Q. You met many times with Fleet White, didn't you?
A. I did.
Q. And it was your responsibility and I'm sure you carried it out in terms of reporting because I think
you get the record so far at least as of August of 1998 you had filed more reports than anybody on this
case, did you know that?
A. I believe so.
Q. And every time you met with Fleet White either because he was and he was a suspect himself,
was he not?
A. Again, that ambiguous suspect label, yes.
Q. And either because he was a suspect as that term is used by the Boulder Police Department or
because he was a witness, each and every time you met with him and had discussions with him it was
your duty and responsibility to prepare a report about it, true?
A. Not necessarily.
Q. Why not?
A. Well, initially he wasn't my assignment. I think Linda Ardnt shouldered a lot of that. And then
after she was removed from the case, Detective Jane Harmer --
Q. I'm not asking about Harmer. I'm asking about you, Mr. Thomas. I don't need to know about
Harmer and Arndt. They can answer themselves. I want to know if you made reports on each of your
meetings with Mr. White. That's my question. Maybe you didn't understand that one.
MR. WOOD: Despite that interruption, you may continue with your answer.
THE DEPONENT: Thank you.
Q. (BY MR. WOOD) Yeah, answer about your contacts with Mr. White and whether you made
reports on each of those or not?
MR. DIAMOND: You asked him why. He was explain' -- answering the why question.
MR. WOOD: I asked him why -- you're right. I asked him why he did not make a report, why he did
not make a report.
MR. DIAMOND: Thank you. And he's about to tell you that if you just let him finish.
Q. (BY MR. WOOD) I assume what you're telling me is because of Arndt and Harmer somehow
what they did, that's why you didn't do reports?
MR. DIAMOND: Why don't you listen to the answer, then you won't have to assume.
Q. (BY MR. WOOD) Why don't you answer my question about why you didn't prepare reports
when you had contacts with Mr. White and then we can move to another question.
MR. DIAMOND: You can now finish your answer, if you haven't completed it.
Q. (BY MR. WOOD) Maybe now you can answer.
A. Detective Harmer inherited I think the Fleet and Priscilla White assignment, if you will, and was
friends with them, compassionate to them trying to do her job as a police detective. When she
introduced me then at some later date to the Whites, I completed and prepared reports on contacts,
meetings, interviews that I felt were relevant at the time certainly and did so concerning the Whites.
But every time I either spoke or met with these people, no, I did not complete a written report.
Q. Give me your best recollection percentage-wise of how many times percentage-wise you think
you may have prepared reports with meetings with Fleet White or Priscilla White, half the time, 75
percent of the time, 90 percent of the time, what is your best estimate?
A. I don't know how many reports I completed and I don't know how many times I met with them,
but completed several reports I'm sure concerning the Whites and met with them a number of more
times in which I didn't. So half, a quarter, I don't know.
Q. So there may be as many as half to 75 percent or 25 to 50 percent of the times you met with
them where we couldn't find a report and find out what you all discussed or what they said to you?
A. As I said, I don't know. I'm trying to answer your question as far as a percentage goes.
Q. I take it if they gave you any significant information as it would apply to the investigation of
JonBenet's murder you would have prepared a report, true?
A. And I did at times.
Q. So we can at least know that any meeting you had with Priscilla White or Fleet White by phone,
in person or otherwise, if there was any significant information about the case, you would have
prepared a report, true?
A. Most likely, yes.
Q. Why would you not, if they had given you significant information about the case, why would you
not prepare a report?
A. Well, again at the time and standing in those shoes, you know, three, four years ago, if it was
significant at the time and I brought it back to the police department and it was significant, yes,
absolutely I think I would prepare a report.