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Part 2. Steve Thomas Deposition

VIDEO TECHNICIAN: The time is 9:45. We're back on the record.
Q. (BY MR. WOOD) I'm going to try to make sure I can avoid any problems that Mr. Diamond might have with my question. Let me go back and withdraw the last question and restate it. What I would like to know, Mr. Thomas, is do you have notes pertaining to your involvement in or the investigation of the murder of JonBenet Ramsey?
A. The Boulder Police Department has those notes. I don't know that I have any notes.
Q. You left the Department by resignation of August the 6th, right?
A. Yes.
Q. 1998?
A. Yes.
Q. When did you turn over all of your notes to the Boulder Police Department?
A. Shortly thereafter.
Q. Who did you turn them over to?
A. I returned my briefcases and those contents, along with all my police equipment, which was inventoried, to Commander Dave Hayes and Sergeant Michael Ready.
Q. Did you turn over your case notebooks?
A. Everything.
Q. How many case notebooks did you turn over?
A. What do you mean by case notebooks?
Q. Don't you know what the case notebook was used in this case, sir, filled out by all of the detectives on a daily basis?
MR. DIAMOND: He may ask you for an explanation, what you're referring to. You're not going to help him out?
Q. (BY MR. WOOD) Do you know, sir, what the case notebooks were in this case in terms of the notebooks prepared by the detectives, I believe on a daily basis?
A. A case notebook that was prepared --
Q. Did you have --
A. -- on a daily basis?
Q. Yes. Did you have a notebook that you kept, maintained with respect to your investigation?
A. I had folders and my working papers which I maintained with respect to my parts of the investigation.
MR. DIAMOND: He's asking about a notebook.
THE DEPONENT: Yeah, I know.
Q. (BY MR. WOOD) You didn't have them in any notebook form?
A. No.
Q. Now, those working papers, all of that was turned back into the Boulder Police Department shortly after you resigned in August of 1998?
A. Yes.
Q. You maintained no notebooks; is that right?
A. I maintained copies of those.
Q. So you have copies of your reports?
A. No, I didn't say that. I don't know that I have those copies anymore.
Q. Well, you said you maintained copies. Copies of what?
A. I maintained copies of what was in my working file briefcase which I returned to the Boulder Police Department.
Q. How many pages of documents are we talking about?
A. A couple hundred maybe.
Q. Do you have those presently in your possession, custody or control?
A. No.
A. I don't know.
Q. They just mysteriously disappeared?
A. No, I have moved twice in the interim. We have some things in storage. We, my wife moved overseas. If I still had a cardboard box full of those documents or materials. I'm unaware of their present location.
Q. When do you last recall looking at them or reviewing them? (Discussion off the record between the deponent and Mr. Diamond.)
A. I last looked at those in –
MR. DIAMOND: He has mentioned the first full report that he -- MR. WOOD: Yeah, well, let him answer that.
MR. DIAMOND: Are you excluding that?
MR. WOOD: No, I'm not excluding anything. I want to learn everything.
A. Early 2000.
Q. (BY MR. WOOD) How early 2000?
A. Probably February or March.
Q. That was the last time you saw them?
A. Right.
Q. And when did you move?
A. I moved -- I sold my house this summer, summer of 2001.
Q. And did you pack up your possessions?
A. Yes.
Q. So you don't have any explanation to offer as to what happened to your JonBenet Ramsey working papers since you last claimed to have seen them sometime in February or March of 19' -- of 2000?
A. Yeah, after I last looked at them, this was a cardboard box full of these documents. And to your question, yeah, I don't know where they are currently.
Q. You did not destroy them intentionally, did you?
A. No.
Q. You didn't intentionally lose them, did you?
A. No.
Q. You didn't think they were valuable to keep?
A. No, not necessarily.
Q. When did you -- in terms of that, you did know at some point that the Ramseys indicated they were going to file a lawsuit against you if you published a book, didn't you?
A. Repeat the question, please.
Q. You knew early on when your book was published that the Ramseys had stated that they were going to file a lawsuit against you?
