0001
 1      VIDEOTAPED INTERVIEW OF
 2   
              PATSY RAMSEY
 3   
                Volume I
 4   
 5   
            August 28, 2000
 6   
 7   
 8   
 9    2140 The Equitable Building
          100 Peachtree Street
10          Atlanta, Georgia
11   
12   
13   
14   Alexander J. Gallo, CCR-B-1332
15   
16   
17   
18   
19   
20   
21   
22   
23   
24   
25   
0002
 1                         APPEARANCES
 2   .
 3   On behalf of John and Patsy Ramsey:
 4   L. LIN WOOD, Esq.
 5   Law Offices of L. Lin Wood
 6     2140 The Equitable Building
 7     100 Peachtree Street
 8     Atlanta, Georgia  30303
 9   .
10   On behalf of The United States:
11     MICHAEL KANE, Esq.
12     BRUCE LEVIN, Esq.
13     MITCH MORRISSEY, Esq.
14     MARK R. BECKNER
15     TOM WICKMAN
16     TOM TRUJILLO
17     JANE HARMER
18   .
19   Also present:
20     Ollie Gray
21     John San Agustin
22   .
23   .
24   .
25   .
0003
 1             VIDEOTAPED INTERVIEW OF PATSY RAMSEY
 2                       August 28, 2000
 3            CHIEF BECKNER:  Let me say we
 4   appreciate the opportunity to talk to you and
 5   ask you questions, and we appreciate your
 6   willingness to do this.  Mr. Wood, I
 7   appreciate your cooperation as well.
 8            MR. WOOD:  Thank you, Chief.  I
 9   appreciate that.
10            THE WITNESS:  We appreciate you
11   being here too.
12            CHIEF BECKNER:  I will just
13   extend again, one of the reasons I made this
14   trip is based on your request that I come. 
15   I normally don't do this. Normally I leave
16   it up to my investigators and to the D.A.
17   prosecutors, but I made this trip partially
18   because of your request.  So if, after this,
19   after today or tomorrow, whenever we get
20   done, you want to meet just to talk in
21   general, I am willing to do that.
22            MR. WOOD:  Thank you.
23            CHIEF BECKNER:  I believe we had
24   introductions.  Do you need everybody to
25   introduce themselves again to refresh
0004
 1   yourself?
 2            MR. WOOD:  I got it.
 3            CHIEF BECKNER:  Primarily today,
 4   at least to start off, Bruce Levin and Mike
 5   Kane are going to be asking the questions. 
 6   We may chime in at times if we have a
 7   follow up question or something, but
 8   primarily they will be asking most of the
 9   questions.
10            MR. LEVIN:  Mrs. Ramsey, we have
11   a lot of questions today.  A lot of the
12   questions we will ask are simple
13   informational questions.  Some of the
14   questions you may take as tough questions, if
15   I can use that term, quote/unquote.
16            Two years ago when you came out
17   to Boulder and we interviewed you in
18   Broomfield, I told Mr. Ramsey that if we
19   ever were to charge an intruder, Mr. Wood
20   will tell you this, every prosecutor in the
21   room will tell you, that the best defense is
22   if you can find an alternative suspect. And
23   if an intruder were ever charged in this
24   case, there is no doubt that their defense
25   would be I didn't do it, that Mr. and Mrs.
0005
 1   Ramsey did it.
 2            And in order to raise the
 3   reasonable doubt about their own guilt, they
 4   would harp on that through the entire trial. 
 5   And, as a result, those types of questions
 6   that would be asked by defense attorney
 7   representing an intruder need to be answered,
 8   and we need to ask you those questions.  We
 9   need to know what is the answer to those 
10   questions.
11            Do you understand that?  Do you
12   appreciate that we ask the question, we need
13   to have an absolutely honest answer, because
14   if we don't, if we don't get a -- if we
15   get a defensive answer, if we get an evasive
16   answer, all we are doing is playing into a
17   defense sometime down the road, some defense
18   attorney is going to use that to say my guy
19   didn't do it, John and Patsy Ramsey did it. 
20   Do you understand that?
21            MR. WOOD:  Let me say this for
22   your benefit, Michael.  I don't know that
23   Patsy understands the intricate nature of a
24   defense in a criminal case, but I can tell
25   you this.  We are here to answer any
0006
 1   questions as represented by the chief and
 2   you.  She is going answer those questions as
 3   honestly as she can.  That is all she is
 4   here to do today.  So why don't we go ahead
 5   and get going.
 6            MR. KANE:  Well, I just want to
 7   make it clear, though, because it is not
 8   going to do anybody any good to give a
 9   defensive answer.  Don't take --
10            MR. WOOD:  She is not going to
11   be offended by any questions.
12            MR. KANE:  Okay. Fair enough.
13            MR. WOOD:  If she is, we will
14   tell you.  But I think we're going to do
15   fine and she's going to give you answers.
16            MR. KANE:  But I would like Mrs.
17   Ramsey to assure me that.  Not --
18            MR. WOOD:  She is going to answer
19   your questions honestly, Michael.
20            MR. KANE:   Mrs. Ramsey, do you
21   understand everything I just said?
22            THE WITNESS:  I believe I do,
23   yes.
24            MR. KANE:  Do you have any
25   questions about that?
0007
 1            THE WITNESS:  Not at this time.
 2            MR. KANE:  Okay. And if you do,
 3   just simply bring it up.  Okay?  
 4            THE WITNESS:  Okay.
 5            MR. KANE:  Mr. Levin is going to
 6   start off.
 7     Q.     (By Mr. Levin)  Mrs. Ramsey, what
 8   I would like to do, your attorney said
 9   uh-huh, uh-uh.  Yes, no works.  The other
10   thing -- Do you understand that?
11     A.     Uh-huh (affirmative).
12     Q.     Let's do a practice.
13     A.     Yes.
14     Q.     We are going to play sort of like
15   we are in court because we have a court
16   reporter.  I don't know if you have given
17   interviews where they are transcribed.  So
18   that we don't drive this man insane, it is
19   important that you wait until the question is
20   finished, then you give your answer so that
21   we don't talk over each other.
22            We are all going to ask you
23   questions, but we are going to try to do
24   that so that he knows  - it is very
25   difficult to take somebody, two people at
0008
 1   once.  Do you understand that?
 2     A.     Yes.
 3     Q.     I have just some background stuff
 4   I would like to ask you, and I don't have
 5   any intention of embarrassing you, but I know
 6   from reading other interviews that in the
 7   past you have taken some medication.  I just
 8   want to make a record on it.  Are you
 9   taking any medication now?
10     A.     Yes, I am.
11     Q.     What do you take?
12     A.     Zoloft.
13     Q.     And what's Zoloft?          
14     A.     Zoloft is for treatment of
15   posttraumatic stress disorder.
16     Q.     Antidepressant type thing?
17     A.     Yes.
18     Q.     I am assuming, you look very
19   bright eyed and very alert, that it doesn't
20   affect your ability to comprehend what is
21   going on around you?
22     A.     That's correct. 
23     Q.     Okay. The other thing is, too, if
24   we ask you a question, whether it is from me
25   or Mr. Kane or Mr. Morrissey, and you are
0009
 1   not clear what we are asking you, instead of
 2   trying to guess, just be very honest and
 3   say, I don't have a clue what you are
 4   saying, Mr. Levin, can you ask that in
 5   English, because lawyers have a tendency to
 6   talk like lawyers instead of people, and we
 7   will try to talk like people here.
 8     A.     All right.  Thank you.
 9     Q.     Where I would like to start is we
10   have heard that you and your husband have,
11   in effect, funded or conducted kind of a
12   parallel personal investigation into the death
13   of your daughter.  Is that correct?
14     A.     Yes, it is.
15     Q.     What I would like you to do is
16   just kind of lay out, let's start with who
17   you have been in touch with, who has been
18   assisting you.  Just list those people.
19     A.     Mr. Ollie Gray, who is here in
20   the room, is working for us in the
21   investigation.
22     Q.     Is there anyone else?
23     A.     John, his assistant, who I think
24   you met earlier. 
25     Q.     Okay.  And how long have you been
0010
 1   associated with Mr. Gray, or has he been
 2   employed by you?
 3     A.     I don't remember exactly.  Quite
 4   some time.
 5     Q.     Can you give us an approximation?
 6   Are we talking months?
 7     A.     Several months.
 8     Q.     Months?
 9     A.     Uh-huh (affirmative).
10     Q.     And before you started your
11   association with Mr. Gray, were there other
12   investigators that performed services for you?
13     A.     Yes.
14     Q.     And who were they?
15     A.     Ellis Armistead & Associates.
16     Q.     And your association with Mr.
17   Armistead goes back to '97; is that correct?
18     A.     Yes.
19     Q.     And how long was he in your
20   employ?
21     A.     Up until fairly recently.
22     Q.     By fairly recently, we are 
23   talking --
24     A.     Probably --
25     Q.     -- a couple of months when 
0011
 1   Mr. Gray became in your employment?
 2     A.     Yes.  Somewhere around that time.
 3     Q.     Does that correspond to when you
 4   terminated your professional relationship with
 5   Hal Haddon's firm and Pat Burke and Pat
 6   Furman, or did Mr. Armistead work for you
 7   after you terminated your professional
 8   relationship with Mr. Haddon's law firm?
 9     A.     I am really fuzzy on all that. 
10   I just -- John would probably know that
11   answer more clearly.  He kind of --
12     Q.     Why don't you give us your best
13   recollection.
14     A.     What was the question again?
15     Q.     When did you terminate your
16   relationship with the law firm of Hal Haddon,
17   and then we'll do Pat Burke and Pat Furman?
18     A.     Well, it was after the grand jury
19   was concluded.
20     Q.     Did Mr. Armistead still perform
21   services for you after you terminated your
22   professional relationship with those attorneys?
23     A.     I don't know exactly.  
24     Q.     Okay.
25     A.     I don't know, you know, exactly
0012
 1   which dates, when it happened.
 2     Q.     Oh, I understand that.  Let me
 3   give you something that is really pertinent,
 4   probably, to all the questions I am going to
 5   ask you.  I understand that we are talking
 6   now about questions dealing with a period of
 7   time three and a half years, going on four
 8   shortly.  I understand that you are not in
 9   every situation going to be able to tell me
10   a day and sometimes not a month.  And that
11   is okay.  Do you understand that?  Remember,
12   it is yes or no.
13     A.     Yes.
14     Q.     Okay.  But what I would like you
15   to do is, to the best of your recollection,
16   when I am asking you questions like this, if
17   you can give me spring of '99, fall of '96,
18   that type of thing, and that is fine.
19            MR. WOOD:  If you know.
20     Q.     (By Mr. Levin)  If you know. 
21   Obviously I don't want to put words in your
22   mouth.
23     A.     I will try.  I will try my best.
24            MR. WOOD:  Let me help a little
25   bit because if you are looking for this
0013
 1   information, I think I am correct in stating
 2   this, that Ellis Armistead was employed by
 3   Hal Haddon and Bryan Morgan, not technically
 4   employed by John and Patsy, but obviously
 5   employed by their lawyers.
 6            Mr. Gray's involvement predates
 7   the time when those lawyers withdrew, no
 8   longer representing John and Patsy.  And Mr.
 9   Armistead's resignation from the case, I
10   think, coincides in time with Mr. Morgan's
11   and Mr. Haddon's termination.
12     Q.     (By Mr. Levin)  So essentially
13   contemporaneous with the end of the grand
14   jury? 
15            MR. WOOD:  Yeah -- well, no. 
16   Actually, the end, first part, somewhere
17   between mid to end of May actually they
18   continued to be involved.
19     Q.     (By Mr. Levin)  Mrs. Ramsey, are
20   there other professionals that you have
21   contacted or that were contacted at your
22   request?  For example, forensic pathologists.
23     A.     I believe so.  I believe that we
24   had a group of experts who had put together
25   some information which we were hopeful could
0014
 1   be presented to the police department and
 2   investigators last January.
 3     Q.     Who was in that group of experts? 
 4   Who do you remember?
 5     A.     I don't know all the names.  I
 6   just know they were, you know, they were
 7   forensic type people.
 8     Q.     Why don't you tell me the names
 9   you do recall?  Do you remember a Dr. Sperry
10   from Georgia, Kris Sperry?  He is a forensic
11   pathologist.
12     A.     I believe that was one of the
13   names.
14     Q.     Did you ever personally meet with
15   him?
16     A.     No.
17     Q.     Was there anyone else that you
18   recall?  And if you don't recall their
19   names, can you tell us what area of
20   expertise?
21     A.     There again, that is kind of John
22   was sort of involved with that more than I. 
23   I really don't.  That is about all I know. 
24   I just know that the meeting was declined.
25     Q.     The meeting?
0015
 1     A.     We had requested to meet and
 2   present this information.
 3     Q.     And were you involved in that? 
 4   Did you directly contact the Boulder Police
 5   Department or contact a member of the
 6   prosecution team?
 7     A.     No, I did not personally.  I
 8   believe one of our lawyers sent a letter to
 9   that effect saying we would like to meet and
10   present some findings, and it was not
11   accepted.
12     Q.     One of the things that we are
13   very interested in is that, since you do
14   have and have had investigators working for
15   you on this case, and, as you refer to them
16   as forensic experts or group of experts I
17   believe is what you are calling them, what
18   have they presented to you that you think is
19   significant that would assist us in getting a
20   prosecuteable case against the killers of
21   your daughter?
22     A.     They haven't presented anything to
23   me. 
24     Q.     Have they presented things to
25   John?
0016
 1     A.     I don't know.
 2     Q.     If I understand you correctly, you
 3   are saying that these people have been, and
 4   I am assuming at a fairly large expense,
 5   been retained by your family and that, that
 6   you -- and obviously you have a great
 7   interest in having -- in helping solve the
 8   murder of your daughter; correct?
 9     A.     Correct.
10     Q.     But if I understood your response,
11   you are saying that you've never sat down to
12   talk to these people to discuss their
13   findings?
14            MR. WOOD:  She said they haven't
15   presented anything to her in way of a
16   presentation.  I don't think she said she
17   wasn't aware, generally, of their finding.
18            MR. LEVIN:  You are on realtime,
19   I assume; is that correct?
20            MR. WOOD:  Yes, I am.
21            MR. LEVIN:  Do you know what we
22   are talking about?  Realtime is the term of
23   art for, he is reading off the court
24   reporter's transcript, rough draft, which we
25   don't have.
0017
 1            MR. WOOD:  But which we will be
 2   glad to hook you up to if you would like
 3   it. 
 4            (Discussion ensued off the
 5   record.)
 6     Q.     (By Mr. Levin)  What your
 7   attorney told me is that there hasn't been a
 8   formal presentation.  Let's talk about
 9   informal.  Have you sat down personally and
10   talked to any of these people that were
11   retained in order to find out what they have
12   uncovered in this case?
13     A.     I have not, no.
14     Q.     Have you received secondhand
15   information concerning what information they
16   have concerning possible alternative suspects? 
17   And that is an alternative to you and John,
18   obviously.
19     A.     I don't remember them saying
20   anything about specific suspects.
21     Q.     You have in the past suggested,
22   during interviews, possible suspects, people
23   that you in your mind think may have been
24   involved in the murder of your daughter;
25   correct?
0018
 1     A.     Correct.
 2     Q.     Why don't you list those for us. 
 3   Who have you stated you believe at some
 4   point in time was involved with the murder
 5   of your daughter?
 6            MR. WOOD:  Now, that -- you have
 7   those prior statements.
 8            MR. LEVIN:  Yes, I do.
 9            MR. WOOD:  Then I -  excuse me.
10            MR. LEVIN:  Pardon me, sir.
11            MR. WOOD:  Then in all fairness,
12   you are asking her to simply repeat what
13   she's already told you, which is exactly what
14   we said we weren't going to do here today.
15            MR. LEVIN:  That is correct.  And
16   the follow-up questions will make it clear
17   why this is not repetitive.
18            MR. WOOD:  But the problem is,
19   how in the world can she sit here and play
20   a memorization game with you about who she
21   may have discussed, when she discussed it. 
22            I mean, if you have got her
23   statements, you know who she has named. And
24   she can't sit here and be expected to
25   remember each and every person because
0019
 1   sometimes you would ask, you know, if anybody
 2   had a key and they would give you names. 
 3   Is that a possible suspect?  I don't know
 4   what the term necessarily means.  But she
 5   has given you those names, Bruce.  You 
 6   have --
 7            MR. LEVIN:  I understand that.
 8            MR. WOOD:  Excuse me.  If you
 9   are here to get additional information, that
10   question is not necessary.  You already have
11   that information.
12            MR. KANE:  Let me follow up on
13   that.
14            MR. WOOD:  Sure.
15            MR. KANE:  Obviously the last
16   statements that we have are two years ago. 
17   So maybe if we ask.
18            MR. WOOD:  Ask if there is
19   anybody that she knows by name since when
20   she last talked with you all.  That is
21   absolutely fair.  I would, you know, let her
22   answer that, but to ask her who she's told
23   you about in the past would almost require
24   her to be familiar with every statement she
25   has given you all over four days or so. 
0020
 1   And she hasn't prepared to do that today
 2   because we weren't going to go into those
 3   areas.
 4            MR. KANE:  Well, but also, I
 5   think it is also relevant to ask what, what
 6   information has subsequently been developed
 7   about people that were named before.  I
 8   mean, two years is a long time.
 9            MR. WOOD:  Well, I mean, I would
10   think then you all ought to go straight -- I
11   am not telling you how to ask your
12   questions, but I would think if you have a
13   name and you want to know if she is aware
14   of any information developed since June of
15   1998, throw the name out there and ask her
16   have you learned anything that you know about
17   this person since June of '98.  She will
18   answer that. 
19            MR. LEVIN:  That is fine.
20            MR. WOOD:  I am not trying to be
21   difficult.  I just don't want --
22            MR. LEVIN:  I understand.  What
23   I'll do --       
24            MR. WOOD:   - to put her in the
25   awkward position of trying to somehow
0021
 1   remembering what she said over four days two,
 2   three years ago because I don't think she
 3   could do that.  She certainly didn't prepare
 4   to do that today, and I wouldn't ask her to.
 5            MR. LEVIN:  No, and I, I
 6   certainly, Mr. Wood, do not expect her to do
 7   that.  That's not where I was going.  But
 8   if it makes you more comfortable, I'll ask
 9   the question another way.
10            MR. WOOD:  Thank you very much.
11     Q.     (By Mr. Levin)  You've named
12   Priscilla White in the past as a possible
13   suspect.  During the course of the last two 
14   years, have you rejected that as a possible
15   suspect in the murder of your daughter, have
16   you rejected Priscilla White?
17     A.     No.
18     Q.     You've named Fleet White, I
19   believe, as a suspect.  Same question, have
20   you rejected him as a possible suspect?
21     A.     No.
22     Q.     Bill McReynolds?
23     A.     No.
24     Q.     No, you have not rejected him?
25     A.     No, I have not rejected him.
0022
 1     Q.     And I believe Chris Wolf you 
 2   also -- 
 3     A.     No, he has not been rejected.
 4     Q.     I assume then that that is a
 5   function of the fact that you have not
 6   received any significant information concerning
 7   the murder of your child in the last two
 8   years that differs from the information that
 9   you received prior to your interviews with
10   representatives of the Boulder district
11   attorney's office?
12            MR. WOOD:  Hold on before you
13   answer.
14            Do you understand that?
15            THE WITNESS:  Not really.
16     Q.     (By Mr. Levin)  Okay.  I'll
17   rephrase it for you.  In June of 1998, the
18   individuals that I've named were, in your
19   mind, potential suspects in the murder of
20   your child; correct?
21     A.     Uh-huh (affirmative).  Correct.
22     Q.     You tell us that today, in August
23   of the year 2000, those individuals remain
24   suspects. Correct?
25     A.     Correct.
0023
 1     Q.     I am assuming, based on that,
 2   that you have not received, through your
 3   investigators or through your experts, any
 4   significant new information about the killing
 5   which caused you to abandon those opinions or
 6   suspicions? 
 7            MR. WOOD:  Let me just caution
 8   you.  Because he tells you it is something
 9   that he assumes, Patsy, I think what he
10   really wants to know is, why have you not
11   necessarily rejected these people in my own
12   mind.  Do you follow me?  I think that is
13   an easier question.  
14            Isn't that what you are driving
15   at, Bruce?
16            MR. LEVIN:  Well, not, no, it is
17   not.
18            MR. WOOD:  For example, Chris
19   Wolf, why do you still think he is not in
20   your mind rejected as a suspect, isn't that
21   what you are trying to get her to answer?
22     Q.     (By Mr. Levin)  What I want to
23   know is, it would seem to me that if you
24   had people who are working on this case for
25   you to develop information concerning the
0024
 1   killing, that if they had developed anything
 2   significant, that it might impact your belief
 3   that Priscilla or Fleet or McReynolds or Wolf
 4   was involved.  Do you understand that so
 5   far?
 6     A.     Yes.
 7     Q.     Is it a fair statement that you
 8   have not received any significant information
 9   concerning the murder of JonBenet in two
10   years?
11            MR. WOOD:  About?
12            THE WITNESS:  We have significant 
13   information about the murder.
14     Q.     (By Mr. Levin)  Okay.  Why don't
15   you tell us what is the significant
16   information that you have been provided in
17   the past two years.  And again, I am not
18   going, you know, I'm not going to ask you
19   months and days, when did you find this out,
20   but I would like --
21            MR. WOOD:  Specific information as
22   to specific people?
23     Q.     (By Mr. Levin)  Specific
24   information concerning the killing generally. 
25   And you can block it out any way you want.
0025
 1     A.     Well, I don't know a whole lot of
 2   detail.  John will, perhaps, be much better
 3   to answer that.
 4            What I know is that we know --
 5   how do I want to say it, forensically,
 6   pathologically, or whatever, how JonBenet
 7   died.
 8     Q.     Why don't you explain what your
 9   belief is concerning her death.
10            MR. WOOD:  See, hold on a second. 
11   You got one question she is trying to
12   answer, and now you -- are you withdrawing
13   that question?
14            MR. LEVIN:  No, I am following it
15   up.
16            MR. WOOD:  Well, but you haven't
17   let her finish the first answer, in fairness,
18   and you are throwing another question out. 
19            THE WITNESS:  I was going to tell
20   you the rest of what I know.
21            MR. WOOD:  And if I go back and
22   look at this record, it looks like she's
23   completed her answer and then you've asked
24   her a new question and you've stopped her in
25   the middle.  Do you want her to go back and
0026
 1   tell you generally what she's learned --
 2            MR. LEVIN:  Sure, you can list
 3   them.
 4            MR. WOOD:   - for the last two
 5   years and then you can move to the second
 6   question?
 7     Q.     (By Mr. Levin)  Go ahead.
 8     A.     Well, I believe that from this
 9   group of experts we know the sequence of the
10   way in which she died.  I am not sure -- I
11   don't think I know.  There may be other
12   things that that group had to present, but
13   that is the one thing that I can remember.
14            Otherwise, I think Mr. Gray has
15   turned over everything, any piece of anything
16   that he thinks is significant to the police
17   department, including just recently a pair of
18   Hi-Tec boots that were obtained from one of
19   the suspects.  We don't know what has
20   happened with that since, and we would like
21   to know that.
22     Q.     Anything else?
23     A.     No. 
24     Q.     Why don't you explain to us your
25   understanding concerning the sequence of
0027
 1   events which led to your -- and I am talking
 2   from a medical perspective, the sequence of
 3   events that led to your daughter's death as
 4   it was explained to you by your forensic
 5   experts.
 6     A.     That she died of asphyxiation, and
 7   the blow to her head was subsequent to that
 8   act.  And the reason that they know that is
 9   because something to do with the very minute
10   presence or negligible presence of blood at
11   the fracture.
12     Q.     Now, this belief that you have,
13   Mrs. Ramsey, was that a product of a
14   conversation that you had directly with Dr.
15   Sperry?
16     A.     No.
17     Q.     What is the source of your
18   information then?
19     A.     I believe my attorney Pat Burke
20   explained that to me.
21     Q.     Dr. Sperry is the source of that
22   information, though, through your lawyer; is
23   that your understanding?
24            MR. WOOD:  If you know that.
25            THE WITNESS:  I don't know that
0028
 1   for sure.
 2     Q.     (By Mr. Levin)  What is your
 3   belief?
 4            MR. WOOD:  If you have a belief,
 5   Patsy. 
 6            THE WITNESS:  Well, he was among
 7   a group of experts.  I mean, it was he and
 8   several others is my understanding who, you
 9   know, thoroughly looked at all of this.  And
10   that was the gist of, in my layman's terms,
11   I am sure it is much more technical than
12   that, but --
13            MR. WOOD:  And I think that,
14   Bruce, that Sperry was one of the people
15   that was offered to you all back in January
16   of 2000.  I was not involved in that offer,
17   but I understood that they were willing to
18   have --
19            THE WITNESS:  They had a complete
20   presentation ready for all of you all.
21            MR. WOOD:  I think that offer
22   still stands.
23     Q.     (By Mr. Levin)  Are you aware of
24   what information he was in possession of,
25   that is, Dr. Sperry?
0029
 1     A.     No, I am not.
 2            MR. LEVIN:  Are you, Mr. Wood? 
 3   Do you know what he had?
 4            MR. WOOD:  Well, I think I have
 5   a general idea.  I haven't sat here and
 6   tried to come up with it in my mind's eye,
 7   but again, my understanding is, I will check
 8   this for you, but you all are welcome to 
 9   sit down and listen to him and talk with
10   him.  He would be better able to tell you
11   that than me.
12     Q.     (By Mr. Levin)  Other than --
13   well, let's talk about the Hi-Tec boots. 
14   You said you believe that a suspect had a
15   pair of Hi-Tec boots that were sent to us.
16     A.     (Witness nodded head
17   affirmatively).
18     Q.     Who was that?
19     A.     His name is Helgother or Gogather.
20     Q.     This is the man who committed
21   suicide?
22     A.     Yes.
23     Q.     How is it that your team, for
24   lack of a better word, how is it that your
25   team came into possession of those?  Do you
0030
 1   know?
 2     A.     No, I do not.
 3     Q.     Have you been told or offered an
 4   explanation?
 5     A.     Of how?
 6     Q.     Of how you got into possession of
 7   a pair of boots that belonged to someone who
 8   committed suicide several years ago.
 9     A.     I believe Mr. Gray obtained them.
10     Q.     I don't believe that I have ever
11   heard you discuss him as a potential suspect
12   in this case.  Can you tell us what
13   information you are in possession of that
14   causes you to hold that belief?
15     A.     I understand that he committed
16   suicide on the 14th day of February '97.  He
17   was in the possession of a stun gun, and we
18   believe, as best we can tell, that it was an
19   AirTaser stun gun, and that apparently
20   matches the markings that were found on
21   JonBenet's body.  And he owned a pair of
22   Hi-Tec boots that appeared to be the same
23   size as the footprint found at the crime
24   scene.
25     Q.     That information, I am assuming,
0031
 1   comes from the work that was done by Mr.
 2   Gray?  Is that the source of that?  If I
 3   am incorrect, tell me what the source is.
 4     A.     Yes, I think.
 5            MR. LEVIN: Mitch or Mike, do you
 6   want to do some more on their investigation?
 7            MR. KANE:  Sure.
 8     Q.     (By Mr. Kane)  Let me just follow
 9   up the last question.  What was the name of
10   the suspect?
11     A.     It is an unusual name.  It is
12   Helgoth or Golgath.
13            MR. WOOD:  I think you all asked
14   her about him in June of 1998 by name. 
15   Michael Helgoth. 
16            MR. LEVIN:  For the Reporter, I
17   believe it's H-e-l-g-o-t-h.
18            THE WITNESS:  Lin just said it is
19   Michael Helgoth.
20     Q.     (By Mr. Kane)  What else do you
21   know about Mr. Helgoth?         
22     A.     That is all, that is all I know.
23     Q.     Did you ever hear that name
24   before?
25     A.     No.
0032
 1     Q.     It was not somebody who was known
 2   to your family?
 3     A.     No.
 4     Q.     Besides Mr. Gray, do you have any
 5   information, has anyone else given you any
 6   information about him?
 7     A.     Not that I can think of, no.
 8     Q.     Besides the fact -- where did 
 9   you --
10            Did Mr. Gray tell you that he had
11   an AirTaser stun gun on him when he
12   committed suicide?
13     A.     Yes.  I believe there is a
14   photograph that he had.
15     Q.     And was it Mr. Gray who told you
16   that he had Hi-Tec boots?  Was he wearing
17   those?  I am sorry, that is a double
18   question.  Was it Mr. Gray who told you that
19   he had Hi-Tec boots?
20     A.     Yes. 
21     Q.     And was he wearing them at the
22   time?  Is that your understanding?
23     A.     I don't know that.
24     Q.     Outside of the fact that he
25   committed suicide, he had a pair of Hi-Tec
0033
 1   boots, and an AirTaser, is there any other
 2   information you have that connects him to
 3   this crime?
 4     A.     Not that I have, no.
 5     Q.     (By Mr. Morrissey)  Have you seen
 6   this photograph where Mr. Helgoth has the
 7   stun gun? Have you actually seen that
 8   photograph?
 9     A.     No, I don't believe so.
10     Q.     (By Mr. Kane)  Do you know how
11   Mr. Gray came into possession of these boots?
12     A.     I don't know exactly, no.
13            MR. WOOD:  I think that was
14   explained in a memo to Chief Beckner by Mr.
15   Gray that he sent to him in the last couple
16   of weeks.
17            THE WITNESS:  You all have the
18   boots now.
19            MR. KANE:  That wasn't my
20   question.  I want to know what you know
21   about those. 
22     Q.     (By Mr. Kane)  So you don't know
23   how he came into possession of those boots?
24     A.     I think he said he might have
25   gotten them from a family member, or --
0034
 1     Q.     When did you learn this?
 2     A.     Some time ago.  A couple of
 3   months ago.
 4     Q.     And was that the first time you
 5   heard about Mr. Helgoth having Hi-Tec boots?
 6     A.     Yes.
 7     Q.     All right.  And did you learn
 8   about that in a personal conversation with
 9   Mr. Gray or did you learn it indirectly
10   through somebody else?
11     A.     I think I probably heard it from
12   John.
13     Q.     Have you ever talked to Mr. Gray
14   about those Hi-Tec boots?
15     A.     Yes.
16     Q.     You mentioned this group of
17   forensic experts, and I think that -- maybe
18   you have answered this question, but did you
19   ever meet Mr. Sperry, or Dr. Sperry, the
20   GBI, Dr. Kris Sperry?
21     A.     I think Mr. Levin asked me that a
22   couple of times.  No, I have not.
23     Q.     Okay.  Have you met with any of
24   the other forensic experts?
25     A.     No. 
0035
 1     Q.     Have you ever asked any of these
 2   to give you a briefing of what they
 3   concluded?
 4     A.     No.
 5     Q.     Why not?
 6     A.     Well, I was hoping to be in this
 7   meeting that we were going to have with you
 8   folks in January, but that never took place.
 9     Q.     Now, I got a letter from an
10   attorney in Oregon about that.  I can't
11   remember his name.  Do you remember what his
12   name was?
13            MR. WOOD:  Why don't you show us
14   the letter.  If we can see it --
15            MR. KANE:  No, I am asking if
16   she remembers the letter.
17            MR. WOOD:  How would she know the
18   name of somebody who wrote you a letter from
19   Oregon?
20            MR. KANE:  Because it was an
21   attorney hired by her and her husband.
22            MR. WOOD:  Who was the attorney? 
23            MR. KANE:  Well, that's what I'm
24   asking --
25            MR. WOOD:  I am not aware of an
0036
 1   attorney hired in Oregon.  I could be wrong.
 2     Q.     (By Mr. Kane)  Do you remember an
 3   attorney hired who lived in Oregon who was
 4   involved in setting up that meeting?
 5     A.     Oh, yes.  John -- John something. 
 6   He is a colleague of Pat Burke's.
 7     Q.     Okay.  Have you ever talked to
 8   him yourself?
 9     A.     Yes.
10     Q.     That attorney?
11     A.     Yes.
12     Q.     Okay.  And it was your
13   understanding that you were going to be part
14   of that meeting between Dr. Sperry and the
15   Boulder law enforcement authorities?
16     A.     I just presumed I would be.  I
17   was hoping to.  I don't know that it
18   actually came to the point where, you know,
19   you are in, you are not, you know.
20     Q.     Dr. Sperry, is it your
21   recollection that Dr. Sperry was the one who
22   gave the opinion that, because of the lack
23   of blood, that would indicate that the
24   strangulation occurred before the blow to the
25   head?
0037
 1     A.     I don't know who exactly gave
 2   what information.  My understanding was there
 3   were several on this team of experts.
 4     Q.     You don't know who any of the
 5   other people were?
 6     A.     No.  I am sorry.
 7     Q.     You never spoke with any of the
 8   other people?
 9     A.     No. 
10     Q.     Did you have a curiosity to speak
11   with them firsthand?
12     A.     I felt that that time would come,
13   but they had work to do.
14     Q.     I guess I don't understand why
15   you didn't speak with them before this
16   planned or suggested meeting with the Boulder
17   law enforcement authorities?
18            MR. WOOD:  That is not a
19   question.  That's just your problem with
20   understanding something.  I have expert
21   witnesses in cases every day, Michael, that
22   never talk to my client.  I give them the
23   information.  I have clients that have lost
24   their daughter, please, sir.  I have had
25   clients that have had children seriously
0038
 1   injured.  I don't sit there and give them
 2   the benefit of sitting down and talking with
 3   the experts that I retain.  No lawyer does
 4   that, necessarily.
 5            MR. KANE:  Well, I am not asking
 6   whether your lawyer did.
 7            MR. WOOD:  You are expressing a
 8   problem understanding it.  You are not asking
 9   her.
10            MR. KANE:  I will ask her.
11            MR. WOOD:  She is not going to
12   be able to help you whether you're able to
13   understand something or not.  You have to
14   work that out.  All I am saying is that
15   from my perspective as a lawyer, it happens
16   every day.
17            MR. KANE:  That is fine.  And I
18   am not asking you, Mr. Wood.  I am asking
19   Mrs. Ramsey.
20            MR. WOOD:  I know that.  In
21   fairness, it is nothing sinister to it.
22     Q.     (By Mr. Kane)  Mrs. Ramsey, why
23   didn't you ask to sit down and talk with
24   these experts?
25            MR. WOOD:  I think she's already
0039
 1   told you that two or three different times,
 2   Michael.
 3            MR. KANE:  No.  She said that
 4   she anticipated going --
 5     Q.     (By Mr. Kane)  Why didn't you ask
 6   to speak with them before this meeting that
 7   was trying to be set up in January?
