By Travis Henry
The Daily Times-Call

BOULDER - Former Ramsey family friend Fleet White Jr. and
his wife, Priscilla, have filed a lawsuit in district court asking a
judge to order the Boulder Police Department to turn over
numerous documents related to the JonBenet Ramsey murder
investigation.

White, who was with John Ramsey when he discovered his
6-year-old daughter's body in the family's basement in
December 1996, is seeking documents pertaining to a California
woman's claim she was sexually assaulted as a child, according
to the lawsuit.

"During the (California woman's) investigation, plaintiffs
learned that (the woman) had falsely reported to the Boulder
police that she had been a victim of serious and violent crimes
committed by members of plaintiffs' family including plaintiff
Fleet Russell White Jr.," the lawsuit states.

"Additionally, (the woman) falsely reported that plaintiffs were
part of a child sex abuse conspiracy and that members of (the
woman's) family were present at plaintiffs' home on Dec. 25,
1996, at which time and place JonBenet Ramsey was sexually
abused and killed," the lawsuit continued.

Boulder police Chief Mark Beckner said on Thursday that his
department and the city plan to fight in court against turning
over the documents.

"We don't want to release information from an open and active
case file," Beckner said. "That has been our position for the
last five years, coming up on six."

The lawsuit could signal White is still attempting to pursue an
investigation against journalists who wrote stories mentioning
him in the JonBenet Ramsey slaying.

White first sought criminal charges after a series of stories in
which the California woman accused a group - some of whom
were reportedly in Boulder on the day JonBenet Ramsey was
killed - of sexually assaulting her as a child.

The woman said she was assaulted in much the same manner
as JonBenet and has known the White family since she was a
small child.

The woman's therapist later said the woman's allegations were
made four years before the slaying of JonBenet Ramsey and
documented at that time.

White's requests for a criminal libel investigation were
eventually dismissed.

According to the lawsuit, the district attorney's office has
handed over some of the documents related to the woman's
claims about the sex abuse, even though it is part of the
Ramsey investigation.

District Attorney Mary Keenan didn't return phone calls
Wednesday, but Beckner said his department worked with the
DA's office in deciding what could be released from the files.

Beckner said most of the information given to the Whites was
"pre-investigation" and wouldn't compromise the Ramsey
murder investigation.

Last October, White was sentenced to 30 days in jail after he
pleaded guilty to ignoring two subpoenas in a Ramsey-related
trial .

White was subpoenaed in May and June of 2001 to appear as a
witness in a criminal bribery trial. He said he chose not to
appear because he didn't think he had any relevant testimony
to give.

The case involved lawyer Thomas Miller, who was accused of
trying to buy a copy of the ransom note found in the Ramseys'
house. Miller was acquitted.

Travis Henry can be reached at 303-776-2244, Ext. 326, or by
e-mail at thenry@times-call.com.

The Whites were subjected to a lot of pain from that incident - - and if the accusations were false, then Fleet has a right to defend his reputation in court.

Beckner is wrong to deny Fleet those files. As for what they have to do with the Ramsey case - they will prove some very WRONG accusations were FALSE!

Come on, Mark, let the truth come out - - let the truth come out.

July 4, 2002

BOULDER, Colo.- Two former friends of John and Patsy Ramsey want a
judge to grant them access to some of the police files kept in the
JonBenet Ramsey murder investigation.

Fleet White Jr. and his wife, Priscilla, have asked officials to turn over
files involving a California woman's claims that the Whites were part of a
child sex abuse ring that contributed to JonBenet's death.

Police have said there is no evidence to support the woman's theory.

Six-year-old JonBenet Ramsey was found strangled in the basement of
her family's home in Dec. 26, 1996. Police have yet to charge anyone in
her death.

The Whites requested access to some of the murder investigation files in
a three-page document filed June 24 in Boulder District Court.

Police Chief Mark Beckner has repeatedly refused the Whites' request,
saying the file is part of the murder investigation and not subject to
disclosure under the state's criminal justice records laws.

Fleet White was with John Ramsey on Dec. 26, 1996, when Ramsey
found JonBenet's body.

