A. Are we talking about Patsy's tablets?

Q. Seventeen through 25 of the tablet that was given to the police that morning by John Ramsey
because it contained handwriting by Patsy.

A. Seventeen through 25 I believe remained unaccounted for.

A. I have heard that.

Q. Did you ever check to see if that were true?

A. I think I was told that it was some sort of card.

Q. From Bill McReynolds?

A. Yes.

Q. Was it ever fingerprinted, do you know?

A. Detective Trujillo would know that. I don't.

Q. Did you ever try to find out?

A. No.

Q. Did you ever try to find out what the card said?

A. I recall at one time. I don't now.

A. I don't know. A blunt object. I don't believe, at least during the time I was involved in the
investigation, it was identified.

Q. Were there any forensic tests conducted to determine the force one would have to exert on her
head to create a fracture of the magnitude found on autopsy?

A. Are we talking like torque and foot pound pressure, that sort of thing?

Q. You're the expert it sounds like, yeah, sure.

A. I'm not. But I'm not familiar with any tests like that.

Q. There apparently could have been some I take it?

A. I don't know that.

Q. Did you all get any experts involved, consultants involved in the Boulder Police Department to
look into that issue?

A. Dr. Spitz in Michigan did some testing.

Q. Anyone besides Dr. Spitz?

A. Not that I'm aware of. But Dr. Spitz' testing was trying to determine potential blunt object
instruments that may have caused that injury.

Q. Not the force or torque or foot pound pressure?

A. Correct.

MR. DIAMOND: Where are you looking?

Q. (BY MR. WOOD) The first paragraph next to the last sentence "The only danger to" John --
"Patsy and John Ramsey when they put on their dog and pony shows did not come from the
interviewers but from themselves." What are you referring to when you -- that you're describing as
their dog and pony shows?

A. My opinion some of these appearances.

Q. What appearances?

A. For example, May 1 of 1997.

Q. What other appearances?

A. I don't know; I would have to review their appearances, Mr. Wood.

Q. You said arranging an interview with the news organization was a tactic they would use
repeatedly in coming years. How many times did they from your understanding use that what you call
a tactic before the publication of their book?

A. I don't think I make that distinction, do I, before or after the publication of their book?

Q. So you were out doing the same thing I guess when you were giving your round of media
interviews in connection with the publication of your book; was that a dog and pony show by you?

A. They have certainly said worse about me than a dog and pony show.

Q. Would you agree you were in the dog and pony show business, too, then since that's the way you
describe their interviews?

A. No. I don't describe mine as dog and pony shows but I have an opinion about what I talk about
here.

A. I believe so.

Q. That was the Aisenberg case, wasn't it, Mr. Thomas?

A. That is the case that is being referred to here, yes.

Q. Right. You understand that charge was dismissed against the family because the transcripts of
the tapes were not consistent with the representations made as to the content by the police?

A. I'm not familiar with that.

Q. You hadn't tried to study what happened to the Aisenberg case at all?

A. No, as we sit here today I don't know the conclusion of the Aisenberg case.

Q. I would suggest it would be interesting for you to look into it in your spare time.

A. Is that a question?

Q. Yes. Clearly you're going to tell me that they thoroughly investigated, the Boulder Police
Department thoroughly investigated John Ramsey and Patsy Ramsey?

MR. DIAMOND: How do you know what he is going to tell you unless you ask him?

MR. WOOD: I just did.

MR. DIAMOND: No.

MR. WOOD: If he wants to disagree with me he can.

MR. DIAMOND: You asked him whether --

MR. WOOD: I'm not asking you.

Q. (BY MR. WOOD) Will you answer my question? Did you understand? I will be glad to make it
clear.

MR. DIAMOND: Why don't you ask him non- argumentative questions.

MR. WOOD: Why don't you ask him questions --

MR. DIAMOND: Objection.

MR. WOOD: -- when you want to.

MR. DIAMOND: Objection. Argumentative.

Q. (BY MR. WOOD) Are you going to answer my question?

MR. DIAMOND: If you can answer that question.

A. It was phrased as a statement but I think I understand the question.

Q. (BY MR. WOOD) Thank you.

A. Given the God almighty obstacles that we were up against, we tried to investigate them as
thoroughly as we could as paper tigers.

Q. When you were under threat of lawsuit, the first thing you did was hired a PR person, Sherill
Wisinhunt (sic) and you hired lawyers, right?

A. No, I didn't hire Sherill Whisenand.

Q. Whisenand, I'm sorry.

A. She was a friend of mine long before this who agreed to take these calls for me and, having been
charged with something and as a defendant in a case, I thought it was necessarily prudent to retain an
attorney.

