forensic psychologist bring

7 to the table?

8 A Well, he brings a lot in terms of

9 analyzing behavior, demeanor, statements, advice on

10 how to conduct interviews, advice on what questions

11 to ask, those areas.

12 Q Would he have been involved in a strategy

13 to bring public pressure on a given individual who

14 was under suspicion?

15 MR. MILLER: Objection to the form of the

16 question. I also object that it's outside the realm

17 of what we're talking about. If you're talking about

18 Chris Wolf --

19 MR. WOOD: I'm talking about matters that

20 it would seem to me to be applicable to Chris Wolf,

21 absolutely.

22 MR. MILLER: Well, I think if you've got a

23 question about Chris Wolf that ought to be the

24 question, but I don't think it should be a question

25 about everybody else.

81

1 MR. WOOD: I haven't asked about everybody

2 else.

3 MR. MILLER: I think that's the way the

4 question was framed.

5 MR. WOOD: Well, he told me about what a

6 forensic psychologist would bring to the table and he

7 gave me a number of areas and I asked him would he

8 also have been involved in a police strategy to bring

9 public pressure on a given individual who was under

10 suspicion.

11 MR. MILLER: Given individual, it seems to

12 me it's everybody, including Chris Wolf.

13 MR. WOOD: I think that's why it's related

14 to Chris Wolf.

15 MR. MILLER: But not specifically to Chris

16 Wolf.

17 MR. WOOD: Well, the question of whether

18 it should have been, if it existed, if the strategy

19 existed and there is evidence that I have that it

20 did --

21 MR. MILLER: What strategy are we talking

22 about?

23 MR. WOOD: Why would it not -- a specific

24 plan that involved Steven Pitt and others, including

25 Bill Hagamaier of the FBI, that was developed around

82

1 a strategy to bring public pressure on individuals to

2 either force them to cooperate or for other reasons

3 I'll discuss later. Let me establish the first.

4 Q (BY MR. WOOD) I'm right about the

5 strategy, am I not, it existed, Steven Pitt was part

6 of it and so was Bill Hagamaier of the FBI?

7 MR. MILLER: I don't think you ought to

8 answer that question. I don't think it's got

9 anything specifically to do with Chris Wolf.

10 MR. WOOD: I'm entitled to know whether or

11 not there was such a strategy because we now have the

12 chief acknowledging that in January of 1997 within a

13 month of this child's murder, Chris Wolf, who was

14 brought to the attention of the authorities by his

15 then live-in girlfriend who was at least credible

16 enough to bring this man in for questioning, who was

17 totally or at least to the chief's recollection at

18 least uncooperative on the question of giving an

19 interview and submitting handwriting exemplars, I

20 want to know whether he was part of the strategy that

21 I have evidence existed about bringing public

22 pressure on suspects or individuals under suspicion

23 to try to get them to cooperate. I think it's

24 absolutely related to Chris Wolf and I'm entitled to

25 an answer, Bob.

83

1 MR. MILLER: I don't see how it's related

2 to Chris Wolf. If you ask it in a specific reference

3 to Chris Wolf, I think he can answer it.

4 MR. WOOD: Why would it not be applicable

5 to Chris Wolf and others?

6 MR. MILLER: I don't know.

7 MR. WOOD: That is what I'm trying to find

8 out.

9 MR. MILLER: Well, but I don't think that

10 is purpose of this deposition. The purpose of this

11 deposition is, as our agreement says, to talk about

12 specifics as to Chris Wolf, not the rest of the

13 world, not the other suspects, not your other

14 clients.

15 MR. WOOD: Don't imply that my other

16 client, that Chris Wolf is a client.

17 MR. MILLER: I think that's got to be a

18 consideration.