The night before, the Ramsey family, including JonBenet and her
then-9-year-old brother, Burke, attended a Christmas party at the
Whites' home.

In a June 3 letter to Beckner, the Whites said that releasing the records
"will not injure the public interest since the false allegations reported ...
are not the subject of an ongoing police or prosecutor investigation."

Police chief refuses to hand over files, says they are part of
investigation

By Pam Regensberg, Camera Staff Writer
July 4, 2002

Fleet White Jr. and his wife, Priscilla, have asked a judge to determine if the city of
Boulder and Police Chief Mark Beckner should turn over files related to the 5-year-old
JonBenet Ramsey murder investigation.

In a three-page court filing, accompanied by letters and a newspaper article, the
former friends of John and Patsy Ramsey contend they should have access to the
investigative file involving a California woman who told police she believed JonBenet
was killed as part of a child sex ring.

Beckner repeatedly has refused the Whites' request for the file.

The Whites claim in the court document filed in Boulder District Court on June 24, the
woman falsely reported to police that the Whites were part of a child sex abuse
conspiracy. The woman, the Whites further claim, told investigators that members of
her family attended a 1996 Christmas party at the Whites' home where 6-year-old
JonBenet was sexually abused and killed.

The Whites said they never heard of the woman until a reporter called them in
February 2000 seeking comment on the allegations, according to the filing.

Fleet White was with John Ramsey on Dec. 26, 1996, when Ramsey found
JonBenet's beaten and strangled body in the basement of the Ramseys' 15th Street
home. The girl was asphyxiated with a garrote and had been hit on the head with a
blunt object.

The night before, the Ramsey family, including JonBenet and her then-9-year-old
brother, Burke, attended a Christmas party at the Whites' home.

In February 2000, police began investigating the California woman's claims. Eleven
weeks later the police issued a statement saying they found no evidence to support
her theory.

Investigators determined the woman, who lived near San Luis Obispo, was sexually
abused by a relative 20 years ago — but found no ties to the Ramsey case.

In a June 3 letter to Chief Beckner, the Whites said that releasing the records "will not
injure the public interest since the false allegations reported ... are not the subject of
an ongoing police or prosecutor investigation."

District Attorney Mary Keenan said Wednesday that her office has released some
information concerning the case to the Whites.

Beckner, however, has repeatedly told the Whites that the file is part of the murder
investigation and not subject to disclosure under the state's criminal justice records
laws.

"All the leads that we get are part of the Ramsey case file," Beckner said Wednesday,
adding the police file is substantially different from the prosecutor's file. "It's not a
separate crime being."

Contact Pam Regensberg at (303) 473-1329 or regensbergp@thedailycamera.com.

The BPD have the Ramsey-case public relations flacks on standby but nothing is happening. Certainly nothing ever would happen on the nutcase from SLO who accuses men of raping her who were two states away at the time.

LAST EDITED ON Jul-05-02 AT 09:53 AM (EST)

I've ALWAYS wondered why the White's are so quiet about all of this.

Why the big falling out with the Ramsey's? The only answers I've heard to that questions (ie mad that John got attorney; mad that John went to media -- are such bullshit.) I'd LOVE to know the truth.

It was 2-3 years ago that Nancy Krebs was telling her story. Personally, I'm not convinced that she IS a nutcase. Maybe Fleet himself wasn't involved. Before today, I NEVER heard that he was involved with Nancy -- only his father.

If it's true that she is kind of nutty, so to speak, and it's a far-fetched tale that she spins, then WHY do the police refuse to let Fleet in on it?

(edit to add, by "it" I mean the Ramsey case)

After all, if I recall correctly, the BPD are the ones that decided that Nancy was not believable. So, if the stories aren't true, then how does this affect the Ramsey case?

I wonder which high-up cop was involved with this case more closely than he's willing to admit? There's no other reason I can think of why they would totally botch this case and refuse help.

Personally, I respect law enforcement officials, but just not these ones.

Edit to note: The only way they will receive respect of any kind is to turn the case over to another agency.

I wonder what this is really about.

Plaintiffs:

FLEET RUSSELL WHITE, and
PRISCILLA BROWN WHITE
V.