A. Was there any test that would establish that?

Q. Did you all to your knowledge, did the Boulder Police Department conduct any test that would
establish that the duct tape that was pulled off of her mouth by John Ramsey that was then picked up
by Fleet White was found somehow to contain a perfect set of JonBenet's lip prints, was any test
performed that made that finding?

A. There was an examination apparently done at some point which was reported back to a detective
briefing at which I was present and I believe that was Wickman or Trujillo that shared that information.

Q. Who conducted that examination?

A. I don't know.

Q. Was it an expert of some type?

A. I don't know that there is such a thing as an expert examination and there is no testing that I'm
aware of. I think that's more common sense observation.

A. We never found the roll of duct tape to source to the duct tape that was covering the victim's
mouth.

Q. And you didn't find any prior application of this type of duct tape in the house, did you?

A. Similar, but I don't know that we ever found a match.

Q. Actually what you said was similar was just one piece that was found on a painting, right, and it
was found not to be in fact from the same --

A. Roll, that's right.

Q. -- from the roll; is that right?

A. Right.

A. You know, I'm not going to say that as I sit here today. I would have to review --

Q. Forget that, don't worry about that. Did you ever find any cord in the house from which the
garrote or the rope that tied her hands together was from? Did you ever find that?

A. No. As far as I know, the cord used on the victim was never sourced to anything in the house.

MR. DIAMOND: If this is a good point, before you change subjects?

MR. WOOD: Let me see how much time I've got. Let me see.

MR. RAWLS: You have something about one ten left.

MR. WOOD: Give me about two minutes, let me just run through a couple other things real quick.

MR. DIAMOND: You have an hour.

MR. DIAMOND: There's one hour left.

MR. WOOD: I do hope you'll give me some consideration on a little extension if we can finish up and I
don't have to take it up with the court.

Q. (BY MR. WOOD) The garrote was made out of a paint brush that was believed to be a paint
brush in a paint tray down in the basement, right?

A. That's my understanding.

Q. And there was the tip end with the brush found in the paint tray, right?

A. No, it's my understanding the brush end --

Q. The brush end was found, the tip end was broken off and never found, right?

A. Yeah, it's my understanding that the handled shaft was fashioned into the garrote handle. And
Lou Smit told me that there was a missing piece that has been unaccounted for.

Q. Did you ever find any evidence to dispute what Mr. Smit told you in that regard?

A. No.

A. If we're talking about pages 17 through 25, if memory serves, yes, those were unaccounted for.

Q. And there was some bleed-through on what has been referred to as the practice ransom note,
right?

A. Correct.

Q. Was there any bleed through on what -- on the ransom note itself?

A. Well, 17 through 25 missing, 26 with bleed-through on it presumably from 25. And if memory
serves, 27 started the ransom note so you had some, I think, bleed-through from the practice note.

Q. The practice note consisted of Mr. -- why don't you tell me what was on the ransom note, the
practice ransom note, as has been described?

A. I believe that said Mr. And Mrs., the what looked like the down stroke of an R which could have
been mistaken for an I.

Q. Did any of the examiners compare that handwriting to the ransom note or was that simply not
sufficient to draw any conclusions about the commonality of authorship?

A. I believe that the ink was matched.

Q. The what, the ink?

A. The ink from the practice note to the ransom note was matched.

Q. In what way?

A. The same pen wrote the practice note that wrote the ransom note.

Q. There were three pens. Did they determine which of the pens wrote the practice note and the
ransom note?

A. The same pen.

Q. And that was a consistent or was that a finding by forensically of an absolute match between pen
and ink?

A. It's my understanding that the Secret Service matched the ink from practice note to the ransom
note.

Q. Pens were in plain view?

A. You're talking pens plural. I'm talking about the pen that wrote --

Q. The pen, that was in a -- it was in plain view?

A. In a cup in the kitchen is my understanding.

Q. Pad was in plain view, given voluntarily by John Ramsey to the police?

A. I don't know about plain view, I wasn't there. But it's my understanding that he produced that
from a countertop area on the first floor.

MR. WOOD: Why don't we take that break now.

VIDEO TECHNICIAN: The time is 4:47. We're going off the record.

(Recess taken from 4:47 p.m. to 4:57 p.m.)

A. That wasn't my conclusion. I think it was Lou Smit that brought that to the attention of several,
and I don't know that those were verbatim quotes that matched the ransom note.

Q. Were you familiar -- well, was that investigated by the Boulder Police Department in terms of
trying to find out from movie rental records whether the Ramseys had ever seen those movies?