 8     A.     I didn't feel like there was a
 9   need for me to speak with them before until
10   they were finished with what their objective
11   was, and then we would all be presented the
12   material together.
13     Q.     Okay.  Now, and that meeting
14   never took place in January?
15     A.     That's right.
16     Q.     Have you met with them since?
17     A.     No, I have not.
18     Q.     Why not? 
19     A.     Because everything fell through.
20     Q.     The meeting fell through, but what
21   about your own becoming aware of what these
22   experts had to say about the death of your
23   daughter, did you ever request to meet with
24   them for a briefing yourself?
25     A.     I did not request a meeting, no.
0040
 1     Q.     You identified Priscilla White as
 2   a suspect back in June of '98.  Is there
 3   anything since that time that -- is there
 4   any additional information that keeps her on
 5   your suspect list?
 6            MR. WOOD:  And, you know, you got
 7   a lawsuit from Chris Wolf.  I am not sure
 8   of the terminology, Michael, that was used
 9   precisely as I sit here, but I know you all
10   asked a lot of questions in the course of
11   your investigation, and information that is
12   provided to you may be in your minds
13   indicating someone is a, quote/unquote,
14   suspect.  I am never sure what a suspect is
15   other than somebody that might be someone
16   that should be investigated.
17            I don't really think there is a,
18   quote/unquote, suspect list.  I think that
19   carries with it a connotation that there is
20   reason to have evidence to say somebody did
21   this, and I think it is more of a list of
22   people that are leads or possibilities that
23   should be investigated.  And I just don't
24   want somehow somebody to start, besides Chris
25   Wolf, filing lawsuits claiming that we've
0041
 1   identified them as a, quote/unquote, suspect. 
 2   That is my concern.  I think you would
 3   appreciate it.
 4     Q.     (By Mr. Kane)  Well, obviously
 5   this is not -- I mean, we don't intend to
 6   make this information public, but in the
 7   course of the investigation, we need to know
 8   if there is additional evidence other than
 9   what we -- what you offered back in June of
10   1998 that would suggest that Priscilla White
11   was a viable suspect in this case, or
12   someone that cannot be excluded?
13     A.     Well, it is kind of like Lin
14   said.  We early on provided a list of people
15   who were, A, in our home, B, worked for us. 
16   You know, we wracked our brains about, you
17   know, who this might have been because we
18   were told early on that it, you know,
19   possibly was someone that was close to us. 
20   And, you know, those were -- they were close
21   friends of ours.
22     Q.     Was Susan Stein ever a suspect?
23            MR. WOOD:  By who, the police?
24     Q.     (By Mr. Kane)  No, by you.
25     A.     No.  I mean, the reason the
0042
 1   Whites, I think, kind of came up on the
 2   radar screen was subsequent to JonBenet's
 3   death they just seemed to act, to us, in a
 4   very unusual manner in terms of being very
 5   confrontational, and, you know, jumping in on
 6   meetings with our priest, and writing
 7   voluminous letters to the governor.  To me
 8   that just seemed unusual, and I wondered to
 9   myself why someone would act that way.
10     Q.     And it was this, the way they
11   were acting, is what, in your mind, made
12   them suspects, potential suspects?
13     A.     Well, potentially, yes.  But, I
14   mean, if I knew from you or from whomever
15   about a lot of people, whether, you know,
16   handwriting has thoroughly been checked, DNA
17   has been checked, et cetera, et cetera, you
18   know, that would help it cross off in my
19   mind.
20     Q.     Other than the thing that you
21   talked about the amount of blood indicating
22   that the asphyxiation occurred before the
23   blow to the head, are there any other
24   details that you have that would suggest the
25   sequence that you know of?
0043
 1            MR. WOOD:  From the forensic
 2   people?
 3            MR. KANE:  From any source.
 4            THE WITNESS:  That a stun gun was
 5   used to silence her.
 6     Q.     (By Mr. Kane)  Where was that
 7   information?  Where did you get that
 8   information? 
 9     A.     I believe that came from Lou
10   Smith.
11     Q.     Have you talked to anybody other
12   than Lou Smith -- well, let me ask you that. 
13   Have you talked to Lou Smith directly
14   yourself?
15     A.     Yes.
16     Q.     About that?
17     A.     Yes.
18     Q.     Have you talked to anybody else
19   other than Lou Smith about a stun gun having
20   been used?
21     A.     Yes.
22     Q.     And who was that?
23     A.     Ollie Gray.
24     Q.     Was Mr. Gray, did he offer up
25   conclusions about that, that a stun gun was
0044
 1   used?
 2     A.     Yes.
 3     Q.     And have you talked to any
 4   medical people about whether a stun gun was
 5   used?
 6     A.     I have not myself.
 7     Q.     Have you heard indirectly from any
 8   medical people about a stun gun having been
 9   used?
10     A.     I believe so.
11     Q.     Who was that that you heard it
12   from?
13     A.     I don't know the names.
14     Q.     What have you heard from these
15   people? 
16     A.     I have heard that it has been
17   substantiated that a stun gun was used.
18     Q.     What was it that substantiated the
19   use of a stun gun?
20     A.     Whatever they do to test markings
21   against known markings of a particular stun
22   gun.
23     Q.     And so that is what it is, the
24   markings?
25     A.     (Witness nodded head
0045
 1   affirmatively).
 2     Q.     Have you ever, to your knowledge,
 3   you or Mr. Ramsey, ever hired a forensic
 4   expert to look at that issue, to look at the
 5   autopsy report or look at any other evidence
 6   that might be available that would have a
 7   bearing on whether a stun gun was used?
 8     A.     I can't say for sure.  John may
 9   know that.
10     Q.     But to your knowledge, you
11   haven't?
12            MR. WOOD:  I think she told you
13   she hasn't.
14            MR. KANE:  She said she can't say
15   for sure.
16            THE WITNESS:  I don't know.
17            MR. WOOD:  I think when you say
18   you can't say for sure, is there anything to
19   add to that, Patsy?
20            THE WITNESS:  No.  I don't know. 
21     Q.     (By Mr. Levin)  Mrs. Ramsey, in
22   the course of your conversation with Mr.
23   Schmidt concerning the stun gun, do you
24   recall whether or not he sat down and showed
25   you photographs of the injuries he believed
0046
 1   to be stun gun injuries?
 2     A.     I believe he did.
 3     Q.     Did you or, at your request, were
 4   copies of those provided to any other medical
 5   people, copies of the photographs to assist
 6   them?
 7     A.     I don't know.
 8            MR. LEVIN:  Are you done, Mike?
 9            MR. KANE:  Yes.  I have other
10   questions, but take a minute.
11     Q.     (By Mr. Morrissey)  We know what
12   you said about Priscilla White.  I am just
13   -- my question is, since we talked to you
14   last, have you developed any evidence that
15   would confirm your suspicion as far as
16   Priscilla White is concerned, anything that
17   you know of in the course of the
18   investigation that you have conducted that
19   would keep her on this list, independent of
20   what you might think we know, that kind of
21   thing?
22     A.     No. 
23     Q.     How about Fleet White, anything
24   that you have developed since the last time
25   we spoke to you that would keep him on this
0047
 1   suspect -- or that would keep him on this
 2   list?
 3            MR. WOOD:  Are you talking about
 4   whether their investigators have developed
 5   information as opposed to like an event
 6   occurring such as filing a criminal civil
 7   case, which is a little odd?
 8     Q.     (By Mr. Morrissey)  Anything new
 9   that we don't know about Fleet White that
10   you have developed or your investigators have
11   developed?
12     A.     I can't remember any.  The only
13   -- I just heard recently that we have come
14   across a copy of his statement to you folks
15   or to the police department on or the day
16   after JonBenet's death and that he was asked
17   about the ransom note and could very closely
18   recite the content, which seemed unusual.
19     Q.     The same, I guess, the same
20   question in regard to Mr. McReynolds, and I
21   am sorry I don't remember Mr. McReynolds'
22   first name.
23            MR. WOOD:  Is it Bill?
24            MR. LEVIN:  Yes.
25            MR. MORRISSEY:  William, yes. 
0048
 1     Q.     (By Mr. Morrissey)  Anything, I
 2   know his name came up, and I was wondering
 3   if anything since the last time you spoke
 4   to, I believe it was the Boulder district
 5   attorneys, I think after the formal
 6   discussion you had on tape and everything,
 7   then you went -- and I heard an audiotape --
 8   where you were focusing on Mr. McReynolds
 9   himself with Mr. DeMouth and a couple of
10   other people.  I was wondering if anything,
11   any follow-up had been done as far as your
12   investigation is concerned, any new
13   information on Mr. McReynolds' possible
14   involvement.
15     A.     I don't know.
16     Q.     And Mr. Wolf?  I mean these,
17   Bruce asked you these kind of in a group of
18   four.  I was interested specifically, since
19   we last spoke to you, what have you
20   developed, if anything, about Mr. Wolf?
21     A.     Well, I think subsequent to that,
22   I know we have a tape from his one-time
23   girlfriend.
24     Q.     Ms. Dilson?
25     A.     Dilson.  She videotaped herself
0049
 1   imploring John and me to help her.  She is
 2   very frightened of him.  She believes that
 3   he did this.  She is in hiding.
 4     Q.     Have you ever spoken to Ms.
 5   Dilson in person or --
 6     A.     I can't, I can't remember. 
 7     Q.     Okay.  But you viewed this tape
 8   of her asking for your help?
 9     A.     Yes, uh-huh, uh-huh.
10     Q.     Anything other than the tape that
11   would indicate to you or keep Mr. Wolf in
12   that position that he was in last time we
13   spoke?
14     A.     I just can't think of anything
15   right now.
16            MR. KANE:  Can I ask a question?
17            MR. LEVIN:  I was going to just
18   follow-up on that, Michael.
19     Q.     (By Mr. Levin)  Have you sent
20   your investigators out to interview Ms.
21   Dilson or try to locate her to follow up on
22   this tape?
23            MR. WOOD:  Well, let me help you
24   a little bit.  Chris Wolf has filed a
25   lawsuit against John and Patsy Ramsey, so you
0050
 1   can rest assured that Chris Wolf and Ms.
 2   Dilson, in terms of information, are being
 3   developed about that in terms of the defense
 4   to that case, among other things.  So if we
 5   come across anything in the course of that
 6   civil litigation, we will get it as quickly
 7   as we can copy it and get it to you. 
 8   Obviously we have begun to study a lot of
 9   his appearances in some other things.
10     Q.     (By Mr. Levin)  So, Mrs. Ramsey,
11   I take it then that the answer to my
12   question as far as to date is no, that no
13   one has gone out and attempted to interview
14   Ms. Dilson on your behalf?
15            MR. WOOD:  If you know.
16            MR. LEVIN:  If you know.
17            THE WITNESS:  I don't know.
18     Q.     (By Mr. Levin)  Have you received
19   any reports or any summaries from any
20   investigator that would cause you to believe
21   that she was contacted directly by your
22   representatives?
23     A.     I just don't know.  That would be
24   -- John, perhaps, would know.
25     Q.     You have no recollection, as you
0051
 1   sit here, of seeing any follow-up information
 2   in any form?
 3     A.     That is correct.
 4     Q.     This tape, was that unsolicited on
 5   the part of your family?
 6     A.     Oh, yes.
 7     Q.     When did you receive that?
 8     A.     Probably sometime last spring.
 9     Q.     The spring of '99?
10     A.     No.  Spring of -- I think spring
11   of 2000 or maybe fall of 2000.
12     Q.     Well, it wouldn't be fall.  So
13   maybe spring of this year?
14     A.     I mean spring, yes.
15     Q.     Or fall of '99?
16     A.     I'm just thinking of, I know we
17   saw it in our apartment.  I am trying to
18   think when, how long we have been in that
19   apartment.
20            MR. LEVIN:  Michael.
21     Q.     (By Mr. Kane)  Have you had any
22   forensic people look into the issue of the
23   pineapple that was found in JonBenet's
24   digestive tract?
25            MR. WOOD:  Let me ask you this,
0052
 1   Michael.  Are you stating as a matter of
 2   fact that it was pineapple without any
 3   question?
 4            MR. KANE:  That was stated two
 5   years ago in the interview.  Yes.  There is
 6   no doubt about it.
 7            MR. WOOD:  Are you stating it as
 8   fact?
 9            MR. KANE:  Lou Smith told Mr.
10   Ramsey that too.
11            MR. WOOD:  I just want to make
12   sure it's clear that you're stating it as a
13   matter of fact and not opinion that it is
14   pineapple.
15            MR. KANE:  It is pineapple.
16     Q.     (By Mr. Kane)  Why did you state,
17   let me ask you, why did you state in your
18   book that it was pineapple?
19            MR. WOOD:  Are you going to
20   withdraw the last question?
21            MR. KANE:  Lin, look, this is not
22   -- we are not in court.
23            MR. WOOD:  But we are making a
24   record, and it is important, because I looked
25   at some of the stuff in the past, and it is
0053
 1   jumping back and forth.  I want to make sure
 2   that, if there is a question pending, the
 3   record accurately reflects that she either
 4   has answered it or at this point in time
 5   you're not insisting upon an answer and you
 6   will come back to it later.
 7            I think from what you are telling
 8   me is you are going to hold off on the last
 9   question about forensics and go to the book.
10            MR. KANE:  I'll ask it, but I
11   was going to preface it with the book, but I
12   will do it in the reverse order.
13            MR. WOOD:  Okay.
14     Q.     (By Mr. Kane)  Have you talked to
15   anybody about findings of pineapple in her
16   digestive system?
17     A.     No.
18     Q.     In your book you said that this
19   was -- that that became an urban legend.
20            MR. LEVIN:  Hang on a second.
21            MR. WOOD:  Hang on one second,
22   Michael. 
23            MR. LEVIN:  Do you want to have
24   him change the tape?
25           MR. WOOD:  He's got about nine
0054
 1   minutes, I guess.
 2            MR. MORRISSEY:  Can I ask a
 3   question or are we just on break or
 4   something?
 5            MR. WOOD:  While he goes to get
 6   a book, yes, of course.
 7     Q.     (By Mr. Morrissey)  Mrs. Ramsey,
 8   will you have any trouble, problems with us
 9   seeing this Dilson tape, at some point
10   getting us a copy of that?
11     A.     Sure.  That would be fine.
12            MR. MORRISSEY:  I mean, I don't
13   know if --
14            THE WITNESS:  I am not sure where
15   it is right now, but I am sure we can run
16   it down.
17            MR. WOOD:  Rest assured that, if
18   you have any kind of request like that, if
19   you'll make it to me, you know, I'll
20   carefully consider it.  And if in any way
21   possible, I will try to get that stuff to
22   you.  That is the kind of thing that's gonna
23   be clearly coming out in the civil case, 
24   so --
25            MR. MORRISSEY:  Right.  That is
0055
 1   why I wasn't sure.  I just wanted to ask
 2   her, but I wasn't sure what your position
 3   was going to be --
 4            MR. WOOD:  Well, you know --
 5            MR. MORRISSEY:  --because I know
 6   that is kind of a shadow case, but I would
 7   sure like to see that tape.
 8            THE WITNESS:  She was very upset.
 9            MR. WOOD:  All right. We're back
10   to Mr. Kane's question now.  Did you have a
11   page, Michael?
12            MR. KANE:  Yeah, on Page 273 in
13   the middle.
14     Q.     (By Mr. Kane)  You say
15   apparently, during the autopsy, an issue was
16   raised about the possibility of JonBenet
17   having eaten pineapple.  Do you recall -- do
18   you recall, during the interviews in June of
19   1998, being told that there was, in fact,
20   pineapple in her system?
21     A.     I don't remember the specific
22   discussion.  I believe someone said there may
23   have been something that looked like
24   pineapple. 
25     Q.     Okay.
0056
 1     A.     I'm not  - no one ever has told
 2   me that it was definitively pineapple.
 3     Q.     All right.  Did John -- so John
 4   never told you that Lou Smith told him that
 5   it was definitely pineapple?
 6     A.     No.
 7     Q.     Have you, whether it was pineapple
 8   or any other type of fruit, it is your
 9   understanding that you haven't asked any
10   forensic experts to, gastroenterologist or
11   someone of that nature, someone with a
12   medical background, what their opinion of
13   that being in her system is? 
14     A.     I don't know.  That may have been
15   part of the presentation that was being
16   prepared.
17     Q.     Well, the presentation was Dr.
18   Sperry.  Let me just clarify this.  Was
19   anybody else besides Dr. Sperry going to take
20   part in that presentation, to your knowledge?
21     A.     To my knowledge, there were
22   several people involved.
23     Q.     But you don't know who these
24   people are?
25     A.     No.
0057
 1     Q.     Do you know what their fields of
 2   expertise were?
 3     A.     I am sorry, I don't.
 4     Q.     And you didn't learn subsequent to
 5   January who these people are and what their
 6   fields of expertise are?
 7            MR. WOOD:  Specific names, I
 8   think she's told you.
 9            THE WITNESS:  I mean, I think, I
10   think I was told, probably, you know, this
11   name, this name, and this is who he is and
12   that is and that is.  They are all like
13   names with degrees this long.  I just knew I
14   was very impressed by the caliber of the
15   individuals consulting on this.
16     Q.     (By Mr. Kane)  Okay.  All right. 
17   And you don't have any problem with giving
18   us those names, do you, afterwards if you
19   and Mr. Ramsey --
20            MR. WOOD:  Whatever names were
21   offered to you and Pat Burke, I will tell
22   you, whatever names were offered in January
23   of 2000 by Pat Burke when that offer was
24   rejected, we will certainly provide you with
25   those names if you don't already have them.
0058
 1            MR. KANE:  Well, I'll tell you
 2   right now there was only one name that was
 3   offered to me, and that was Dr. Sperry from
 4   GBI.
 5            MR. WOOD:  That may be true, but
 6   my understanding is there were other
 7   individuals either contemplated in that
 8   presentation, that it was more than one, but
 9   you've got his name and if there were 
10   others --
11            THE WITNESS:  And if we want to
12   do the presentation, we can do it.
13            MR. WOOD:   - we will get those
14   names to you, no question.  In fact, what we
15   can do at some point, if we can figure out
16   an appropriate time, but like this Dilson
17   tape, or these names, et cetera, if you can
18   get a list and you all can get it to me,
19   and then we will try to go through it and
20   see what we can get to you if you don't
21   have it.
22            MR. LEVIN:  Mr. Wood, I am taking
23   maybe incorrectly, I am taking your statement
24   that if we wanted to personally just directly
25   contact Dr. Sperry that we can do that?
0059
 1            MR. WOOD:  I would have to make
 2   that decision.  I haven't thought about it.
 3            MR. LEVIN:  I don't want to --
 4            MR. WOOD:  I wouldn't make a seat
 5   of the pants decision on something like that. 
 6            MR. LEVIN:  Sure.
 7            MR. WOOD:  Obviously he is a
 8   retained expert.
 9            MR. KANE:  Can I clarify that?
10     Q.     (By Mr. Kane)  Has he been
11   retained by you?  That was the whole issue
12   that was presented to us when Pat Burke was
13   suggesting this meeting.  I asked whether he
14   had been retained by you.  Was he retained
15   by you?
16            MR. WOOD:  If you --
17            MR. KANE:  If you know.
18            THE WITNESS:  I don't know.
19            MR. WOOD:  That is probably
20   something she wouldn't know the legal
21   niceties of.
22            THE WITNESS:  I mean, I don't
23   know who.
24            MR. WOOD:  Listen, we'll sort out
25   the question of Sperry's status.  
0060
 1            MR. KANE:  Okay.
 2            MR. WOOD:  And you know,
 3   unfortunately I don't have the direct
 4   knowledge that Pat Burke has, but we will
 5   sort out that in terms of what he
 6   contemplated offering you all and what their
 7   status is and how available they will be.  I
 8   will get those answers to you one way or the
 9   other.
10            MR. KANE:  I just have one thing
11   to follow up on, Bruce.
12     Q.     (By Mr. Kane)  Bruce said that
13   Ellis Armistead had been hired in 1997.  Do
14   you recall that Mr. Armistead, in fact, was
15   hired in December of 1996?
16     A.     I can't say for sure.  I don't
17   know.
18            MR. WOOD:  I think that he was,
19   just if that helps you.
20            MR. KANE:  Yeah, I just wanted to
21   clarify, Mr. Levin said '97.
22            MR. WOOD:  He said as far back
23   as '97, as I recall.
24            MR. KANE:  But it was as far
25   back as 1996.
0061
 1            THE WITNESS:  I just remember he
 2   was there very -- you know, my days are
 3   really foggy then.  I just remember we were
 4   intensely afraid for our safety, and he -- I
 5   just remember, you know, in my trauma,
 6   looking up at this big guy and thinking,
 7   boy, am I glad he is here.  So I don't
 8   know what day that was, or --
 9     Q.     (By Mr. Kane)  Did he ever
10   interview you?
11     A.     Quite possibly.  I can't remember.
12     Q.     You don't have any recollection of
13   ever being interviewed by Mr. Armistead or
14   anybody else working for him?
15     A.     I mean, we talked, certainly.  I
16   don't know if you would say it was an
17   interview.
18     Q.     Did Mr. Armistead or any other --
19   I guess it was Jennifer Getty worked for
20   him.  Do you recall her?
21     A.     Uh-huh, uh-huh (affirmative).
22     Q.     John Foster, do you recall him?
23     A.     Yes.
24     Q.     David Williams, do you recall him?
25     A.     Yes.
0062
 1     Q.     Did any of these people ever take
 2   statements from you about what happened?
 3            MR. WOOD:  Subsequent to June of
 4   1998?
 5            MR. KANE:  No.
 6     Q.     (By Mr. Kane)  Of the events of
 7   December 25th, 26th, of 1996.
 8     A.     I can't remember.
 9     Q.     You don't have any recollection of
10   being interviewed?
11            MR. WOOD:  She told you she can't
12   remember.
13            MR. KANE:  Lin, if you are going
14   to object to every question --I asked you --
15            THE WITNESS:  I can go back and
16   look. 
17            MR. KANE:  Because I am asking a
18   clarifying question.
19            MR. WOOD:  No, no.  I am not
20   objecting.  I am just making sure that we
21   are fair here.  You know, when she says I
22   can't remember and you look over and go, you
23   mean you can't remember, I mean, the tone of
24   that implies that there is something wrong
25   with a truthful answer being I can't
0063
 1   remember.  That is all -- she tells you
 2   something, you know, you don't have to beat
 3   her over the head with her answer.  Once
 4   ought to be enough.
 5            MR. KANE:  Well, is that your
 6   objection, that I am beating her over the
 7   head?
 8            MR. WOOD:  It is not an
 9   objection.  No, no.
10            MR. KANE:  I think, you know, we
11   came down here with the understanding that we
12   could ask questions.  And what you are
13   trying to do is channel those questions into
14   a certain tone.  And I --
15            MR. WOOD:  No, I am not.  I
16   really am not.  I mean, you came down here
17   under the request of Chief Beckner to ask
18   new questions about information that has been
19   obtained by you since June of 1998 or
20   developments that have arisen since June of
21   1998.  That was the request.  We agreed to
22   that. 
23            MR. KANE:  Okay.
24            MR. WOOD:  And all I am saying
25   is that, in the process of giving
0064
 1   information, there may be an answer that to
 2   you strikes you, as you can't remember that.
 3   If she can't remember, Mitch, that is the
 4   truth, and, you know.
 5            MR. MORRISSEY:  I am Mitch.
 6            MR. WOOD:  I don't mean the
 7   phrase, I am sorry, Michael.  I don't mean
 8   to use the phrase -- I don't think you beat
 9   her over the head.  I am just using the
10   phrase that sometimes lawyers do tend to beat
11   witnesses over the head when they don't
12   either like or necessarily react favorably to
13   an answer.  You haven't beat her over the
14   head here today.  I wouldn't let you do
15   that.  And I don't mean to suggest otherwise
16   on the record.
17            MR. KANE:  Okay.
18            MR. LEVIN:  Lin, if I, if I can
19   just follow up your statement a little bit,
20   we are, the four of us, extremely experienced
21   trial lawyers, and I can't imagine that, in
22   the course of your practice, you have not
23   either, during the course of a deposition or
24   in formal interview with a witness or in a
25   courtroom, gotten a witness who says I can't
0065
 1   remember and then not follow it up to see if
 2   you can kind of spark their memory.  I think
 3   that is all we are trying to do. 
 4            MR. WOOD:  I am not going to
 5   prevent that type of follow-up, and I know
 6   you guys are experienced.  And I have
 7   managed to do a little bit of that myself
 8   over the last 23 years.  So I fancy myself
 9   as quite experienced in trial law also.
10            And I understand the difference,
11   though, between an interview and a
12   cross-examination.  In a cross-examination,
13   you might follow up and, as we lawyers say,
14   beat on the witness a little bit.  This is
15   not a cross-examination of my client.  And 
16   there is a difference.
17            This is an interview where you
18   are here to get information about the new
19   questions, as I have earlier stated.  But I
20   am not sitting here saying, Patsy Ramsey has
21   been offered up for you skilled trial lawyers
22   to cross-examine her.
23            MR. LEVIN:  We have no intention.
24            MR. WOOD:  That is the
25   difference.
0066
 1            MR. LEVIN:  I'm sure it is
 2   apparent to you that we are not
 3   cross-examining your client.
 4            MR. WOOD:  Listen, I think we are
 5   doing very well so far.  I am pleased.
 6            MR. LEVIN:  I'm just saying that
 7   we try to prod her memory a little bit, if
 8   we get a --
 9            MR. WOOD:  I have no problems
10   with you trying to jog someone's recollection
11   at all.
12            MR. LEVIN:  Great.  I appreciate
13   that.
14            THE VIDEOGRAPHER:  We need to
15   make a tape change.  One moment.
16            (A recess was taken.)
17            THE VIDEOGRAPHER:  We are rolling.
18            MR. LEVIN:  Mrs. Ramsey, I
19   believe that Chief Beckner has a couple of
20   questions for you concerning your
21   investigation, and then we're gonna move onto
22   another area.
23     Q.     (By Chief Beckner)  Now, I am
24   just a little bit confused because it
25   certainly had been our impression through
0067
 1   public statements and communications that you
 2   and John have had very publicly about having
 3   a secondary investigation conducted by your
 4   people, hiring a team of experts to do
 5   follow-up investigation, and had really
 6   expressed a desire to share this information
 7   with us.
 8            I get the sense that you are not
 9   controlling that investigation, sitting here
10   today, which is a different sense.  So I
11   wanted to ask you if you are in charge of
12   that investigation.
13     A.     Am I personally in charge of the
14   investigation?
15     Q.     Are you and John heading up that 
16   investigation into JonBenet's death?
17     A.     Well, we are having the
18   investigation done.
19     Q.     Who is directing it?  Who is
20   directing that investigation?  In other
21   words, who is making the day-to-day
22   decisions, we need to do this, we need to
23   hire this person, those sorts of things?
24     A.     Ollie Gray.
25     Q.     So you have hired Ollie Gray with
0068
 1   instructions to conduct an investigation, and
 2   he is given a free hand to do whatever that
 3   takes?
 4     A.     Yes.
 5            MR. WOOD:  He is employed
 6   full-time on that at the present time.
 7     Q.     (By Chief Beckner)  Has that
 8   always been the case or has that been a
 9   recent development?  Because we talked about
10   a lot of other people that have been
11   involved from '96 on.
12     A.     Right.
13     Q.     Is that a recent development?
14     A.     Well, within the past year.
15            MR. WOOD:  You are talking about
16   with Ollie?
17            CHIEF BECKNER:  Yes, with Ollie. 
18     Q.     (By Chief Beckner)  Is John more
19   involved than you are --
20     A.     Yes.
21     Q.      - in terms of getting
22   information?
23     A.     Yes.
24     Q.     And knowing where the
25   investigation is going?
0069
 1     A.     Yes.
 2     Q.     But John does not share that with
 3   you?
 4     A.     He shares some of it with me.
 5     Q.     But not all of it?
 6     A.     That is right.
 7            MR. KANE:  Can I ask a follow-up
 8   to that then?
 9     Q.     (By Mr. Kane)  What is your
10   understanding of the reason that Ellis
11   Armistead is no longer working on the case?
12     A.     Well, I think -- I don't know
13   exactly why he is not and why Ollie is, but
14   Ollie is full-time.  They were I don't
15   believe capable of continuing it on on a
16   full-time basis.
17     Q.     Is that your understanding?
18     A.     That is my understanding.
19     Q.     They couldn't do it full-time, so
20   you got somebody else?
21     A.     Correct. 
22            MR. WOOD:  Let me just correct,
23   when you say -- Ollie has been involved
24   before Ellis left.  And I think Ellis's
25   leaving was tied to the fact that Bryan and
0070
 1   Hal would no longer be in the case and the
 2   question of how much could really be done
 3   effectively and whether it could be done by
 4   one full-time person and whether there was
 5   really anything else for Ellis to do.
 6            CHIEF BECKNER:  Let me follow-up.
 7     Q.     (By Chief Beckner)  Who was in
 8   charge of the investigation prior to Ollie?
 9     A.     Ellis Armistead, John Foster, and
10   Williams, David Williams.
11     Q.     So when Mr. Gray came on the
12   investigation, Ellis Armistead was still on
13   at that time?
14     A.     Yes.  There was a transition in
15   time.
16     Q.     So Ellis was still in charge at
17   that time?
18     A.     I don't know who was in charge. 
19   I think it was kind of a change in command.
20     Q.     And what was John's involvement at
21   that time?
22     A.     I don't know exactly, but he
23   basically has been the point man. 
24            MR. WOOD:  And don't leave out
25   Pat Burke and Bryan Morgan, Chief.  I think
0071
 1   they were taking on a more active role in
 2   making decisions about things that could or
 3   should be done as opposed to what now is
 4   more Ollie's area.
 5            CHIEF BECKNER:  Yeah, I was just,
 6   because the impression was that, based on
 7   some of the statements that you've made
 8   publicly and John specifically about spending
 9   all of his time trying to find the killer of
10   JonBenet, I am trying to get at, you know,
11   what are you doing and how involved are you. 
12   Because I was getting the sense here that
13   you aren't particularly involved in that.
14            THE WITNESS:  Well, I am not
15   day-to-day involved with it.  John speaks
16   with Ollie, I would say, on a daily basis. 
17   You know, where we are, what's been --
18            CHIEF BECKNER:  On a daily basis?
19            MR. WOOD:  You sure about that?
20            THE WITNESS:  I don't know if it
21   is daily, but it is frequently.
22            MR. MORRISSEY:  Okay.
23            MR. KANE:  Can I ask, is 
24   Mr. Gray employed by you or employed by 
25   Mr. Wood?
0072
 1            MR. WOOD:  Employed by me, which
 2   would be standard handling, as I understand
 3   it.
 4     Q.     (By Chief Beckner)  So the
 5   decisions to hire the forensic  people, those
 6   were not made by you or John?
 7     A.     I, you know, I don't know who
 8   actually says, you know, let's hire him and
 9   him and him.  I am sure that it was, this
10   is what we want to do.  We want to have
11   people look at this and that and the other,
12   you know, competent experts, and we said
13   great.
14            I mean, we entrusted them to make
15   the decisions.  I mean, we don't know how to
16   investigate.
17     Q.     No, I understand that.  Experts
18   can be quite expensive.
19     A.     Yes, they are.
20     Q.     Quite costly.  So I am just, I'm
21   trying to figure out whether whoever is in
22   charge of the investigation at whatever
23   particular time has a free hand to hire
24   those experts.  I mean, is it kind of like
25   an open checkbook kind of thing or do they
0073
 1   have to come back?
 2            THE WITNESS:  No, not --
 3            MR. WOOD:  I don't think it is
 4   an open checkbook.
 5            THE WITNESS:  No.
 6            MR. WOOD:  Certainly not now.  I
 7   don't think it ever has been, Chief.  I
 8   think that there was a -- Pat Burke and
 9   Bryan Morgan were out there and dealing more
10   directly with that issue.  I am quite
11   confident John, you all can ask him, he can
12   tell you, but I am quite sure that, as any
13   lawyer would do with any major expenditure
14   first, it has to be approved by the client. 
15   So that is my understanding.
16            CHIEF BECKNER:  That is what I am
17   getting at.
18            THE WITNESS:  Yes.
19     Q.     (By Chief Beckner)  It was
20   somebody, whether it was you or John,
21   somebody had to be aware of who was being
22   hired to do work for the investigation?
23     A.     Yes.
24     Q.     And you think it was John who was
25   well aware of those decisions?
0074
 1     A.     Yes.
 2            CHIEF BECKNER:  Okay.
 3     Q.     (By Mr. Morrissey)  Mrs. Ramsey,
 4   what does Mr. San Agustin do?
 5     A.     He assists Ollie.
 6     Q.     So he works for Ollie?
 7     A.     Now, there again, I don't know
 8   who signs whose paychecks or whatever.
 9     Q.     Right.  I am not asking you that.
10     A.     But Ollie brought him in.
11     Q.     What does he do?  Do you know?
12     A.     He is, in lay terms, a computer
13   whiz.
14            MR. WOOD:  Business partner. 
15            THE WITNESS:  Business partner,
16   yeah, but he --
17     Q.     (By Mr. Morrissey)  He is a
18   computer guy?
19     A.     He is a computer guy.
20     Q.     Okay.
21            MR. WOOD:  I don't know if he
22   would necessarily agree with computer guy --
23            THE WITNESS: I mean, I know
24   that's probably not fancy enough.
25            MR. GRAY:  He is basically, as
0075
 1   you know, Mitch, an evidence specialist as
 2   far as courtroom evidence goes.
 3            MR. MORRISSEY:  Demonstrative
 4   evidence type stuff, yeah, that has been my
 5   experience with him.  I just thought he was
 6   in the employ of the El Paso County
 7   Sheriff's Office.
 8     Q.     (By Mr. Levin)  Ms. Ramsey, we
 9   are going to move on to another area.  And
10   what I want to discuss with you is the
11   underpants that JonBenet was wearing at the
12   time that she was discovered on the 26th. 
13   We are going to try to get some background
14   information on those from you.  Hopefully you
15   can help us out a little bit.  Okay?
16            I don't, I'll be perfectly honest
17   with you, I don't follow all of the media
18   developments in this case, so I am not quite
19   sure what is out in the public sector.  But
20   what I would like to get a feel for is just
21   what your belief is with regard to the
22   significance of the underpants that your
23   daughter was wearing at the time that she
24   was found murdered.
25            MR. WOOD:  With all due fairness,
0076
 1   didn't you cover that in June of 1998?
 2            MR. LEVIN:  I don't believe so,
 3   and I think that will become apparent.
 4            MR. WOOD:  Okay.  Well, maybe if
 5   you help me, just so I understand, when you
 6   say what is the significance of it, are you
 7   really just trying to find out what she
 8   might know about why she was wearing them? 