Defendants: Court Use Only
THE CITY OF BOULDER, COLORADO
a Colorado home rule municipality and
MARK R. BECKNER, individually
and in his capacity as Chief of the Boulder
Department of Police and Custodian of Records for the Department of Police

Plaintiff filing Application for Order to Show
Cause without attorney:

Names: Fleet Russell White, Jr.
Priscilla Brown White
Address: (redacted)

APPLICATION FOR ORDER TO SHOW CAUSE

For its application for an order to show cause plaintiffs state as follows:

1. Plaintiffs Fleet Russell White, Jr. and Priscilla Brown White are husband and wife and are
residents of Boulder, Colorado.

2. Defendant City of Boulder is a Colorado home rule municipality located in the City of
Boulder, County of Boulder, Colorado.

3. Defendant Mark R. Beckner (“Beckner”) is employed by the City of Boulder as Chief of
Police of the City of Boulder Department of Police (“Boulder Police”). Beckner is custodian as
defined by CR S 24-72-302 (5) as evidenced by his control of Boulder police criminal justice
records in this matter.

4. By letter dated March 20, 2002 plaintiffs made a written request to Beckner to inspect and
copy all Criminal justice records relating to the concluded Boulder Police investigation of
reports of criminal conduct made by an individual identified to plaintiffs by the Boulder Police as
Nancy Jo Krebs (‘the Krebs investigation.). A copy of the March 20, 2002 letter is attached as
Exhibit I.

5 According to an official City of Boulder News Release dated May 15, 2000 the
Krebs investigation commenced no later than February 2000 and concluded on or about
May 15, 2000. A copy of the May 15, 2000 City of Boulder Press Release is attached as
Exhibit 2.

6. During the Krebs investigation plaintiffs learned that Krebs had falsely reported to the
Boulder police that she had been a victim of serious and violent crimes committed by members
of plaintiffs’ family including plaintiff Fleet Russell White, Jr. Additionally. Krebs falsely reported
that plaintiffs were part of a child sex abuse conspiracy and that members of Krebs’ family
were present at plaintiffs home on December 25, 1996 at which time and place JonBenet
Ramsey was sexually abused and killed.

7. Any report made by Krebs to the Boulder Police alleging criminal conduct by plaintiffs was
false. Plaintiffs have never met Krebs nor were plaintiffs aware of her existence until her
identity was given to plaintiffs by a reporter seeking plaintiffs’ comment late in the evening
prior the publication of Krebs’ allegations by the Boulder Daily Camera newspaper on February
25, 2000. The February 25, 2000 Boulder Daily Camera article is attached as Exhibit 3 By
knowingly making false reports to the Boulder Police, Krebs and possibly other individuals
involved in causing the transmission of Krebs’ false reports violated CR5 18-18-111(b) and (c)
and possibly other Colorado Criminal Statutes.

8. Any documents or materials made, maintained or kept by the Boulder Police relating to the
Krebs investigation are criminal justice records as defined by C.R.S. 24-72-302(4).

9. By letter dated April 2, 2002 Beckner denied plaintiffs’ March 20, 2002 written request for,
criminal justice records relating to the concluded Krebs investigation. In that letter. Beckner
stated that the JonBenet Ramsey homicide is still under investigation. Pursuant to CR8.
24-72-305(5), these materials are investigative files and are therefore not subject to disclosure
under the criminal justice records statutes.’ A copy of Beckner’s April 2, 2002 letter is attached
as Exhibit 4.

10. By letter dated April 25, 2002 plaintiff once again requested access to the criminal justice
records relating to the Krebs investigation. A copy of plaintiff’s April 25, 2002 letter is attached
as Exhibit 5.

2

11. By letter dated May 1, 2000 Beckner responded to plaintiffs’ April 25, 2002 letter by
denying our request for access to the criminal justice records relating to the Krebs
investigation. A copy of Beckner’s May 1, 2002 letter is attached as Exhibit 6.

12. By letter dated June 3, 2002, plaintiffs responded to Beckner’s letter of May 1,
2002, and once again requested access to criminal records relating to the Krebs investigation.
A copy of plaintiffs June 3, 2002 letter is attached as Exhibit 7.

