Boulder Skies at Dusk

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Part 9. Steve Thomas Deposition

MR. DIAMOND: According to John Ramsey?
Q. (BY MR. WOOD) What the Boulder Police Department concluded. In your -- let me tell you in your description of how JonBenet Ramsey was killed, what was your position about whether Patsy Ramsey was in bed or out of bed that morning when John Ramsey got up?
A. Well, without reviewing multiple transcripts and reports, I don't recall the -- the Ramseys made several inconsistent statements --
Q. About who got up first?
A. If I could finish my answer.
Q. Well, if you could stay on track, it would be helpful. 5
MR. DIAMOND: Finish your answer.
MR. WOOD: Please make it responsive to my question about the issue about who got out of bed first that morning.
MR. DIAMOND: If you find his answer to be non responsive, your remedy, I believe, under the Federal Rules is to move to strike it and I believe that --
MR. WOOD: I appreciate you informing me of the Federal Rules. Now I know that you do know that some of things you're doing is not in accordance with the Federal Rules in terms of your statements on the record.
MR. DIAMOND: I'm only trying to do you a favor. MR. WOOD: Thank you. I don't need your favors, but I appreciate them anyway.
MR. DIAMOND: Is the question withdrawn or can he finish his answer?
MR. WOOD: I want to go back and make sure we're on task by restating it. So I'll withdraw it and restate it.
Q. (BY MR. WOOD) I'm asking you, Mr. Thomas, what was your position in your description of this child's murder as to whether Patsy Ramsey was in bed or out of bed when John Ramsey woke the morning of December 26, 1996?
A. From John Ramsey's account?
Q. I'm asking you, sir, what was your position in your description of this child's murder as to whether Patsy Ramsey was in bed or out of bed when John Ramsey woke the morning of December 26th?
A. I believe I write in my hypothesis that she was out of bed.
Q. She would have to be, wouldn't she? If you believe that John Ramsey, as you say you do, is not in any way involved, you would have to believe a couple of things, that she had not gone to bed when John went to bed, and that when John woke up, she was already -- she was not in bed. And you would have to believe one other thing, wouldn't you, detective, former detective, that John Ramsey didn't hear the scream at midnight, right?
A. You have a series of five phrases and questions --
Q. Let me break them down one at a time. Listen carefully to me. Under your position of the description of this child's murder, John Ramsey did not hear the screams described by Melody Stanton, right?
A. He never indicated, as far as I know, that he heard the scream of a child.
Q. If he was as you say he was, totally uninvolved in the murder of his daughter, he didn't hear the scream, did he, because if he had heard the scream, you would have expected that he would have reacted to it or been certainly willing to tell you about it?
MR. DIAMOND: Objection. Argumentative. You may answer.
Q. (BY MR. WOOD) If he's innocent as you say he is?
MR. DIAMOND: Objection. Argumentative. You may answer.
A. One could speculate that he would have heard a scream from within the house.
Q. (BY MR. WOOD) You will concede that in fact Melody Stanton may be right that 8 the scream occurred and that John Ramsey did not hear it, you would concede that as a possibility supported by your description of the events, right?
A. It is a possibility, yes.
Q. And it is more consistent with your statements about John Ramsey's uninvolvement than it would be consistent with the idea that he was involved; can we agree on that?
A. I don't understand your question.
MR. DIAMOND: I don't either.
Q. (BY MR. WOOD) Do you understand it, just so we make sure?
MR. RAWLS: Got it, I'm on it.
MR. WOOD: Thank you. I kind of figured that nobody on that side of the table would understand it but everybody on this side would.
MR. DIAMOND: Can we ask Sean?
MR. SMITH: I think Sean has already taken his position that he doesn't understand any of my questions. I've dealt with him too long. He's never going to acknowledge that any of them are understandable.
Q. (BY MR. WOOD) When was Steven Pitt hired?
A. I don't know if Pitt came to the investigation through the district attorney's office or through Sergeant Wickman but I recall Mr. -- or Dr. Pitt being on scene or being in Boulder, being involved with the investigation was it summer of 1997 maybe. I don't know for sure.
Q. Was there any plan or strategy on the part of Boulder Police Department or any other law enforcement agencies to try to put pressure on the Ramseys through the public?
A. I think so.
Q. And wasn't that part of what Steven Pitt was there to do?
A. I don't know what his employment agreement or what his motivations were for being there, but he certainly offered advice.
Q. On that issue?
A. Yes.
Q. And isn't it true that Lou Smit's approach to build a bridge with the Ramseys really was in conflict with the Boulder Police Department's strategy of putting public pressure on them?
A. Yes.
Q. And the FBI was involved, Bill Hagmaier, who I happened to know from Richard Jewell's case?
A. Great guy.
Q. Yeah, wrong on Richard Jewell, wrong on Ramsey, that's consistent. Mr. Hagmaier was involved in the formulation of this plan of public pressure on the Ramseys, wasn't he?
A. I believe there were discussions with the FBI, yes, about how to exert some public pressure on people who are not cooperating, yes.
Q. Part of that was to try to portray them clearly to the public as being uncooperative and therefor appearing to be possibly involved in the death of their daughter, right?
A. I think it was two different things. I don't think they were necessarily trying to further paint them as uncooperative. I think they were using the media to get them back in to help us with the case.