 9   I am not sure what significance, with regard
10   to significance --
11            MR. LEVIN:  What I would like to
12   know is what Mrs. Ramsey's belief, as she
13   sits here, is significant about the
14   underpants.  In a normal homicide case, what
15   kind of underpants someone is wearing is
16   typically not national news.  Fair enough?
17            THE WITNESS:  Yes.
18            MR. LEVIN:  But apparently it has
19   become national news, and I just want to get
20   a sense, before I start asking some specific
21   questions, which I hope she can help us
22   with, why you think, what is your
23   understanding of what the significance is.
24            MR. WOOD:  Bruce, I don't know,
25   just so it is clear, I don't know that her
0077
 1   underwear has become national news.  
 2            Now, I don't know, sitting here
 3   today, I may want to go back and look at
 4   them, but it may be something that the
 5   tabloids have written about, but I don't know
 6   of any national news from reputable news
 7   agencies that have made that a major issue. 
 8            But I am not arguing with that.  
 9   I just want to make sure I don't agree with
10   you by acquiescence, but --
11            MR. LEVIN:  I understand.
12            MR. WOOD:   - the question is, I
13   think he wants to know, and maybe I am still
14   not clear, you assume she attaches some
15   significance to it, but I am not sure.  If
16   you asked her a factual question, maybe she
17   will understand.
18     Q.     (By Mr. Levin)  Well, let's start
19   with what  - I will make it very simple for
20   you, Mrs. Ramsey.  What information are you
21   in possession of or what do you know about
22   the underwear that your daughter was wearing
23   at the time she was found murdered?
24     A.     I have heard that she had on a
25   pair of Bloomi's that said Wednesday on them.
0078
 1     Q.     The underwear that she was
 2   wearing, that is Bloomi's panties, do you
 3   know where they come from as far as what
 4   store?
 5     A.     Bloomingdales in New York.
 6     Q.     Who purchased those?
 7     A.     I did. 
 8     Q.     Do you recall when you purchased
 9   them?
10     A.     It was, I think, November of '96. 
11     Q.     In the fall of 1996, how many
12   trips did you make to New York?
13     A.     Two, I believe.
14     Q.     Do you recall, and again, the
15   same, same qualification I gave you when we
16   started, which is, I understand that you are
17   not going to give me exact dates, but the
18   two trips you made, did you make those with
19   different groups of people?
20     A.     Yes.
21     Q.     The first trip, who was that trip
22   with?
23     A.     The first trip was a
24   mother-daughter trip with my mother Nedra
25   Paugh, my sister Pam Paugh, friends Susan
0079
 1   Flanders from Charlevoix, Michigan, and her
 2   daughter and a friend of Susan's, Ms.
 3   Kirkpatrick I believe was her name, and her
 4   daughter, and JonBenet and myself.
 5     Q.     And the second trip you made was?
 6     A.     The second trip we made was with
 7   Glen and Susan Stein.
 8     Q.     Is that the trip -- which trip
 9   was the November trip? 
10     A.     With the children.
11     Q.     Was that -- that is the first
12   trip?
13     A.     Yes.
14     Q.     And the second trip that you and
15   your husband and the Steins took, was that
16   also November, but later in the month, or
17   was that a December trip?
18     A.     I think it was December.
19     Q.     And maybe this will help jog your
20   memory as to time.  I believe that was the
21   time of the Christmas parade in Boulder.
22     A.     Yes.
23     Q.     Is that correct?
24     A.     Yes.
25     Q.     Were you out of town?
0080
 1     A.     I remember that.
 2     Q.     Which of those two trips did you
 3   purchase the Bloomi's?
 4     A.     The first trip.
 5     Q.     Was it something that was selected
 6   by JonBenet?
 7     A.     I believe so.
 8     Q.     Was it your intention, when you
 9   purchased those, for those to be for her,
10   not for some third party as a gift?
11     A.     I bought some things that were
12   gifts and some things for her.  So I 
13   don't --
14     Q.     Just so I am clear, though, it is
15   your best recollection that the purchase of
16   the underpants, the Bloomi's days of the
17   week, was something that you bought for her,
18   whether it was just I am buying underwear
19   for my kids or these are special, here's a
20   present, that doesn't matter, but it was your
21   intention that she would wear those?
22     A.     Well, I think that I bought a
23   package of the -- they came in a package of
24   Monday, Tuesday, Wednesday, Thursday, Friday. 
25   I think I bought a package to give to my
0081
 1   niece.
 2     Q.     Which niece was that?
 3     A.     Jenny Davis.
 4     Q.     They came in, if you recall, do
 5   you remember that they come in kind of a
 6   plastic see-through plastic container.
 7     A.     Right.
 8     Q.     They are rolled up?
 9     A.     Yes.
10     Q.     So if I understand you correctly,
11   you bought one package for Jenny Davis, your
12   niece, and one for JonBenet?
13     A.     I am not sure if I bought one or
14   two.
15     Q.     Do you remember what size they
16   were?
17     A.     Not exactly.
18     Q.     JonBenet was found wearing the
19   Wednesday Bloomi's underpants, and your
20   understanding is correct, that is a fact, you
21   can accept that as a fact, when she was
22   found murdered.  Those underpants do not fit
23   her.  Were you aware of that?
24            MR. WOOD:  Are you stating that
25   as a matter of fact --
0082
 1            MR. LEVIN:  I'm stating that as a
 2   matter --
 3            MR. WOOD:   - for a six-year-old
 4   child?
 5            MR. LEVIN:  I am stating that as
 6   a matter of fact.
 7            MR. WOOD:  Don't fit her
 8   according to whose standard?  
 9            MR. LEVIN:  By --
10            MR. WOOD:  I mean, I have got an
11   11-year-old boy, and he wears underwear that
12   potentially hangs down to his knees, Bruce. 
13   I mean, I don't know how you can come up
14   with that as a fact.  That sounds to me
15   like more of an opinion.  Who states that as
16   fact?
17     Q.     (By Mr. Levin)  Ms. Ramsey, your
18   daughter weighed, I believe, 45 pounds;
19   correct?
20     A.     Uh-huh (affirmative).
21     Q.     She was six years old?
22     A.     Uh-huh (affirmative).
23     Q.     What size underpants would you
24   normally buy for her?
25     A.     8 to 10.
0083
 1     Q.     Ms. Ramsey, would you say that it
 2   would, it is safe to assume that, if she is
 3   wearing underpants designed for someone who
 4   weighs 85 pounds, who is 10 to 12 years old,
 5   that those would not fit her? 
 6     A.     Those -- I mean, I am sure she
 7   could wear them, yes, but they wouldn't fit
 8   as well as a smaller pair.
 9     Q.     And as a mother, you would know
10   that someone who is 85 pounds is
11   significantly larger than your little
12   six-year-old?
13            MR. WOOD:  Can't we assume that
14   as a matter of 85 is more than 45 without
15   her having to document a mathematical fact,
16   Bruce?
17     Q.     (By Mr. Levin)  40 pounds is the
18   wrong size pair of underpants, would you
19   agree?
20     A.     Yes.
21     Q.     Okay.  What we are trying to
22   understand is whether -- we are trying to
23   understand why she is wearing such a large
24   pair of underpants.  We are hoping you can
25   help us if you have a recollection of it.
0084
 1     A.     I am sure that I put the package
 2   of underwear in her bathroom, and she opened
 3   them and put them on.
 4     Q.     Do you know if -- you bought
 5   these sometime in mid to early December, is
 6   that correct, as far as -- no, I am sorry,
 7   you bought them in November?
 8     A.     Right. 
 9     Q.     Do you recall, was she wearing
10   these?  And I don't mean this specific day
11   of the week, but was she wearing, were you
12   aware of the fact that she, you know, was in
13   this package of underpants and had been
14   wearing them since the trip to New York in
15   November?
16     A.     I don't remember.
17     Q.     Ms. Hoffman Pugh generally did the
18   laundry for the family, that is part of her
19   duties; is that correct?
20     A.     Correct.
21     Q.     Exclusively, or did you wash
22   clothes on occasion?
23     A.     I washed a lot of clothes.
24     Q.     Do you have any recollection of
25   ever washing any of the Bloomi panties?
0085
 1     A.     Not specifically.
 2     Q.     Was it something that, the fact
 3   that she is wearing these underpants designed
 4   for an 85-pound person, did you ever -- and
 5   I will give you a minute to think about it
 6   because I know it is tough to try to pin
 7   down a couple of months of casual
 8   conversation -- do you recall ever having any
 9   conversations with her concerning the fact
10   that she is wearing underwear that is just
11   too large for her?
12     A.     No. 
13     Q.     Knowing yourself as you do, if it
14   was, if it had caught your attention or came
15   to your attention, do you think you might
16   have said, JonBenet, you should, those don't
17   fit, put something on that fits, that is
18   inappropriate?  Do you think, if it came,
19   had come to your attention --
20     A.     Well, obviously we, you know, the
21   package had been opened, we made the
22   decision, you know, oh, just go ahead and
23   use them because, you know, we weren't going
24   to give them to Jenny after all, I guess,
25   so.
0086
 1            I mean, if you have ever seen
 2   these little panties, there is not too much
 3   difference in the size.  So, you know, I'm
 4   sure even if they were a little bit big,
 5   they were special because we got them up
 6   there, she wanted to wear them, and they
 7   didn't fall down around her ankles, that was
 8   fine with me.
 9            MR. MORRISSEY:  Did you ever see
10   if they fell down around her ankles or not?
11            THE WITNESS:  No.
12            MS. HARMER:  But you specifically
13   remember her putting on the bigger pair? 
14   And I am not saying --
15            THE WITNESS:  They were just in
16   her panty drawer, so I don't, you know, I
17   don't pay attention.  I mean, I just put all
18   of her clean panties in a drawer and she can
19   help herself to whatever is in there.
20            MS. HARMER:  I guess I am not
21   clear on, you bought the panties to give to
22   Jenny.
23            THE WITNESS:  Right.
24            MS. HARMER:  And they ended up in
25   JonBenet's bathroom?
0087
 1     A.     Right.
 2     Q.     (By Ms. Harmer)  Was there  - I'm
 3   sorry.  Do you recall making a decision then
 4   not to give them to Jenny or did JonBenet
 5   express an interest in them; therefore, you
 6   didn't give them to Jenny?  How did that --
 7     A.     I can't say for sure.  I mean, I
 8   think I bought them with the intention of
 9   sending them in a package of Christmas things
10   to Atlanta.  Obviously I didn't get that
11   together, so I just put them in her, her
12   panty drawer.  So they were free game.
13     Q.     (By Mr. Morrissey)  At the time,
14   how old was Jenny?
15     A.     I don't know.  Probably -- I
16   don't know. She is older than JonBenet, but
17   I don't know exactly how old she was.
18     Q.     Would these panties, size wise, be
19   more appropriate for -- is she an older
20   girl?
21     A.     Yes. 
22     Q.     And I assume a larger girl?
23     A.     Well, at that time, no, not -- I
24   mean, she is not -- I mean, today she is a
25   young woman, but then she was a little girl.
0088
 1     Q.     How old is she now?
 2     A.     She is now 15, I believe.
 3     Q.     So she would have been about 12
 4   or somewhere --
 5     A.     11.
 6     Q.     -- 11, 12?
 7     A.     Yeah.
 8     Q.     And based on the, I guess,
 9   dimensions that Mr. Levin has talked about,
10   these would have been a size appropriate for
11   her?
12     A.     Uh-huh (affirmative).
13            MR. WOOD:  Do you know that?
14     Q.     (By Mr. Morrissey)  Based on your
15   knowledge of her?  I mean, I never have seen
16   this girl, so --
17            MR. WOOD:  Guys, I think -- if
18   you all have kids, I mean, I just think you
19   are making assumptions based on poundage,
20   apparently, that isn't necessarily, you know,
21   in touch with the realities with kids and
22   their clothes.  But you know, if you know
23   that, Patsy, please tell them. 
24            Why don't you go ahead and
25   restate your question.
0089
 1     Q.     (By Mr. Morrissey)  You purchased
 2   these specifically for a person?
 3     A.     Okay.
 4            MR. WOOD:  Is that your
 5   recollection?
 6            THE WITNESS:  Yes.
 7            MR. WOOD:  Okay.
 8     Q.     (By Mr. Morrissey)  And I assume
 9   you wanted them to fit her and she be able
10   to wear them or there would be no sense in
11   purchasing them; right?
12     A.     Right.
13     Q.     Okay.  Would the size that has
14   been described here be appropriate for the
15   size of the girl you purchased them for?
16     A.     I was guessing at her size, so I
17   had hoped that they would be.
18     Q.     Now, we have talked -- you know,
19   the fact that a boy may wear boxer shorts
20   that go down to his ankles -- 
21     A.     Uh-huh (affirmative).
22     Q.     --has nothing to do with girls,
23   when you purchase girl's panties; right?
24            MR. WOOD:  Come on, Mitch.  
25   Mitch --
0090
 1            THE WITNESS:  I mean, if --
 2            MR. WOOD:  Don't answer that. 
 3   That's not a --         
 4            MR. MORRISSEY:  It is different.
 5            MR. WOOD:  I made the statement
 6   because of my kids, but let me just tell
 7   you, my nine-year-old daughter likes to wear
 8   my XL T-shirts.  I mean, you are asking now
 9   about the realm of kids, and I don't think
10   that is a factual question that she is
11   really here to give you information about.
12            MR. MORRISSEY:  Mrs. Ramsey, I
13   never purchased a pair of girl's panties. 
14   Okay.
15     Q.     (By Mr. Morrissey)  What do you
16   do, I mean, when you do that, what do you
17   think about as far as the person you're
18   purchasing them for?
19     A.     Well, you just look, small,
20   medium, large, you know, and you pick the
21   one you think would most likely fit.
22     Q.     And do they have age groups or
23   are they suggested for like a 10-year-old
24   through a 12-year-old or a 13-year-old
25   through a 15-year-old?  Do they do it that
0091
 1   way too?
 2     A.     I never paid any attention if
 3   they do.
 4            MR. MORRISSEY: Okay.
 5     Q.     (By Mr. Kane)  Let me ask it
 6   this way.  Did you say you bought more than
 7   one set of Bloomi's?
 8     A.     I can't remember.
 9     Q.     You bought some for JonBenet?
10     A.     I can't remember.
11     Q.     Why is it that you remember
12   buying Bloomingdale's panties in November of
13   1996? 
14     A.     Because --
15            MR. WOOD:  Because she remembers
16   it.  I mean --
17            MR. KANE:  Wait a second, Lin. 
18   Would you please let her answer the question?
19   It is a simple question.
20            MR. WOOD:  Why is it that you
21   remember something?  
22            MR. KANE:  Yes, why do you
23   remember --
24            MR. WOOD:  Because she remembered.
25     Q.     (By Mr. Kane)   - that, that
0092
 1   detail?
 2     A.     Well, for starters, it has been
 3   made such a big detail.
 4     Q.     Okay, well, that is my question.
 5     A.     I remember that I -- and I, you
 6   know, we were kind of shopping around, and
 7   it was close to Christmas season, so we
 8   might pick up a little souvenir.  I 
 9   bought -- I think I picked up a little
10   something for a baby-sitter, you know.
11     Q.     Where was it that you became
12   aware that this was -- where was it that it
13   was made a big deal?  What was the source
14   of your information that Bloomingdale's
15   panties somehow were significant that made
16   you then say, wait a second, did I ever buy
17   those?
18            MR. WOOD:  Do you have a precise
19   recollection of that event occurring where
20   all of a sudden something happened and you
21   decided it was some big deal?
22            THE WITNESS:  I don't know.  I
23   mean, my first thought is something in the
24   tabloids, but, you know, they get everything
25   wrong, so --
0093
 1     Q.     (By Mr. Kane)  Okay.  Were you
 2   aware that these were the size of panties
 3   that she was wearing, and this has been
 4   publicized, it is out in the open, that they
 5   were size 12 to 14?  Were you aware of
 6   that?
 7     A.     I have become aware of that, yes.
 8     Q.     And how did you become aware of
 9   that?
10     A.     Something I read, I am sure.
11     Q.     And I will just state a fact
12   here.  I mean, there were 15 pair of panties
13   taken out of, by the police, out of
14   JonBenet's panty drawer in her bathroom.  Is
15   that where she kept -  
16     A.     Uh-huh (affirmative).
17     Q.     -- where you were describing that
18   they were just put in that drawer?
19     A.     Yes.
20     Q.     Okay.  And every one of those was
21   either a size four or a size six.  Okay? 
22   Would that have been about the size pair of
23   panties that she wore when she was six years
24   old?
25     A.     I would say more like six to
0094
 1   eight.  There were probably some in there
 2   that were too small.
 3     Q.     Okay.  But not size 12 to 14? 
 4     A.     Not typically, no.
 5            MR. KANE:  Okay.
 6     Q.     (By Mr. Morrissey)  And you
 7   understand the reason we are asking this, we
 8   want to make sure that this intruder did not
 9   bring these panties with him, this was
10   something -- 
11     A.     Right.
12     Q.      - that was in the house.
13     A.     Yes.
14     Q.     And we are clear that, as far as
15   you know, that is something that was in this
16   house?
17     A.     Yes.
18     Q.     -- that belonged to your daughter,
19   these panties?
20     A.     Correct.
21     Q.     (By Ms. Harmer)  Mrs. Ramsey,
22   have you ever seen a crime scene photo of
23   the underwear that your daughter was found
24   in?
25     A.     No.
0095
 1     Q.     Did Lou Schmidt ever show you a
 2   photo?
 3     A.     No.
 4     Q.     (By Mr. Kane)  I want to follow
 5   up with something you said earlier.  You
 6   said she would have just gone in and gotten
 7   a pair herself?
 8     A.     Uh-huh (affirmative).
 9     Q.     Okay. Was she -- did she usually
10   dress herself? 
11     A.     She was pretty much able to dress
12   herself.
13     Q.     And I can't recall if you've
14   ever, and forgive me if you have answered
15   this before, but did she have a bath that
16   day, Christmas Day?
17            MR. WOOD:  You have asked that
18   before, several times.
19     Q.     (By Mr. Kane)  What was the
20   answer?  Can you refresh my memory?
21            MR. WOOD:  You know that I'm sure
22   better than I do.
23            MR. KANE:  Oh, come on, Lin, I
24   was just asking a question so that I can
25   follow up on the thing.  If you are going
0096
 1   to start getting into you asked that one
 2   time, I just don't have a recollection of
 3   it.
 4            MR. WOOD:  Sure I am.  Calm
 5   down.
 6     Q.     (By Mr. Kane)  Did she have a
 7   bath that day?
 8            MR. WOOD:  Excuse me one second,
 9   Patsy.  Calm down, Michael.  I am not trying
10   to create a problem for you.
11            MR. KANE:  You certainly are.
12            MR. WOOD:  No, I am not.
13            MR. KANE:  You certainly are. 
14            MR. WOOD:  Let me finish. I am
15   not going to interrupt you.  Please don't
16   interrupt me.
17            The fact that you know it has
18   been asked --
19            MR. KANE:  I don't know that it
20   has been asked.
21            MR. WOOD:  Are you going to let
22   me finish?
23            MR. KANE:  No, because I did not
24   say that --
25            MR. WOOD:  Then let's take a
0097
 1   break, and when you can let me speak without
 2   being interrupted, we'll start again.
 3            MR. KANE:  You mischaracterized
 4   what I said.  I said I don't remember if it
 5   has been asked.  Forgive me if it was.
 6            MR. WOOD:  Let me go back and
 7   let's look at it.
 8            It is not clear.  Why don't we
 9   take a break and look and see if it has
10   been asked.
11            MR. KANE:  We don't need to take
12   a break.  It is just a simple question.
13            MR. WOOD:  Listen.  All of the
14   questions should be simple.
15            MR. KANE:  It is a very simple
16   question.  Did she have a bath that day? 
17            MR. WOOD:  Right.  But please
18   remember that I have to make sure that we
19   abide by what you requested.
20            MR. KANE:  Well.
21            MR. WOOD:  I really am going to
22   take a break.
23            MR. KANE:  Go ahead.  Make your
24   speech.
25            MR. WOOD:  I am not making a
0098
 1   speech.
 2            MR. KANE:  That is exactly what
 3   you are doing, Lin.
 4            MR. WOOD:  I am not making a
 5   speech.  Chief Beckner asked us to come down
 6   here, you all to come out here to ask new
 7   questions about developments that have
 8   occurred since June of 1998 and information
 9   that has been obtained since June of 1998.
10            And I am confident that the
11   question about JonBenet taking a bath or a
12   shower has been asked before, and I would
13   simply say let's don't start, even when it
14   seems like it is not important at the
15   moment, let's don't start going down the road
16   of asking questions that have been asked
17   before because that is specifically what you
18   and Chief Beckner told me you weren't going
19   to do.
20            And so I will be glad at a break
21   to look that up and see if we can find the
22   answer for you.  And then we can come back,
23   give her a chance to look and see what she
24   said before, put that in the context of your
25   question and she will answer the question if
0099
 1   it is a new one.
 2            MR. KANE:  Okay, so in other
 3   words what you are doing is, and just to
 4   make this clear, you're directing your client
 5   not to answer that until she's had a chance
 6   to go back and look to see whether she's
 7   asked and answered that before.
 8            MR. WOOD:  No.  It's really more
 9   of a chance for you and I to look and see
10   if she's answered it.
11            MR. KANE:  You are directing her
12   not to answer the question?
13            MR. WOOD:  I am asking you to --
14            MR. KANE:  No.  Are you directing
15   her not to answer the question?
16            MR. WOOD:  I am asking you to,
17   in the spirit of why you all wanted to come
18   here and we agreed for you to come here
19   about new questions on information developed
20   or obtained since June of 1998, I am asking
21   you, on what appears even to you to be a
22   situation where it probably was asked in June
23   or, if not, April of '97, to let's take a
24   time at a break.  You're well prepared here. 
25   You've looked at this.
0100
 1            MR. KANE:  All right. 
 2            MR. WOOD:  If she has been asked
 3   that, then you will have your answer.  And
 4   if she hasn't been asked that, then she will
 5   give you that answer today; although, I don't
 6   know why you wouldn't have asked her that
 7   before.
 8            MR. KANE:  So you are directing
 9   her not to answer that question?            
10            MR. WOOD:  I am asking you to
11   defer it.
12            MR. KANE:  Yes or no, are you
13   directing her not to answer the question?
14            MR. WOOD:  I am asking you to
15   defer it, Michael.  That's all.
16            MR. KANE:  Let me, let me just
17   say something.  We are down here to solve a
18   murder.  Are you telling me that you are
19   going to tell her not to answer that
20   question, whether it has anything to do with
21   this murder, you are directing her not to
22   answer that question?
23            MR. WOOD:  I have not direct --
24            MR. KANE:  Because of some,
25   because of some rule that has been
0101
 1   established for this?
 2            MR. WOOD:  Are you through?
 3            MR. KANE:  Yeah.
 4            MR. WOOD:  I understand that you
 5   are investigating a murder.  Do you
 6   understand that I understand that?
 7            MR. KANE:  I hope you do.
 8            MR. WOOD:  I understand it, Mr.
 9   Kane.  Now listen to me.
10            I was asked, and my clients
11   agreed to answer new questions about
12   information that has been obtained since June
13   of 1998 after three full days of interviews
14   which had been followed by April of 1997 in
15   almost a full day of an interview by Patsy
16   Ramsey, new questions about new information
17   since June of 1998 or developments that have
18   come up since June of 1998.
19            That was the request made by
20   Chief Beckner.  That was what we agreed to
21   do because that is what we were asked to do. 
22            Now, if you want to change the
23   format, then let's consider that after we
24   finish this format.  But I didn't ask Patsy
25   Ramsey or John Ramsey to go back and study
0102
 1   what they had said before to try to memorize
 2   it or refresh their recollections, period,
 3   because it was represented to me that you
 4   weren't going to do that.  
 5            So if you do it, I am not really
 6   directing her not to answer it.  I am
 7   directing you that you are outside of the
 8   scope of your request and, therefore, your
 9   question is not fair and appropriate.  It is
10   as simple as that.  I  am not trying to be
11   difficult.
12            MR. KANE:  If that is your
13   definition of what is fair, then that is
14   fine.  All right.  You've made your record. 
15   I withdraw that question.
16            MR. WOOD: I think it is very
17   fair.  I made my statement.  It is not
18   meant to be a record, necessarily.
19     Q.     (By Mr. Kane)  Here's a question
20   that was not asked, Mrs. Ramsey.  Did you
21   dress JonBenet Christmas Day?
22     A.     I can't remember.
23     Q.     (By Mr. Levin) Mrs. Ramsey, do
24   you know whether or not she changed her
25   underwear Christmas Day?
0103
 1     A.     I don't know.
 2     Q.     We are going to assume the fact
 3   that she did not take a bath because you
 4   previously stated that.  Would she change her
 5   underwear if she didn't take a bath on
 6   Christmas Day?
 7            MR. WOOD:  Excuse me.  You
 8   remember that she has been asked that now.
 9            MR. LEVIN:  I have known that.
10            MR. WOOD:  Why didn't he know
11   that?
12            MR. LEVIN:  I can't speak for Mr.
13   Kane.
14            MR. KANE:   I don't have a big
15   catalog of every single question and answer.
16            MR. LEVIN:  I don't either.  I
17   can assure you Mr. Kane knows many facts I
18   don't know.
19            MR. WOOD:  Well, you all planned
20   the interview.  You have got him over here
21   claiming he doesn't know if a question's been
22   asked.  Why didn't you pop up and look over
23   and say she had answered that.
24            MR. LEVIN:  I didn't want to
25   interrupt you, Mr. Wood.  You were very
0104
 1   upset.
 2            MR. WOOD:  I am not upset.  
 3            MR. LEVIN:  You were upset that
 4   you were interrupted by Mr. Kane.
 5            MR. WOOD:  I'm upset that when I
 6   tried to speak I was interrupted, but why
 7   didn't you look over and say, Mitch, I mean,
 8   Michael, she has answered that.
 9            MR. LEVIN:  I was just going to
10   let each of you speak and then ask my
11   question.
12     Q.     (By Mr. Levin)  Do you know if
13   she changed her underwear?
14     A.     I do not know.
15     Q.     Would it be her routine habit or
16   practice, if she is going out for dinner at
17   friends, for her to change from head to toe,
18   including her underwear, getting dressed to
19   go out for the evening, even if she didn't
20   take a bath?
21     A.     I don't know that there is any
22   particular routine.  She may have.  I don't
23   know.
24     Q.     If she listened to mom, would she
25   have done that?  I mean, we are going out,
0105
 1   you change from head to toe, wash up?
 2            MR. WOOD:  You are saying if she
 3   had said that?
 4            MR. LEVIN:  No.  I am saying,
 5   this child was raised by Mrs. Ramsey, and I
 6   am assuming that, in the course of your
 7   raising your child, that it was JonBenet, we
 8   are going out, even if she hadn't taken a
 9   bath, you wash up, you change your clothes,
10   and that would include if she hasn't bathed,
11   change your underwear because she is running
12   around and playing all day.
13            MR. WOOD:  Are you stating that
14   is what you do with your children?
15            MR. LEVIN:  No.  I am asking
16   her.
17            THE WITNESS:  I don't, I don't
18   remember the course of events --
19            MR. LEVIN:  Okay.
20            THE WITNESS:   - really.
21     Q.     (By Mr. Levin)  So you just don't
22   know whether or not she changed her
23   underpants?
24     A.     I don't know.
25     Q.     During the course of one of the
0106
 1   prior interviews, I think it was '98, but I
 2   am not certain, you were asked and stated
 3   that, on occasion, she would leave her
 4   underclothes at a friend's house if they had
 5   gone swimming or gotten wet.  Do you 
 6   remember that?
 7            MR. WOOD:  Hold on.  Do you have
 8   a copy of that?
 9            MR. LEVIN:  I don't have it right
10   here.
11            MR. WOOD:  I mean, I asked you
12   all to be able to produce those prior
13   statements so we can look at it in context.
14            MR. LEVIN:  We've got it in the
15   computer.  Mr. Wood, I will represent to you
16   that that is a statement that your client
17   made.  I have a clear recollection.  I am
18   not -- this is not an attempt to make her
19   -- I am developing a question that assumes
20   that to be true.  I will represent to you
21   that, to a near certainty, as certain as
22   someone can be, in reviewing statements and
23   working on this case for two years, I
24   believe that statement to be made.  And I am
25   not trying to trick you or your client.  I'm
0107
 1   trying  - as Mr. Kane said, I am here to
 2   try to solve the murder of a young child. 
 3   And I'm not --
 4            MR. WOOD:  We are here to help
 5   you.
 6            MR. LEVIN:  And I understand that
 7   and I appreciate that.
 8            MR. WOOD:  Within the request as
 9   made and the request as agreed to.
10            MR. LEVIN:  I understand that. 
11   And if you were a judge, I would look you
12   in the eye and say as an officer of the
13   court, Your Honor, I have no -- I believe in
14   my heart that statement was made.  Okay?
15            MR. WOOD:  And the judge would
16   look at you, Bruce, and say, Mr. Levin, it
17   is your responsibility, when asking about a
18   prior statement, to produce the statement for
19   the witness to look at to put it into
20   context.  Am I right, Mr. Levin?  That is
21   all I asked you to do.
22            MR. LEVIN:  My judge would take
23   my word because my word is my bond, sir.
24            MR. WOOD:  Well, my judge would
25   say the proper examination would give the
0108
 1   witness an opportunity, not only to take your
 2   statement as you set it forth, which you
 3   admit may or may not be exactly accurate,
 4   but to take that statement and look at it in
 5   context because I don't know what question
 6   you will necessarily follow up with, Bruce. 
 7   That is all.  We are not judges.  We are
 8   lawyers.  But I did ask Chief Beckner, if
 9   there were going to be prior statements for
10   you all to bring them so that we could look
11   at them and put her, put them into context. 
12   That is all.
13            MR. LEVIN:  And we have them. If
14   you want to take time --
15     Q.     (By Mr. Levin)  I mean, there is
16   a simple way.  You recall saying that, don't
17   you?  Isn't that the easy way to do it? 
18            MR. WOOD:  That may be fine, but
19   I think she is entitled to see it anyway. 
20   That is all I am saying so she can look at
21   it.
22            MR. LEVIN:  If I was in a
23   courtroom and she was under oath.  It is not
24   a deposition.  This is an interview.  That
25   is all.
0109
 1            MR. WOOD:  She is not.  It's an
 2   interview.  And all I asked going into the
 3   interview is, if this came up, because there
 4   has been so many hours and days of
 5   interviews and statements that, fairly, now
 6   two years plus since June of 1998, three
 7   years plus since April of 1997, that if
 8   there is statements, media or otherwise, put
 9   them out there, she will look at it, she
10   will answer your question.
11            MR. LEVIN:  Why don't we just ask
12   her if she recalls it, and then we can save
13   some time.
14            MR. WOOD:  Well, we can ask her
15   that, and I will let her answer that, Bruce,
16   but I want to set the procedure correctly
17   that, when we get into these things about
18   prior statements, that I really did expect
19   and think it fair that you all have them for
20   her to look at it and put it into context. 
21   It may not be of consequence here, but it
22   certainly may be later when there are more
23   difficult questions.  Okay?
24            MR. LEVIN:  I understand.
25     Q.     (By Mr. Levin)  Do you remember
0110
 1   saying that during one of your interviews?
 2     A.     Tell me what --
 3     Q.     That on occasion JonBenet may go
 4   over to a friend's house, I think you talked
 5   about the White's daughter Daphne, and they
 6   could go swimming or do something and she
 7   might leave her underwear there, get a clean
 8   pair from a friend and then be laundered,
 9   returned, you would do the same for her
10   girlfriends who may have been -- got wet
11   from swimming or doing, got dirty playing
12   outside.  Do you recall saying that?
13     A.     Not specifically.
14     Q.     Do you recall that occurring then?
15     A.     Probably did.  I can't say for
16   sure, but --
17     Q.     Okay.  What I am interested in is
18   whether or not you have a recollection as to
19   whether or not any of the Bloomi panties,
20   and I certainly wouldn't want to pin you
21   down to the day or the week, all right, but
22   do you ever recall any of the Bloomi panties
23   from November to the time of JonBenet's
24   murder being left at a friend's house and
25   then returned to you?
0111
 1     A.     No.
 2     Q.     Do you recall any occasions where
 3   JonBenet had an accident at school and -- I
 4   know that they kept at her school like I
 5   think they do at most grammar schools, they
 6   have a box of like clean underpants if a kid
 7   has an accident at school, do you ever
 8   remember her getting to that situation and
 9   borrowing panties from the school and having
10   to return them?
11     A.     No.
12     Q.     Okay.  I am slightly confused,
13   and I would like this clarified.  When I
14   first started to ask you about the purchase
15   of the panties in November, I got the
16   impression that you were somewhat unclear as
17   to whether you bought two sets or one.
18            In follow-up questions, I got the
19   impression that you felt confident that you
20   only bought one.  Do you know?
21     A.     I really can't remember.
22     Q.     Do you recall that you did -- you
23   never mailed this pair out to --
24     A.     Jenny, yes.
25     Q.     Okay.  So if there was an
0112
 1   unopened package, it would have been left in
 2   the house?
 3     A.     Yes.
 4     Q.     (By Mr. Morrissey)  Mrs. Ramsey,
 5   prior to going to the Whites, did you see
 6   JonBenet in panties?  In other words, were
 7   you at any point, prior to going to the 
 8   Whites, in the process of her getting
 9   dressed, did you ever see if she was wearing
10   panties?
11     A.     I mean, I just probably didn't
12   notice. I would, she must have had them on
13   or I would have certainly noticed if she
14   didn't have any on.
15     Q.     When you came home and you got
16   her ready for bed, did you notice if she was
17   wearing panties?  When you changed her out
18   of the black velvet -- 
19     A.     Uh-huh (affirmative).
20     Q.      - type pants --
21     A.     Right.
22     Q.     -- and into the long underwear
23   pants --
24     A.     Uh-huh, right.
25     Q.     -- the White ones, did you notice
0113
 1   if she had a pair of panties on?
 2     A.     Yes, she did.  I believe she did.
 3     Q.     Why do you remember that?  I
 4   mean, what do you remember?  I just want to
 5   know what you remember about that.
 6     A.     Well, I took the jeans off and
 7   put the long leggies on.
 8     Q.     And you noticed that she had
 9   panties on in that process?
10     A.     Uh-huh (affirmative).
11     Q.     You have to answer yes or no.
12     A.     Well, I noticed -- I mean,
13   nothing was unusual.  I mean, if she hadn't
14   had panties on, it would have been unusual. 
15   So -- 
16     Q.     So there was nothing unusual
17   there?