13. By letter dated June 3, 2002, Beckner denied plaintiffs request for access to criminal justice
records relating to the Krebs investigation. A copy of Beckner’s June 13, 2002 letter is attached
as Exhibit 8.

14. The refusal of the Boulder Police and Beckner as custodian, to allow plaintiff to inspect and
copy criminal justice records relating to the Krebs investigation violates the Colorado Criminal
Justice Records Act, C.R.S. 24-72-301 et. seq.

15. C.R.S 24-72-305(7) provides that any person denied the right to inspect and copy any
criminal justice record may apply to the district court of the district wherein the record is found
for an order directing the custodian to show cause why he should not permit inspection and
copying of such record. The statute further provides that a hearing shall be held at the earliest
practical time.

16. The decision of the Boulder police and Beckner as custodian, to refuse to allow plaintiffs to
inspect and copy the criminal justice records relating to the Krebs investigation is arbitrary and
capricious, thereby entitling plaintiff to recover their costs pursuant to C.R.S. 21-72-305(7).

WHEREFORE, plaintiffs respectfully request that this Court enter an Order directing defendants
to show cause why they should not permit plaintiffs to inspect and copy criminal justice records
relating to the Krebs investigation. If this Court finds that denial or plaintiffs request was
improper, plaintiff requests that this Court order defendants to permit such inspection. Plaintiffs
further request that this Court award plaintiffs their costs and such further relief as this Court
deems proper.

Respectfully submitted this 24th day of June 2002.

Fleet Russell White, Jr.
Priscilla Brown White

PLAINTIFFS FILING APPLICATION TO SHOW CAUSE WTTHOUT ATTORNEY

3

CERTIFICATE OF MAILING

I hereby certify that on this 24th day June, 2002, the original of this APPLICATION FOR ORDER
TO SHOW CAUSE was filed with the Boulder
District Court, and that a true and accurate copy of this APPLICATION FOR ORDER
TO SHOW CAUSE was served on the other party by placing it in the United States
mail. postage pre-paid and addressed as follows:

The City of Boulder
Office of The City Attorney
Joseph N. de Raismes. JR
P0. Box 791
Boulder CO 80306

Mark R. Beckner
Chief of Police
City of Boulder
Department of Police
1805 33t Street
Boulder, CO 80301

Fleet Russell White, Jr. Plaintiff

EXHIBIT 1

Attached to Application for Order to Show Cause

Fleet Russell White and Priscilla Brown White
(address redacted)

March 20, 2002

Via Certified Mail

Mary Keenan
District Attorney
Twentieth Judicial District
P.O. Box 471
Boulder, CO 80306

Mark R. Beckner
Chief of Police
City of Boulder
Boulder Police Department
1805 33rd Street
Boulder, CO 80302

Subject: Request for Criminal Justice Records
Dear Ms Keenan and Chief Beckner,
Pursuant to Colorado statutes, we hereby request that all criminal justice records relating
to the investigation of the allegations of Nancy Jo Krebs be made available to us for inspection
and copying. Both of your agencies were involved in this investigation that commenced no later
than February, 2000 and ended on or around May 15, 2000 when City of Boulder news release
stated:

“Boulder Police and prosecutors have concluded an investigation that began in February when a
37-year-old California woman reported her belief that JonBenet Ramsey was murdered as part
of a child sex ring. The investigation found no additional evidence to support this theory.”

We would appreciate a timely response to this request.

Sincerely,

Fleet Russell White, Jr Priscilla Brown White

Exhibit 2
Attached for Order to Show Cause
News Release City of Boulder

May 15, 2000

Boulder Police end investigation into California woman’s report

Boulder Police and prosecutors have concluded an investigation that began in February when a
37 yea rold California woman reported her belief that JonBenet Ramsey was murdered as part
of a child sex ring. The investigation found no additional evidence to support this theory.

In February, The woman contacted the Boulder Daily Camera with allegations of a child sex
abuse conspiracy involving her own family members, the Ramsey family and close friends of
the Ramseys. The woman also claimed that some of her own family members were at a party
attended by JonBenet Ramsey and her parents on December 25, 1996, just prior to JonBenet’s
death. The woman believed JonBenet was likely killed at the party by adults who sexually and
physically abused her.