A. I had heard through the media that they had made those threats.
Q. You didn't think it might be wise to keep up with your notes to have those in the event there was a lawsuit?
A. Those are all available in the Boulder Police Department.
Q. So everything that you had, the 200 pages is available from the Boulder Police Department; is that right?
A. Yes, as I said, I turned everything back to the Boulder Police Department.
Q. In fact, there's quotes in your book, for example, of interview testimony from different individuals. For example, there are quotes alleged to have been made by Burke Ramsey in June of 1998, by John Ramsey in June of 1998, by Patsy Ramsey in June of 1998, by John Ramsey in April of 1997, by Patsy Ramsey in April of 1997 during police or district attorney interviews.
MR. DIAMOND: You'll represent that is the case?
Q. (BY MR. WOOD) Yeah, well, that is the case, isn't it; you know that to be true, don't you?
A. That the book contained --
Q. Quotes from the interviews of April 1997 and June of 1998 of John and Patsy Ramsey and from Burke of June of 1998?
A. Yeah, I would agree with that.
Q. I'm just trying to find out, for example, your notes, would they -- would the notes have those quotes in them?
A. What notes are you referring to?
Q. The notes that you can't find now. How would you have quotes –
MR. DIAMOND: I'm going to object.
MR. WOOD: Let me.
MR. DIAMOND: He didn't say he couldn't find them. He said he doesn't know where they are. You haven't asked him whether he's been looking for them recently, have you?
MR. WOOD: Well, I mean, I will ask him that in a minute. Again, Chuck, we'll move quicker if you limit yourself to instructions on privilege.
MR. DIAMOND: Mischaracterizes his testimony in your -- MR. WOOD: That's not an objection on privilege, nonetheless.
Q. (BY MR. WOOD) Mr. Thomas, I'm trying to figure out whether you had notes that would have had these precise quotes in them and that's how you were able to use them to come up with the quotes in your book. Or did you come up with those quotes from their various interviews from your mind's eye, your own recollection only? Do you follow me?
A. Yes.
Q. Which was the case?
A. They were either in notes which I had or in documents I subsequently received.
Q. And what documents did you subsequently receive about the investigation?
A. After I left the police department, over a period of time I received through the mail various documents concerning the investigation.
Q. From whom?
A. Anonymously through the mail.
Q. Postmarked from where?
A. Boulder or Denver.
Q. And were these documents police files or reports on the JonBenet Ramsey investigation?
A. Yes.
Q. Were they documents from the district attorney's office on the JonBenet Ramsey investigation?
A. What do you mean from the district attorney's office?
Q. Well, for example, a report prepared by Michael Kane, as opposed to a report prepared by Mark Beckner. One works for the Boulder PD and one works for the district attorney or did. You know the difference.
A. No, these were Boulder Police Department documents.
Q. And how many pages of documents did you receive subsequent to the time that you left the Boulder Police Department that concerned the JonBenet Ramsey murder investigation?
A. Several hundred.
Q. Where are those documents?
A. Unknown. They would be in the same box if I still have it.
Q. So how many -- let me see if I've got all the sources of written materials that you had after you left the Boulder Police Department on August the 6th, 1998. You had some couple hundred pages of your work papers that you had copied, correct?
A. Correct.
Q. You didn't make copies of police reports?
A. In what context are you talking about?
Q. In this 200 some odd pages of your working papers, were there also copies of police files, police reports on the JonBenet Ramsey investigation?
A. Yes, these were my working papers, yes.
Q. Well, for example, would it only be reports prepared by you or did you have copies of reports prepared by other officers?
A. As I was the affiant on the master affidavit in this case I certainly was in possession of reports from others to include in any search or arrest warrant in this case.
Q. So the answer is yes?
A. To what question?
Q. The one I asked you. Did you have copies of other officers' reports on the JonBenet Ramsey case in your working papers?
A. Yes.
Q. You make reference to being the affiant on the master affidavit. Did your working papers then include copies of all of the documents that you had and had in any way relied on in preparing the master affidavit in the JonBenet Ramsey case?
A. If I understand you correctly, no.
Q. Were you authorized to keep those copies by the Boulder Police Department?
A. When I resigned abruptly, I returned all those papers to the Boulder Police Department and there was no further communication between us.
Q. But did you tell them you had kept copies of the papers?
A. No.
Q. Am I correct that everything you had in your physical possession in terms of case files, case reports, notes, at the time that you resigned, whatever you turned over to the Boulder Police Department at the time of your resignation, you made copies of and kept yourself; is that right?