18     A.     Correct.
19     Q.     When you actually removed those --
20   you have -- they are black velvet pants?
21     A.     Yes.
22     Q.     And did the panties come down
23   with them when you removed those pants, if
24   you remember?
25     A.     I don't remember.
0114
 1     Q.     If they had, would you remember,
 2   or is that too long ago?
 3     A.     It has been a long time.
 4     Q.     But did you change -- did you put
 5   a fresh pair of panties on her at that point
 6   when you were getting her ready for bed?
 7     A.     No.
 8     Q.     (By Mr. Wickman)  Mrs. Ramsey, I
 9   have a daughter myself, and kids do strange
10   things, but was it her habit, when she
11   changed clothes, did she have a routine to
12   put them in a basket if they were dirty? 
13   How did that work?
14     A.     She usually probably dropped them
15   wherever they came off.
16            MR. WICKMAN:  Okay.  Thank you. 
17     Q.     (By Mr. Levin)  Was that pretty
18   much her practice with most of her clothes?
19     A.     Uh-huh (affirmative).
20     Q.     I mean, not just her underwear,
21   just they are off, new pair?
22     A.     (Witness nodded head
23   affirmatively).
24            MR. WOOD:   Wait until he
25   finishes and then answer.
0115
 1     Q.     (By Mr. Levin)  For the record,
 2   you were nodding your head, and I take that
 3   as a yes.
 4     A.     Yes.
 5            MR. LEVIN:  Anything else on that
 6   topic?
 7            MR. KANE:  No.  Go ahead.
 8     Q.     (By Mr. Levin)  Mrs. Ramsey, I
 9   would like to ask you some questions on an
10   area that actually you started to talk about
11   when we were talking about the investigation
12   being conducted at your behest, and that is
13   the Hi-Tec shoes.
14            You are, I would assume, aware of
15   the fact that there is a Hi-Tec shoe
16   impression in the wine cellar?
17     A.     Yes, I am.
18     Q.     How did you become aware of that,
19   if you can recall?
20     A.     I don't remember if I read it in
21   the paper or one of our lawyers told us.
22     Q.     Was it something you have been
23   aware of for a substantial period of time,
24   though?
25     A.     Yes.
0116
 1     Q.     And do you recall, I know you had
 2   several conversations with Lou Schmidt or
 3   other investigators working for you, is it
 4   something, prior to your interviews in 1998,
 5   that you had discussed either with your
 6   lawyers or with your investigators?  And I
 7   don't want to know about the conversations
 8   between you and your attorneys, obviously,
 9   but something that you talked about?
10     A.     I can't remember if I knew about
11   it before then or not.
12     Q.     When you were interviewed in 1998
13   by the Boulder D.A.'s office and some of
14   their helpers, were you at that time aware
15   of the fact that the Hi-Tec existence or non
16   existence of an identifiable source for the
17   Hi-Tec shoes was something that seemed to be
18   important to the investigation?
19     A.     Are you asking me if they were
20   wanting to know if I knew anyone with Hi-Tec
21   boots?
22     Q.     No.  What I'm ask --see, I am
23   talking like a lawyer.  Let's see if we can,
24   I'll talk like a person, if I can.  You
25   were interviewed --
0117
 1            MR. WOOD:  That assumes that
 2   lawyers are people.  Some would disagree that
 3   they are sharks or whatever.
 4     Q.     (By Mr. Levin)  In June of 1998,
 5   you were interviewed by the Boulder D.A.'s
 6   office; right?
 7     A.     That was Hannay, Mr. Hannay.
 8     Q.     Yes.  Mr. DeMouth?
 9     A.     Yes.
10     Q.     Prior to commencing that
11   interview, did you know that identifying the
12   source of the Hi-Tec shoes was a priority
13   for the investigation?  That would be more
14   than two years after, a year and a half
15   after your daughter's murder.
16            MR. WOOD:  Are you asking her if
17   she knew what was a priority in your all,
18   the investigator's minds?
19            MR. LEVIN:  No, no, no.  In her
20   mind.  Did she believe --
21     Q.     (By Mr. Levin)  Did you believe,
22   and if I didn't throw that in, I thought it
23   was clear, did you believe that, in the
24   course of the investigation, that identifying
25   the source of the Hi-Tec shoes was important?
0118
 1     A.     Well, I would think it is
 2   important, yes.  I mean, I can't remember at
 3   that time if I knew about the Hi-Tec shoes
 4   or not.  I don't remember when all that
 5   surfaced.
 6     Q.     You have since then, since 1998,
 7   become aware that the source of the Hi-Tec
 8   shoes is important?
 9     A.     Yes.
10     Q.     You know that today?
11     A.     Yes.
12     Q.     And you thought that one of the
13   things that made Helgoth viable was the fact
14   that you believe he had Hi-Tec shoes?
15     A.     Correct.
16     Q.     Have you, whether it was before
17   the interview in 1998 or subsequent to the
18   interview in 1998, have you personally made
19   attempts to find possible sources for the
20   Hi-Tec shoe impression?
21     A.     You mean like ask around if
22   anybody had --
23     Q.     Pick up the phone and call some
24   friends, for example.
25     A.     I didn't, no.
0119
 1     Q.     Had you at any time, for example,
 2   some of the kids, like the Colby kids ever
 3   come over, did you ever go and just pick up
 4   the phone or walk across the alley and say,
 5   do you guys have Hi-Tec shoes?  Did you ever
 6   do anything like that? 
 7            MR. WOOD:  You are assuming she
 8   may have learned about it at the time she
 9   still lived there.  She told you she wasn't
10   sure when she first learned that.
11            THE WITNESS:  No, I did not call
12   the Colbys to ask if their children had --
13     Q.     (By Mr. Levin)  Whether it was
14   from Boulder or Atlanta?
15     A.     Right.
16     Q.     Okay.  Did you sit down and
17   discuss with Burke at any length whether or
18   not he ever had Hi-Tec shoes?
19     A.     No.
20     Q.     Did it cross your mind that he
21   might be the source of that, for the Hi-Tec
22   shoes?
23     A.     No.  Because my understanding was
24   that it was an adult footprint.  He was nine
25   years old at the time.
0120
 1     Q.     Do you know the source of your
 2   belief that it was an adult's foot,
 3   footprint?
 4     A.     Whoever told me about it or
 5   wherever I learned it in the first place.
 6     Q.     Did you get any details concerning
 7   how much of a shoe impression was present?
 8     A.     No.  It was just a footprint. 
 9     Q.     Did you take that to, to be a
10   full footprint, and by that I mean like a
11   shoe, a complete shoe impression?
12     A.     That is what I imagined, yes.
13     Q.     And that, whether you were told
14   that directly or you just assumed that, you
15   believe is the source of your belief that it
16   was an adult's shoe?
17     A.     Yes.
18     Q.     You have been asked about whether
19   or not anyone in your family owns Hi-Tec
20   shoes or ever owned Hi-Tec shoes?
21     A.     Yes.
22     Q.     And I am not restating a
23   question, Mr. Wood.  And do you recall you
24   said no one ever did?
25     A.     Yes.
0121
 1     Q.     You have had -- and that was in
 2   '98, more than two years ago.  You have had
 3   an opportunity to, now that you are in
 4   possession of knowledge causing you to
 5   believe this is a significant fact in the
 6   investigation, you have had almost, we will
 7   assume, at least a year to rethink that. 
 8   Have you given it some thought as to maybe
 9   someone in the family had Hi-Tec shoes?
10            MR. WOOD:  Are you asking her
11   whether she thought about whether somebody in
12   the family -- I mean, all of the prefatory
13   comments leading up to that.
14            Is the question, since June of
15   1998, Ms. Ramsey, have you given any thought
16   as to whether someone in your family had
17   Hi-Tec shoes?
18            MR. LEVIN:  That is correct. 
19   That is the question.
20            MR. WOOD:  All right.  You can
21   answer that question.
22            THE WITNESS:  No.
23     Q.     (By Mr. Levin)  Did you try, in
24   your mind, and perhaps to assist your
25   investigator, identify sources close to your
0122
 1   family that might be the origin of the
 2   Hi-Tec shoe impression?
 3     A.     I think, you know, I may have
 4   asked Susan if she had ever seen any.  I
 5   mean, I didn't, I don't know what a Hi-Tec
 6   boot looks like, per se.  I have tried to
 7   kind of, as I am in shoe stores, look around
 8   trying to see what, what's the significance
 9   and special about a Hi-Tec boot, and I
10   haven't, haven't even seen any yet.  But I
11   may have asked Susan, did you know anybody
12   that looked like they wore Hi-Tec shoe,
13   boots, or whatever.
14     Q.     Do you recall a period of time,
15   prior to 1996, when your son Burke purchased
16   a pair of hiking boots that had compasses on
17   the shoelaces?  And if it helps to 
18   remember --
19     A.     I can't remember.
20     Q.     Maybe this will help your
21   recollection. They were shoes that were
22   purchased while he was shopping with you in
23   Atlanta.
24            MR. WOOD:  Are you stating that
25   as a fact?
0123
 1            MR. LEVIN:  I am stating that as
 2   a fact.
 3     Q.     (By Mr. Levin)  Does that help
 4   refresh your recollection as to whether he
 5   owned a pair of shoes that had compasses on
 6   them?
 7     A.     I just can't remember.  Bought so
 8   many shoes for him.
 9     Q.     And again, I will provide, I'll
10   say, I'll say this as a fact to you, that,
11   and maybe this will help refresh your
12   recollection, he thought that -- the shoes
13   were special because they had a compass on
14   them, his only exposure for the most part to
15   compasses had been in the plane and he kind
16   of liked the idea of being able to point
17   them different directions.  Do you remember
18   him doing that with the shoes?
19     A.     I can't remember the shoes.  I
20   remember he had a compass thing like a
21   watch, but I can't remember about the shoes.
22     Q.     You don't remember him having
23   shoes that you purchased with compasses on
24   them?
25            MR. WOOD:  She will tell you that
0124
 1   one more time.  Go ahead and tell him, and
 2   this will be the third time.
 3            THE WITNESS:  I can't remember.
 4     Q.     (By Mr. Levin)  Okay.  Does it
 5   jog your memory to know that the shoes with
 6   compasses were made by Hi-Tec?
 7            MR. WOOD:  Are you stating that
 8   as a fact?
 9            MR. LEVIN:  Yes.  I am stating
10   that as a fact.
11            THE WITNESS:  No, I didn't know
12   that.
13     Q.     (By Mr. Levin)  I will state this
14   as a fact.  There are two people who have
15   provided us with information, including your
16   son, that he owned Hi-Tec shoes prior to the
17   murder of your daughter.
18            MR. WOOD:  You are stating that
19   Burke Ramsey has told you he owned Hi-Tec
20   shoes?
21            MR. LEVIN:  Yes.
22            MR. WOOD:  He used the phrase
23   Hi-Tec?
24            MR. LEVIN:  Yes.
25            MR. WOOD:  When? 
0125
 1            MR. LEVIN:  I can't, I can't give
 2   you the source.  I can tell you that I have
 3   that information.
 4            MR. WOOD:  You said Burke told
 5   you.
 6            MR. LEVIN:  I can't quote it to
 7   you for reasons I am sure, as an attorney,
 8   you are aware.
 9            MR. WOOD:  Just so it is clear,
10   there is a difference between you saying that
11   somebody said Burke told them and Burke
12   telling you because Burke has been
13   interviewed by you all December of 1996,
14   January of 1997, June of 1998.
15            Are you saying that it is within
16   those interviews?
17            MR. LEVIN:  No.
18            MR. WOOD:  So he didn't tell you,
19   he told somebody else you are stating as a
20   fact because I don't think you all have
21   talked to him other than those occasions,
22   have you?
23            MR. KANE:  Mr. Wood, we don't
24   want to get into grand jury information. 
25   Okay?
0126
 1            MR. WOOD:  Okay.
 2            MR. KANE:  Fair enough?
 3            MR. LEVIN:  I am sorry, I should
 4   have been more direct.  I thought you would
 5   understand --
 6     Q.     (By Mr. Levin)  Fleet Junior also
 7   says that he had Hi-Tec shoes.  
 8     A.     Okay.  Now --
 9     Q.     Does that jog your memory?
10     A.     Is, are you talking like Hi-Tec
11   like --
12     Q.     The brand name.
13     A.     These are really high tech or the
14   brand name?  Did the children understand the
15   difference, or are they --
16     Q.     I was talking brand name.
17     A.     They knew like a brand name like
18   Nike, whatever?
19     Q.     Yes, yes, ma'am.
20     A.     Okay.
21     Q.     That doesn't jog your recollection
22   at all?
23     A.     No.
24            MR. WOOD:  You are answering no
25   for the reporter?
0127
 1            THE WITNESS:  No, it does not.
 2            MR. WOOD:  You gave it a nod of
 3   the head.
 4     Q.     (By Mr. Morrissey)  Just so we
 5   are clear, these boys may have referred to
 6   them as boots.  Does that make any
 7   difference to you as far as distinguishing
 8   between shoes and boots?
 9            MR. WOOD:  She would have to see
10   what those boys said in context, in all
11   fairness, Mitch, before she can comment on
12   what they might have meant and how it
13   affects her.
14            THE WITNESS:  I mean, I just, I
15   can't remember shoes with compasses, and I
16   don't know all of the brand names of all the
17   shoes that I buy for my children.  So -- 
18     Q.     (By Mr. Morrissey)  And I am just
19   asking do you remember a pair of boots with
20   compasses?
21            MR. WOOD:  For the fourth time
22   now.
23            THE WITNESS:  I don't remember
24   compasses on any shoes.
25            MR. WOOD: Fair enough.  Shoes,
0128
 1   boots, compasses.
 2            THE WITNESS:  I have a picture in
 3   my mind of a compass on a watch, but --
 4     Q.     (By Mr. Morrissey)  Shoes, boots,
 5   you don't remember a compass on footwear?
 6     A.     No, I can't.
 7            CHIEF BECKNER:  I have a
 8   follow-up question.
 9     Q.     (By Chief Beckner)  You said you
10   had never seen the photograph of a footprint?
11     A.     Right.
12     Q.     Have you seen some of the crime
13   scene photos?
14     A.     I have seen photographs of her
15   bedroom, and I think I have seen photographs
16   of the downstairs bathroom, basement bathroom. 
17   A few.
18     Q.     (By Mr. Levin)  Just to follow-up
19   on Chief Beckner's --
20            MR. WOOD:  You all asked her, you
21   all gave her a ton of photographs in June.
22            MR. LEVIN:  Right, and that's
23   what I was going to ask her, if you've seen
24   photos. 
25     Q.     (By Mr. Levin)  I mean, they
0129
 1   spent days, day and a half going through
 2   photographs with you.  Other than in that
 3   setting in June of '98, have you ever been,
 4   have you ever had a sit down with someone
 5   and gone through some of the crime scene
 6   photographs other than that, that particular
 7   experience, which we don't need to rehash?
 8     A.     I don't think so.  No.
 9     Q.     (By Chief Beckner)  Lou Smith has
10   never shown you any photographs that he has?
11     A.     I can't remember if he has.  I
12   am sure I would have remembered if they
13   were.
14     Q.     How about Ellis Armistead?
15     A.     I just can't remember.
16     Q.     Ollie Gray?
17     A.     No.
18     Q.     Any of your attorneys?
19            MR. WOOD:  Well, you are going
20   into what attorneys may have shown her, I
21   think that may be infringing into the
22   attorney-client privilege.  I don't want to
23   go there.
24            THE WITNESS:  I can't, I mean, if
25   you would show me something and say have you
0130
 1   seen this before, maybe I can remember if I
 2   have seen it before.
 3     Q.     (By Chief Beckner)  You just
 4   don't recall sitting down and having any of
 5   your investigators show you any photos?
 6            MR. WOOD:  Well, you were asking
 7   about crime scene photos, Chief, I thought.
 8            CHIEF BECKNER:  Yes.
 9            THE WITNESS:  They have shown me
10   photos of people and said do you recognize
11   this person.
12     Q.     (By Chief Beckner) Okay.  I am
13   specifically referring to photos taken inside
14   the house or outside the house.
15     A.     Yeah.  Right.  Well, certainly
16   when we did that interview.
17     Q.     Yeah, I am not talking about the
18   photos we showed you.
19     A.     Yeah.
20     Q.     I am just asking  -
21     A.     Other ones.
22     Q.     -  other photos that your
23   investigators may have shown you.
24     A.     No. 
25     Q.     (By Mr. Kane)  You said at one
0131
 1   point you might have asked Susan.  Are you
 2   talking about Susan Stein?
 3     A.     Uh-huh (affirmative).
 4     Q.     You said you might have asked
 5   her.  Do you have any recollection of asking
 6   her about Hi-Tec?  Is there anything that
 7   makes you think that you might have asked
 8   that?  What made you --
 9     A.     Well, we just spent quite a lot
10   of time together, and she is very interested
11   in the case.  And we kind of hung around
12   the same people. 
13     Q.     Uh-huh (affirmative).
14     A.     And I could have asked her, you
15   know, do you know anybody with Hi-Tec boots
16   or something.
17     Q.     But you don't have any specific
18   recollection of that?
19     A.     I don't specifically remember
20   saying that.
21     Q.     Okay.  Is this the first time
22   that you've heard that Burke says that he
23   had Hi-Tec?
24     A.     Yes, it is.
25     Q.     This is the very first time?
0132
 1     A.     Yes.
 2     Q.     When you said in your book and
 3   then you said at other times too that you
 4   didn't own either brand -- 
 5            MR. WOOD:  Hold on.  If you have
 6   got a reference of the book.
 7            MR. KANE:  I'm sorry.  Page 232.
 8            MR. WOOD:  And then you said at
 9   other times, too.  Be more specific to it.
10            MR. KANE:  Okay.  Well, I will
11   stick to the book.  
12     Q.     (By Mr. Kane) But I don't think
13   it is any big 
14   secret that you've said that a bunch of
15   times.
16     A.     I don't remember --
17            MR. WOOD:  Okay.  What is the
18   question?
19     Q.     (By Mr. Kane)  When you made that
20   statement in your book -- I mean, maybe I
21   ought to authenticate.  You wrote this book,
22   is that  -
23     A.     Sure.
24            MR. WOOD:  We are not asking you
25   to authenticate it.  We are just asking you
0133
 1   to refer us to the page.
 2     Q.     (By Mr. Kane)  Okay.  Well, I
 3   just want to make it clear that this wasn't
 4   written by somebody else or a ghost writer
 5   or something like that.
 6            MR. WOOD:  I think they had some
 7   help, but I don't think it was like Mr.
 8   Davis who wrote Mr. Thomas's book.
 9            THE WITNESS:  I think we were
10   referring that John or I didn't, did not
11   ever have -- were not in possession of --
12     Q.     (By Mr. Kane)  So when you said
13   we, you were referring to John or you?
14     A.     Yes.  It never occurred to me
15   about Burke's shoes.
16            MR. WOOD:  You are assuming,
17   number one, Burke said it.  You said, and I
18   accept your representation in terms of what
19   is clear in terms of when, but the question
20   obviously still remains whether Burke is
21   accurate or not.  But be that as it may,
22   next question.
23     Q.     (By Mr. Kane)  But I mean, but
24   my question was, when you said we, you were
25   talking about you or John?
0134
 1     A.     Well, what is the, what size
 2   print is the Hi-Tec?  Is it a child's or is
 3   it an adult's?
 4     Q.     I don't think there is any
 5   difference between the two.  And I think
 6   that has been pretty well publicized too.
 7            MR. WOOD:  Well, you all can
 8   debate that another day, if necessary.
 9            MR. KANE:  Yeah, I mean.  That
10   is obvious, yes.
11            MR. WOOD:  The point is, it would
12   probably be of some consequence to know the
13   context of what Burke said, at age, at age,
14   at age what?
15            THE WITNESS:  Nine.
16            MR. KANE:  Nine. 
17            MR. WOOD:  No, he didn't say it
18   at age nine.
19            THE WITNESS:  Eight.
20            MR. WOOD:  You are telling me he
21   said it sometime late fall of 1999, and I
22   think his age would have been closer in the
23   neighborhood of 12.
24            MR. LEVIN:  I think 11 going on
25   12.  
0135
 1            MR. WOOD:  No, I think he turned
 2   13 January of 2000.  So he was 12, and it
 3   was some three years after the murder of his
 4   sister, if that is when he first said it.
 5            THE VIDEOGRAPHER:  Pardon me.  We
 6   need to make a tape change.
 7            (A recess was taken.) 
 8            THE VIDEOGRAPHER:  All right.
 9     Q.     (By Mr. Kane)  I just want to
10   follow up, Mrs. Ramsey.  How many times have
11   you spoken with Lou Schmidt personally? 
12   Let's put it this way, since the grand jury
13   ended to narrow it down.
14     A.     Oh, half a dozen.
15     Q.     Was that here in Atlanta or back
16   in Colorado or both?
17     A.     Both.
18     Q.     During any of those discussions,
19   did you ever talk about the Hi-Tec shoeprint
20   that was found?
21     A.     Probably.  Not -- I can't
22   remember specifically what we talked about
23   each time.
24     Q.     Okay.  I mean, what was your,
25   were your -- the times that you did talk to
0136
 1   him, was it about the investigation or about
 2   evidence and that kind of thing or was it
 3   more social?  Maybe that is an unfair
 4   question.
 5            MR. WOOD:  That is a bunch of
 6   things.  I think he wants to know what you
 7   talked to him about, generally.
 8     Q.     (By Mr. Kane)  Did you talk about
 9   the investigation?
10     A.     Yes.
11     Q.     Okay.  But you don't have any
12   recollection of the shoeprint being part of
13   those discussions; is that what you are
14   saying?
15     A.     Well, not specifically.  I am
16   sure we talked about it.  I mean, you know,
17   I've just heard many references made to the
18   Hi-Tec shoeprint.
19     Q.     Okay.  I think you said that you
20   don't recall whether Lou showed you any
21   photographs.  Did he ever show you, on a
22   computer image, of any of the photographs? 
23     A.     I think so.
24     Q.     Have you seen a photograph of the
25   Hi-Tec shoeprint yourself?
0137
 1     A.     I can't remember.  I have this
 2   vague image, but I don't know whether I am
 3   imagining it in my mind or if I saw the
 4   picture.
 5     Q.     (By Mr. Levin)  Mrs. Ramsey, on,
 6   I believe it was Saturday the 28th of
 7   December, your sister Pam went and was
 8   permitted to take personal property out of
 9   the house.  Do you recall that?
10     A.     Yes.
11     Q.     Can you give us -- and again I
12   don't want to be unfair to you.  I am not
13   certainly expecting you to itemize what came
14   out, but can you just give us kind of an
15   overview of what you recall what types of
16   things were brought out?
17            MR. WOOD:  Let me just ask, in
18   fairness to the request, isn't that long
19   since knowledge?  We are talking about
20   developments and information since June of
21   1998.  I mean, that seems to me you all
22   were aware of that long ago, discussed in
23   Thomas's book.
24            MR. LEVIN:  Well, I haven't read
25   Thomas's book, and to be perfectly honest
0138
 1   with you, Mr. Wood, we are not exactly
 2   certain what was taken out of the house. 
 3   And there are some things, some specific
 4   things I am going to get into, but I am
 5   trying to get a sense beyond what is
 6   documented in the police reports of what came
 7   out of the house.
 8            And I think it is helpful for the
 9   investigation.  I think it will move things
10   forward.
11            MR. WOOD:  Well, I am going to
12   let her answer. I just wanted to make sure
13   that it was clear that, in my mind, that
14   would not, would not be -- I am going to
15   let her go, I am going to let her answer
16   the question, but it does go back to areas
17   that clearly were available for examination
18   for three days.
19            MR. KANE:  Let's clarify that.  I
20   am under the understanding that you said the
21   purpose of this was to ask new questions
22   which means we are not going to plow old
23   ground again, but there are certainly a lot
24   of questions that have developed that involve
25   evidence that may have been known day one.
0139
 1            MR. WOOD:  I understand that.  I
 2   am trying, I'm going to be, I'm going to be
 3   extremely liberal in the definition of events
 4   that have occurred since or developed since
 5   or information developed since with the
 6   emphasis in my mind on what was asked in
 7   terms of new questions.  So I am going to
 8   let her answer that.  But I did want to
 9   just make it clear that that was something
10   that you all I thought had known about from
11   long ago.
12            MR. LEVIN:  I am unaware of it.
13            MR. WOOD:  Do you want to restate
14   it or, Patsy, I will read it back to you. 
15   He said, can you give us, and again, I don't
16   want to be unfair to you, I'm certainly not
17   expecting you to itemize what came out, but
18   can you just give us kind of an overview of
19   what you recall what kinds of things were
20   brought out.  Do you understand the question? 
21   If you know the answer, go ahead and answer
22   it for him.
23            THE WITNESS:  I think the kinds
24   of things that were brought out were --
25   well, Pam asked me, what did I need from the
0140
 1   house.  And I told her the only thing I
 2   cared about in that house were my things in
 3   the little baby curio cabinet where I kept
 4   the children's baby shoes and christening
 5   gown and locks of hair and little special
 6   little things.  And aside from that, I don't
 7   know what came out.
 8            I know that there is a list
 9   because she didn't take anything that wasn't,
10   you know --
11            MR. WOOD:  Inventoried.
12            THE WITNESS:  -- inventoried as
13   she --
14     Q.     (By Mr. Levin)  Did you provide
15   her, you personally or John at your request
16   or some third party at either your or John's
17   request, did you provide a list of clothing
18   that you needed, that you had an immediate
19   need for that you asked for?
20     A.     No.
21     Q.     She brought, she did bring
22   articles of clothing out though?
23     A.     I don't know that she did.  I
24   don't know.
25     Q.     Just so that I am clear, what you
0141
 1   are saying is you just don't have a present
 2   recollection of whether or not she brought
 3   clothes out, not that she did not; is that
 4   right?
 5     A.     I don't know whether she did or
 6   not.  I know Susan Stein had to go out to
 7   -- she said that she went to Foley's to buy
 8   me some clothes and some shoes because I
 9   didn't have any, so -- except what I had on
10   leaving the house, so --
11     Q.     After the funeral, you move back
12   to Atlanta, that house is packed -- and the
13   police released the house back to the family
14   after they finished their search, the
15   contents is packed up and shipped to Atlanta;
16   is that what happened?
17     A.     Yes.
18     Q.     So anything not taken out by your
19   sister Pam or seized by the Boulder Police
20   Department during their search was returned
21   to you?
22     A.     I think so.  I don't know if our
23   -- I think our investigators spent time in
24   the house after the police investigators were
25   finished.  I don't know.  They may have
0142
 1   taken some things.
 2     Q.     Were there things that your
 3   investigators took that was done at your
 4   direction or John's direction that you are
 5   aware of?
 6            MR. WOOD:  Are you talking about
 7   a specific request for an investigator to get
 8   something?
 9            MR. LEVIN:  Yes.
10     Q.     (By Mr. Levin)  For example, take
11   this particular coat, it might be important,
12   or take this jacket, it might be important,
13   any of those types of conversations?
14     A.     No.  The only things I cared
15   about in that house were my baby things.  It
16   could have burned to the ground.
17     Q.     So I take that as saying, no, I
18   never had a conversation with the
19   investigators to assist them in seizing
20   things that might be of evidentiary value?
21     A.     Correct. 
22     Q.     To your knowledge, did John have
23   a conversation of that nature with the
24   investigators suggesting items that might be
25   important to your investigation?
0143
 1     A.     Not to my knowledge.
 2     Q.     In December of 1998, there was a
 3   fairly well publicized request from the
 4   Boulder Police Department for assistance in
 5   identifying and perhaps retrieving a Santa 
 6   Bear.  Do you recall that?
 7     A.     Yes.
 8     Q.     Was it your understanding that the
 9   bear that was sought was the same bear that
10   you were shown photographs of in 1998 June?
11     A.     Yes.
12     Q.     The same bear that you were
13   unable to identify?
14     A.     Yes.
15     Q.     We collectively, the prosecution
16   team, received from either Mr. Morgan or Mr.
17   Haddon the bear, the bear.  Is that your
18   understanding?
19     A.     Yes.
20     Q.     How did we get it?  I mean, what
21   was your participation in the chain of events
22   that led to the recovery of that bear?
23     A.     The -- well, I think our lawyers
24   asked Gene Matthews, who was a local retired
25   police officer who had helped us with some
0144
 1   security at our home --
 2     Q.     Your home in Atlanta?
 3     A.     In Atlanta.
 4            -- to go through boxes and look
 5   for the bear.
 6     Q.     Did you assist him or is it her?
 7     A.     It is a him.
 8     Q.     Okay.  Did you assist Mr.
 9   Matthews, you personally?
10     A.     You mean in digging through boxes?
11     Q.     No.  In offering suggestions to
12   where to look.
13     A.     Well, I believe at that time we
14   were in the throes of a remodeling session,
15   and JonBenet's things that had come out of
16   her room in Colorado were packed and were in
17   the basement at my mother and father's house
18   in Roswell, Georgia.
19            So I told him that is where he
20   should start looking.
21     Q.     Mrs. Ramsey, you emphatically
22   denied, in June of 1998, knowledge of that
23   bear.  Did you have a change of
24   recollection, following the interviews in
25   1998, as to whether or not you had prior
0145
 1   knowledge of  that bear?
 2            MR. WOOD:  Do you know what he
 3   is asking you?
 4            THE WITNESS:  Do I recognize the
 5   bear?
 6            MR. WOOD:  The emphatic part is
 7   the only thing that concerns me.  I am not
 8   denying that it was emphatic, but I think
 9   the point is you denied it in June of 1998,
10   and the question I think he is asking you is
11   when you found it, did that jog your
12   recollection that you might remember the
13   bear.  Is that what you are asking?
14            MR. LEVIN:  That is not quite the
15   question, but it is pretty close.
16     Q.     (By Mr. Levin)  What I am asking
17   you is, in June of 1998, you stated I do
18   not recognize this bear?
19     A.     Correct.
20     Q.     You recall that.  The cry went
21   out for help in locating the origin of the
22   bear.  Did you, at some point between our
23   request for assistance and in June of 1998,
24   have an opportunity to rethink the origin of
25   the bear and realize that that was, in fact,
0146
 1   JonBenet's Santa Bear?
 2            MR. WOOD:  I think you meant
 3   between your request and December of 1998.
 4     Q.     (By Mr. Levin)  Between June of
 5   1998 and our request for help in December of
 6   1998 --
 7            MR. WOOD:  That's right.
 8     Q.     (By Mr. Levin)  -- did your
 9   recollection get jogged and you realized that
10   you did, in fact, own the bear?
11     A.     No.  I mean, it was still a bear
12   that I did not recognize.
13     Q.     Have you since that time had
14   anything that has refreshed your recollection
15   in that regard so that you now presently
16   know the source of that bear?
17     A.     No.
18     Q.     I am going to provide you with
19   some information to see if we can jog your
20   memory.  I have seen a videotape taken at a
21   pageant in December, in fact, December 14,
22   1996.  I think that was -- was that the
23   last -- I believe that was the last pageant
24   that JonBenet participated in.
25            MR. WOOD:  Is that right?
0147
 1     Q.     (By Mr. Levin)  I am asking you
 2   if that is your recollection as well.
 3            THE WITNESS:  Is that the
 4   Christmas, one of the Christmas ones down by
 5   the --
 6     Q.     Yes.  
 7     A.     All right.
 8     Q.     Was that the last formal pageant
 9   she participated in?
10     A.     Uh-huh (affirmative).
11     Q.     I have seen a videotape of that. 
12     A.     Uh-huh (affirmative).
13     Q.     And in the videotape it shows the
14   prizes. 
15     A.     Uh-huh (affirmative).
16     Q.     And that bear is in the videotape
17   with you in the videotape?
18     A.     Oh, really?
19     Q.     And JonBenet won that bear at
20   that pageant.  Assuming that that is a 
21   fact --
22            MR. WOOD:  And you represent it
23   as fact.
24            MR. LEVIN:  I'm representing that
25   it is my belief that that is true, and I
0148
 1   have seen videotape that shows what appears
 2   to be that bear.
 3            MR. WOOD:  The question, though,
 4   is are you representing it is that bear
 5   because there is a difference, and I think
 6   you understand it.  I haven't seen the
 7   videotape that you are referring to, but I
 8   mean, you are saying it appears to be.
 9            THE WITNESS:  Yeah, I would like
10   to see that too because it was my
11   recollection that she won a bear, but it had
12   a little banner on it, and it was like a
13   little angel bear or something.  It was all
14   white.
15     Q.     (By Mr. Levin)  Assuming that
16   that is correct, that, and, of course,
17   perhaps my observations are incorrect, just
18   assuming that, does that refresh your
19   recollection as to the origin of the Santa
20   Bear that we saw?
21     A.     Well, this bear that I think she
22   was presented at that pageant did not have
23   Santa, Santa attire.  It was a little angel
24   bear, which I have someplace.
25     Q.     And just, I don't want to mislead
0149
 1   you because I am trying to jog your memory
 2   to see if you can help us out here.
 3     A.     I appreciate that.
 4     Q.     And Detective Harmer is the one
 5   that came up with the videotape.
 6            MR. WOOD:  I don't suppose we
 7   have it.
 8            MS. HARMER:  No, I don't have it. 
 9            THE WITNESS:  But it is the one
10   in the Santa outfit?
11            MS. HARMER:  Can I --
12            MR. LEVIN:  Yeah, because we are
13   trying to get Ms. Ramsey to see if we can
14   jog her memory.
15            MS. HARMER:  The person who
16   provided the gifts is LaDonna Graygo.  
17            THE WITNESS:  All right.
18            MS. HARMER:  Is she with All
19   Stars or America?  I can't remember which.
20            THE WITNESS:  I don't remember
21   either.
22            MS. HARMER:  Whatever pageant she
23   was in on the 14th of December, and LaDonna
24   was involved in it, that is where the bear
25   came from.
0150
 1            THE WITNESS:  Oh, okay. 
 2            MR. WOOD:  According to?
 3            THE WITNESS:  LaDonna?
 4            MS. HARMER:  Yes.
 5            MR. WOOD:  Just so we are clear,
 6   we are now talking about two things.
 7            MS. HARMER:  And the video.
 8            MR. WOOD:  The video shows a
 9   Santa Bear.
10            MS. HARMER:  Yes.  The video is
11   taken at the same pageant where LaDonna
12   passed out these prizes, one of which was
13   the bear.
14            MR. WOOD:  Again, I am just
15   trying to make sure, do you have a video of
16   JonBenet holding or receiving a Santa Bear or
17   are you saying that Santa bears were given
18   out to some of the people there?
19            MS. HARMER:  The video shows the
20   Santa Bear on the table.
21            MR. WOOD:  Well, the table, who
22   all is in the picture?