A. Unfortunately, one of the obstacles we ran into with movie rental records was after the Thomas
Hill, Anita, I can't remember her last name, hearings. Movie records are very, very restricted and
without warrants or subpoenas or something above and beyond, we couldn't just go to the video store
and check rental history.

Q. Didn't the Ramseys give you almost 100 releases to get information?

A. I believe after I left.

Q. But nonetheless, you believe they did that?

A. I have heard, I think even you say that after -- or at a point in time after which I left the
investigation, I was of the impression that after Kane came on board, they gave a number of consent
releases.

Q. They also provided a considerable amount of historical writings from Patsy Ramsey, didn't they,
in addition to the five exemplars?

A. I don't know if those were -- if those were seized by crime scene search warrant or if those were
surrendered.

Strange.
Okay now.
We know that the pad did not have pages that contained sequentially printed numbers, such as a forensic notebook would have.

The "page numbers" were determined forensically and they probably started with "1" rather than "0" since they are not programmers.

So it is assumed that pages 1-16 exist and contain 'something'.

Pages 17-25 are not on the pad and were removed by persons unknown for reasons unknown.

Page 26 was the "Practice note" found in the trashcan.

Page 27 was the first page of the "Ransom Note".

If page 26 did in fact contain 'bleed through' from page 25 then it should be able to reconstruct some of the writing that was on page 25 which is missing.

Any such reconstructed content of page 25 would aid in identifying when the pad was used.

I simply can not fathom anyone leaving pages 1-16 intact for 'some reason' but removing pages 17-25.

Removal of such pages might indicate prior access to the pad after having obtained access to the home on a prior occasion. I can not understand why the intruder would have removed some of the pages.

MR. DIAMOND: Can I just -- I just want to get the context.

MR. WOOD: Last paragraph.

MR. DIAMOND: I see where it is. I just want to --

A. I missed it; we're on 160 on the bottom of the page?

Q. (BY MR. WOOD) Bottom paragraph, "Then the defense attorneys were allowed inside the
Boulder Police Department to examine the actual ligature and garrote that killed JonBenet." Have I
read that correctly?

A. Yes.

Q. "I watched sick inside, and Sergent Wickman bellowed in protest 'You're giving the fucking
murder weapon to the suspects.'" Have I read that correctly?

A. Yes.

Q. Are those statements true and accurate?

A. Yes.

A. On the record this was per Barb Fernie and I think it included her, Priscilla White and a third
party.

Q. Who was the third party?

A. I don't know.

Q. Were they the same people that had planned to have a talk about it with Patsy after Christmas?

A. That was my understanding and, again, that's on the record with Barb Fernie.

Q. And quote, end quote, mega-JonBenet thing, whose phrase was that?

A. Barb Fernie.

A. No, not now nor did I do it in the book.

A. I don't know who applied that to the computer screen.

Q. Did you think that was professional?

A. Oh, sometimes police humor can be less than professional behind closed doors.

Q. Well, did you suggest it might be better to take that off since you were in the process of
investigation, there were a number of suspects beyond the Ramseys?

A. I did not make that suggestion.

Q. How long did it stay on the computer?

A. I don't know. I recall seeing it a few times over the course of a week or two.

Q. Was it up in 1997?

A. That's when we were over at the DA's war room.

Q. When was that, when was the war room?

A. Summer of 1997.

Q. So that's when it was up, summer of '97, right?

A. Yes.

MR. WOOD: I will represent if you give me 25 minutes, I will be done in terms of my discovery
deposition of Mr. Thomas in the Wolf versus Ramsey case. I can't speak to Darnay, obviously, because
there was the issue, as you recall, about the testimonial deposition that is still in the process, indicated by
Judge Carnes to follow, but I'm done. In other words, I'm not going to go bang on Carnes and say, I
need 15, 20, 30 more minutes.

(Discussion off the record between deponent and Mr. Diamond.)

MR. WOOD: You wouldn't be coming back on my deposition. You would be coming back on Mr.
Hoffman's.

MR. DIAMOND: My understanding of the conference, and I think the record transcript will bear this
out, is that the hour that Mr. Hoffman asked for was his direct testimony for use at trial.

MR. WOOD: No, I disagree with you. I think Judge Carnes was clear I would have a discovery
deposition to be able to cross-examine on a testimonial deposition if Mr. Hoffman chooses to present
him by deposition at a trial or live at trial. Pretty clear. But be that as it may whether I'm right or wrong
--

MR. DIAMOND: I'm just speaking to whether Mr. Hoffman is now complete. And my view --

MR. WOOD: I don't know whether he intends to take a testimonial deposition or not, but there is
nothing that you and I can agree to that would prohibit him from doing so, nor do I think that I can sit
here and agree that I wouldn't come back and take a testimonial deposition. I'm trying to finish the
discovery deposition. I'm asking for, in effect, 15, 10 minutes or 18 minutes more than what I think I'm
entitled to.