A. I believe so.
Q. And that was only a couple hundred pages?
A. I believe so, yes.
Q. And did you keep, for example, a transcript of the April 30, 1997 interview that you conducted with Patsy Ramsey?
A. I don't know.
Q. So subsequent to leaving, from what period of time until what period of time were you receiving anonymous police file information on the JonBenet Ramsey case that you say totaled several hundred pages? When did it start and when did you last get something?
A. Initially after I had made my intentions known that I was going to tell my story through a book. And that was probably early, maybe January of 1999 and throughout that calendar year of 1999.
Q. Any materials in the year 2000?
A. Not that I recall.
Q. Did you make any efforts to solicit information from any member of the Boulder Police Department about the investigation after you left?
MR. DIAMOND: May I ask a clarifying question? Solicit written materials or just talking to somebody?
MR. WOOD: Information, case information about the case.
A. Can you repeat the question please?
Q. (BY MR. WOOD) Sure, did you make any efforts to solicit information about the JonBenet murder investigation from any member of the Boulder Police Department after you left the department in August of 1998?
A. No.
Q. Do you have any idea who sent you any of these alleged anonymous documents?
A. These are smart people. No.
Q. How do you know they were accurate if you don't know who sent them to you?
A. Because I had previously seen all of them.
Q. So this was information that was contained in the case file that you didn't copy when you left the force, but it predated your leaving the force; is that true?
A. Yes.
Q. Did you ever receive any information about grand jury testimony or evidence in the case?
A. Never.
Q. Did you ever receive any information about the investigation in terms of efforts and information subsequent to the investigation August 1998? Let me withdraw that and make it a little bit cleaner. I want to know, you tell me the information you got predated your resignation date. Did you ever get any new information, that is to say information that was generated about the case after August of 1998?
A. Without reviewing this box, I would have to say as we sit here now that it was all pre-August '98. I don't recall sitting here that any of it was post-August '98.
Q. So that the documents that you have and the information that you had about the case, your best recollection is that would have been limited to information generated prior to August of 1998, true?
A. Yes.
MR. DIAMOND: Counsel, I see no relevance to this line other than to find out what he knew at the time he wrote the book. I instruct him not to answer. If you want to take this up with the judge, I am happy to do so. If you want to make a record as to why this is relevant to the Wolf case, I'm happy to listen to you. Otherwise, he's instructed not to answer. Move on.
MR. WOOD: Is there a privilege being asserted?
MR. DIAMOND: You heard me, move on.
MR. WOOD: Sir, if you will be polite, we will be polite, also.
MR. DIAMOND: Go ahead. I am happy to be polite.
MR. WOOD: Yes, sir, please do.
Q. (BY MR. WOOD) My question is, I'm trying to find out about your knowledge concerning the JonBenet Ramsey investigation. And it seems from what I am hearing that your knowledge is limited to information about the case from the date of the murder in 1996 through August of 1998. Is that right?
MR. DIAMOND: From police sources is what you have asked him about?
MR. WOOD: My question is on the table, now, sir. We can call Judge Carnes and correct the problem that we're experiencing with you if we need to. I hope we don't need to.
MR. DIAMOND: We may well have to.
MR. WOOD: We certainly may have to if you keep interrupting inappropriately under the Federal Rules of Civil Procedure, procedure for depositions.
Q. (BY MR. WOOD) Could you answer my question, please, Mr. Thomas?
A. Could you repeat it for me, please?
Q. Sure. I'm going to read it right back to you. I'm trying to find out about your knowledge concerning the JonBenet Ramsey investigation. And it seems from what I'm hearing that your knowledge is limited to information about the case from the date of the murder in 1996 through August of 1998; is that right?
A. No, after August of 1998, I certainly followed media accounts and what was released publicly and followed the case with some interest.
Q. Fair enough. Let me add that in. Can I then say in terms of drawing a circle around your knowledge of the JonBenet Ramsey murder investigation, that your knowledge consists of knowledge about the police information and to some extent district attorney information from the date of the murder until the time you left in August of 1998 and subsequent to 1998 has been supplemented by what you have learned either through media accounts or through official statements from the Boulder Police Department or the district attorney's office; is that right?
A. Very confusing question. Can you break that up for me? I don't understand what you --
Q. I just want to find out what you've got. You've got your personal knowledge. You've got the police file information that you described for me, the copies of the documents you copied, the documents that have been sent to you subsequent. And that all dealt, you believe, pre-August 1998, right?