23            MR. KANE:  Maybe I can clarify
24   it.  LaDonna Graygo purchased the bear,
25   purchased the Santa Bear.  It was the prize
0151
 1   to JonBenet, and she told us the prize that
 2   JonBenet was awarded for winning little Ms.
 3   Christmas.  That was the prize and it was
 4   the only bears that she had, and she got it
 5   from someplace in Nebraska, a mail order
 6   company.  I can't remember the name.
 7            THE WITNESS:  Okay.
 8     Q.     (By Mr. Kane)  Did you look at
 9   the bear when it was found by -- what is
10   her name?
11     A.     Gene.
12     Q.     Gene, or his? 
13            MR. LEVIN:  Mr. Matthews.
14            THE WITNESS:  Uh-huh
15   (affirmative).
16     Q.     (By Mr. Kane)  You looked at it
17   before it was shipped off to Colorado?
18     A.     Yes.
19     Q.     And that didn't ring any bell
20   with you?
21     A.     Uh-uh (negative).
22     Q.     But you remember getting -- she
23   won a bear at that pageant?
24     A.     I thought it was the little white
25   angel bear, but maybe it was, maybe she got
0152
 1   that some other time.
 2     Q.     (By Mr. Levin)  If I understand
 3   you correctly, Mrs. Ramsey, you do recall, my
 4   sense is, and if I am wrong, tell me, you
 5   do recall with some degree of certainty she
 6   won a bear at that pageant, her last
 7   pageant?
 8     A.     Yes.
 9     Q.     And then what I am understanding
10   you to say is, what you are not certain of
11   is the type of bear?
12            MR. WOOD:  No, she is not saying
13   she is not certain.  She is saying I thought
14   it was the little white angel bear, but
15   maybe she got that some other time.
16     Q.     (By Mr. Levin)  And I took that
17   to mean that you are not certain that it was
18   the angel bear --
19     A.     Or the Santa Bear.
20     Q.     -- or the Santa Bear?
21     A.     Right.
22     Q.     So if I understand you correctly,
23   you are saying that you don't have an
24   independent memory today to state emphatically
25   she didn't win the Santa Bear?
0153
 1     A.     Right.
 2     Q.     Did you, when you directed Mr.
 3   Matthews where to look for the bear, that
 4   is, in the box of things from JonBenet, did
 5   you know that that bear had been taken out
 6   of the house with your other property?  I
 7   suppose what I am getting at is, had you
 8   been able to go through all of the things
 9   that were removed from the Boulder house --
10     A.     No.
11     Q.     -- prior to December of '98?
12     A.     No. 
13     Q.     Did you go through any of the
14   property at all, if you recall?
15     A.     No.
16     Q.     You were shown, I believe,
17   photographs that were taken -- and this is
18   during your '98 interview -- photographs that
19   were taken at the White's house Christmas
20   night at dinner.  In that you are wearing a
21   red coat, kind of a wool, wool jacket.  Do
22   you recall seeing that?
23     A.     It is kind of a black and red
24   and gray fleece.
25     Q.     Cut more like a blazer than --
0154
 1     A.     Like a peacoat.
 2            MR. WOOD:  Well, the picture is
 3   the picture, isn't it?
 4     Q.     (By Mr. Levin)  Right, like a
 5   peacoat.  I just want to make sure we are
 6   talking about the same thing.  Do you
 7   remember that jacket?
 8     A.     Uh-huh (affirmative).
 9     Q.     I would like you to give us a
10   little background on that coat, and again I
11   am not going to hold you to days of the
12   week, but do you recall, first of all, where
13   you purchased it?
14     A.     Well, Priscilla had had one like
15   it that I admired.  And she told me, I
16   believe she told me she got hers at EMS. 
17   So I went there to look.  And they didn't
18   have one or I didn't want to get one exactly
19   like hers.  So I think I got that one at
20   Marshals in Boulder.
21     Q.     Do you recall what year you
22   purchased it?
23     A.     No.
24     Q.     Let's -- I can understand that. 
25   Now I am going to -- we will take a time
0155
 1   frame.  Was it a fairly, by your
 2   recollection, was it a fairly recent purchase
 3   that you had or was this a coat you'd had
 4   for some period of time prior -- and, of
 5   course, I am using it as the date of
 6   JonBenet's murder.
 7     A.     Well, I can't remember.  I am
 8   sure I bought it in -- as it was getting
 9   colder.  So it was either probably fall of
10   '96 or '95.
11     Q.     That, the coat that you wore the
12   night to the Whites, was it something that
13   was -- I mean, the primary color is red.
14            MR. WOOD:  Well, don't fight over
15   -- excuse me, Patsy.  Don't you have a
16   picture?
17            MR. LEVIN:  I don't have a
18   picture with me.
19            MR. WOOD:  Why characterize it. 
20   It is what it is. 
21            THE WITNESS:  There is a picture.
22            MR. WOOD:  It is in the picture. 
23   Let's look at that.
24            MR. LEVIN:  Just to expedite
25   things, because I am not fighting over the
0156
 1   color, what I want to know is --
 2            MR. WOOD:  I think she said it
 3   was red and black and gray.
 4            THE WITNESS:  A red and black and
 5   gray check.
 6     Q.     (By Mr. Levin)  What I am, what
 7   I am interested in is, I am certainly not
 8   going to debate concentration of colors.  It
 9   is irrelevant.  What I am interested in, is
10   it something that you wore exclusively during
11   the Christmas season or is this a coat that
12   you wore anytime it was appropriate for the
13   weather?
14     A.     Anytime it was appropriate.
15     Q.     So it is not like a special
16   Christmassy type, type of Christmas sweater, 
17   I know you talked about Christmas?
18     A.     (Witness shook head negatively).  
19            MR. WOOD:  Your answer is not,
20   because you are nodding your head. 
21            THE WITNESS:  No, it is not.
22            MR. WOOD:  So the record is
23   clear.
24     Q.     (By Mr. Morrissey)  We were
25   provided that coat by, I believe, Ellis
0157
 1   Armistead.
 2            MR. TRUJILLO:  Correct.
 3     Q.     (By Mr. Levin)  What I would like
 4   you to help us with is to understand how the
 5   coat got from you to Ellis, if you know.
 6     A.     The -- I think you all requested
 7   it.
 8     Q.     That is correct.
 9     A.     So I went to my closet, dug it
10   out, put it in a box, and sent it to Ellis.
11     Q.     Was that coat something that was
12   taken -- you didn't wear that coat out of
13   the house when the police took you out of
14   the house the afternoon of the 26th.  Do you
15   recall?
16     A.     No, I don't think I did.
17     Q.     Do you know how you came into
18   possession?  Was that something that came
19   through Pam when she picked up some clothes
20   for you or was that something that was boxed
21   up and shipped when the house was packed?
22            MR. WOOD:  Just so I am clear,
23   when was the request made?
24            MR. TRUJILLO:  It was received
25   January of '98.  So it was -- 
0158
 1            MR. WOOD:  Are we talking about
 2   sometime between December of '96, and then
 3   you all asked for it when, a year later?
 4            MR. TRUJILLO:  I don't have the
 5   exact date.
 6            THE WITNESS:  It was a long time
 7   later.  We were in the house in Atlanta when
 8   the request was made.
 9            CHIEF BECKNER:  December of '97.
10            MR. WOOD:  So a year later you
11   all asked for the clothes, and they produced
12   it in January of '98?
13            MR. TRUJILLO:  Yes.
14            MR. WOOD:  Okay.  Does that help
15   just put it in the time context of when it
16   might have been?
17            MR. LEVIN:  And because everyone
18   needs a computer whiz, we have Mr. Kane.
19   We're talking about that coat.
20            THE WITNESS:  Yes.
21            CHIEF BECKNER:  Is that a, just
22   for clarification, is that a coat or a
23   sweater?
24            THE WITNESS:  It is kind of a
25   little jacket, coat.
0159
 1            CHIEF BECKNER:  We called it a
 2   sweater in the past.
 3            THE WITNESS:  It is a jacket. 
 4            CHIEF BECKNER:  Ellis Armistead
 5   called it a sweater in his letter to us. 
 6   So I just want to clarify we are talking
 7   about the right piece of clothing.
 8            THE WITNESS:  Well, we are
 9   talking about that.  You can call it
10   whatever you want.  It is kind of a jacket
11   more.
12            MR. WOOD:  I'd go with jacket.
13            THE WITNESS:  I mean, I, you
14   know, it is something you put on to go
15   outside in the cold.
16            MR. WOOD:  All right.  Now, I
17   had to interrupted you to try to figure out
18   if we can put it into context of time. 
19   Your question was?
20            THE WITNESS:  You want to know
21   did it come to --
22            MR. WOOD:  Let's let him figure
23   out what it was.  Hold on a second.  He
24   asked, was that something that came through
25   Pam when she picked up some clothes, which I
0160
 1   am taking to be back early right after 
 2   the --
 3            MR. LEVIN:  I'm talking about,
 4   yes.
 5            MR. WOOD:  Pam picked up some
 6   clothes right after.
 7            MR. LEVIN:  Saturday the 28th of
 8   December, 199  -
 9            MR. WOOD:  Right.  Was that
10   something that was boxed up and shipped when
11   the house was packed?  Does that help you? 
12   Do you know the answer?
13            THE WITNESS:  No.
14            MR. WOOD:  If so, tell him.
15     Q.     (By Mr. Levin)  When the request
16   came to you, though, from, either I suppose
17   your lawyers, about turning that jacket over,
18   it was, if I understand you correctly,
19   hanging in your closet?
20     A.     Uh-huh (affirmative), in Atlanta,
21   yes.
22     Q.     And that would be, the request is
23   made approximately a year after your daughter
24   is murdered.  Is it something that was just
25   hanging in your closet or something that you
0161
 1   continued to wear if you recall during the
 2   one-year period or any portion thereof?
 3     A.     I don't remember.
 4     Q.     I will take -- tell me if this
 5   is correct.  I am taking that as saying you
 6   may have worn it, but some point in time
 7   between the murder of JonBenet and when you
 8   turned it over, you may not have; you have
 9   no independent recollection?
10     A.     Correct.
11     Q.     Did you, if you recall, did you
12   clean it at any time -- I believe it is
13   wool, primarily wool -- dry-clean it from
14   when you -- which may sound like a silly
15   question, but I will put it in a larger 
16   context.  The clothing that came boxed, did
17   you -- those items that you kept, continued
18   to use or at least have available, did you
19   clean them all before you put them away,
20   take them all to the cleaners?
21            MR. WOOD:  I am going to ask you
22   to go back and redo that one because that
23   one kind of went in about three different
24   directions, Bruce.  
25            MR. LEVIN:  Okay.
0162
 1            MR. WOOD:  You started off asking
 2   about whether she had this jacket cleaned and
 3   then you started talking about clothes that
 4   were boxed up.  And I don't know if she
 5   knows whether this one was boxed up or not.
 6            MR. LEVIN:  Right.  And I
 7   understand that.
 8     Q.     (By Mr. Levin)  So what I am
 9   trying to do is just to, because I
10   understand you can't identify a particular,
11   whether it was this particular item. 
12     A.     Uh-huh (affirmative).
13     Q.     Let's start with the clothes that
14   were boxed up.  The clothes that were boxed
15   up that you then reintegrated into your
16   wardrobe, did you clean all of those before
17   you did that?
18     A.     No.
19     Q.     Do you have any recollection as
20   to this particular coat, whether or not you
21   ever cleaned it before giving it to Mr.
22   Armistead?
23     A.     No.
24     Q.     It is a coat that you would
25   dry-clean, though?
0163
 1     A.     I am not so sure about that.  I
 2   think, I think it is able to be thrown in
 3   the washing machine.
 4            MR. KANE:  I believe it was made
 5   of acrylic, if that helps.
 6            THE WITNESS:  Yeah.
 7            MR. WOOD:  You all gotta decide,
 8   he says wool, you say acrylic.
 9            MR. LEVIN:  It was acrylic.
10            MR. WOOD:  It ought to say
11   dry-cleaning only on it, if it is, or if it
12   doesn't, sometimes it'll get washed.  Do you
13   know for a fact, that is the key, do you
14   know whether you dry cleaned it or washed it
15   as you sit here today, Patsy?
16            THE WITNESS:  No, I don't.
17            MR. MORRISSEY:  Do you know if
18   Mr. Armistead did before he sent it to us?
19            THE WITNESS:  No, I don't.
20     Q.     (By Mr. Levin)  I will take that
21   as a statement that, once you turned the
22   coat over or may have boxed it up and
23   shipped it to Mr. Armistead, that your
24   personal knowledge of what happens to it is
25   none?
0164
 1     A.     Correct.
 2     Q.     It is not something that you and
 3   he ever discussed during the course of maybe
 4   a briefing or something like that?
 5     A.     No.
 6     Q.     Was it a jacket that you wore
 7   around the house?  I know this is an indoor
 8   picture.  Did you do that commonly?
 9     A.     Sometimes, if it was particularly
10   chilly.
11     Q.     Do you recall whether or not you
12   wore that on either the 23rd of December
13   1996, the 24th, or the 20-- well, we know
14   you wore it on the 25th.  The 23rd or the
15   24th?
16     A.     I don't remember.
17     Q.     Was it something that you would
18   frequently wear inside the house?
19     A.     Sometimes I would, but what is
20   frequently?  You know, I don't --
21     Q.     Frequently would be three or four
22   times -- I mean, was it, if you are chilly,
23   was this the item that you always threw on?
24   That is what I am getting at.
25     A.     Not necessarily, no.
0165
 1     Q.     You talked about, in your '98
 2   interview, that you, on the 24th, that you
 3   were in the basement and you were wrapping
 4   presents.  Do you know, when you were doing
 5   that, whether or not you had on that coat?
 6     A.     I don't know.
 7     Q.     You have told us that you painted
 8   as a hobby.  Would you wear this coat to
 9   paint?
10     A.     No.
11            MR. LEVIN:  Mitch?
12            MR. MORRISSEY:  Nothing about the
13   coat.
14     Q.     (By Mr. Levin)  Mrs. Ramsey, we
15   were sent, and Detective Trujillo probably
16   can give me dates on this to orient
17   everyone, two black shirts.
18            CHIEF BECKNER:  Same time.  It
19   was January 28, 1998.
20            MR. TRUJILLO:  Same date.
21            MR. LEVIN:  Received the same
22   date as the red coat?
23            CHIEF BECKNER:  Yes.
24     Q.     (By Mr. Levin)  We have asked for
25   -- we had also requested, through your
0166
 1   attorneys, that we be sent a black shirt, a
 2   black shirt that John was wearing at the
 3   Whites on Christmas of 1996.  Were you aware
 4   of that request in addition to the request
 5   for your red coat?
 6     A.     I am sure I was.
 7     Q.     Did you participate in collecting
 8   that?  What I mean by that is you said,
 9   well, I went in my closet and grabbed my
10   jacket.  Did you go and grab what you
11   thought was John's shirt?  How did that come
12   about?  Why don't you just tell us in your
13   own words? 
14     A.     I don't remember.  More likely he
15   found his shirt, I found my jacket.
16     Q.     He sent us two black shirts.  I
17   am going to show you a photograph here.  It
18   shows you wearing your red coat and then
19   John wearing a black shirt.  He sent us two,
20   two different black shirts.  This one, does
21   this have a collar, this shirt?
22     A.     I can't tell.
23     Q.     While Mr. Kane tries to get a
24   little closer, I have some more questions. 
25   John sent us two black shirts.  One had a
0167
 1   collar and one did not.  Was there any
 2   discussion that he had with you in which he
 3   tried to obtain your assistance in refreshing
 4   his memory as to which of those two shirts
 5   he wore Christmas of 1996?
 6     A.     I don't remember.
 7     Q.     If it took place, you just don't
 8   recall it?
 9     A.     I don't remember, no.
10     Q.     I think this is a little better
11   shot.
12            MR. WOOD:  I don't believe
13   there's contrast.
14            THE WITNESS:  I can't tell, you
15   know, which one that was.  He has got
16   several.
17            MR. WOOD:  You are talking about
18   the question of the collar, though, on that
19   one.  I don't think you can tell, even from
20   the zoom I can't tell.
21            THE WITNESS:  You can't tell if
22   there's a collar.
23     Q.     (By Mr. Levin)  And the sheriff,
24   this is just, the two he sent us, the one
25   that this appears to be, it is a wool shirt
0168
 1   that is made in Israel, which is kind of
 2   unusual.  It wasn't a gift that maybe you
 3   bought for him, something like that, that
 4   would make it stand out?
 5            MR. WOOD:  Let me stop.  You are
 6   saying this one appears to be.  You are
 7   talking about the picture that Mr. Kane has
 8   just shown us?
 9            MR. LEVIN:  Yes.  And then we
10   are --
11            MR. WOOD:  You say it is a wool
12   shirt that is made in Israel.
13            MR. LEVIN:  The shirt that your
14   husband sent us.
15            MR. WOOD:  Which is kind of
16   unusual.  I don't know if that is true or
17   not.  But the point is, are you asking if
18   this shirt was one that was made -- are you
19   asking her if she knows whether this is a
20   wool shirt that was made in Israel?
21            MR. LEVIN:  Yes.
22            MR. WOOD:  The one that you see
23   in this photograph, are you able to know
24   that?
25            THE WITNESS:  No, I don't know. 
0169
 1     Q.     (By Mr. Levin)  The wool shirt
 2   that he sent us was made in Israel.  Is it
 3   a shirt that maybe you bought him as a gift?
 4     A.     I don't remember.
 5     Q.     I am not going through, from the
 6   minute you walked in the door Christmas
 7   coming back from dropping presents off, but
 8   what I would like to do, and I don't believe
 9   you have been asked this, if you can recall
10   when you got upstairs, had John hung up his
11   clothes that he had worn on the 25th, if you
12   remember?
13            MR. WOOD:  Had he hung them up?
14            MR. LEVIN:  Yes.
15            THE WITNESS:  You mean when I
16   came up to get ready for bed?
17     Q.     (By Mr. Levin)  Yes.  Do you
18   remember if he had just left them laying
19   around or if he had hung them up?
20     A.     I don't remember.  I mean, my
21   dressing room, bathroom, was this direction
22   and his was that direction.  So I didn't, I
23   didn't see it.
24     Q.     Your husband's routine practice
25   and habit, as far as when he would get
0170
 1   undressed, if things needed to be hung up,
 2   did he generally hang things up or if they
 3   needed to go into the hamper or the laundry
 4   chute, would he put them right in the
 5   laundry chute?
 6            THE WITNESS:  Usually.
 7            MR. WOOD:  Hold on a second. 
 8   You were going to say something else.
 9            MR. LEVIN:  We can, we can take
10   it one at a time.
11            MR. WOOD:  Well, I mean, her
12   answer doesn't give you any information as I
13   see it because you asked her, did he
14   generally hang it up or if they needed to go
15   into the -- why don't you ask a specific
16   question.  I'm not sure --
17            MR. LEVIN:  I was going to split
18   it.
19            MR. WOOD:  I think she jumped on
20   top of you actually.  Let him finish the
21   question, Patsy, and then go ahead and do
22   it.
23            MR. LEVIN:  Let's do it, we will
24   do it one step at a time.
25     Q.     (By Mr. Levin)  Your husband's
0171
 1   routine practice and habit, if he had
 2   clothing that he was changing out of that
 3   could be worn again, would he normally hang
 4   them up?
 5     A.     I don't know if he has a routine.
 6   Sometimes he does.  Sometimes he doesn't.
 7     Q.     When he had clothes that were not
 8   going to -- that he'd just worn that he was
 9   changing out of that he was not going to
10   wear again, was it his habit, routine habit
11   and practice, to just leave them laying
12   around or would he normally throw them in
13   the laundry chute?
14     A.     Both.  Sometimes he puts some in
15   the laundry chute and sometimes he left some
16   in the bathroom.
17     Q.     Do you have any recollection with
18   regard to the clothing that he wore on
19   January -- excuse me, December 25th if they
20   went in the laundry chute, hung up, any
21   recollection whatsoever?
22     A.     No.
23     Q.     (By Mr. Morrissey)  What was your
24   practice in your house when things that were
25   dry cleaned would go out?  How did you
0172
 1   handle that, not laundry items, but
 2   dry-cleaning items?
 3     A.     Yeah.
 4            MR. WOOD:  You mean like did she
 5   put it in a special place to make the run
 6   to the dry cleaner?
 7     Q.     (By Mr. Morrissey)  Was there
 8   like a bag or how did that work?
 9            MR. WOOD:  Do you understand what
10   he is asking you, Patsy? 
11            THE WITNESS:  Yeah.  I don't know
12   that we had a particular routine.  I mean,
13   if -- I think if I was going to the dry
14   cleaners, I would kind of check around and
15   see if anything was left, and I would pick
16   it up and take it.
17     Q.     (By Mr. Morrissey)  Did you have
18   like a dry-cleaning bag?  I know some people
19   have --
20     A.     No.
21     Q.      - like a bag that is
22   specifically for that or a place that is
23   specifically for those kinds of items.
24     A.     I wasn't that organized.
25     Q.     Well, and some people have dry
0173
 1   cleaners that come to their house, pick the
 2   stuff up, and then bring it back in a couple
 3   of days and hang it on their door.  Did you
 4   have any of that kind of service in Boulder
 5   there?
 6     A.     I think I tried that a couple of
 7   times, but it just never -- I could never
 8   promise when I was going to be there to pay
 9   them and all of that.
10            MR. MORRISSEY:  Thank you.
11     Q.     (By Mr. Levin)  You told us 
12   that -- I believe you said you didn't help
13   JonBenet get dressed for the Whites'
14   Christmas Day '96?
15            MR. WOOD:  When did she tell you
16   that?
17            MR. LEVIN:  I thought she told
18   that to Mr. Kane.
19            MR. WOOD:  Earlier today?
20            MR. LEVIN:  I thought so.  I
21   could be mistaken.  We don't need to go
22   through it.  I can just ask her the
23   question.
24            MR. WOOD:  Let's just make sure
25   of what she said.
0174
 1            MR. LEVIN:  Okay.
 2            MR. WOOD:  How do you search, 
 3   Mr. Gallo?
 4            MR. GALLO:  F1.
 5            MR. WOOD:  F9?
 6            MR. GALLO:  F1.
 7            MR. WOOD:  F1, search down?  I
 8   am not finding it under dress.  Why don't
 9   you just ask the question again, if you
10   don't mind, Bruce.
11            MR. LEVIN:  No problem.
12     Q.     (By Mr. Levin)  Did you help
13   JonBenet get dressed for the Whites'
14   Christmas Day '96?
15     A.     Yes.
16     Q.     Did you do this by yourself or
17   did John help you too?
18     A.     No, John did not help me.
19     Q.     You told us that you changed
20   JonBenet's clothing when she came home to put
21   her in clothes to sleep?
22     A.     Correct.
23     Q.     Did John assist in that process? 
24     A.     He, I believe, took her coat off,
25   maybe her shoes.
0175
 1     Q.     Okay.  As far as putting the
 2   longjohns on her for sleeping purposes, did
 3   you do that alone?
 4     A.     Yes.
 5     Q.     While you were at the Whites'
 6   house, if JonBenet went to the bathroom, did
 7   either you or he ever go in to help her for
 8   some reason that you can recall?
 9     A.     I did not.
10     Q.     Do you have a recollection of
11   John having to go in and help her for any
12   reason?
13     A.     No.
14     Q.     And under normal -- barring a
15   problem, under normal circumstances, she would
16   just go on her own?
17     A.     Yes.
18     Q.     Mrs. Ramsey, you told us that the
19   red coat that we showed you in the
20   photograph, that you didn't paint with it, to
21   the best of your recollection?
22     A.     To the best of my recollection.
23     Q.     And you have told investigators
24   before that, as the holiday season began,
25   that the painting equipment which is normally
0176
 1   kept in the butler's  pantry was transferred
 2   to the basement by Ms. Hoffman Pugh.  Do you
 3   remember that?
 4            MR. WOOD:  Why don't you give her
 5   the statement so she can look at that.  You
 6   now are directly asking her to reaffirm
 7   something she's already apparently said.
 8            MR. LEVIN:  I didn't think it was
 9   a matter of discussion.  Let me ask a second
10   question.
11            MR. WOOD:  I don't know whether
12   it is or not, Bruce, but I mean, it is not,
13   apparently by the nature of your question,
14   something new.  You already have gotten the
15   information from a question, so --
16     Q.     (By Mr. Levin)  Let me just, let
17   me just ask another question.  We will just
18   drop that one.
19            At the time of JonBenet's death,
20   your painting supplies were found in the
21   basement.  Did you ever paint in the
22   basement?
23     A.     No.
24     Q.     When you were helping JonBenet get
25   ready for bed, were you still wearing the
0177
 1   red coat -- excuse me, the red, black, and
 2   gray coat?
 3            MR. WOOD:  Well, from what I saw,
 4   it looked like the red and black jacket.
 5            THE WITNESS:  I don't remember.
 6            MR. WOOD:  The one we have been
 7   discussing that Mr. Kane had a picture of.
 8            THE WITNESS:  I don't remember.
 9            MR. WOOD:  Did you get your
10   answer?
11            MR. LEVIN:  Yes, I did.
12     Q.     (By Mr. Levin)  I believe you
13   said you don't remember.
14            Was that the outer coat that you
15   were wearing Christmas, or did you have a
16   heavier coat that you wore on top of that?
17            MR. WOOD:  For outdoors?
18            MR. LEVIN:  For outdoors.
19            THE WITNESS:  I don't remember. 
20   I think, I think that was the only one I
21   wore.  Because we were in the car and out,
22   but I don't remember exactly.
23            MR. MORRISSEY:  Mrs. Ramsey, I am
24   sorry to interrupt you.  Before you get
25   going too far, when was the last time you
0178
 1   remember using the paint set?
 2            THE WITNESS:  Oh, god.  Oh, you
 3   know, probably that fall sometime, I --
 4            MR. WOOD:  Do you remember that,
 5   Patsy?  Be sure of your answer.
 6            THE WITNESS:  No, I don't
 7   remember the last time I used it.
 8     Q.     (By Mr. Morrissey)  Right. I am
 9   not asking for a date.  
10     A.     Yeah.
11     Q.     A season.
12     A.     Yeah.
13     Q.     And you indicate the fall?  I
14   don't want to put words in your mouth.
15     A.     Well, the last time I used it was
16   in conjunction with this art class that I
17   signed up to, and I can't remember when that
18   was exactly from CU.  And all of my stuff
19   was there in the butler's pantry.  But then
20   the holidays came, we needed that space, and
21   we moved all of the junk to the basement.
22     Q.     Once it was moved to the
23   basement, you never hauled it up and painted
24   or anything?  You never used it again?
25     A.     No.
0179
 1     Q.     (By Mr. Levin)  Mrs. Ramsey, you,
 2   you had cut evergreens, I believe, in a
 3   bucket of water in your house during the
 4   holidays.  Do you recall that during
 5   Christmas of '96, like boughs or --
 6     A.     Greenery, yeah, I decorate with
 7   greenery.
 8     Q.     Greenery.  Did you have garden
 9   gloves that you wore when you were, when you
10   were -- I assume, you tell me if I am
11   wrong, I assume that you cut them off some
12   of your Evergreen trees outside?
13     A.     Yeah.
14     Q.     Do you wear gloves when you do
15   that? 
16     A.     No.
17     Q.     And I know that you -- there were
18   some flower beds I believe that you
19   occasionally worked with, that you worked on
20   that were on, is it, the south side of the
21   house?
22     A.     The rose, I think the roses.
23     Q.     Did you wear gardening gloves when
24   you worked out in the yard?
25     A.     Not usually.
0180
 1     Q.     Did you own gardening gloves?
 2     A.     I don't think so, no.
 3     Q.     Do you recall ever seeing in your
 4   house brown kind of work gloves, cotton?
 5     A.     Brown cotton?  John had -- I
 6   don't remember brown work gloves.
 7     Q.     Can you picture what I am talking
 8   about?
 9            MR. WOOD:  Do you have a photo
10   maybe or something?
11            MR. LEVIN:  No, I, we, we don't.
12     Q.     (By Mr. Levin)  Have you ever
13   seen, they are kind of a --
14            MR. WOOD:  No, I don't think so. 
15   You got to do better than that.  You can
16   conjure up a zillion different brown work
17   gloves.
18     Q.     (By Mr. Levin)  Cotton brown work
19   gloves.
20     A.     Cotton brown work gloves?
21     Q.     Costs you about three bucks in
22   the grocery store.  I am not creating any
23   images for you?
24     A.     No.
25     Q.     Okay.
0181
 1            MR. WOOD:  Me either.
 2            MR. LEVIN:  We will just leave
 3   that.
 4            CHIEF BECKNER:  Before we go too
 5   far, for clarification for me, when you were
 6   asked about wearing garden gloves, you said
 7   not usually, I believe.  Does that mean
 8   sometimes you would?
 9            THE WITNESS:  I don't remember
10   doing that.  I mean, I do wear them now
11   because now I am wearing these funny
12   fingernails, I don't want to get them messed
13   up, but I don't think I was doing it then. 
14   So I don't, I don't ever remember -- I am
15   not a big gardener, so I didn't have all of
16   the trappings, you know, all of that stuff. 
17   So I do not remember having any gardening
18   gloves.
19     Q.     (By Mr. Kane)  You started to say
20   that John had.  John had what?
21            MR. WOOD:  Let's see exactly what
22   she said.
23            MR. KANE:  Lin, she said John had
24   30 seconds ago.  What did John have? 
25            MR. WOOD:  Excuse me.  The
0182
 1   question was, do you recall ever seeing in
 2   your house brown kind of work gloves, cotton,
 3   and you went brown cotton, and you said John
 4   had, and you said I don't remember brown. 
 5   All I want to do is put it in the context
 6   of what she said.  Do you remember saying
 7   that?
 8            THE WITNESS:  Yes.
 9            MR. WOOD:  Now, Mr. Kane, go
10   right ahead.
11     Q.     (By Mr. Kane)  Now that you've
12   had time to think about it for a minute,
13   what did John have?
14     A.     What kind of gloves did he have?
15     Q.     What were you about to say?  You
16   said John had.
17     A.     John had ski gloves.
18     Q.     (By Mr. Levin)  In addition to
19   his ski gloves, Mrs. Ramsey, do you recall
20   John having any kind of work gloves that he
21   might have kept in the car if he had to
22   change a tire or anything like that?
23     A.     No.
24     Q.     Just for clarification, for the
25   record, when you say no, does that mean no,
0183
 1   you don't recall whether he did or didn't or
 2   no, he did not own any work gloves? 
 3     A.     I don't recall that he did.  You
 4   will have to ask him if he did.
 5     Q.     Fair enough.  Thank you.  
 6            Mr. Morrissey?
 7     Q.     (By Mr. Morrissey)  What color
 8   were the ski gloves that you were thinking
 9   about?
10     A.     It seems to me like they were
11   black.  I can't be sure, but I think they
12   were black.  They were the puffy kind.
13     Q.     (By Mr. Levin)  Now, Mrs. Ramsey,
14   you -- are you aware, I should say, that
15   your paint kit was found very close to the
16   wine cellar door?
17     A.     I have heard that.
18     Q.     Did you recall at any time that
19   you were shown photographs in that regard?
20     A.     No.
21     Q.     We have found, and I want you to
22   help us, maybe you can offer an explanation
23   for this.  We have found fibers in the paint
24   tray that appear to come off of the coat in
25   the photograph we showed you.
0184
 1     A.     In the paint tray?
 2     Q.     Yes.
 3     A.     What's a paint --
 4            MR. WOOD:  Hold on.  Let him ask
 5   you his question and then answer his
 6   question.  What is your question?
 7            MR. LEVIN:  I did.  
 8            MR. WOOD:  You got your answer?
 9            MR. LEVIN:  Well, I got, she said
10   what's a paint tray.
11            MR. WOOD:  No, she didn't.  She 
12   was following your question, in the paint
13   tray because you said we have found, and I
14   want you to help us, maybe you can offer an
15   explanation for this.  We have found fibers
16   in the paint tray that appear to come off of
17   the coat in the photograph we showed you. 
18   What is the question?
19     Q.     (By Mr. Levin)  Can you explain
20   for us how the fibers from the coat got in
21   the paint tray?
22            MR. WOOD:  Are you stipulating as
23   a fact that the fibers that you say are in
24   the paint tray, in fact, came from that coat
25   that we earlier discussed, or is it simply a
0185
 1   matter that you say they may have?  Because
 2   I am not going to let her answer
 3   argumentative, hypothetical opinions.  I will
 4   let her answer if you are going to state it
 5   as a matter of fact that that fiber came
 6   from that jacket.
 7            MR. LEVIN:  I can state to you,
 8   Mr. Wood, that, given the current state of
 9   the scientific examination of fibers, that,
10   based on the state of the art technology,
11   that I believe, based on testing, that fibers
12   from your client's coat are in the paint
13   tray.
14            MR. WOOD:  Are you stating as a
15   fact that they are from the coat or is it
16   consistent with?  What is the test result
17   terminology?  Is it conclusive?  I mean, I
18   think she is entitled to know that when you
19   ask her to explain something.
20            MR. KANE:  It is identical in all
21   scientific respects.
22            MR. WOOD:  What does that mean? 
23   Are you telling me it is conclusive?
24            MR. KANE:  It is identical.
25            MR. WOOD:  Are you saying it is
0186
 1   a conclusive match?
 2            MR. KANE:  You can draw your own
 3   conclusions.
 4            MR. WOOD:  I am not going to
 5   draw my own conclusions.
 6            MR. KANE:  I am saying it is
 7   identical.
 8            MR. WOOD:  Well, what you are
 9   saying in terms of how you interpret a lab
10   result may or may not be the lab result. 
11   If you have it, let's see it.  I would be
12   glad to let her answer a question about it,
13   but I don't want to go into the area of
14   where we are dealing with someone's
15   interpretation of something that may not be a
16   fact and have her explain something because
17   she can't explain something that might be
18   someone's opinion or someone's interpretation.
19            She can try to answer something
20   if you are stating it as a matter of fact.
21            MR. LEVIN:  Well, I believe that
22   Mr. Kane's statement is accurate as to what
23   the examiner would testify to.
24            MR. WOOD:  Will he testify that
25   it is a conclusive match?
0187
 1            MR. KANE:  Yes.
 2            MR. WOOD:  Everybody is -- you
 3   all want to take a minute and confer on
 4   that?
 5            MR. KANE:  No.
 6            MR. WOOD:  Because I want to make
 7   sure, if I am going to let her answer this,
 8   that you are representing and stipulating
 9   that it is a conclusive match.
10            MR. KANE:  Well, come on, Lin, we
11   have been around a long time.  You know, you
12   know exactly what I am saying.