MR. DIAMOND: Are you planning on taking a testimonial deposition?

MR. WOOD: I have no way to say that to you right now. I don't think Darnay could say that to you
right now. We're so far away from even knowing whether we'll ever have a testimony. This case
could come up on summary judgment, for gosh sakes, that could make us a year or two away from
even deciding that point, Chuck; isn't that fair?

MR. RAWLS: That's fair.

MR. DIAMOND: Let me consult for a moment. (Discussion off the record between Mr. Diamond
and the deponent.)

MR. DIAMOND: Start.

MR. WOOD: Let's go back on Thank you. I'll get it right here on the money. I'll mark it. You've got
25 minutes of tape left?

VIDEO TECHNICIAN: I have 35 minutes of tape left.

MR. DIAMOND: You get that on the record?

MR. WOOD: We know we've used it up. Nobody can try to sneak more than that extra ten in.

MR. DIAMOND: Just so the record is clear, we're agreeing to your proposal.

MR. WOOD: Thank you very much. I appreciate it. If the opportunity should ever present itself, I
would certainly consider like accommodation and consider more if necessary.

VIDEO TECHNICIAN: The time is 5:58. We're back on the video depo.

A. Like a trap and trace or a wire tap?

Q. An LUD or an Amadump, where you actually go in and get the outgoing calls and the incoming
calls?

A. What that sounds, in the jargon I'm familiar with, Mr. Wood, is in Colorado we would call that like
a trap and trace. But I think it's different because you have to be up on the trap and trace to record
incoming/outgoing, also known as a pen register. But a dump, whereas anything prior -- I'm not
explaining this well.

Q. Let me see if I can help. Was there a mechanism in Boulder that would allow you to go to the
phone company and say I want you to go back and tell me today on the 26th of December all outgoing
and ingoing calls to the Ramsey number for, say, the last two or three days?

A. No.

Q. You had to do it forward, not backward?

A. Right, I'm not familiar with any -- the phone company here having any capability to do that.

Q. Do you know for a fact that they could not?

A. With the exception, and I don't know how detailed you want to get into this, but certainly toll calls,
toll calls you can certainly go back and retrieve.

Q. Long-distance toll calls?

A. Yeah.

Q. Did you all do that with the Ramsey records?

A. I think so.

A. Let me look at 309 real quickly. 308, 309?

Q. It's on 309 and I've got a copy of that press release where he says there were 27 tasks
remaining. I'm just wondering if that's the correlation.

A. Oh, if I understand you correctly, did these 27 reasons correspond with the 27 tasks left on the
to-do list?

Q. Yes.

A. No.

A lot of supposition.

A. I don't.

Q. Or it's 54 percent, I think?

A. I think the statistics that we had at Quantico at that big FBI meeting, they gave us some
statistics. I may have them in the book, but you would have to lead me to them.

Lots of jumping around from this subject to that - - with limited time, it seems they have to do that. Sometimes they come back and fill in- - other times they just don't ask all they might on a subject.

I don't think deposing someone is easy - - have to be sure of the facts you have, know the case well and think quick during the deposition.

A. Yes.

Q. Would you also agree that communities across America should not allow any police officer to
become an emperor and merely interpret the law as he or she sees fit?

MR. DIAMOND: Objection. Argumentative. You may answer.

A. In the context, again, please, Mr. Wood.

Q. (BY MR. WOOD) Yes, just as a statement of principle that communities across America should
not allow any police officer to become an emperor and merely interpret the law as he or she sees fit, it
would apply to politicians and police officers, wouldn't it?

A. Non committal on that.

Q. You don't have a position on the difference between a politician and police officer in terms of
interpreting the law?

A. I'll give it some thought.

Q. Okay.

A. I believe, and I can't definitively, but I believe that was in the summer of 1997.

Q. June, July or August of '97, you believe?

A. As we sit here right now, yeah, I recall that as being the summer of 1997.

If the Ramseys had given this deposition, the BORG would have gone wild - - and Ramsey supporters would have had serious questions.

I can almost hear the vacuum as Thomas supporters are sucking in here....

ST's Angel says she will still support her man. Interesting, but not really a surprise. (I wonder if she will actually read the deposition and deal with the details in discussion or if she will just stand there screaming that he is still her hero.

Doesn't matter - - his own words expose him totally.