A. I'm not following you, Mr. Wood.
Q. Well, stick with me. I'll try and make it simple for you.
A. Please.
Q. More simple. You've told me about the documents. I've covered all the documents, haven't I? You've got the documents you copied and you've got the documents that were anonymously sent to you, right?
A. Yes, that's correct.
Q. Do you have any other documents about this investigation, other than those documents? Do you?
A. Oh, I'm sorry. If I understand the question correctly, no, as I said, not that I recall because post-August '98 began the grand jury. And certainly I don't have any information from the grand jury room.
Q. So we've got your personal knowledge about your involvement in the case, right?
A. Yes.
Q. We've got your knowledge from the written documents that you've just described for me?
A. Yes.
Q. And then subsequent to August of 1998, your knowledge about the case and its status would be limited to what you have either seen or heard in the media or what may have been officially stated by law enforcement authorities, right?
A. As far as I recall, I don't recall anything, as I have said, post August of 1998 coming my way, but I'm not limiting myself to that, if that answers your question.
Q. As we sit here today, can you think of anything other than that? Is that your best recollection as you sit here today, sir?
A. Yes, as I sit here right now, if I understand this correctly, that's my answer.
Q. And I'm sure that you came to this deposition in an effort to prepare for it and to refresh yourself about the investigation, you knew you were going to be asked about it, didn't you?
A. The question being I know I was going to be asked about the investigation?
Q. Sure.
A. Yes.
Q. JonBenet Ramsey, that was the first murder investigation that you were involved in; is that right?
A. As a detective, yes.
Q. You were involved in a murder investigation in some other capacity?
A. I had been on homicide scenes as a uniformed officer.
Q. But as a detective actively investigating the murder, was JonBenet Ramsey the first murder investigation in that capacity for you?
A. Yes.
Q. Can we also say that it was the only one?
A. No.
Q. So you were involved as a detective in other homicide investigations?
A. Yes.
Q. Tell me about those. How many?
A. One other.
Q. When was that?
A. In 1997, I believe.
Q. Is that the one where the police officer was present when someone shot someone else in a domestic dispute?
A. Yes.
Q. And then the person came down and admitted that he had shot or she had shot their spouse?
A. Yes.
Q. And that was kind of the end all of that case, wasn't it? Pretty open and shut, wouldn't you agree?
A. When you say end all, yes, that concluded rather quickly.
Q. Yeah, I mean as I understand that case, there was a domestic dispute call, the police officer was there and one of the spouses shot the other one and killed them, right?
A. Yes.
Q. And then came down to the police headquarters, and I believe you may have even been the person talking to the perpetrator, and that person admitted to shooting his -- was it his spouse or her spouse?
A. Her spouse.
Q. Her spouse. Anything other than that one case prior to the JonBenet Ramsey murder investigation, did you have any other case where you were involved in a homicide investigation as a detective?
A. No.
Q. Okay. So it was the only other one; JonBenet Ramsey was your last one I'm sure, right?
A. No, the last one was this Jakob-Chien homicide we're describing.
Q. That was the last one, I thought that was in -- oh, I'm sorry, that was in 1997 but your involvement ended in '97. The last one you've been involved in went through '98 and that was JonBenet Ramsey?
A. Right.
Q. From the time you were assigned to the JonBenet Ramsey case up until the time that you left, were you assigned to any other homicide case?
A. Other than the one we noted, no.
Q. And I take it the JonBenet Ramsey case, other than the case that you noted, pretty much was your full-time job; is that right?
A. Yes.
Q. And have you ever had any training, formal training, in handwriting analysis?
A. No.
Q. Have you ever had any formal training in criminal profiling?
A. No.
Q. Other than the 1997 case where you obtained the confession from the spouse who shot her husband while the police officer was present on the premises, and other than the Ramsey case, have you ever conducted any other interrogations of murder suspects or potential suspects?
A. On reported homicides, no, not that I'm aware of.
Q. Would you be willing to authorize us, subject to your counsel's recommendation or right to object if he asked, would you be willing to authorize us to obtain a copy of your Boulder Police Department personnel file?
MR. DIAMOND: You don't have to answer that. If you want to make a request to me, I will respond.

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