13            MR. WOOD:  No, I don't.  I
14   honestly do not.
15            MR. KANE:  Well, I am telling
16   you, it is -- is it conclusive in the sense
17   that, that there is something unique about it
18   that could only come from a particular item,
19   then the answer is no. 
20            Is it that it is identical in all
21   respects to the fibers off of the jacket,
22   then the answer is yes.
23            Now, does that mean it is
24   conclusive?
25            MR. WOOD:  It doesn't sound like
0188
 1   it to me.
 2            MR. KANE:  Then you have got your
 3   answer. 
 4            MR. WOOD:  It sounds like to 
 5   me --
 6            MR. KANE:  Then you have your
 7   answer.
 8            MR. WOOD:  Then it is a matter
 9   of opinion.  It is not a matter of fact.
10            MR. KANE:  Then you have your
11   answer.
12            MR. WOOD:  I want to make sure,
13   because this is an area that you are asking
14   her to explain something that may or may not
15   be a fact because you are representing to
16   her, Ms. Ramsey, a fiber from your red and
17   black and gray jacket was found in the paint
18   tray, how do you explain it.
19            I mean, if it is a matter of
20   fact, I will let her answer that.
21            MR. LEVIN:  Well, Mr. Wood, let
22   me -- I thought I made it as clear as
23   possible.  I will try to clarify for you.
24            I assume that, in your practice,
25   that you have dealt with --
0189
 1            MR. WOOD:  Don't assume anything
 2   about my practice.  I am asking you a
 3   question.  You used the term in your
 4   question, Mr. Levin, you used the term in
 5   your question, and I am sure that you have
 6   precisely framed your questions.  You said
 7   appears.
 8            Now, "appears to be" and "is," in
 9   my practice, are two different things.  I
10   want to make very clear what the question is
11   before I let her answer.  That is all I am
12   asking.
13            MR. LEVIN:  Given -- and I want
14   to answer your question.  I am going to try
15   to answer your question before I phrase it
16   to your client.
17            Given the status of fiber
18   analysis, the state of the art, that fiber
19   is identical in all respects to fibers from
20   your client's coat; however, as is the case
21   with any type of scientific evidence, even
22   DNA evidence, where you get numbers that say,
23   for example, the likelihood of a random match
24   would be 1 in, say, 14 trillion.  An expert
25   is not going to get up, they'll talk about
0190
 1   numbers, but they are not going to get up
 2   and say that that is the DNA from that man.
 3            MR. WOOD:  Maybe you should give
 4   us the numbers on this fiber.
 5            MR. LEVIN:  There are no numbers
 6   on the fiber.
 7            MR. WOOD:  Give us that, whatever
 8   you got, and we will look at it.
 9            MR. LEVIN:  Do you understand
10   what I'm saying?  I don't want to, I don't
11   want to mislead you because scientific
12   evidence is always subject to --
13            MR. WOOD:  That's why I don't
14   think she should be put into the position of
15   explaining something that scientists may
16   differ on.
17            MR. LEVIN:  Well, scientists will
18   differ on many, many things.
19            MR. WOOD:  Well, then -- that is
20   my point.  She shouldn't be explaining
21   something that one person may say this
22   appears to be the case and the other person
23   may say no, it doesn't appear to be the
24   case.  You are putting her in an incredibly
25   awkward situation.
0191
 1            CHIEF BECKNER:  Let me try to
 2   offer a compromise.
 3            MR. WOOD:  We are ready to hear
 4   it.
 5            CHIEF BECKNER:  Instead of wording
 6   the question in terms of fibers from the
 7   jacket or appear to be from the jacket,
 8   maybe if you word it fibers that by
 9   scientific analysis are identical to fibers
10   from the jacket and not say, not identify
11   those fibers from the jacket but say
12   identical to fibers --
13            MR. WOOD:  What if we left out
14   the fiber problem altogether and just simply
15   ask her whether or not she ever had the
16   jacket, the red and black, gray jacket in
17   the proximity of the paint tray.  We don't
18   have to fight the question of what the fiber
19   is or isn't.  Isn't that what you really
20   want to find out?
21            CHIEF BECKNER:  Well, I think
22   that is probably what Bruce and Mike were
23   trying to get to is is there an explanation.
24            MR. WOOD:  Well, but again, I am
25   not trying to prevent there from being an
0192
 1   explanation as to the question of the jacket
 2   in proximity to the paint tray, but I am
 3   very much concerned about her trying to
 4   explain something that may or may not be the
 5   case scientifically based on opinion.
 6            MR. LEVIN:  I will rephrase the
 7   question and maybe this will satisfy you.
 8            MR. WOOD:  Okay.
 9     Q.     (By Mr. Levin)  Mrs. Ramsey, I
10   have scientific evidence from forensic
11   scientists that say that there's fibers in
12   the paint tray that match your red jacket. 
13   I have no evidence from any scientist to
14   suggest that those fibers are from any source
15   other than your red jacket.
16            MR. WOOD:  Well, you can't ask
17   her -- Come on.  What other sources did they
18   test?  How many other red jackets and red
19   and black jackets did they test?  That is an
20   unfair question on the face of it, Bruce. 
21   Did they test anything other than that red
22   and black jacket?
23            I mean, they can't have
24   information that it could come from another
25   source if they didn't test another source,
0193
 1   for gosh sakes.  So, I mean, that doesn't
 2   help solve the dilemma.
 3            I think what you want to know is,
 4   you suspect, apparently, for whatever reason,
 5   that there may be a match or there may be a
 6   fiber from her red and black jacket that was
 7   on the paint -- in the paint tray, but we
 8   are not at all clear whether that is a fact
 9   or whether that's just something that you
10   believe may or may not be the case.
11            MR. LEVIN:  Well, I told you in
12   the question and I told you face-to-face
13   that, given the most sophisticated testing
14   available at this time, there is fiber
15   evidence in that paint tray that matches.
16            MR. WOOD:  Then fairly we would
17   like to see that evidence so we can then let
18   her answer it so she can fairly know what
19   the actual results are.
20            I think that is a fair request.
21            MR. LEVIN:  Whether it is her
22   fiber or not, I mean, if she can say I
23   can't explain it, I can't explain it, it
24   doesn't matter what the test says.
25            MR. WOOD:  No, no, I think it
0194
 1   would be fair for her to be able to
 2   recognize the question of whether this is
 3   something that she even has to explain.
 4            MR. MORRISSEY:  Lin.
 5            MR. WOOD:  You know, a red fiber
 6   can be in a paint tray from any number of
 7   sources.  I mean, we don't, you are asking,
 8   specifically you are trying to attach
 9   apparently a red fiber, I take it from her
10   jacket to the paint tray.
11            MR. MORRISSEY:  Lin, if we charge
12   an intruder in this case, this is a question
13   that is going to get asked her.
14            MR. WOOD:  Well, I mean, but
15   you're going to be able, that intruder's
16   defense lawyer is going to have the benefit
17   of knowing what result, the test result that
18   you are looking at; true?  So why shouldn't
19   Pat --
20            MR. MORRISSEY:  And he is going
21   to be asking her this very same question.
22            MR. WOOD:  Wouldn't that person
23   have the benefit of knowing your test result?
24            MR. MORRISSEY:  Exactly.
25            MR. WOOD:  And I think Patsy
0195
 1   ought to have the benefit too because I am
 2   not going to let her speculate, and I don't
 3   think you want her to speculate, that is all
 4   I am saying.  We will let her answer the
 5   question, but I would like for her to fairly
 6   know exactly what the factual underpinning is
 7   or even if it is a factual underpinning or
 8   whether it is a disputed issue in the case.
 9            And then if you all -- why don't
10   we tag that and come back to it maybe after
11   lunch and let me think about it a little bit
12   and then you all think about it.  And then
13   maybe after, we will resolve it, I think, in
14   a way that gets you the information that you
15   want.
16            MR. MORRISSEY:  The problem is,
17   even if it is somewhat in dispute, it is
18   going to get asked.  I mean, a judge is,
19   would, would allow that.  And, and these are
20   questions, these kinds of questions are the
21   things we need to know the answer to if we
22   are confronted with a scenario where we have
23   to put Mrs. Ramsey on the witness stand and
24   subject her to, explain to us how is it that
25   fibers that are identified back to your,
0196
 1   quote, coat as the source.  Now, you know --
 2            MR. WOOD:  But her answer may be,
 3   you know, did you check anything else?
 4            MR. MORRISSEY:  Well --
 5            MR. WOOD:  I mean, you know, the
 6   intruder, what was, if you find the intruder
 7   and you find clothing there, did you check 
 8   the intruder's clothing to see if it matches
 9   the same, better, or whatever.  I mean,
10   there are so many hypotheticals there that we
11   just have to know what we are talking about,
12   in all fairness, Mitch.
13            MR. MORRISSEY:  But you understand
14   the position we are in as far as that is
15   going to get asked.
16            MR. WOOD:  Yeah, but I also
17   understand that the body or universe of
18   evidence that may be in existence when that
19   is asked is totally different than what
20   exists here today.  We don't even know what
21   other items were tested.  We don't even know
22   what the test results are.  And I am just
23   very hesitant to have Patsy speculate over
24   something that we don't know whether it is
25   true or not, we don't know what other things
0197
 1   were tested, et cetera.
 2            That is my dilemma.  Let me think
 3   about it.  We won't take a hard position on
 4   it yet, but you all think about it in terms
 5   of whether you might be able to can get some
 6   additional information on it and we can come
 7   back at a later date and answer it or we
 8   can do it in a different fashion.
 9            THE VIDEOGRAPHER:  We need to
10   make a tape change.
11            MR. LEVIN:  I think it is a good
12   lunch break and you can think about it
13   because there are other similar questions, so
14   the answer, your decision on this will
15   dictate what happens with a series of coming
16   questions, just so you know what is coming.
17            MR. WOOD:  Well, and fairly, I
18   anticipated there might be something because,
19   I mean, the forensics issue is one that I
20   think everyone is aware of, tests that have
21   been done subsequent to June of 1998, and I
22   just wanted to make sure that we were not
23   asking her to answer questions that are based
24   on what could be differing opinions on
25   forensics --
0198
 1            THE VIDEOGRAPHER:  Audio cassette
 2   has ended.
 3            MR. WOOD:  -- versus fact.
 4            MR. LEVIN:  I understand, I
 5   understand your position.
 6            MR. WOOD:  Okay, thank you.
 7            (A recess was taken.)
 8            MR. KANE:  Are you ready to roll?
 9            CHIEF BECKNER:  Yes.
10            MR. LEVIN:  Yes.  Mr. Wood, we
11   left off with, I had posed the question to
12   Mrs. Ramsey concerning her offering an
13   explanation for fiber or fibers found in her
14   paint tray.  You did not want her to answer
15   prior to the break.  You wanted some time to
16   think about it.  I assume that you've had
17   that opportunity.  So the question now is
18   will she answer the question?
19            MR. WOOD:  Not as phrased.  And
20   let me explain just quickly why.
21            I do not want, nor do I think
22   you should expect for Mrs. Ramsey, for Patsy,
23   to speculate.  Pure speculation is always
24   fraught with peril in anybody's part.  And
25   your question not only calls for, I think,
0199
 1   gross speculation, but it is at best a
 2   hypothetical that reasonably may not even be
 3   based on fact.  Here is what I would offer
 4   in terms of a compromise, and that is, you
 5   have indicated, at least by your questions,
 6   that you are comfortable in giving us, at
 7   least, your verbal statement of the results
 8   of these tests.
 9            I think, if you would give us,
10   subsequent to this or if you want to do it
11   today, this afternoon, or tomorrow, you can
12   get those, if you can give us the actual
13   result, not looking for the details of the
14   testing, but just the results, the
15   terminology used, we will then consider,
16   reconsider, and maybe we can get you some
17   additional information.
18            But right now as it stands, I am
19   just not willing to let Patsy sit here and
20   speculate about scenarios that may not, in
21   fact, be based in fact.  I just don't think
22   that is fair.
23            MR. LEVIN:  Just so you know,
24   what I would like to ask her is the
25   following, and you will have this in case
0200
 1   you have a change of heart in the future.
 2            MR. WOOD:  Okay.
 3            MR. LEVIN:  I think that is
 4   probably fair.  Based on the state of the
 5   art scientific testing, we believe the fibers
 6   from her jacket were found in the paint
 7   tray, were found tied into the ligature found
 8   on JonBenet's neck, were found on the blanket
 9   that she is wrapped in, were found on the
10   duct tape that is found on the mouth, and
11   the question is, can she explain to us how
12   those fibers appeared in those places that
13   are associated with her daughter's death. 
14   And I understand you are not going to answer
15   those.
16            MR. WOOD:  Right.  Not, not
17   without -- I mean, with all due respect,
18   Bruce, even the discussion we had, as I can
19   best recall it, we didn't get a consistent
20   description of the fiber results on the
21   question of the paint tray.  You are sitting
22   here making a record saying that it is a
23   fact, and I don't know that.
24            MR. LEVIN:  I understand that,
25   and I'm just -- 
0201
 1            MR. WOOD:  And I think what we
 2   will probably find, more likely than not, is
 3   when we look at your test results, we will
 4   find that there was -- there were fibers
 5   that were consistent with or similar to
 6   fibers that you believe were found on Patsy's
 7   sweater or jacket.
 8            I think we will also find, if you
 9   put all of the information out there, that
10   there were an extraordinary number of fibers
11   that are not, in fact, in any way similar to
12   any item associated with Patsy Ramsey on
13   these very items.  
14            And to single out now in this
15   record and say a fiber was found on the
16   ligature that was consistent with Patsy
17   Ramsey's jacket, fairly, I think if asked,
18   you would say, Mr. Wood, there were an
19   extraordinary number of other fibers that we
20   do not relate in any way to Mrs. Ramsey and
21   probably you would tell me you don't have an
22   explanation for.  
23            So I don't want this record to be
24   accusatory based on your statements about the
25   fibers.  Fiber evidence, as you know, is
0202
 1   pretty, pretty -- I won't say weak, but
 2   let's just say that it is subject to a great
 3   amount of debate in the profession.  And
 4   that is why I am just not comfortable
 5   leaving your statements there without, I
 6   think, putting a more accurate picture,
 7   Bruce, on the whole record. 
 8            MR. LEVIN:  I understand your
 9   position.
10            In addition to those questions,
11   there are some others that I would like you
12   to think about whether or not we can have
13   Mrs. Ramsey perhaps in the future answer.  I
14   understand you are advising her not to today,
15   and those are there are black fibers that,
16   according to our testing that was conducted,
17   that match one of the two shirts that was
18   provided to us by the Ramseys, black shirt.
19            Those are located in the
20   underpants of JonBenet Ramsey, were found in
21   her crotch area, and I believe those are two
22   other areas that we have intended to ask
23   Mrs. Ramsey about if she could help us in
24   explaining their presence in those locations.
25            MR. WOOD:  And again, you state
0203
 1   that on this record as fact, and I really
 2   think that is unfair.  I think if you would
 3   produce the full truth of the fibers that
 4   you have collected that it would probably be
 5   at best similar to, which is not uncommon. 
 6   And I think you would also probably have to
 7   admit that there are any number of other
 8   fibers found in these areas that you have no
 9   explanation for, and I don't want this record
10   to be distorted down the road as being a
11   situation where somehow there is greater
12   weight given to these similar fibers you
13   represent in terms of their location and
14   their alleged origin than really is fair
15   under the truth of fiber evidence and the
16   total fiber evidence in this case.
17            So I mean, I understand your
18   position, and we may very well be able to
19   get over it.  You all are willing verbally
20   to tell us the result.  I think you clearly,
21   in fairness, should be perfectly willing to
22   show us the result.  And when you do that,
23   that would give us an opportunity to perhaps
24   reconsider and answer the question.
25            Would you all be willing to do
0204
 1   that, Bruce?
 2            MR. LEVIN:  I think that is
 3   something we'd have -- I would have to
 4   discuss with Chief Beckner.  And I think you
 5   can appreciate why, when we are talking about
 6   physical evidence in an ongoing investigation,
 7   which is not a filed case, that we are
 8   reluctant to release reports.
 9            MR. WOOD:  Well, in fairness to
10   John and Patsy, though, you are willing to
11   state that these fibers, you believe, match,
12   and it seems to me then you are not giving
13   away anything by simply giving us the actual
14   result.  What did the forensic expert say? 
15   What is the actual result?  
16            If you are willing to say it
17   verbally and characterize it, it seems to me
18   you don't jeopardize anything in an ongoing
19   investigation not filed by giving us the
20   result and letting us see if, in fact, what
21   the result says is consistent with the way
22   you represent it today.  It seems to me that
23   would be fair and wouldn't hurt you in the
24   slightest.
25            MR. LEVIN:  I understand your
0205
 1   position.
 2            MR. WOOD:  Okay.
 3     Q.     (By Mr. Levin)  Mrs. Ramsey, your
 4   son Burke, when he was attending grammar
 5   school in Boulder, there was a weekly sort
 6   of report that was sent by the teacher to
 7   the parents.  Do you recall that?
 8     A.     Vaguely.
 9     Q.     And you were, as a parent, given
10   the opportunity or asked to provide some
11   input or response to teacher's little report
12   that was sent out once a week.  Do you
13   remember doing that?  The Friday folder I
14   think is what --
15     A.     Oh, Friday folder, yeah, I
16   remember the Friday folder.
17     Q.     Okay.  Up until the murder of
18   your daughter, your, as a parent, your
19   response in the Friday folder was always
20   handwritten.  Following the death of your
21   daughter, your responses were always typed.
22   Can you explain why you changed that?
23     A.     I didn't -- I wasn't aware that
24   they were typed.
25            MR. WOOD:  Do you have any that
0206
 1   you can let her look at?
 2            THE WITNESS:  Do you have any of
 3   those? 
 4            MR. LEVIN:  I don't think we have
 5   any in the computer.
 6            MR. KANE:  Not in the computer.
 7            MR. LEVIN:  No, no, we don't have
 8   those.
 9            MR. WOOD:  Are you representing
10   that every one afterwards was in fact typed?
11            MR. KANE:  That is what Burke's
12   teacher has told us.
13            MR. WOOD:  Do you have them, the
14   actual reports?
15            MR. KANE:  We certainly don't
16   have them here.  I am not sure if we have
17   them.
18            MR. WOOD:  Well, I --
19            THE WITNESS:  I don't ever
20   remember -- I mean, I don't have any
21   recollection of ever typing anything in the
22   Friday folder, but --
23            MR. WOOD:  I mean, if we can see
24   them somewhere down the road, that might help
25   refresh and give us some indication of an
0207
 1   explanation if they, in fact, are as you say
 2   or as his teacher says.
 3     Q.     (By Mr. Levin)  So I am assuming,
 4   Mrs. Ramsey, then the answer to my question,
 5   which was, can you explain why the change,
 6   you can't offer one because you don't recall
 7   the change occurring --
 8     A.     Correct.
 9     Q.     -- as you sit here today?
10     A.     Right.
11            MR. LEVIN:  Mike, do you have
12   some more questions.
13            MR. KANE:  Yes.
14     Q.     (By Mr. Kane)  Mrs. Ramsey, in
15   your book, and it is in here numerous times
16   on television programs after you wrote your
17   -- first of all, why did you write the book? 
18   What was your primary purpose in writing this
19   book?
20     A.     Primary purpose was to get
21   information out about who we think the
22   intruder was so that more people would be
23   aware of that profile and could help us.
24     Q.     Okay.  And that was your number
25   one goal?
0208
 1     A.     Yes.
 2     Q.     All right.  In that book you talk
 3   about a chronology, I think you call it, of
 4   cooperation, something along that line, a
 5   chronicle of cooperation.  Actually the
 6   second line, this is on page 393, Mr. Wood,
 7   it says police interviewed and questioned,
 8   police interviewed and questioned John and
 9   Patsy on December 27 and John again on
10   December 28.  Did you give any interviews to
11   the police on the 27th?  It was the day
12   after you found her body.
13            MR. WOOD:  Are you talking about,
14   what do you mean by, a sit down interview?
15            MR. KANE:  Well, it says here,
16   police interviewed and questioned John and
17   Patsy.
18            THE WITNESS:  Police were there
19   in the home where we were staying, and we
20   were talking with them all the time.
21     Q.     (By Mr. Kane)  Were you
22   interviewed and questioned on the 27th, to
23   your recollection?
24     A.     To my best recollection, yes.
25     Q.     Do you remember having a meeting
0209
 1   with, I am not sure if it was at Barbara
 2   Furner's house, but you met with Linda Arndt
 3   one time and I believe your mother was
 4   there?  Do you remember that?
 5     A.     My mother?
 6     Q.     There was a meeting that was set
 7   up between sort of within the first couple
 8   of months of the homicide.
 9            MR. KANE:  I don't know the date.
10            MR. WOOD:  January, February of
11   '97?
12            MR. KANE:  Yeah.  You met with
13   Linda Arndt.  And it was you and your mother
14   and I believe Barbara Furner was there.  
15            THE WITNESS:  Okay.
16            MR. KANE:  Remember that?
17            THE WITNESS:  I don't remember my
18   mother being there, but I don't remember a
19   lot from those days.
20     Q.     (By Mr. Kane)  Okay.  Why was it
21   at that meeting that one of the ground rules
22   was that you couldn't talk about the case?
23     A.     I don't know.
24     Q.     Well, that was your ground rule.
25            MR. WOOD:  Wait a minute.  Help
0210
 1   us know that.  Whose ground rule was it? 
 2   Linda Arndt?  How was it conveyed?  Who was
 3   it conveyed to?
 4            MR. KANE:  Well, Linda Arndt was
 5   told.
 6            MR. WOOD:  By whom?
 7            MR. KANE:  By your lawyer.
 8            MR. WOOD:  That is different. 
 9   Come on.
10            MR. KANE:  During that meeting,
11   do you recall at one point telling her that,
12   when the subject matter of the case came up,
13   that you couldn't talk about that?
14            MR. WOOD:  Do you have a
15   statement?  Do you have a recorded statement?
16     Q.     (By Mr. Kane)  I am asking if
17   you have a recollection of it.
18            THE WITNESS:  I have a
19   recollection --
20            MR. WOOD:  Excuse me a second,
21   Patsy.  Do you have a statement that she
22   made?
23            MR. KANE:  Yes, I do.
24            MR. WOOD:  Well, let her see it.
25            MR. KANE:  No, I don't, I don't
0211
 1   have, there is no statement made just because
 2   there was no statement made.  That was the
 3   point, there was no discussion --
 4            MR. WOOD:  Was the discussion
 5   that you are talking about recorded?
 6            MR. KANE:  No.
 7            MR. WOOD:  No report was entered
 8   by Linda Arndt?
 9            MR. KANE:  There was a report.
10            MR. WOOD:  Can we see that?
11            MR. KANE:  I don't have it here. 
12   It is Linda Arndt's report.  It's not your
13   client's report.
14            MR. WOOD:  But it's a statement
15   you are trying --
16            MR. KANE:  I am asking if it is
17   true or  false.
18            MR. WOOD:  Let me finish.  If
19   you have a report, we can look at it in
20   context.  I think that would be fair.
21            MR. KANE:  No.  Well, I am
22   asking if she recalls it.
23            MR. WOOD:  I mean, if you are
24   telling her that her lawyer told Linda Arndt
25   that she didn't want her to discuss a
0212
 1   certain area of questioning, are you asking
 2   her basically did you follow your lawyer's
 3   advice?
 4            MR. KANE:  I am asking if she
 5   recalls having a meeting and recalls that
 6   that was one of the ground rules?
 7            MR. WOOD:  Mr. Kane, when did
 8   this develop after June of 1998?
 9            MR. KANE:  Once again, we are
10   back to the question that I asked you
11   earlier.
12            MR. WOOD:  It is a new question. 
13   Excuse me.  It is a new question, based,
14   though, on developments that have occurred or
15   information that has been obtained since June
16   of 1998.
17            MR. KANE:  So in other words, if
18   it was something that was available at the
19   time, you are saying you won't answer any
20   question to anything that was available to us
21   since June of 1998?
22            MR. WOOD:  Here is the question. 
23   Chief Beckner's letter to me of May the
24   10th, since the last interviews you gave to
25   law enforcement in June, a lot of information
0213
 1   has been developed in the continuing
 2   investigation in JonBenet's death.  This has
 3   resulted in many new questions.
 4            MR. KANE:  Okay.
 5            MR. WOOD:  Now, this information
 6   had to be known to Linda Arndt and to all
 7   of you back in 1997.
 8            MR. KANE:  Well, I wasn't on the
 9   case until June of 1998, so it was news to
10   me.
11            MR. WOOD:  Whether you were on
12   the case or not does not dictate whether
13   someone else on the case would know this.
14            MR. KANE:  Let's stop arguing. 
15   Are you telling her she can't answer any
16   questions about this?
17            MR. WOOD:  No.
18            MR. KANE:  I don't want to debate
19   it.  It's either yes or no.
20            MR. WOOD:  It is not always black
21   and white, Michael.  Sometimes there is an
22   in between.
23            MR. KANE:  That's what I'm
24   saying, I'm asking the question and are you
25   telling her not to answer or are you telling
0214
 1   her to answer?
 2            MR. WOOD:  Why don't you give me
 3   a minute.
 4            THE WITNESS:  Why is it 
 5   important --
 6            MR. KANE:  There is nothing to
 7   debate, there is nothing to debate.
 8            MR. WOOD:  I am not debating.  I
 9   am looking through my notes here.
10            This is Chief Beckner's letter of
11   July the 13th.  I believe we have made it
12   clear in our telephone conversation on
13   Friday, July the 7th, that our intent was to
14   not rehash old questions but that we still
15   had new questions on the prior evidence based
16   on new information and additional forensic
17   testing.
18            Now, I don't think it can be any
19   clearer.  That is not a statement that we
20   have new questions based on information we
21   had prior to June of 1998 but we either
22   forgot to ask or Mr. Kane was not involved
23   in the case and would now like to ask.
24            I didn't come in here with my
25   client prepared to go into areas that I was
0215
 1   never told we would go into.  This is very
 2   clear that we are talking about subsequent to
 3   June of 1998.
 4            MR. KANE:  So in other words --
 5            MR. WOOD:  Don't you agree it is
 6   as clear as a bell, Mike?
 7            MR. KANE:  We have been talking
 8   about December 26, 1996 all morning.
 9            MR. WOOD:  Well, now, wait a
10   minute, that's what I don't want to get into
11   where you're going to start claiming that
12   you're talking about a date certain now
13   you've got the right to do it.  I made it
14   very clear when we talked about those dates
15   today that you were asking about forensic
16   tests that you got --
17            MR. KANE:  Lin, you made it
18   clear.
19            MR. MORRISSEY:  The new
20   information is in the book.
21            MR. KANE:  And that's where I am
22   getting that.
23            MR. WOOD:  Well, tell us where in
24   the book.  That is not the question you
25   asked.  You are talking about Linda Arndt.
0216
 1            MR. KANE:  Okay.  I am not going
 2   to ask that question, Lin, because it's clear
 3   you are not going to let her answer it.
 4            MR. WOOD:  It is not clear.
 5            MR. KANE:  So let the record
 6   reflect you will not let her answer the
 7   question.
 8            MR. WOOD:  No, no, no.  We will
 9   take a break.  Let's take a break and make
10   sure we don't get off track.
11            MR. KANE:  I said I'm withdrawing
12   the question.
13            MR. WOOD:  We have been doing
14   pretty well today.  Let's take a moment and
15   let everybody make sure we gather ourselves
16   and then let's take a five-minute break.  I
17   don't want a problem that would disrupt this.
18            MR. KANE:  You don't want a
19   problem, then let's get down to the 
20   bottom --
21            MR. WOOD:  Don't point your
22   finger or we will have a problem with this.
23            MR. KANE:  Let's get down to the
24   bottom line of this.  We're down here
25   purportedly because Mr. and Mrs. Ramsey want
0217
 1   to solve the murder of their daughter.  To
 2   get to that point, there is one prosecuting
 3   authority that's got any -- that's got any
 4   say in who gets prosecuted and when they get
 5   prosecuted, and that's the Boulder Police and
 6   the Boulder D.A.  
 7            Now, unless we get beyond Mr. and
 8   Mrs. Ramsey, we are never going to get to
 9   the end of this case.  And if the purpose,
10   if your purpose in objecting is because you
11   don't want to answer any questions that might
12   reflect badly on them, well, then just simply
13   state it.  But if the purpose --
14            MR. WOOD:  That is so, pardon my
15   language, asinine, Michael.
16            MR. KANE:  Then why are you not
17   letting, why are you throwing up these
18   artificial barriers? 
19            MR. WOOD:  No, sir.
20            MR. KANE:  That is what you are
21   doing.
22            MR. WOOD:  When you are finished,
23   then I'll respond.  You let me know when you
24   are finished.
25            MR. KANE:  You are throwing up an
0218
 1   artificial barrier to a simple question.
 2            MR. WOOD:  You are misrepresenting
 3   what is happening here.  Now, when you are
 4   finished, I don't want to interrupt.
 5            MR. KANE:  The record will
 6   reflect it.
 7            MR. WOOD:  The record will
 8   reflect what Chief Beckner asked my clients
 9   to do.  I just read it verbatim from his
10   July the 13th letter.  That's what he made
11   clear to us, that's what we agreed to do,
12   that's what I brought them in here prepared
13   to do.
14            MR. KANE:  Okay.
15            MR. WOOD:  I didn't, excuse me. 
16   I did not bring them in here prepared to go
17   back and answer questions about things that
18   occurred prior to June of 1998 that you all
19   have known about all along and questioned
20   them about in June of 1998 for three days,
21   in April of 1997 for a day, and, fairly, if
22   that's what you wanted to do, then you
23   should have asked me that.  I could have
24   discussed it with them.  They could have
25   made a decision, which may very well have
0219
 1   been to come in and do that with you.  I
 2   don't know.  But you didn't ask that.
 3            Now, you can't sit in here today
 4   and change the scope of what you asked for
 5   and turn around, because we say you didn't
 6   ask for it and we didn't agree, and then
 7   make this accusatory statement that is
 8   totally unsupported, and again, pardon my
 9   language, it's an asinine statement, that I'm
10   objecting to questions the answers of which
11   might reflect adversely on my client.
12            I am going to try, and I've been
13   doing, to give you all of the leeway I can
14   within the framework of your request, but you
15   don't have the right, Mr. Kane, to come in
16   here and ask unfair questions, and you don't
17   have the right to come in here and ask
18   questions in subject matters that the Chief
19   didn't ask for when he asked for the
20   request.  That's unfair, and I am not going
21   to let it happen today, and it doesn't mean
22   one thing in terms of it reflecting adversely
23   or otherwise on my clients.  It's simply not
24   what you asked to do.  Okay?
25            MR. KANE:  I said I withdrew the
0220
 1   question.
 2            MR. WOOD:  No, but then you made
 3   a speech.  And then, well, usually as
 4   lawyers go, one good speech deserves another. 
 5   Let's take two minutes now just so we can
 6   try and catch some water and take a break.
 7   All right?  Because I usually, when we get
 8   into a little back and forth, it's better to
 9   get calmed down, stay focused and get the
10   information that you came here to do.  Let's
11   take five minutes.  All right?
12            MR. KANE:  It is your office. 
13   You do what you want.
14            MR. WOOD:  Well, I'm not being
15   unfair about that.  Anytime you say the same
16   thing, just look over to me and say let's
17   take five, okay?
18            MR. KANE:  That is fine.
19            (WHEREUPON, a brief recess was
20   taken.)
21            THE VIDEOGRAPHER:  All right.
22     Q.     (By Mr. Kane)  Mrs. Ramsey, after
23   the homicide, I mean, you mentioned several
24   times in the book on several occasions where
25   you wondered if the killer was watching you
0221
 1   or following you.  You know, I think you
 2   described one time when you had some cable
 3   that was cut at your house by some workmen
 4   and the lights were out or something like
 5   that, and Mr. Ramsey wondered if the killer
 6   might be in there.
 7            I mean, you had a concern about
 8   this person being out there and coming after
 9   you and your family after the homicide?
10     A.     Yes.
11     Q.     All right.  And I take it your
12   biggest concern was for Burke; is that
13   correct?
14     A.     Yes.
15     Q.     All right.  And you got -- there
16   were some security arrangements for Burke
17   when he went back to school, I believe, at
18   the end of January.  Were you involved in
19   those discussions --
20     A.     Absolutely.
21     Q.     -- of the security arrangements? 
22   Do you remember who those took place with or
23   where they took place?
24     A.     At the High Peak School, we made
25   arrangements for Tracy Temple to be in there. 
0222
 1   She is with a security company in Colorado. 
 2   There were also parent volunteers who sat
 3   outside the classroom and basically watched
 4   him at all times.
 5     Q.     All right.  And so you wanted to
 6   have security in the school in case somebody
 7   were to come in and try to do harm to
 8   Burke?
 9     A.     And we set up a 911 system.  The
10   teacher, I believe the teacher and one of
11   the parents would always have a little
12   medallion that they could press in an
13   emergency.
14     Q.     Why was Tracy Temple only hired
15   for one week?
16            MR. WOOD:  Why was she what?
17     Q.     (By Mr. Kane)  Why was Tracy
18   Temple only employed for one week to be at
19   the school?
20     A.     Well, we wanted her to stay
21   longer, but the school felt like it was a
22   disruption to the children.
23     Q.     So it was the school's decision,
24   not yours?
25     A.     Yes.  So we compromised and had
0223
 1   the Burke watch set up.
 2     Q.     Why did you insist that Ms.
 3   Temple be inside the classroom rather than
 4   out in the hall?
 5     A.     She wasn't in the classroom.
 6     Q.     No, no, no.  Why did you -- but
 7   there was discussion that you had with the
 8   school authorities that Tracy be allowed to
 9   be inside the classroom, and the school
10   authorities objected to that.  Do you recall
11   that? 
12            MR. WOOD:  Do you represent that
13   as fact?
14            MR. KANE:  Yeah, that's a fact.
15            THE WITNESS:  I don't, I --
16     Q.     (By Mr. Kane)  Do you remember
17   that?
18     A.     I don't remember that.
19     Q.     Okay.  What was your concern?  I
20   mean, what was in your mind when you were
21   trying to construct these security
22   arrangements with the 911 thing, with 
23   Ms. Temple, with the moms and all?  What was
24   the scenario you had in mind that you were
25   trying to protect against?
0224
 1     A.     One of my children had just been
 2   brutally murdered in the sanctity of our
 3   home.  I have one remaining child, and I
 4   didn't want him let out of my sight.  I
 5   didn't want him to return to school.  I
 6   didn't want to return to Boulder.  I was
 7   frightened for all of our safety.