Boulder Police spent about 11 weeks investigating the allegations which included conducting 22
interviews, reviewing medical and psychological records, reviewing photographs and
recordings, consulting with a forensic psychiatrist, and comparing the allegations against
physical evidence and current knowledge of the case. As a result, Boulder Police and
prosecutors working on the case have concluded that other than the woman’s statements,
there is no evidence to support this theory of JonBenet’s murder.

“The Boulder Police have spent a significant amount of tine investigating the claims made by
this woman and her attorney.” Prosecutor Mike Kane said. ‘There is simply no credible
evidence to link anything she alleges to the death of JonBenet. The expenditure of additional
police and prosecutorial resources is unwarranted.

Boulder Police have made no judgments or conclusions about abuse the woman may have
suffered in prior years in California. It is well established that she was a victim of sexual abuse
in 1979-80, for which a suspect was arrested and convicted. However. current investigation did
not find any connection between the abuse she suffered and the death of JonBenet Ramsey.

Boulder Police have forwarded information to the FBI in reference to some of the woman’s
allegations regarding the operation of a child ring. Police also advised her to contact California
authorities with any information she has regarding crimes that may have occurred in California.
This is the second time Boulder Police have investigated the possibility of JonBenet’s death
being connected to a “sex ring” or pornographic operation involving numerous people. On each
occasion, no credible evidence was found to support such speculation.

“We needed to take the time to complete a thorough investigation. Police Chief Mark Beckner
said. Unfortunately, allegations have led to speculation that Fleet and Priscilla White, former
close friends of the Ramseys and hosts of the 1996 Christmas party, were somehow involved
in the sexual abuse and death of JonBenet. We have no evidence whatsoever to support this
and have never had evidence to support such an allegation. Nor do we have any evidence that
John and Patsy Ramsey were part of or participated in a child sex ring operation.”

Because she is a sexual assault victim, Boulder Police are not releasing the name of the
California woman.

Exhibit 3 is a copy of the front page article in The Boulder Daily Camera from Friday,
February 25, 2000 titled “DA pursues new Ramsey lead, and subtitled “Hunter asks police
to investigate woman’s story of sex abuse.” by Barrie Hartman

_______________EXHIBIT 4 _______________
Attached to Application for Order to Show Cause.
OF
BOULDER
DEPARTMENT OF POLICE

April 2. 2002

Fleet White. Jr
Priscilla White
(address redacted)
Dear Mr. and Mrs White:

I was out of state last week when your certified letter was delivered to my office. I returned to
the office today and found your two “Request for Criminal Justice Records” which were
contained in the certified letter. You have requested that “criminal justice records” on two
matters be made available to you for your inspection and copying”: (1) The Boulder Police
Department investigation (case P00-11362) conducted in 2000 allegations of criminal libel
against you; and, (2) The Boulder Police Department investigation conducted in 2000 into the
“allegations of Nancy Jo Krebs.”

As to your request to inspect and copy Boulder Police Department records relating to case
number P00-2362, concerning your allegations of criminal libel against you: I believe that you
were previously provided with a copy this material. However, you may contact Jojo Field,
Manager ol the Boulder Police Department Records Division (phone number redacted) to make
an appointment to inspect the records you are requesting. She can also provide you with an
estimate of the costs for copying any or all of the materials.

As to your request to inspect and copy Boulder Police Department records relating to the
investigation into the allegations of Nancy Jo Krebs:”I must deny your request to copy and
inspect these materials. As you know, the JonBenet Ramsey homicide is still under
investigation. Pursuant to C.R.S. 24-72-305 (5), these materials are investigative files and are
therefore not subject to disclosure under the criminal justice records statutes.

Sincerely,

Mark R. Beckner
Chief of Police

EXHIBIT 5
Attached to Application (or Order to Show Cause)

Fleet Russell White, Jr. and Priscilla Brown White
(address redacted)

Via Certified Mail

April 25, 2002

Mark R. Beckner
Chief of Police
City of Boulder
Department of Police
1805 33rd Street
Boulder, C0 80301

Subject: Your letter dated April 2, 2002 re: request for criminal justice records
Dear Chief Beckner:
Thank your for your letter dated April 2,2002 responding to our letters dated March 20, 2002 in
which we requested access to criminal justice records.

