"Thomas deposition - part 1"
I am cleaning it up to post - - taking out page numbers and making it more "user friendly" so this will
take a while.
Part 1 follows:
Deposition of Steven Thomas September 21, 2001
For the Plaintiff:
DARNAY HOFFMAN, ESQ. (By telephone)
For the Defendants:
JAMES C. RAWLS, ESQ.
L. LIN WOOD, ESQ.
For the Deponent:
CHARLES P. DIAMOND, ESQ.
SEAN R. SMITH, ESQ.
JAY R. REN, CLVS
TODD TOMPKINS, Videographer Intern
O.M. "Ollie" Gray
Deposition of Steven Thomas
September 21, 2001
VIDEO TECHNICIAN: The time is 9:07. We're on the record. This is the deposition of Steve
Thomas for the case of Robert Christian Wolf versus John Bennett Ramsey and Patricia Paugh
Ramsey, Case Number 00-CIV-1187 in the U. S. District Court, Atlanta Division, State of Georgia.
Today is September 21st, 2001.
We are located at 1100 Fourteenth Street, Denver, Colorado. The court reporter is Kelly Mackereth of
Boverie, Jackson, Busby and Speera. The videographer is Jay R. Ren, certified legal video specialist
for Ren Video Services.
The attorneys will identify themselves beginning with the attorney on the left and the deponent's
MR. WOOD: My name is Lin Wood. I represent John and Patsy Ramsey.
MR. RAWLS: I'm Jim Rawls. I'm co-counsel with Lin Wood representing John and Patsy Ramsey.
MR. GRAY: My name is Ollie Gray. I'm an investigator in this case.
MR. DIAMOND: I am Chuck Diamond of O'Melveny & Myers representing the witness, Steve
MR. SMITH: I'm Sean Smith, and I also represent Steve Thomas.
VIDEO TECHNICIAN: Also, on the phone.
MR. WOOD: Your turn, Darnay.
MR. HOFFMAN: I'm Darnay Hoffman, and I represent the Plaintiff, Robert Christian Wolf.
VIDEO TECHNICIAN: The reporter will now swear in the witness.
MR. WOOD: You ready for us?
VIDEO TECHNICIAN: Yes, we're ready to swear in the witness.
MR. WOOD: Would you swear the witness, please.
STEVEN THOMAS, having been first duly sworn, was examined and testified as follows:
EXAMINATION BY- MR.WOOD:
Q. This will be the deposition of Steve Thomas. The deposition is taken pursuant to the Federal
Rules of Civil Procedure and the Federal Rules of Evidence. The deposition is taken pursuant to
subpoena duly served and notice duly filed and also pursuant to the order and rulings of Judge Jewell
Carnes in denying Mr. Thomas' motion to quash the subpoena. And I would also note for the record
that within the ruling of Judge Carnes' counsel for Mr. Thomas and for the parties have agreed as to
the date and the location of the deposition.
I understand that Mr. Thomas will read and sign the deposition. We would agree that can be
undertaken before an authorized notary public. Everybody set?
MR. DIAMOND: Go ahead.
Q. (BY MR. WOOD) All right. Mr. Thomas, you've been sworn. Let me ask you for the record,
please, to state your full name.
A. My full name is William Steven Walton Thomas.
Q. You go by Steve?
A. I do.
Q. Do you have any preference? I'll probably call you Mr. Thomas but if you would rather I call
you Steve or something you just let me know?
A. Steve, Mr. Thomas.
Q. All right. I may bounce back and forth. What is your --
MR. DIAMOND: Let's stay on a last-name basis. It is a sworn testimony.
MR. WOOD: Yeah.
Q. (BY MR. WOOD) Well, let me ask you this if you would, Mr. Thomas, would you give me your
present residence address?
A. (redacted portions will be left as blank fields)
MR. DIAMOND: That's what I think he wanted.
Q. (BY MR. WOOD) Do you have any present plans to move from that residence?
A. Ultimately I will leave Colorado but, no, for the moment, that's where I'm residing.
Q. Do you have any plans even though they may be tentative in terms of when you would hope to
A. Certainly not before this matter is resolved.
Q. This matter being the Chris Wolf case or this matter being the lawsuit filed by John and Patsy
Ramsey against you?
Q. Okay. So we would be safe to say you're here in Colorado at least through the duration of those
two matters; is that true?
MR. WOOD: (First part redacted) ... take it. If you have an instruction to the witness to make, make
it and we'll move onto the next question.
MR. DIAMOND: We'll designate that confidential. We can talk about that at the conclusion of the
MR. WOOD: Sure. We're going to have at some point a protective order to present you with that you
all will have the opportunity to sign onto.
MR. DIAMOND: Yeah, I've seen that.
MR. WOOD: Yeah, and that would protect that information if he wants to give it to me. If you all
want to then designate it within the time period allowed by law so subject to that designation I
you will let him answer.