 8            Then it became apparent that it
 9   would be in Burke's best interest to be back
10   in a routine in his normal environment with
11   his friends, and I saw the benefit of that. 
12   And I said the only way I will let him go
13   is that if there is a great deal of security
14   put in place.
15     Q.     And that's why you hired
16   professionals such as Tracy Temple?
17     A.     Yes.
18     Q.     I think Ellis Armistead also had
19   some involvement in that; correct?
20     A.     Well, together or somehow they
21   installed that wiring system and all that
22   kind of stuff.
23     Q.     Why did you allow Burke to go to
24   school without a guard and have Susan Stein
25   transport him?
0225
 1     A.     Well, Susan had the medallion. 
 2   The medallion was in Burke's proximity at any
 3   given time.
 4     Q.     That medallion worked in the
 5   school, it was tied into something in the
 6   principal's office; is that correct?
 7     A.     Right, right.
 8     Q.     So on the way to school it
 9   wouldn't work.  Why did you allow her to go
10   without any security and against Tracy
11   Temple's advice, as a matter of fact, to be
12   transported to and from school when he was
13   most vulnerable?
14     A.     Well, he left the garage in a
15   locked car and drove straight to school and
16   then was escorted into the school.
17     Q.     You didn't have any concerns about
18   somebody at a stop sign?
19            MR. WOOD:  Mr. Kane, Michael --
20            MR. KANE:  What is the objection
21   now?
22            MR. WOOD:  I just wonder what
23   does this have to do with the investigation
24   into finding who killed JonBenet Ramsey?
25            MR. KANE:  The very fact that I'm
0226
 1   asking it means it has something to do with
 2   it.
 3            MR. WOOD:  What?
 4            MR. KANE:  I don't have to, I
 5   don't have to, if you're now going to make
 6   me justify every question that I ask, now
 7   we're so, you know, in the very beginning,
 8   Lin, you sent a letter --
 9            MR. WOOD:  Don't point.
10            MR. KANE:  I am not.  I am just
11   emphasizing.  You sent a letter --
12            MR. WOOD:  I point sometimes.
13            MR. KANE:  You know, this is
14   nothing personal.  You are doing your job
15   and I am doing mine.  
16            In the very beginning you sent a
17   letter to us, and you laid down this fair
18   and objective, as long as these questions are
19   fair and objective you'll answer, and I wrote
20   back to you, I wrote a letter back, and
21   within five minutes of you getting that
22   letter off your fax machine, you were on the
23   phone with me.  And then the next thing you
24   said --
25            MR. WOOD:  You know, I wrote a
0227
 1   letter to Chief Beckner, which I would be
 2   glad to make part of this record, and then I
 3   got a letter from you, and I called you.  
 4            MR. KANE:  That's right.  And we
 5   spoke about that the next day.
 6            MR. WOOD:  We talked for over an
 7   hour and a half.   
 8            MR. KANE: And the next day you
 9   wrote another letter saying that there would
10   be no conditions on this interview.
11            MR. WOOD:  Now, wait a minute.
12            MR. KANE:  Oh, yes, you did.
13            MR. WOOD:  I didn't impose any
14   conditions.
15            MR. KANE:  You are now.  Now
16   you're asking me what's the purpose of me
17   asking a question.  That's a condition.
18            MR. WOOD:  No, it's not.
19            MR. KANE:  What do you call it?
20            MR. WOOD:  Just what it was.  
21   I asked you a question.
22            MR. KANE:  And I'm saying I don't
23   have to explain my purpose.  I am asking the
24   question.
25            MR. WOOD:  Mr. Kane --
0228
 1            MR. KANE:  If you don't want to
 2   answer the question, don't answer it, but I
 3   don't have to justify the question.
 4            MR. WOOD:  Mr. Kane, you
 5   misrepresent my letter to you.  You
 6   misrepresent our conversation.  You
 7   misrepresent your statements that I have
 8   imposed conditions.  Let me finish.
 9            MR. KANE:  You know, Mr. Wood,
10   this is a sham. 
11            MR. WOOD:  No, it's not.
12            MR. KANE:  This is a big
13   publicity stunt on your part.
14            MR. WOOD:  No, it's not.
15            MR. KANE:  You want to go out
16   there and say my clients answered every
17   question.  Well, don't say that because you
18   are not letting your client answer this
19   question.
20            MR. WOOD:  Mr. Kane, why don't
21   you sit down and let's try --
22            MR. KANE:  You are obstructing. 
23   You are obstructing, Lin.  You are asking me
24   now to justify why I am asking the
25   questions.
0229
 1            MR. WOOD:  Mr. Kane, sit down.
 2   Sit down.
 3            MR. KANE:  Yes or no, can she
 4   answer that question?
 5            MR. WOOD:  Mr. Kane, life does
 6   not always turn on what Michael Kane thinks
 7   is fair.  Just give me a second.  I don't
 8   think I am being unreasonable.
 9            MR. KANE:  I think you are. 
10   You're asking me to justify.
11            MR. WOOD:  Give me a chance to
12   talk without jumping up and making your
13   preplanned speeches.
14            MR. KANE:  You stated your
15   objection. 
16            MR. WOOD:  Now wait a minute. 
17   You all made the request and you all set the
18   conditions, and I agreed to them at the
19   direction of John and Patsy.  I got the
20   letters that demonstrate and document that. 
21   The only thing I asked for was the courtesy
22   of whether you would consider this being done
23   in Atlanta, and you quickly said yes.  I
24   asked for a stenographic reporter because of
25   the concern over an accurate transcript
0230
 1   because there never had been one in the
 2   prior interviews in April of '97 and in June
 3   of 1998.
 4            And that's it.  I didn't impose
 5   any conditions, and I don't want to be
 6   misrepresented in that connection.
 7            All I've done today, because I
 8   thought we were here to be productive, in
 9   looking for the killer of this child, the
10   parents want to come in here and help you,
11   but when you start asking questions about why
12   did you let Burke go to school with Susan
13   Stein, I mean, with all due respect, I mean,
14   I haven't instructed that she can't answer
15   it, but I don't think it's unfair and
16   unreasonable for me to say, what in the
17   world does that have to do with the question
18   of moving this investigation forward on who
19   killed this child. 
20            MR. KANE:  Let's go back to what
21   I said.
22            MR. WOOD:  I didn't mean to get
23   you all upset and hot and bothered.  I just
24   thought it was a fair question.  To my mind,
25   Susan Stein drove Burke Ramsey to school in
0231
 1   a locked automobile and dropped him off, I
 2   am having a lot of trouble finding something
 3   sinister about that or inconsistent with a
 4   parent's love and protection of their son.
 5            MR. KANE:  Well, I think it is
 6   inconsistent, number one.  Number two, it
 7   doesn't matter what I think.
 8            MR. WOOD:  It does.  You are the
 9   special prosecutor.
10            MR. KANE:  What matters is, if
11   you ever think an intruder is going to be,
12   and I'm going to go back to the speech I
13   made in the very beginning that I made two
14   years ago to John Ramsey, if you ever expect
15   for us to be able to put a case against an
16   intruder together, the intruder is going to
17   ask that question.  The intruder is going to
18   say, why is it that the parents of a month
19   after their child is murdered allow their son
20   to be transported at a time when he is most
21   vulnerable, at a time when their own security
22   people said this is crazy to be transported
23   with no protection.  And that is a
24   legitimate question.
25            Now, are you going to let her
0232
 1   answer or not?
 2            MR. WOOD:  Let me say this to
 3   you.  That, again, Mr. Kane -- and I don't
 4   mean, Mr. Kane -- Michael, you know, you
 5   have a perspective.  I just think that what
 6   you are trying to represent about the lack
 7   of security --
 8            MR. KANE:  Mr. Wood, you are an
 9   obstructionist.  
10            MR. WOOD: Let me finish, Mike. 
11   I'm not an obstructionist.
12            MR. KANE:  You go out there and
13   you tell these press people that they
14   cooperated, and I will go out and tell them
15   what really happened in here.
16            MR. WOOD:  Mr. Kane, what's
17   happened here is you are looking to storm
18   out for no reason.
19            MR. KANE:  I'm looking to go
20   storm out because I can't ask a question --
21            MR. WOOD:  Take five, take five
22   minutes and be reasonable enough to listen.
23            MR. KANE:  Look, I don't need
24   this.  It is a game.  You're playing a
25   game.
0233
 1            MR. LEVIN:  Take five minute.
 2            MR. WOOD:  Take five minutes.
 3            MR. KANE:  Are we going to take
 4   every five minutes every time I ask a
 5   question because you want to, you want to
 6   know what it is that's in my mind.  I just
 7   told you what's in my mind. 
 8            MR. WOOD:  Mr. Kane, we are both
 9   trying to do our jobs under very unusual and
10   difficult circumstances.
11            MR. KANE:  Right.  And my job is
12   not to stand in the way of the truth.
13            CHIEF BECKNER:  Let us take a
14   time out.
15            MR. LEVIN:  Let's take five
16   minutes.
17            MR. WOOD:  If you are implying my
18   job is to obstruct the truth, I take that as
19   a professional insult.  And you will not be
20   staying in my office.  I pay the rent here. 
21   I will not be insulted by you.
22            MR. KANE:  That's fine.
23            CHIEF BECKNER:  Time out.  Time
24   out.
25            (A recess was taken.) 
0234
 1            (Mr. Morrissey is no longer
 2   present).
 3            MR. WOOD:  It is my
 4   understanding, and, Chief Beckner, correct me
 5   if I am wrong, I will try to state it and
 6   see if we can get at least an accurate
 7   record of the ending of Patsy's interview. 
 8            It is my understanding that the
 9   only area that you did not cover with Patsy
10   Ramsey that you wanted to discuss with her
11   today was the area of Burke's security. 
12   Other than the issue of the fiber results
13   that we discussed right after lunch and just
14   before lunch that we talked about we can
15   address and perhaps come back and be able to
16   deal with another day.
17            CHIEF BECKNER:  Correct.
18            MR. WOOD:  And you decided,
19   because of my questions that resulted in the
20   colloquy of counsel, that you do not wish to
21   complete your questioning of Patsy on the
22   issue of Burke's security, but it is my
23   understanding that that was it in terms of
24   what you wanted to talk to her about today
25   is what you told me in the hallway, isn't
0235
 1   it?  Didn't you tell me that in the hall?
 2            CHIEF BECKNER:  I told you that
 3   there was no reason to go further with
 4   Patsy.  That was the consensus of the group.
 5            MR. WOOD:  Well, I thought you
 6   told me -- but, Chief, you told me the only
 7   areas you had to wrap up with her anyway was
 8   the security and the fibers.  The fibers we
 9   already agreed to disagree for the moment
10   with the chance of resolution.  Didn't you
11   tell me that?
12            CHIEF BECKNER:  I don't know that
13   I was that clear, and if I was, then I
14   apologize.
15            MR. WOOD:  What other areas are
16   there that you have to talk to Patsy Ramsey
17   about?  And if so, I want to make sure you
18   understand, she is here, she is available,
19   she is ready.  The only question we had that
20   has come up that has been an area to defer
21   has been the area of the fibers.
22            MR. LEVIN:  Mr. Wood, let me
23   address that issue, if I might, with you. 
24   We did have an opportunity, because it was
25   left up in the air as to whether or not we
0236
 1   would provide you with reports from our
 2   forensic experts, and we have discussed that,
 3   and we are not going to do that.  And I
 4   understand that you will not permit her
 5   without seeing those reports, to answer those
 6   question, which we understand.
 7            CHIEF BECKNER:  I will also say
 8   that was not a condition prior to this
 9   interview, that you had to see police reports
10   or lab reports in order to answer questions
11   based on evidence.
12            MR. WOOD:  No, no, no.  The idea
13   never was discussed.  I mean, it's not a
14   condition now.
15            CHIEF BECKNER:  So it was not a
16   condition.
17            MR. WOOD:  And it's not a
18   condition now.  I simply said that it would
19   be unfair to have a witness speculate about
20   a scenario's explanation based on a
21   representation of the significance of a
22   forensic test on the fibers when it seems to
23   me very simple, if you're going to sit here
24   and say that it appears to be her jacket, a
25   fiber from her jacket, and we are trying to
0237
 1   figure out what "appears to be" means because
 2   it was one of the weak areas of evidence in
 3   the law, fiber evidence when you are talking
 4   about appears to be and similarities, that,
 5   you know, with all due respect, I wanted to
 6   see not the full report, just the conclusion
 7   of the person that did the test to find out
 8   if that is really an accurate
 9   characterization.
10            And based on knowing that, in
11   terms of it being in the examiner's words
12   versus the prosecutor's words, we might very
13   well be able to answer the question.  That's
14   not a condition.  That's a fair request. 
15   You all don't want to be unfair, I wouldn't
16   think.
17            CHIEF BECKNER:  Well, it is a
18   condition, whether you think it is fair or
19   unfair.
20            MR. WOOD:  You all throw around
21   the word condition.  If I ask a question, it
22   becomes a condition.  If I ask a question,
23   in this man's mind, Mr. Kane's, it becomes
24   an objection or instruction not to answer,
25   which this record will not bear out.  
0238
 1            I mean, if you're telling me you
 2   have other areas for Patsy Ramsey and it's
 3   not what you just represented to me in the
 4   hallway, and I don't know if you were there
 5   or not, Ollie, but, Chief, you told me that
 6   was all you wanted to ask about anyway was
 7   the security and then the fibers and you
 8   were done.
 9            And you know, then I said, if
10   that's the case, let's make that record and
11   we will move on to John, but now Mr. Kane
12   is saying there are other areas.
13            MR. KANE:  Well, I think given
14   the fact that you put on three types of
15   objections during the questioning, and let me
16   just answer, the three objections that you
17   raised are no question that has been covered
18   before, and we have no problem with that
19   from the very beginning, we don't want to
20   plow old ground.
21            MR. WOOD:  Don't fault me for
22   that one.
23            MR. KANE:  No, I am not.  But
24   there were two others that became clear
25   today.  And one was that you wouldn't
0239
 1   entertain any question that involved
 2   information that was available to us before
 3   June of 1998 but not asked, and you made
 4   that specific --
 5            MR. WOOD:  Don't fault me for
 6   that one because I read the Chief's 
 7   letter --
 8            MR. KANE:  Let me finish.
 9            MR. WOOD:  You are making it
10   sound like I did something wrong.  All I'm
11   doing is stating what we agreed to.
12            MR. KANE:  No.  Well, see that's
13   where we had the disagreement.
14            MR. WOOD:  Have I misread this
15   letter?
16            MR. KANE:  That's where we have a
17   disagreement.
18            MR. WOOD:  I am reading the
19   letter that says, of July 13th, I think it's
20   mis-dated June 13th --
21            MR. KANE:  Lin, Lin, you've
22   already made a record of this.  We don't
23   need to, we don't need to hash this out.
24            MR. WOOD:  You are accusing me of
25   doing something improper in my objection and
0240
 1   yet you won't --
 2            MR. KANE:  I am just stating, no,
 3   I am saying that's what you're interpreting
 4   your letter to mean that no question that
 5   could have been asked before June of 1998
 6   that wasn't asked.
 7            MR. WOOD:  That is what it says.
 8            MR. KANE:  Okay.  That's all I
 9   am saying.
10            MR. WOOD: It says our intent was
11   not to rehash old questions but that we
12   still had new questions over prior evidence
13   based on new information and additional
14   forensic testing.  Asking old questions would
15   be a waste of our time.  
16            That's what the Chief told me he
17   wanted to do.  Now you're making a record
18   that says I'm somehow improper in objecting.
19            MR. KANE:  I am saying that's
20   your -- no, I'm saying that's your
21   interpretation of it.
22            MR. WOOD:  It is plain language.
23            MR. KANE:  We are debating an
24   abstract of that.
25            CHIEF BECKNER:  In interpreting
0241
 1   that, you are interpreting it differently. 
 2   Over prior evidence, prior evidence can be at
 3   any time.
 4            MR. WOOD:  But prior evidence
 5   based on new information and additional
 6   forensic information.
 7            CHIEF BECKNER:  Sure.
 8            MR. WOOD:  You can't leave that
 9   out.
10            CHIEF BECKNER:  No, I know.  But
11   you develop new information on old evidence
12   oftentimes as we continue the investigation.
13            MR. WOOD:  And we got into the
14   question about Linda Arndt on a meeting with
15   her in February of '97, and I asked about
16   whether that was based on new information or
17   additional forensic testing, which wouldn't
18   apply, and it seemed to me that Mitch
19   Morrissey was getting ready to show us
20   something in the book and then you all
21   didn't want to go there.
22            CHIEF BECKNER:  Without debating
23   that particular issue, I just want to make
24   clear that --
25            MR. WOOD:  Let me tell you
0242
 1   something, I know exactly what we came here
 2   to do, there's no doubt in my mind, it was
 3   documented by our letters.  My clients are
 4   willing to do it.  Patsy Ramsey is willing
 5   to complete any areas within what you ask
 6   and we agreed to do.
 7            MR. KANE:  Okay.  No.  All I am
 8   saying --
 9            MR. WOOD:  And if you're really
10   telling me now that you've got a number of
11   other areas for Patsy, different as I
12   understood what you told me in the hall,
13   Chief, and maybe I misunderstood, I thought I
14   did understood.  But I'll --
15            CHIEF BECKNER:  I said they
16   didn't have any additional questions, and
17   without the explanation it goes beyond that.
18            MR. WOOD:  Well, do you have any
19   areas for Patsy Ramsey other than the
20   security of Burke when he returned to school
21   or what we've already made I think a clear
22   record on about the fibers?
23            MR. KANE:  Yes, absolutely.
24            MR. WOOD:  Well, why don't we get
25   her back in here and finish.
0243
 1            MR. KANE:  Fine, as long as
 2   you're not going to object, but if are you
 3   going to object and say, if the question
 4   could have been asked in June of '98 but it
 5   wasn't and the information that would have
 6   prompted that question was available in June
 7   of '98, but the question wasn't asked, if
 8   that's going to be your objection, then, no,
 9   I don't, but if that's the way you are
10   interpreting what is agreed to --
11            MR. WOOD:  Why don't you, Mr.
12   Kane, why don't you just state in plain
13   English what you want to do.  I thought it
14   was clear as a bell from Chief Beckner's
15   letters that you wanted to ask these new
16   questions based on new information or
17   information developed since June of 1998.
18            MR. LEVIN:  Mr. Wood, let me,
19   I'll make this --
20            MR. WOOD:  That is what the
21   letter says.
22            MR. LEVIN:  -- I will make this
23   as clear as possible.
24            MR. WOOD:  That would help.
25            MR. LEVIN:  What we want to do
0244
 1   is we would like to ask some questions of
 2   John Ramsey.  The reason why we choose to
 3   ask additional or not additional questions of
 4   Patsy is not going to be productive to go
 5   back and forth.
 6            MR. WOOD:  It is going to
 7   determine whether we can legitimately move
 8   forward with John.  If you are going to walk
 9   out, in effect, of Patsy's interview, what's
10   the difference?  I am going to take the same
11   position with John.
12            MR. LEVIN:  For whatever 
13   reason --
14            MR. WOOD:  I am going to make
15   you live up to what you said you came here
16   to do.
17            MR. KANE:  We keep debating. 
18   Okay.  You're not even interpreting --
19            MR. WOOD:  Why don't you leave
20   for a minute and let the lawyers work this
21   out, John.  
22            (Mr. Ramsey leaves the deposition
23   room).
24            MR. WOOD:  It's just not fair for
25   John and Patsy to sit here and listen to us
0245
 1   haggle back and forth. 
 2            Let me say this, Michael, it
 3   makes no sense to me at all that you don't
 4   want to finish with Patsy.
 5            MR. KANE:  It makes no sense at
 6   all --
 7            MR. WOOD:  Make your record.
 8            MR. KANE:  It makes no sense to
 9   me at all that you were going to object when
10   we ask the question that could have been 
11   ask -- is this not what your objection is? 
12   Please.  Tell me.  
13            I think you have raised three
14   objections.  We already went over the first
15   one, nothing that was covered before.  But
16   the other two objections that you've raised
17   are nothing that involved information that
18   was available in June of '98 but that we
19   didn't ask a question about.
20            In other words, we are not going
21   to get a second bite of the apple, something
22   that could have been asked in June of 1998. 
23   Is that your objection?  Is that how you are
24   interpreting that?  
25            MR. WOOD:  I really, with --
0246
 1            MR. KANE:  Is it or isn't it?
 2   Because if it's not the way you are
 3   interpreting it, let me ask the question.
 4            MR. WOOD:  I told you I accepted
 5   on the face of what Chief Beckner asked us
 6   to do, and I think he put it in writing and
 7   I answered him back and said it, and this
 8   whole idea was to deal with new questions
 9   based on information developed since June of
10   1998.
11            MR. KANE:  Right.  And that's --
12            MR. WOOD:  Now, that's what you
13   asked us to come here to do.  John and
14   Patsy directed me to agree to that.  That's
15   what they came in here prepared to do.  It
16   seems like what's happened is you would like
17   to do more than that, and now you are upset
18   with me because I won't say okay, let's go
19   beyond what you asked for and they were
20   prepared to do.
21            MR. KANE:  That's all I am saying
22   is we have a disagreement.  We have a
23   disagreement.
24            MR. WOOD:  Why are you stopping
25   it is what makes no sense.  Maybe I will
0247
 1   object to 10 questions out of the next 100. 
 2   You will get 90 answers, Michael.  Don't you
 3   want those 90?  
 4            MR. KANE:  Lin, that's not what
 5   you're --
 6            MR. WOOD:  You came out here, we
 7   are ready to do it.  Don't you want the
 8   information?
 9            MR. KANE:  Absolutely.  So why
10   are you raising objections?
11            MR. WOOD:  Why are you abandoning
12   the ability to --
13            MR. KANE:  All I'm saying is that
14   I don't even know why we are having this
15   discussion.
16            MR. WOOD:  Because you stormed --
17   you threatened to storm out of the room and
18   leave.  You were packing your bag.
19            MR. KANE:  We are having this
20   discussion because you said just a minute ago
21   that it's your understanding that we only had
22   one more area to cover, and I am telling
23   you, and I'm telling you --
24            MR. WOOD:  I misunderstood what
25   Chief -- I think Chief Beckner will come
0248
 1   slightly to my defense in what I thought he
 2   told me was not unreasonable.
 3            CHIEF BECKNER:  No, it is not.
 4            MR. WOOD:  It is not.
 5            MR. KANE:  Okay.  That's fine. 
 6   That's fine.  But all I am saying to you is
 7   that that is not the case with me.  Is that
 8   I have a lot of other questions, but if you
 9   are not going to, if you are going -- let
10   me finish.
11            If you are going to interpret
12   that, because it's not clear, if you are
13   going to interpret that to mean that no
14   question that could have been asked but
15   wasn't, then I have no further questions in
16   that area, particularly when the third
17   objection that you have raised is that we
18   now have to explain what the relevance of a
19   question is to further the investigation,
20   which was the last objection that you raised.
21            So given that, given that, those
22   conditions, no, there is nothing further that
23   we have of her.
24            Okay?  I mean, now we've made our
25   record.
0249
 1            MR. WOOD:  Well, I didn't come
 2   here to make a record.
 3            MR. KANE:  That's exactly what
 4   you said, that you want to make a record.
 5            MR. WOOD:  Well, I didn't come
 6   here to make a record.
 7            MR. KANE:  Neither did I.  I
 8   came here to ask questions.
 9            MR. WOOD:  I may be forced to
10   make a record, which apparently I have been
11   forced to do so, but I didn't came here to
12   do it.  I came here to present John and
13   Patsy Ramsey to you and the other six
14   interrogators to ask your questions and get
15   answers to move this investigation forward. 
16   Okay?
17            Now, I thought it was very clear
18   what the request was.  We spent some time
19   clarifying it.  It's documented.  It seems
20   to me that there shouldn't be any fighting
21   over it.  Maybe it's not what you thought
22   coming in, Michael.  Maybe you wanted more,
23   but that's not what I was asked to give, and
24   that's not what my clients came prepared to
25   give.  And what your request was, Chief, I
0250
 1   thought and my clients thought, even though I
 2   had my lawyer concerns, that they thought it
 3   was reasonable and they would come here to
 4   help.
 5            I didn't make an objection about
 6   Burke's security.  I asked a question.  And
 7   I think it's a fair question.  You could
 8   have said, Mr. Wood, I am not going to
 9   answer your question, and you could have
10   forged on --
11            MR. KANE:  Which I did, and you
12   still didn't let her answer it.
13            MR. WOOD:  I really think, I
14   really -- I don't think you're going to 
15   find --
16            MR. LEVIN:  Just hang on a
17   minute.
18            MR. WOOD:  -- where I instructed
19   Patsy not to answer that question.  I think
20   what happened is you took off after me
21   because you didn't like me asking you the
22   question.
23            MR. KANE:  Whatever.
24            MR. WOOD:  I just, I hear
25   everything you are saying, Michael, and with
0251
 1   all due respect, it makes no sense to me,
 2   when we're here and Patsy is here, you
 3   brought six people out from Colorado -- well,
 4   six from Colorado, one from Pennsylvania, and
 5   you say you got other subject matters. 
 6   Let's ask her the questions.
 7            If you -- look, so what if
 8   something comes up that as a lawyer I feel I
 9   have to give her instruction to protect my
10   client's interests or to do what I think is
11   fair in terms of the parameters of the
12   agreement.  You can't deny me that right. 
13   It doesn't mean that you're still not going
14   to get information about things to do with
15   this investigation that I think you would
16   want to have.  
17            But you are saying, Mr. Wood,
18   unless you agree to let her answer every
19   question, even if you think it's unfair or
20   outside the scope of the agreement, we are
21   not going to ask her any questions.  That,
22   Michael, makes no sense to me, and I don't
23   think it makes sense to any reasonable
24   person.
25            MR. KANE:  Do you remember the
0252
 1   letter I sent to you?
 2            MR. WOOD:  I do.  Painfully
 3   remember.
 4            MR. KANE:  And where I said, you
 5   will remember, we object, Chief Beckner and I
 6   object to your placing a condition that as
 7   long as the questions are fair and objective,
 8   and I said that definition can be used to
 9   exclude anything.
10            MR. WOOD:  You haven't been
11   excluded on hardly anything here today.
12            MR. KANE:  And you wrote -- and
13   then you called me, and then you wrote the
14   next day.  You called me and said you're
15   misinterpreting what I am saying.
16            MR. WOOD:  You were.  You are
17   misinterpreting what is happening here today. 
18            MR. KANE:  You assured us, you
19   assured us that was not designed and it was
20   not going to be used to exclude questions. 
21   Look, you made your record.  I made my
22   record.  There really is no record here. 
23   This isn't a deposition.
24            MR. WOOD:  I'm not, but I'm 
25   not --
0253
 1            MR. KANE:  We don't have a judge
 2   that we can go to with a motion to compel. 
 3   Okay?  We are used to civil cases, I think,
 4   you and I.  We are not in front of a --
 5   this is simply questioning of individuals,
 6   and there is no reason to --
 7            MR. WOOD:  I still haven't heard
 8   a reason why you don't want to ask Patsy
 9   other questions.
10            MR. KANE:  I stated my position,
11   you stated your position, so I have no
12   further questions based on what I stated.
13            MR. WOOD:  I am not sure what
14   you stated.
15            MR. KANE:  It doesn't matter.
16            MR. WOOD:  It does matter.  It
17   does matter.  It does matter.
18            MR. KANE:  Oh, Jesus, Lin.  Let's
19   go, guys.
20            MR. WOOD:  I sat here for a day,
21   Michael --
22            MR. KANE:  Let's go.  
23            CHIEF BECKNER:  Take five.
24            MR. KANE:  We're going to take
25   five.
0254
 1            CHIEF BECKNER:  Let's take five.
 2            MR. KANE:  We are going to take
 3   five.
 4            MR. WOOD:  Stay on the record. 
 5   I will say what I was going to say and we
 6   will come back and get going one way or the
 7   other.
 8            MR. KANE:  Could we have a
 9   conference here? 
10            MR. WOOD:  I mean --
11            MR. KANE:  You just said you --
12   come on, Lin, five minutes ago you said I
13   will extend the courtesy to you.
14            MR. WOOD:  I think you came here
15   to leave.  I don't think you came here to
16   question.
17            MR. KANE:  I came here to ask
18   questions, and I thought they had been
19   answered --
20            MR. WOOD:  You have got them, you
21   got them all, you got them, you got them,
22   and now I am offering you more and you don't
23   want them.
24            MR. KANE:  Lin, I'm not going to
25   debate the point.  I'm not going to debate
0255
 1   the point.  You have your interpretation. 
 2   You have your spin.
 3            MR. WOOD:  I don't have spin.
 4            MR. KANE:  That is what it is.
 5            MR. WOOD:  Listen to me, I don't
 6   have spin.
 7            MR. KANE:  Don't point.
 8            MR. WOOD:  I told you a minute
 9   ago, I do point occasionally.  I don't have
10   spin.
11            MR. KANE:  Okay.  It doesn't
12   matter.
13            MR. WOOD:  You people put a spin
14   in this thing for three and a half years
15   before I ever get involved with this thing.
16            MR. KANE:  I have never ever,
17   ever -- the only time I have gone on the
18   public record in this case, Lin, was to
19   clear your client, Burke Ramsey, and to tell
20   the world that it was outrageous what they
21   did to Burke Ramsey, and you settled for
22   probably millions a week later.  So don't
23   ever say that we spun anything.  You're on
24   every nightly television show for the past
25   two weeks telling the public --
0256
 1            MR. WOOD:  That is a total
 2   exaggeration of the truth.  I was on one
 3   series of days.
 4            MR. KANE:  -- telling the public
 5   that you're here to say -- you are here,
 6   that your clients, against your advice, are
 7   going to answer any question, and we are
 8   finding out that is not the case.
 9            MR. LEVIN:  Mr. Kane, let me
10   interrupt for a second.  Mr. Wood, let's --
11            MR. WOOD:  By the way, I didn't
12   settle the case in December when your
13   interview was published.  It settled several
14   months after.
15            MR. KANE:  Right.  After I made
16   the statement.  Yeah.
17            MR. WOOD:  And I appreciated your
18   candor with respect to that interview, and I
19   so stated to you.
20            MR. KANE:  But it's the only time
21   I've ever said anything publicly.
22            MR. WOOD:  I painted too broad of
23   a brush when I said you all.  You all
24   probably meant the Boulder Police Department,
25   at times the Boulder district attorney,
0257
 1   former members of the police department.
 2            MR. KANE:  Nobody present here.
 3            MR. WOOD:  It's hard for me 
 4   to -- well, I am not going to agree with
 5   that.  It's hard for me to sit here and be
 6   accused of spin when all I do is turn on
 7   Good Morning America and get spin --
 8            MR. LEVIN:  Mr. Wood, I've 
 9   been --
10            MR. WOOD:  -- from the other
11   side.
12            MR. LEVIN:  I am sorry, I did
13   not mean to interrupt you.  Are you
14   finished?
15            MR. WOOD:  Yes, for the moment.
16            MR. LEVIN:  This is the bottom
17   line.  The bottom line is, for whatever
18   reason, we have made a decision that we no
19   longer wish to ask questions of your client,
20   Mrs. Ramsey.  We are asking you if we may
21   begin to ask questions of John Ramsey,
22   regardless of whatever is going on in your
23   mind -- and no one is accusing you of any
24   misconduct or ill purpose in any way, shape,
25   or form -- all we are saying is we would
0258
 1   like to begin questioning John.  And we can 
 2   do --
 3            MR. WOOD:  And I would like you
 4   to finish with Patsy.
 5            MR. LEVIN:  I understand that. 
 6   We are finished with Patsy for whatever
 7   reason, and we stated what we believe is our
 8   reasons.  We will not state any more.  We
 9   would like to start questioning John --
10            MR. WOOD:  It is 4:15.
11            MR. LEVIN:  -- if we can do
12   that, we will do that.
13            MR. WOOD:  It is 4:15.  I am
14   tired.  I spent more time talking today than
15   I thought I would have to.  Why don't we
16   come back at 9:00 and get John in the
17   morning if that works.  I mean, that seems
18   to me reasonable.
19            MR. KANE:  It is a quarter to,
20   we've taken a break every hour.  We have
21   taken an hour and a half.
22            MR. WOOD:  I am going to talk to
23   John and Patsy and make a decision whether
24   or not, when you come in here and you create
25   what I think is an artificial record to
0259
 1   somehow justify --
 2            MR. KANE:  Okay.  Go ahead.  Go
 3   ahead, Lin.
 4            MR. LEVIN:  Would you give us a
 5   couple of minutes to collectively discuss
 6   your timing proposal, please, sir?
 7            MR. WOOD:  Okay.  Let me have a
 8   couple of minutes while you are doing that
 9   to make sure because I have spoken without
10   talking to John and Patsy.  
11            MR. LEVIN:  We understand.
12            MR. WOOD:  Let me finish this by
13   saying something to you, Michael.  I don't
14   know your background, but we are all trying
15   to do our jobs, and I am not going to laugh
16   at you.  If you want to laugh when I say
17   something, that is your prerogative.  I just
18   don't think that's productive because I
19   think, of all the people, of all the 
20   people --
21            MR. KANE:  You are doing your
22   job.
23            MR. WOOD:  -- who get involved,
24   well I -- doing my job is not to laugh at
25   another professional.  
0260
 1            But I think that, of all of the
 2   people who have been involved with this, that
 3   I have tried more, whether you think I have
 4   done everything that you wanted me to do, I
 5   think I have been on the phone and I have
 6   made a greater effort to try to get your
 7   side and my side together than anybody else.
 8            That doesn't fault anyone else
 9   involved.  They made very good decisions in
10   my judgment for their reasons.  I don't
11   criticize any other lawyer in this case.  I
12   only speak for myself.  And I think that I
13   have tried to be extremely reasonable.  And
14   I didn't physically block the door for John
15   and Patsy to come in here.  I didn't feel
16   good about it.  You know that one of the
17   reasons that I didn't feel good about it was
18   because you were going to be involved.
19            I went to the Chief after your
20   letters and our discussions and I said I
21   have some real concerns about Michael Kane's
22   objectivity, and I think it might be better
23   if he were not involved, and I was told that
24   your involvement would be a deal breaker. 
25   Either you got to be involved or nobody
0261
 1   wanted to talk to John and Patsy.  
 2            And I've got to tell you, with
 3   all due respect again -- I hate to use that
 4   phrase because usually you figure something
 5   bad is coming, and it usually does -- I
 6   think you came here on a self-fulfilling
 7   prophecy.  I think you came in here ready to
 8   jump on me the minute I  opened my mouth. 
 9   If I made a request, it was going to be
10   called a condition.  If I asked a question,
11   it would be deemed an objection.  You kept
12   trying to get me to say that I was
13   instructing Patsy not to answer, and I don't
14   think that is what I have done.