We appreciate your giving us JoJo Field’s name and phone number regarding our request to
inspect and copy all Boulder Police Department criminal justice records relative to case number
P00-11362 concerning our complaints of criminal libel. Those complaints were in response to
the publication and dissemination of the allegations, claims, and beliefs of Nancy Jo Krebs. We
will be contacting Ms Field in the near future to make an appointment to inspect those records.

In your letter you claim that Boulder Police Department criminal justice records relative to he
investigation of Krebs’ allegations are not subject to disclosure under CRS 24-72 305 (5) since,
the JonBenet Ramsey homicide is still under investigation.” On that basis, you have denied our
request to inspect and copy the Krebs criminal justice records. Perhaps there is a
misunderstanding. According to an official City of Boulder News Release dated May 15, 2000,
an eleven-week Boulder police and prosecutor investigation found no credible evidence to link
anything she (Krebs) alleges to the death of JonBenet.” Moreover, that same news release
stated that “Boulder Police and prosecutors “had “concluded” their investigation of Krebs claims
and allegations. Therefore, the criminal justice records we wish to inspect and copy are relative
to an investigation of allegations, claims and beliefs that had nothing to do with the Ramsey
homicide and which ended in May 2000, almost two years ago. We have enclosed a copy of the
May 15, 2000 City of Boulder News Release.

Pursuant to Colorado open records statutes, we once again request access to all criminal
justice records relative to the investigation of the allegations, claims and beliefs of Nancy

Mark R. Beckner
April 25, 2002
Page Two

Jo Krebs. In the event you remain unwilling to provide such access on the basis of CRS
24-72-305 (5), please provide us with a written statement describing the nature of the public
interest to be protected by your denial as required by CRS 24-72-305 (6).

Sincerely.
Fleet Russell White, Jr. Priscilla Brown White
enclosure

May 1, 2000
Fleet White. Jr
Priscilla White
(address redacted)

Dear Mr. and Mrs. White:

I received your letter dated April 25. 2002, which again requests that the “Krebs criminal
justice records” be made available to you for your “inspection and copying.” I had previously
denied this same request from you on the grounds that the JonBenet Ramsey homicide is still
under investigation and, pursuant to CR.S. 24-72-305 (5), the requested materials are
investigative files and are therefore not subject to disclosure under the criminal justice records
statutes.

In your new request, you refer to information contained in a May 15, 2000, City press release
regarding “Krebs allegations.” You cite language from the press release that the investigation
was ‘concluded” and that there was “no credible evidence” to link Krebs allegations to the death
oC JonBenet Ramsey. As I stated to you in my first letter, and as you know, the investigation
into the JonBenet Ramsey homicide is still open. The investigation of Krebs’ allegations
necessarily involved some issues and aspects of that investigation. To disclose aspects of our
investigation into tips and information received could inhibit persons from coming forward with
information and prevent witnesses from cooperating in the future. Furthermore, releasing
information concerning Krebs’ allegations could disclose information not previously made
public. The JonBenet Ramsey homicide investigation is still an open, active investigation.

For these reasons, I must again deny your request to copy and inspect these materials.
Pursuant to C.R.S. 24-72-305 (5), I believe JonBenet Ramsey homicide these materials are
investigative files and are therefore not subject to disclosure under the criminal justice records
statutes.

Sincerely.

Mark R. Beckner
Chief of Police
EXHIBIT 7
Attached to Application for Order to Show Cause

Fleet Russell White, Jr and Priscilla Brown White
(address redacted)
June 3, 2002

Mark R. Beckner
Chief of Police
City of Boulder
Department of Police
1805 33rd Street
Boulder, CO 80301

Subject: Your letter of May 1, 2002 re: request for criminal justice records

Dear Mr. Beckner:

We received your letter of May 1, 2002 responding to our letter dated April 25,2002 in which
we repeated our March 20, 2002 request for criminal justice records regarding the 2000
investigation of the
beliefs, claims and allegations of Nancy Jo Krebs. By your May 1 letter, you have once again
denied that request. We wish to review the basis for your denial.