MR. DIAMOND: I will.
Q. (BY MR. WOOD)
MR. DIAMOND: Do you know? If you don't know, you don't know.
Q. (BY MR. WOOD) That's something you could get copies of down the road if we need it I'm
A. I'm sure we have those somewhere.
Q. Okay. Do you have any other -- do you engage in any other present activities for compensation
in terms of trying to earn money, other than your business as a carpenter?
A. Occasionally I'm asked to speak.
Q. Speak in what capacity?
A. Occasionally I'm asked to speak to different groups, law enforcement primarily.
Q. Do you solicit invitations to speak from organizations?
A. Recently we have in conjunction with some defense fund raising.
Q. When you say "we have" who is we?
A. People who are helping me with that legal defense fund raising.
Q. Who is "we" then, please, by name?
A. Sherill Whisenand.
Q. Anyone else?
Q. And what is Sherill Wisinhunt?
MR. DIAMOND: Whisenand.
Q. (BY MR. WOOD) Whisenand. When did you first meet her?
A. I probably first spoke with her in 1999.
Q. And who is she employed with?
A. Currently I believe she's self-employed.
Q. What is the name of her company, do you know?
A. I also think she -- I do think she also has other employment but the name of her company is Wise
Q. Is she a public relations person?
A. I don't know how she bills herself.
Q. What do you see her as?
A. A friend.
Q. You don't know what her business is?
A. I know she works with Dr. Lauraas a producer with that radio show.
Q. You don't know what type of business she does in connection with her work Wise Connections?
A. Yes, she helps me with speaking.
Q. Did she form that company Wise Connections just to help you?
A. I don't know.
Q. Do you know whether it existed before she met you?
A. I don't know.
Q. How did you come to meet her?
A. Through a mutual friend.
Q. Who is that?
A. Anthony Robbins.
Q. Tony Robbins, the fellow we see on TV?
Q. And when did you -- I'm sorry. You first spoke with her, is that when you met her in 1999?
A. No, I did not meet her in personuntil some point after that. I spoke withher for a period of time
on the telephone.
Q. And I assume that that was in connection with, what, raising funds did you tell me?
A. At what point are you talking about --
Q. When you met --
A. -- when I first met her?
A. No, I wasn't raising funds in 1999. When I first met her was simply we struck up a friendship
when I was calling Tony Robbins' office.
Q. When did you get into, in effect, a business relationship with her, when did that start?
A. I think at some point I tired oftaking media calls and the calls for speakingand she volunteered to
take those for me.
Q. When did that happen?
A. Probably late '99, 2000, sometime during the calendar year of 2000.
Q. Or late the calendar year of 1999?
A. Possibly. I don't recall.
Q. Well, your answer was when I said when did that happen you said probably late '99, 2000,
sometime during the calendar year 2000; is that correct?
A. I'm trying to give you a sense for when that occurred.
MR. DIAMOND: What's your best recollection? I'm sorry, I lost the thread. The time period --
MR. WOOD: I'm trying to find out -- yeah, hold on one second, I'll tell you exactly. I asked him the
date of when he entered into, in effect, a business relationship with her, the date.
A. I think it would have been the calendar year sometime during 2000 because that's when the calls
and the requests came.
Q. (BY MR. WOOD) Let me see if this will help you. Was it prior to the publication of your book?
A. I don't recall, but as I mentioned I think when I had her take over these calls and requests was
after the flurry, after the book was released.
Q. Does that lead you to believe that in probability you did not engage in a business relationship with
Sherill Whisenand until after the April 2000 publication of your book "JonBenet, Inside the Ramsey
A. Well, there's not a bright line in my head because I still consider her a friend and when that
transitioned at some point to some business work the friendship certainly didn't cease and that doesn't
stand out in my head.
Q. Did you have any flurry of phone calls from the media prior to the publication of your book?
Q. Did you handle all of those or do you recall Sherill Whisenand handling some of them?
A. She may have handled some of those.
Q. So that tells me it may be that you were involved in a business relationship with her prior to the
publication of your book possibly?
A. Well, when you say business relationship --
Q. When she's handling media calls for you?
A. The fact that she took calls for me she certainly did that as a friend as well because she
volunteered to do that.
(Exhibit-1 was marked.)
MR. DIAMOND: Counsel, I expect you're going to tie this into a line of questioning that has to do with
the work that he did as a police investigator in connection with the Ramsey case?
MR. WOOD: Stay tuned. I'm going to let you look at it and I'm going to ask him questions about it.
MR. DIAMOND: Well, I'm going to limit you to that because that's what this deposition is about.
MR. WOOD: If you have an instruction under the Federal Rules of Civil Procedure to make, Mr.
Diamond, feel free to make it. I've asked you to take a look at this exhibit. I'm going to ask Mr.
Thomas to take a look at it. It's been marked for purposes of identification as Exhibit 1.
MR. DIAMOND: Go ahead.