15            I'll tell you this, if I did it,
16   boy, I am going to be unhappy with myself
17   because I sure didn't mean to do it.  I
18   wanted to facilitate your getting these
19   questions answered.  I still would like to
20   do that.  You haven't gotten on the plane to
21   go back yet.  I think it is still serves a
22   purpose to try to sit here and answer some
23   questions.  
24            So you all talk about timing, let
25   me talk to John and Patsy, and let's see if
0262
 1   there is any place to go.  I hope there is. 
 2   I hope we can still go forward and be
 3   productive.  Okay?
 4            (WHEREUPON, a brief recess was
 5   taken.)
 6            MR. WOOD:  Everybody ready?  I
 7   don't know what you all decided, but I have
 8   spoken with John and Patsy.  It was your
 9   condition, Chief and Mr. Kane, that Patsy
10   Ramsey be finished first before John Ramsey
11   was interviewed.  It is my understanding that
12   you've got a number of areas to inquire of
13   Patsy Ramsey.  She is here, and we are
14   prepared to go forward and complete her,
15   understanding that the fiber issue is one
16   that we would, although you say you have
17   made your decision, I would urge to you
18   reflect upon it, perhaps reconsider it.
19            But we are here for any and all
20   other areas, but in all fairness to my
21   clients, after you imposed this condition, I
22   think it is proper that you finish with
23   Patsy Ramsey before you do John Ramsey.  And
24   if you are unwilling to do that, then
25   unfortunately your decision will end this
0263
 1   day.  So I will ask John to step out.  I
 2   will let Patsy finish.  It's your call.
 3            CHIEF BECKNER:  If you have no
 4   other questions, then you have no other
 5   questions.
 6            MR. WOOD:  If you are willing to
 7   stipulate that you had no further questions
 8   beyond the security and the fibers that we've
 9   already talked about ad nauseam, pardon my
10   language, I think that is probably accurate,
11   then John can go forward, but if you are
12   telling me you have other questions, but for
13   the reasons you've stated you are not going
14   to ask them today, then we are done because
15   I am going to insist that you live up to
16   your demand that Patsy go first and be
17   finished.  I am not going to change my
18   position about my right to defend my clients
19   in what I think is a very clear
20   understanding of what we agreed to do at
21   your request.
22            MR. KANE:  Given what I --
23            MR. WOOD:  It is your call.
24            MR. KANE:  -- said about the
25   parameters that you placed on it, I don't
0264
 1   have any further questions.
 2            MR. LEVIN:  And I am in the same
 3   position.
 4            MR. WOOD:  But you acknowledge,
 5   absent my parameters, you have other areas
 6   for Patsy.
 7            MR. KANE:  Yes.
 8            MR. WOOD:  Well, she's here. 
 9   We'll sit here for you to ask questions.
10            MR. KANE:  Okay.  Well, then let
11   me ask you this, are you going to raise
12   those objections?
13            MR. WOOD:  I am going to continue
14   to make sure that we play by the rules you
15   all established, yes, sir.
16            MR. KANE:  I mean, we are back
17   into the debate.
18            CHIEF BECKNER:  Now that is not
19   fair if you say, based on those parameters
20   they don't have any further questions.  I
21   don't know how it can be fair then to say,
22   well, go ahead and ask those questions
23   because you have parameters of what you are
24   going to let her answer.
25            MR. WOOD:  I have not.  That is
0265
 1   not true.  The only thing that I have told
 2   you that we will not answer today are the
 3   issues of the fiber based on what I think
 4   are potentially mischaracterizations of
 5   laboratory results that I would like to have
 6   verified just by the result itself so that
 7   we could then know exactly what facts we are
 8   testifying to as opposed to speculation on
 9   issues that may be hypothetical and not based
10   in fact.  And that's it.  You won't find
11   where I've instructed her not to answer
12   another question.
13            So she is here.  We are prepared
14   to go forward.  You all insisted that there
15   was some mystical, magical reason that she
16   had to be finished before John could done,
17   and if you didn't finish her you didn't want
18   John.  You either are going to do what you
19   said you're going to do, gentlemen, or we
20   are done.
21            CHIEF BECKNER:  I don't know
22   where we ever said that.
23            MR. WOOD:  Let me just say 
24   this --
25            MR. WOOD:  You said it was a
0266
 1   deal breaker, Patsy would go first or you
 2   wouldn't take John --
 3            MR. KANE:  This is a just a
 4   tennis game.
 5            MR. WOOD:  We assumed you 
 6   wanted --
 7            CHIEF BECKNER:  You assumed, but
 8   you are stating as though there were some
 9   statement somebody said that --
10            MR. WOOD:  Were you telling me
11   you just wanted to start with her but not
12   finish before you started John?
13            CHIEF BECKNER:  I didn't say
14   that.
15            MR. WOOD:  Don't you think it is
16   a reasonable assumption, when you insist on
17   her going first, that I would have assumed
18   you were going to finish her before you did
19   John?
20            CHIEF BECKNER:  Not necessarily.
21            MR. WOOD:  Well, you changed --
22            CHIEF BECKNER:  -- ask her some
23   additional questions.
24            MR. WOOD:  You can have John and
25   Patsy back in an ongoing dialogue if we
0267
 1   weren't involved in this kind of stuff.  But
 2   this stuff is not going to be productive. 
 3   It is unfortunate, but as they say, it --
 4   look, I do not believe that I ever agreed or
 5   you requested that Patsy start, not finish,
 6   John come back, Patsy come back.  I don't
 7   think it ever was going to be a ping pong
 8   match with these people coming back and
 9   forth.  
10            I thought it was clear you wanted
11   her first or you wouldn't talk to either
12   one.  I think it was a reasonable assumption
13   on my part that meant you would finish her
14   back to back as you called it, and then we
15   would move on with John.  
16            Now you're telling me that's not
17   necessarily the case, then I really am
18   concerned about whether we can agree on
19   anything in terms of what you mean when you
20   talk plain and simple English.  That is not
21   meant to be defensive.
22            CHIEF BECKNER:  You said it was a
23   condition.  That was never a condition.
24            MR. WOOD:  It wasn't.  It was an
25   assumption on my part, when you said you
0268
 1   wanted Patsy first, that we would finish her
 2   and go back to back with John.  I don't
 3   think it was an unreasonable assumption on my
 4   part.
 5            But the point is, she is here,
 6   you have got, as you say, Mr. Kane, a murder
 7   you want to try to solve.  You've all
 8   represented that you need to ask her
 9   questions.  She may not be able to answer
10   all of them because I may feel like that
11   there are areas where I am not comfortable,
12   for legitimate reasons in my mind, we may
13   not reach agreement on the legitimacy of
14   those.  I am comfortable with what I have
15   done so far.  If you don't want the other
16   part, then just say so.
17            MR. KANE:  I am not going to say
18   a word, Mr. Wood, because every time I say a
19   word, I hear a ten-minute speech.
20            MR. WOOD:  Well, then I think
21   your characterization shows your lack of
22   objectivity.  Do you want to ask questions
23   or not?  Let's go.  If you want to ask
24   them, ask the next question.
25            MR. KANE:  Is Mr. Ramsey going to
0269
 1   step out? 
 2            MR. WOOD:  All right.  
 3            (Mr. Ramsey leaves the room. ) 
 4            MR. WOOD:  Ready to go?
 5            MR. KANE:  I am ready.
 6     Q.     (By Mr. Kane)  Mrs. Ramsey, the
 7   last question I asked you was, you had this
 8   concern about Burke and this killer and the
 9   potential that he could be harmed, and in
10   spite of concerns by your security people,
11   you had him transported to and from the
12   school by Susan Stein.  Did Ms. Stein have
13   any kind of training in self-defense, to your
14   knowledge?
15     A.     I don't know.
16     Q.     Does she have any kind of
17   training in taking evasive maneuvers if
18   someone were to try to get into her car at
19   a stop sign or anything like that?
20     A.     I don't know if she had any
21   formal training in that.
22     Q.     Was there a discussion, when you
23   talked about security issues with either
24   Tracy Temple or with Ellis Armistead, were
25   you privy to discussions about the potential
0270
 1   for harm to come to Burke while being
 2   transported to or from school?
 3     A.     No.
 4     Q.     And in your recollection, that
 5   never came up as an issue?  Is that what
 6   you are saying?
 7     A.     No.
 8     Q.     No, it didn't come up or --
 9     A.     I was unaware if it ever came up.
10     Q.     Okay.  When I asked you about
11   what it was that you had in mind in setting
12   up a security system, I take it that you
13   thought somebody could come into the school
14   and do harm to Burke inside the school; is
15   that correct?
16     A.     Correct.
17     Q.     Okay.  The --
18     A.     That's inconclusive of media as
19   well.
20     Q.     Oh, okay.  But was it more media
21   than the killer?
22     A.     Well, it was all of those.  You
23   know, the media would alert -- their presence
24   there would alert everyone that Burke was at
25   the school, so I wasn't crazy about them
0271
 1   hanging around the school.  Of course, the
 2   killer was still out there; although, we had
 3   been advised that he probably would not, you
 4   know, come out because now everybody is
 5   alerted and looking for him.
 6            You know, and then there is what
 7   they call copy cat people, you know, who
 8   want to get a piece of the publicity, and
 9   they would be lurking around. 
10     Q.     And who was it who gave you this
11   advice that the killer would probably not
12   want to come back?
13     A.     John Douglas.
14     Q.     Okay.  And did Mr. Douglas tell
15   you that -- or what did he tell you?
16     A.     Well, he said we had to be aware
17   of three situations.  One, obviously the
18   killer was at large; two, what you call a
19   copy cat killer, somebody that says, oh, that
20   looks like an interesting idea, I think I
21   will try to do the same thing; and, three,
22   what he termed vigilante perpetrators or
23   whatever term you want to use for them.  You
24   know, somebody that says, oh, you know, the
25   police aren't taking care of this, I will
0272
 1   take care of it.
 2            In other words, just alerting us
 3   that there are a lot of crazy people out
 4   there.
 5     Q.     And the first, so the first
 6   concern he said was that it was probably
 7   unlikely that the killer would come back, the
 8   person that perpetrated the crime; is that
 9   what he said?
10     A.     He said it was very unlikely.
11     Q.     Okay.  But how about the copy cat
12   killer, what kind of opinion did he offer
13   about the potential for that?
14     A.     He said it was very great. 
15     Q.     And this would be somebody who
16   would try to pattern what had already
17   happened to JonBenet, to do the same thing
18   to Burke?
19     A.     Uh-huh (affirmative).  Right.
20            MR. LEVIN:  Can I interrupt you
21   just a second, Mike?  I am sorry.
22            MR. KANE:  Yes.
23     Q.     (By Mr. Levin)  Mrs. Ramsey, as I
24   understand it, at this point in time, which
25   would be early 1997, your belief was that
0273
 1   the murder of your daughter was an act of
 2   retaliation for some unknown reason towards
 3   either you or your husband?
 4     A.     Right.
 5     Q.     You no longer hold that belief;
 6   correct?
 7     A.     Not necessarily.
 8     Q.     I was under the impression that,
 9   in your book, you stated you thought it was
10   a pedophile.
11     A.     Well, it could be one in the
12   same.
13     Q.     I see.
14            MR. LEVIN:  Thank you, ma'am.
15     Q.     (By Mr. Kane)  In the third, the
16   vigilante, what was Mr. Douglas' opinion
17   about the probability or possibility about
18   somebody feeling that the authorities weren't
19   getting to the bottom of this so that they
20   would do harm? 
21     A.     Uh-huh (indicating affirmatively).
22     Q.     What was his opinion about how
23   strong of a threat that was?
24     A.     He just thought it was very
25   strong because, in his years of experience,
0274
 1   there are lots of those kinds of strange
 2   people out there.
 3     Q.     Did he talk to you about where
 4   your copy cat killer or vigilante might
 5   strike and where you should be careful?
 6     A.     No.
 7     Q.     But you thought that school was
 8   certainly one of the places that a person
 9   could come in?
10     A.     Well, since that's where Burke
11   spent the greatest part of his day.
12     Q.     Okay.  
13     A.     You know, I'm the mother of a
14   murdered child.  I was fearful, just fearful
15   of everything.  Most particularly about my
16   child, my husband, and myself.
17     Q.     Okay.  And, I mean, did you have
18   discussions either with Mr. Douglas or with
19   Ellis Armistead or any of the other security
20   people that you had, had you had discussions
21   with them about how somebody might pose a
22   threat to Burke while he was in school?
23     A.     Not specifically.
24     Q.     Did you have any kind of security
25   on Burke outside of school?
0275
 1     A.     Well, he was with us all the
 2   time.  You know, he was pretty much in a
 3   protected environment other than the time he
 4   was in school.
 5     Q.     When you say a protected
 6   environment, other than the fact that his
 7   parents were there, was there any protection
 8   afforded to him outside of school?  You
 9   hired Tracy Temple, obviously, who was a
10   trained martial arts person, I believe.
11     A.     Yeah.  Well, we had, you know,
12   for many days, we had security people, you
13   know, with us at the homes where we were
14   staying for quite some time.
15     Q.     Where, which homes?
16     A.     Jay Olowski's.  I know we had
17   somebody there then.  And I believe there
18   might have been someone when we were at Mike
19   Bienam's house.
20     Q.     Who were these people?  Who were
21   the security people?
22     A.     Somebody Ellis's group sent.
23     Q.     So Ellis Armistead hired somebody
24   to be at Jay Olowski's house?
25     A.     Yes.
0276
 1     Q.     Did they stay in the house or
 2   outside the house?
 3     A.     Inside.
 4     Q.     Inside the house?
 5     A.     Mostly at night. 
 6     Q.     And you moved into Mike Bienam's
 7   house at some point?
 8     A.     Uh-huh (affirmative).
 9     Q.     Was that after Jay Olowski?
10     A.     No.  That was before.
11     Q.     Okay.  And then how about the
12   Stein's, did you have anybody there?
13     A.     I can't remember.  I don't think
14   we did as much.  We may have for a few
15   days when we first got there.
16     Q.     The people, the security people
17   that were hired while you were at Mike
18   Bienam's, let me -- how long did you stay at
19   Bienam's after?
20     A.     My memory is real fuzzy with
21   those days, but -- I can't remember that.  A
22   few days.  Maybe a week or something.
23     Q.     And then you went to Jay
24   Olowski's?
25     A.     Right.
0277
 1     Q.     And you were there for a month or
 2   so?
 3     A.     A couple of months, right.
 4     Q.     And then you went to the Stein's?
 5     A.     Right.
 6     Q.     And this person or these people,
 7   how many -- was it one person that you had
 8   as security at Jay Olowski's or was it a
 9   series of people?
10     A.     It might be different people.
11     Q.     Was this 24 hour a day coverage?
12     A.     No.  It was mostly at night.
13     Q.     And you say they were inside? 
14   They were hired to be inside the house?
15     A.     Yes.
16     Q.     For the whole time that you
17   stayed at Jay Olowski's house?
18     A.     I don't remember.  I don't know
19   if it was the whole time.
20     Q.     Did these people -- this security,
21   you don't remember who it was?
22     A.     No.
23     Q.     Did they have any -- did you
24   discuss with them transporting Burke to
25   school?
0278
 1     A.     No.
 2     Q.     Did you discuss with anybody
 3   having a professional security person
 4   transport Burke to school?
 5     A.     I don't know.  John may have.  I
 6   don't know.
 7     Q.     How about you, though?  You were
 8   involved in discussions with the school and
 9   with the school district and with the
10   principal, I believe, is that correct, about
11   security arrangements while Burke was in
12   school?
13     A.     I think so, yes.  I mean, part
14   of the concern was I wanted him protected,
15   but at the same time I didn't want him made
16   paranoid, you know.  And he didn't want -- I
17   didn't want him -- he didn't like Tracy
18   Temple being there.  He said, mom, why is
19   this woman watching me all the time, and he
20   knew the kids knew that she was watching.
21            And so I am trying to walk a
22   fine line to keep me happy and peace of mind
23   about the security of my child, at the same
24   time not making him overly paranoid.  So
25   the, you know, the best situation that we
0279
 1   could come up with that was satisfactory to
 2   both John and me was that he would be, you
 3   know, picked up by Susan Stein.  She began
 4   taking him to school when we were at the
 5   Olowski's.  She would take him, and I
 6   believe at that time nobody really knew where
 7   we were.  And he would duck down, you know,
 8   and she would get him to the school and that
 9   kind of thing.
10     Q.     So you made a conscious decision
11   then not to have security --
12     A.     In the transport.
13     Q.     -- because Burke didn't feel
14   comfortable having security; is that what you
15   --
16     A.     Right.  He was, you know, he 
17   was --
18            MR. WOOD:  You are talking about
19   the lady Temple?
20     Q.     (By Mr. Kane)  No.  You said
21   that --
22     A.     Well, Susan, you know -- see, we
23   were -- the objective was to try to give him
24   as much normalcy as possible, but at the
25   same time putting, you know, security,
0280
 1   security measures in place that would, you
 2   know, ensure his security.
 3     Q.     Why was the decision made to have
 4   the security inside the classroom versus to
 5   and from school?
 6     A.     Well, because -- and she -- I
 7   don't believe Tracy was inside the classroom. 
 8   I think she was standing in the hall like
 9   near close to the front doors so she could
10   kind of be watching doors.
11     Q.     Well, inside the school proper.
12     A.     Yeah.
13     Q.     Why was the decision made, as you
14   said --
15     A.     Well, it was much more of an
16   uncontrolled environment.  I mean, when you
17   go from a locked garage to locked car to,
18   you know, adult escort into the classroom,
19   you know, that's pretty safe.
20     Q.     Is that what was represented to
21   you, was that it was more secure -- it was
22   more unsecure inside the school than it was
23   going to and from school?
24     A.     Yes.
25     Q.     And who represented that to you? 
0281
 1   Who told you that?  I mean, when you say
 2   that, let me ask it this way.  
 3            When you say that was represented
 4   to you, was this represented to you by a
 5   security consultant or Tracy Temple or Ellis
 6   Armistead?
 7     A.     I don't remember.  You know, I
 8   just remember saying that I wanted somebody
 9   at the school watching, you know.  And at
10   first, you know, we put Tracy Temple there,
11   and then, you know, Burke was bothered by
12   her being there, the children didn't know who
13   she was, and the school said, you know, this
14   is kind of becoming disruptive.
15            And I said, well, you know, if
16   there is nobody there, he's coming out.  And
17   then is when Susan and Roxy Walker got
18   together with the principal, I believe, and
19   said, you know, could we set up what they
20   call a Burke watch.  
21            And they had a team of volunteer
22   parents, all of whom I knew, who volunteered
23   around the clock to be right at the door,
24   right outside the door of his fourth grade
25   classroom.
0282
 1            And if he went to the bathroom or
 2   somewhere, somebody would (indicating), you
 3   know, without being right on his back, but
 4   they were watching.
 5     Q.     And what were they expected to do
 6   if somebody came into the school and tried
 7   to harm Burke?
 8     A.     The first thing was to punch that
 9   Lavalier, and call 911 and start screaming.
10     Q.     And then what were they expected
11   to do after doing this, while the 911
12   response came in?
13     A.     I don't know --
14            MR. WOOD:  I don't want to stir
15   this up, but, you know, you guys got all the
16   meat off this chicken you are going to get. 
17   Come on, move on to something else.  I am
18   sitting here listening.  You know, this is
19   just absurd.  This doesn't have anything to
20   do with JonBenet's murder.
21            MR. KANE:  Are you asking her not
22   to answer the question?
23            MR. WOOD:  I am asking you to
24   move on to something productive.  You just
25   beat this one to death, man.  Let's go.
0283
 1            THE WITNESS:  I don't know what
 2   they were supposed to do.  They were
 3   supposed to be there as a pair of eyes on
 4   him and at a, you know, at an arm's length
 5   without disrupting him, necessarily, but
 6   keeping him as safe as possible. 
 7     Q.     (By Mr. Kane)  Well, Mr. Douglas
 8   was brought into the case early, back in
 9   January of 1997, and why was he brought into
10   the case?
11     A.     I --
12            MR. WOOD:  Mr. Kane, you don't
13   really want to ask questions on stuff
14   subsequent to June of 1998, do you?
15            MR. KANE:  I made the record.  I
16   said if the objection is going to be that I
17   can't, then I have no further questions. 
18   And you said go ahead and ask your
19   questions.
20            MR. WOOD:  No.  I told you that
21   I was not going to change my position.  You
22   were either going to do what Chief Beckner
23   asked to be done and we agreed to --
24            CHIEF BECKNER:  Before we go on,
25   time out, time out.
0284
 1            MR. WOOD:  Mr. Kane just wants a
 2   free-for-all.  We didn't come here prepared
 3   to do that.  Maybe we would have done it if
 4   you asked for it.  I don't know.  But this
 5   is not in good faith what you asked me to
 6   do, Chief.
 7            CHIEF BECKNER:  Hang on here.  I
 8   believe the questions you are leading up to
 9   are based on, while it goes back to an event
10   prior to June of 1998, it is based on
11   information from interviews that you got
12   subsequent to June of 1998; isn't that
13   correct.
14            MR. KANE:  Correct.
15            MR. WOOD:  Well, you all can work
16   that out amongst themselves, but asking why
17   they hired John Douglas, I mean, you know,
18   that's just not going to get it, so I am
19   going to ask you to move on to something
20   that is new, a new question based on
21   information developed or evidence since June
22   of 1998.  
23            I'm going to draw the line now
24   with you, and I am going to draw it very
25   firm.  Okay?  
0285
 1            If you want to make a record with
 2   me making that statement, I will be glad to
 3   make it each and every time, and maybe you
 4   will catch a question I will let her answer
 5   and maybe you won't.
 6     Q.     (By Mr. Kane)  Did John Douglas
 7   interview you?
 8     A.     Yes.
 9     Q.     Did he interview you individually?
10     A.     Individually?  You mean like
11   without anybody else in the room?
12     Q.     Well, when I say individually,
13   without Mr. Ramsey being present.
14     A.     I believe so. 
15     Q.     That's your recollection?
16     A.     Yes.  I can't remember exactly. 
17   I mean, we have been with him, you know,
18   more than once.  So --
19     Q.     I am talking about back in
20   January of 1997.
21            MR. WOOD:  Did you know that 
22   Mr. Douglas had been involved in January of
23   1997?
24            MR. KANE:  I knew he was, but I
25   was never given access to him until probably
0286
 1   January of 1999.
 2            MR. WOOD:  Is that --
 3            MR. KANE:  I never got access to
 4   him until January of 1999.  I asked.
 5            CHIEF BECKNER:  So that's new
 6   information.
 7            MR. WOOD:  What is new
 8   information, that he got access to him in
 9   January of 1999?
10            MR. KANE:  I got to ask him
11   questions in January of 1999.
12            MR. WOOD:  What does that have to
13   do with asking her questions?
14            MR. KANE:  Here we go again. 
15   Okay.  Let's move on.  I don't want to sit
16   and debate this all day.  I'll move on and
17   note your objection.
18            MR. WOOD:  Thank you.
19     Q.     (By Mr. Kane)  Okay.  The
20   JonBenet Ramsey Foundation, is that still in
21   existence? 
22     A.     Yes.
23     Q.     Does it have any money in it?
24     A.     A little.
25     Q.     What is the most it has had in
0287
 1   it since it was started?  Do you know?
 2     A.     I don't know.
 3     Q.     Do you have any idea?
 4     A.     Not really.  I don't keep the
 5   books.
 6     Q.     Have you ever looked at the books
 7   of the Foundation or looked at any kind of a
 8   financial statement about it?
 9     A.     I don't know that I have.  I
10   don't think so.
11     Q.     Have you ever conducted any kind
12   of efforts to raise money for the Foundation?
13     A.     No.
14     Q.     Has the Foundation, to your
15   knowledge, ever spent any money on any of
16   the things that the purpose of it, you know,
17   is stated --
18            MR. WOOD:  Other than what she
19   told you about back in June of 1998?
20            MR. KANE:  I never asked anything
21   in June of 1998.
22            MR. WOOD:  Are you representing
23   to me that the Foundation was never discussed
24   in June of 1998?
25            MR. KANE:  I don't know if it
0288
 1   was or not.  I don't think it was.
 2            MR. WOOD:  Why don't you find
 3   that out, and then we will decide whether to
 4   answer it.
 5            THE WITNESS:  I think I --
 6            MR. WOOD:  Wait.  He's going to
 7   find out whether he discussed it or not.  
 8            MR. KANE:  Okay.  Here's 
 9   another --
10            MR. WOOD:  I personally am
11   getting disgusted that we are talking about
12   the finances of the JonBenet Ramsey
13   Foundation when we are supposed to be talking
14   about information about the death of the
15   child.  I just am getting to the point where
16   maybe I had enough.  
17            Do you want to ask something to
18   move this investigation forward or do you
19   want --
20            MR. KANE:  I feel this is moving
21   it forward.
22            MR. WOOD:  I am sure you do,
23   sir.
24            MR. KANE:  You know what, we are
25   the only law enforcement agency that has the
0289
 1   authority to --
 2            MR. WOOD:  You are still a law
 3   enforcement agent?
 4            MR. KANE:  I am under contract
 5   with the Boulder D.A.'s office.
 6            MR. WOOD:  Do you have a copy of
 7   that contract?  
 8            Are you being paid by the hour
 9   for your time here or are you doing it pro
10   bono?
11            MR. KANE:  No.  I'm being paid. 
12   I am being paid to be here.
13     Q.     (By Mr. Kane)  What, to your
14   knowledge, if any, money was spent for any
15   purposes that the Foundation was being set up
16   to advance?
17            MR. WOOD:  This is your last
18   question on the Foundation unless you can
19   relate it to who murdered the child.  I am
20   going to draw the line.
21            THE WITNESS:  There have been
22   gifts donated if that's what you are asking.
23     Q.     (By Mr. Kane)  No, I'm not asking
24   about donations.  I am asking about money
25   going out.
0290
 1     A.     That is what I am saying.  There
 2   have been gifts given to non-profits.
 3     Q.     Do you know what those are?
 4            MR. WOOD:  Didn't I just say that
 5   we need to move on to another subject?  I
 6   think that --
 7            THE WITNESS:  I do know some of
 8   them.
 9            MR. WOOD:  Can you go on to
10   something that will help us figure out who
11   killed the child?
12            MR. KANE:  Lin, how do you, let
13   me ask you then, will you please define --
14            MR. WOOD:  I mean, I'm so
15   disgusted at what you are doing, I am not
16   going to define anything for you, Mr. Kane.
17            MR. KANE:  Well, then I have no
18   idea of whether any questions --
19            MR. WOOD:  I don't think you have
20   any idea what is a relevant question in a
21   murder investigation. 
22            MR. KANE:  Now you're --
23            MR. WOOD:   I just think I'm
24   just tired.
25            MR. KANE:  I think you are right.
0291
 1            MR. WOOD:  It's been a long day
 2   and I've had to listen to a lot of back and
 3   forth.  It's five minutes to 5:00.  Maybe
 4   I'm just wearing down.  But, you know, why
 5   don't we just close it up --
 6            CHIEF BECKNER:  Just keep going.
 7            MR. WOOD:  Why don't we close it
 8   down for the day.  5:00 was my kind of cut
 9   off time anyway.  I don't know about you
10   all, but I am pretty tired.
11            MR. KANE:  I can go on all
12   night.
13            MR. WOOD:  Mr. Kane, that 
14   doesn't -- I don't want to -- you may be
15   Superman, but I'm not.
16            MR. KANE:  So are you saying you
17   want to stop it?  Obviously --
18            MR. WOOD:  No, I mean, I'm 
19   just -- 
20            MR. KANE:  Well, then tell me, do
21   you want to stop it or keep going?
22            MR. WOOD:  My goal coming in was
23   to go to 5:00, and it's five minutes to
24   5:00. 
25            MR. KANE:  Okay.  Five more
0292
 1   minutes.
 2     Q.     (By Mr. Kane)  All right.  Since
 3   I can't ask my questions about the
 4   Foundation, I'll move on to something else.
 5            When you said in your book and
 6   you said recently in interviews that the
 7   reason, I don't know the specific page, but
 8   let me ask you.
 9            MR. WOOD:  Let's try to find one.
10     Q.     (By Mr. Kane)  The reason that
11   you went on CNN in January of 1997 was
12   because Fleet White insisted --
13            MR. WOOD:  Let's find that now.
14            MR. KANE:  I mean, is it --
15            MR. WOOD:  No, no, Patsy, please
16   wait.  You've got something in the book or
17   some interview, please let us see it, put it
18   in context.
19     Q.     (By Mr. Kane)  Let me ask you
20   this way, did you say that in your book?
21            MR. WOOD:  No.  You already
22   represented it's in the book and you're
23   coming from there.  So let's just find it in
24   the book and let her look at it in context.
25            MR. KANE:  Okay.  I will find
0293
 1   it.  I will find it.
 2            MS. HARMER:  It is around 45, 44. 
 3   Around 45, 44.
 4            MR. KANE:  Thank you.
 5     Q.     (By Mr. Kane)  All right.  Mr.
 6   Ramsey's statement on page 43.
 7            MR. WOOD:  Hold on.  We found
 8   it.  Let me just take a look at it.  
 9            Okay.  We are with you.
10     Q.     (By Mr. Kane) This was obviously
11   Mr. Ramsey stating this in the book, the
12   last paragraph on page 43, but was that your
13   understanding too?  Is that why you went to
14   see him, partially because Fleet had
15   insisted?
16     A.     That was a large part of it.
17     Q.     Okay.  Now, that was January the
18   1st of 1997; is that correct?  It was the
19   day after the funeral.
20     A.     Was it?  Okay.  I don't remember
21   what day it was.
22     Q.     All right.  And this, you
23   described, in that same chapter, that same
24   page, about confrontations you had with
25   Fleet.
0294
 1            MR. WOOD:  What page are you
 2   talking about now?
 3            MR. KANE:  This whole, that's the
 4   whole chapter.
 5            MR. WOOD:  The chapter Facing the
 6   Cameras?
 7            MR. KANE:  Yes.  I mean, the two
 8   paragraphs before that, after Fleet arrived
 9   in Atlanta, he kept arguing that we didn't
10   need lawyers to defend us.  The solution was
11   to go on national television and tell our
12   story.
13            MR. WOOD:  Okay.  
14            MR. KANE:  There is a point in
15   here, and if you are going to make me tell
16   you the exact spot, I will find it for 
17   you where you say.
18            MR. WOOD:  We want to be fair.
19            MR. KANE:  -- Fleet got into --
20   or you got a phone call from Mr. Ramsey's
21   brother Jeff.
22            MR. WOOD:  What page are you on?
23            MR. KANE:  I don't have the page.
24            MR. WOOD:  Well, you have to --
25            MR. KANE:  All right.  All right. 
0295
 1   I am not going to ask the question.
 2            MR. WOOD:  I don't mind her
 3   answering if you just help us.
 4            THE WITNESS:  Well, I mean, I
 5   remember --
 6     Q.     (By Mr. Kane)  You remember the
 7   whole thing?  Okay, outside of the book --
 8            MR. WOOD:  I want to put it 
 9   in --
10            MR. KANE:  All right.  I'll close
11   the book.  I won't --
12            MR. WOOD:  I do want to see what
13   you're talking about in the book.
14            THE WITNESS:  There is someplace
15   where John talks about with you know 
16   Fleet --
17            MR. WOOD:  Jane, do you know?
18            MS. HARMER:  I believe she made a
19   statement today in this interview prior about
20   this situation.
21            MR. KANE:  There have been a
22   bunch of statements.  I am not going to
23   quote the book.
24            MR. WOOD:  But you started the
25   book and you leave it dangling about the
0296
 1   book, and I want you to help me find in the
 2   book what you're talking about.
 3            MR. KANE:  It is my question
 4   though.  It is my question.
 5            MR. WOOD:  And it's not my
 6   witness.
 7            MR. KANE:  I am withdrawing that
 8   part of the --
 9     Q.     (By Mr. Kane)  Isn't it not true, 
10   Mrs. Ramsey, that Fleet White, according to
11   John's brother, that Fleet and he got into
12   some kind of argument and you got a phone
13   call at your mother's house that Fleet was
14   on his way over?
15            MR. WOOD:  Hold on.  The reason
16   I am asking for the book here is you all
17   asked about that, haven't you?  And I
18   thought we were going to have some new
19   information in the book that would go back
20   over that.
21            MR. KANE:  It is repeated in the
22   book.
23            MR. WOOD:  Then what is the new
24   information?  I mean, what's the point of
25   having her restate it?
0297
 1            MR. KANE:  Are you saying we are
 2   quitting at 5:00?
 3            MR. WOOD:  I know I am pretty
 4   tired.  I know you are not.  Guys, what
 5   time is it, what's Colorado time right now?
 6            CHIEF BECKNER:  3:00.
 7            MR. WOOD:  Well, no wonder I am
 8   the only one tired.  I am in Georgia time.
 9            MR. KANE:  I live in the east.
10            MR. WOOD:  You already told me
11   you can go all night.  I already told you I
12   can't keep up with that.
13            CHIEF BECKNER:  How much more do
14   we have?
15            MR. KANE:  Lots and lots of
16   stuff.
17            MR. WOOD:  Well, we might as well
18   come back.
19            CHIEF BECKNER:  Do you have an
20   accurate --
21            MR. WOOD:  Let's kick it off
22   tomorrow at 9:00.
23            MR. LEVIN:  Your clients will
24   both be available tomorrow?
25            MR. WOOD:  That was our
0298
 1   agreement.  We will live up to our
 2   agreement.
 3            MR. KANE:  Okay.
 4            (Whereupon, the videotaped
 5   interview of PATSY RAMSEY was continued to
 6   August 29, 2000.)
 7   .
 8   .
 9   .
10   .
11   .
12   .
13   .
14   .
15   .
16   .
17   .
18   .
19   .
20   .
21   .
22   .
23   .
24   .
25   .
0299
 1   STATE OF GEORGIA:
 2   COUNTY OF FULTON:
 3     I hereby certify that the foregoing
 4   transcript was reported, as stated in the
 5   caption, and the questions and answers
 6   thereto were reduced to typewriting under my
 7   direction; that the foregoing pages represent
 8   a true, complete, and correct transcript of
 9   the evidence given upon said hearing, and I
10   further certify that I am not of kin or
11   counsel to the parties in the case; am not
12   in the employ of counsel for any of said
13   parties; nor am I in anywise interested in
14   the result of said case.
15   .
16   .
17   
18          ALEXANDER J. GALLO, CCR-B-1332
19          My commission expires on the
20          17th day of March, 2001.
21   .
22   .
23   .
24   .
25   .