In your letters of April 2 and May 1, 2002, you denied our request for criminal justice records
pursuant to C.R.S. 21-72-305(5). You thus claimed that releasing the requested records would
be contrary public interest. Apparently in an attempt to describe the “general nature of the
public interest to be protected” as required by C.R.S.24-72-305 (6), you stated in your May I
letter that he requested records are “investigative files” of the JonBenet Ramsey homicide
investigation that “is still an active, open investigation.” You further stated that the
“investigation of Krebs” allegations necessarily involved some issues and aspects of that
investigation” and that “releasing information concerning Krebs’ allegations could disclose
information not previously made public.”

We wish to repeat that we are requesting only those criminal justice records that relate to an
investigation that, according to your press release of May 15, 2000, had been “concluded” and
which found no credible evidence linking anything she (Krebs) alleges, to the death of As
persons in interest, we are seeking the release of only those criminal justice records relating to
a concluded investigation of reports to authorities alleging criminal conduct that were false and
not relevant to the Ramsey homicide investigation. Releasing the requested criminal justice
records will not injure the public interest since the false allegations reports by Krebs are not the
subject of an ongoing police or prosecutor investigation. That investigation concluded on or
about May 15, 2000. There is not, therefore, any legitimate basis for your claim that the Krebs
criminal justice records are exempt from lawful public disclosure on the grounds that they are
part of an ongoing investigation. We believe that your assertion that the requested criminal
justice records are part of the “investigative files” of the Ramsey investigation was made
Mark K Beckner
June 3. 2002
Page Two

in furtherance of an attempt to avoid or delay the lawful and proper release of those public
records.

As for your statement that the requested records “could disclose” information that has not been
previously disclosed to the public, we fail to see any relevance to your claim of injury to the
public interest. Releasing the Krebs criminal justice records will obviously involve information
not previously disclosed. It is for that reason that we are making our request.

In your May 1, letter you also offered the following vague argument that disclosure of the
requested criminal justice records would be contrary to the public interest since:

“To disclose aspects of our investigation into tips and information received could only inhibit
persons from coming forward with information and prevent witnesses from cooperating in the
future”

It is unclear whether you were referring to (1) persons and witnesses who may provide
information concerning Krebs’ allegations; (2) persons and witnesses who may provide
information concerning the Ramsey homicide; or (3) persons and witnesses who may provide
information concerning criminal activity in general. If you were referring to the possible
inhibiting of persons and witnesses in the investigation of Krebs’ false allegations of criminal
conduct by members of our family, we will remind you that the investigation was “concluded”.
Since the investigation was concluded (and Krebs allegations and claims and beliefs were
determined to be false). there is not an investigation to be hampered by the release of the
requested criminal justice records and, therefore, no possibility of injury to the public interest.

If, on the other hand, you were referring to the possible inhibiting of persons and witnesses
who may provide information concerning the Ramsey homicide or the possible inhibiting of
persons and witnesses who may provide information concerning crime generally, you are
referring to a problem we are unfortunately very familiar with. As you know members of our
families, including our children came forward to your agency with whatever information we had
concerning the Ramsey homicide. We did so willingly, without reservation and, eventually at
great sacrifice. In the months and years following JonBenet’s death the substance of our police
interviews, and in some cases our actual words have heen published in newspapers,
magazines, supermarket tabloids and books or broadcast during endless hours of television
programming and radio talk shows- As a direct result, our family has suffered harassment,
ridicule, intimidation, retaliation and a significant loss of our privacy. There is absolutely no
question that public disclosure by employees and agents of the Boulder Police Department and
the Boulder District Attorney of our information concerning the Ramsey homicide—all of which
was
Mark R. Beckner
June 3, 2002
Page Three

believed to be true and given in good faith——has drastically reduced the willingness of our
family to voluntarily come forward to law enforcement as crime victims or witnesses.

