17 Q Who was in charge of the Chris Wolf
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?
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?
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
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?
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
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
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
1 based on the evidence?
2 MR. MILLER: Do you understand the
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
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
24 Q I don't either but that's the -- you
25 wouldn't view as it as exculpatory?
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
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
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
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.
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
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
2 A Again, to the best of my recollection,
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
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.
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,
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.
1 MR. WOOD: I haven't asked about everybody
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
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
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
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
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.
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
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
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