In the Krebs case, however the “tips and information” alleging serious crimes that your agency
received and investigated as a result of efforts and prodding by a disreputable attorney the
editor, the editor of a local newspaper, an author of true crime books and a vindictive and
discredited district attorney, were knowingly false. As you know, false reporting to authorities is
a crime punishable under Colorado law. Yet, to our knowledge, no one has been investigated
or punished as a result of Krebs’ knowingly false reports to your agency and to the Boulder
District Attorney and the Federal Bureau of Investigation. We doubt very much that it is the
official policy of the Boulder Police Department, the Boulder District Attorney or any other
Colorado law enforcement agency or prosecutor to tolerate and overlook such a blatant and
extreme episode of criminal conduct. Yet, such has been the case with the false reports made
by Nancy Jo Krebs.

Mr. Beckner, releasing criminal justice records relating to the investigaiion of false reporrts that
were made or transmitted in bad faith, as they were in the Krebs case, will not inhibit the public
from coming forward in good Faith to report and bear witness to crimes. What does inhibit
people from coming forward is their perception that crime victims and witnesses can suffer
extreme mistreatment at the hands of law enforcement and the news media and that agencies
such as yours will foster or tolerate such mistreatment and allow it to be unquestioned,
uninvestigated, unchallenged and unpunished. Such mistreatment has been a hallmark of the
Ramsey investigation. The Krebs case and the wasteful and protracted eleven-week Boulder
Police “investigation” of her highly public , false and libelous allegations of pornography, child
sex abuse, rape, torture and homicide is perhaps the most egregious example.

Your contention that granting our request will somehow inhibit witnesses from coming forward
is illogical and dishonest and under the circumstances we deeply resent your attempt to avoid
releasing the Krebs criminal justice records on that basis.

There is simply no injury to the public interest that can be reasonably asserted or speculated
that will outweigh the certain and compelling public benefit that will result from a public review
and scrutiny of the decisions and conduct of numerous public servants and the news media with
respect to the extraordinary case of Krebs’ false reports to authorities. It is our belief that your
agency’s denial of our request was not motivated by a genuine desire to ovoid injury to the
public interest, but rather by a wrongful desire to prevent public scrutiny of official conduct in
the Krebs case. Your denial of our request for criminal justice records pursuant to C.R.S.
24-72405(5) is arbitrary, capricious and itself contrary to the public interest in the extreme.

Mark R. Beckner
June 3, 2002
Page Four

As you may be aware, the Boulder District Attorney has recently responded positively to our
requests for criminal justice records by providing us with documents in its custcdy and control
concerning Nancy Jo Krebs and the investigation of her false allegations. In doing so the
District Attorney has recognized that ‘Under the unique circumstances involved here” it is
“appropriate” 10 provide such criminal justice records.
Pursuant to Colorado public records statutes, we wish to make a final request for access to all
criminal justice records relative to the investigation of the allegations, claims and beliefs of
Nancy Jo Krebs.
-We will appreciate a prompt reply to this final request. Thank you.
Sincerely.
Fleet Russell White, Jr. Priscilla Brown White
cc Ron Secrist, Boulder City Manager
Mayor and Members of the City Council
EXHIBIT 8
Attached to Application for Order to Show Cause

City of Boulder Mark R. Beckner
Department of Police Chief of Police

June 13, 2002
Mr And Mrs. Fleet Russell White Jr.
(address redacted)
Dear Mr. And Mrs. White,

Our decision in not releasing Ramsey case file information is firm. Please refer to my two
previous letters for our reasons for not releasing case information. I am sorry this decision is
upsetting to you, but there is nothing further I can say or do to assist you in this matter.

Sincerely,

Mark R. Beckner
Chief of Police

The personal investigating I did in regards to Ms. Krebs revealed, as is claimed in the Whites' suit, that Krebs had never even met Fleet White Jr.

I believe the Whites deserve the right to pursue clearing their names in regards to Krebs' false accusations, and may be entitled to reparation from her.

Question. Why wait 2 years to become upset about this?

And yes, NK claimed that White Sr and Jr had molested her and were part of an ongoing child sex abuse "ring".

I don't know of anything happening there at all and i think the case is shelved - - just "open" officially so they don't risk having it go to a special investigator who might actually solve it!