Q. Were they also thinking that they might use the media to apply pressure so that there might be a possibility that one of the parents might confess involvement in the crime? Was that ever discussed?
A. That may have been -- that may have been some motivations.
Q. Do you believe from your recollections that that was discussed?
A. I wouldn't disagree with it. I don't have any concise, clear recollection of a conversation like that.
Q. Did you ever review reports of the officers that were with John and Patsy Ramsey on a 24-seven basis from the time of the discovery of JonBenet's murder up until the time they left to go to Atlanta for her burial? Did those officers provide the department with reports?
A. At least some did, yes.
Q. Did those reports contain discussions of the Ramseys' actions, conduct, and just conversations?
A. Yes.
Q. Those officers were there not only to possibly protect the Ramseys; they were there clearly also to have the Ramseys under 24-seven surveillance to ascertain what they might say that might be incriminatory, right?
A. Some of that; most of it was prior to my involvement in the case so I don't know what their instruction was.
Q. What do you believe from your review of the records in terms of the reports that these officers compiled?
A. Certainly 24-seven security but these officers weren't going to ignore any statements or comments by anyone that may be incriminating.
Q. These officers weren't sitting outside the door guarding the house. They were literally, as you know from the reports, they were right there in the room with the Ramseys, right next to them 24-seven, weren't they?
A. I believe so.
Q. Which points a little bit more towards surveillance than guarding them, doesn't it, sir?
A. In your mind maybe; I don't know, I wasn't there.
Q. What about in your mind when you reviewed the reports particularly since you had the benefit of the substance of what these officers were saying?
A. As I said, it's my belief that they were there 24-seven as security but also they certainly weren't going to ignore any statements. You might ask John Eller about that.
Q. Well, if I have the opportunity he and a lot of others I would ask. You don't know who ordered the guards 24-seven, do you, or the surveillance 24-seven, whichever the case may be, or some combination of it?
A. I think John Eller.
Q. And from your review of the reports, do you have a recollection of seeing anything unusual about the family's comments or conduct from these 24-seven police officers who were filing reports about them?
A. Yes, I remember they included in their narrative verbatim quotes made by the Ramseys and others.
Q. Do you recall any of those quotes?
A. I remember, I think it was in Chromiak's report about Patsy and her sisters praying, in another report Patsy making a comment that she didn't want to live anymore, didn't have a reason to live anymore. The comings and goings of the Ramseys, just a general recollection along those lines.
Q. Nothing in that that I'm hearing that sounds incriminatory, wouldn't you agree?
A. Again, without reviewing the reports, that's what comes to me off the top of my mind.
Q. Let me ask you about that. How many cases have you been involved in where you were analyzing the demeanor and conduct of parents who had a child found murdered in their home; what was your experience in that type of a case?
A. None.
Q. Do you have any experience, formal training, in how psychologically or otherwise one expects a parent to grieve when a child has been murdered?
A. No.
Q. You met many times with Fleet White, didn't you?
A. I did.
Q. And it was your responsibility and I'm sure you carried it out in terms of reporting because I think you get the record so far at least as of August of 1998 you had filed more reports than anybody on this case, did you know that?
A. I believe so.
Q. And every time you met with Fleet White either because he was and he was a suspect himself, was he not?
A. Again, that ambiguous suspect label, yes.
Q. And either because he was a suspect as that term is used by the Boulder Police Department or because he was a witness, each and every time you met with him and had discussions with him it was your duty and responsibility to prepare a report about it, true?
A. Not necessarily.
Q. Why not?
A. Well, initially he wasn't my assignment. I think Linda Ardnt shouldered a lot of that. And then after she was removed from the case, Detective Jane Harmer --
Q. I'm not asking about Harmer. I'm asking about you, Mr. Thomas. I don't need to know about Harmer and Arndt. They can answer themselves. I want to know if you made reports on each of your meetings with Mr. White. That's my question. Maybe you didn't understand that one.
MR. WOOD: Despite that interruption, you may continue with your answer.
THE DEPONENT: Thank you.
Q. (BY MR. WOOD) Yeah, answer about your contacts with Mr. White and whether you made reports on each of those or not?
MR. DIAMOND: You asked him why. He was explain' -- answering the why question.
MR. WOOD: I asked him why -- you're right. I asked him why he did not make a report, why he did not make a report.
MR. DIAMOND: Thank you. And he's about to tell you that if you just let him finish.
Q. (BY MR. WOOD) I assume what you're telling me is because of Arndt and Harmer somehow what they did, that's why you didn't do reports?
MR. DIAMOND: Why don't you listen to the answer, then you won't have to assume.
Q. (BY MR. WOOD) Why don't you answer my question about why you didn't prepare reports when you had contacts with Mr. White and then we can move to another question.
MR. DIAMOND: You can now finish your answer, if you haven't completed it.
Q. (BY MR. WOOD) Maybe now you can answer.
A. Detective Harmer inherited I think the Fleet and Priscilla White assignment, if you will, and was friends with them, compassionate to them trying to do her job as a police detective. When she introduced me then at some later date to the Whites, I completed and prepared reports on contacts, meetings, interviews that I felt were relevant at the time certainly and did so concerning 8 the Whites. But every time I either spoke or met with these people, no, I did not complete a written report.
Q. Give me your best recollection percentage-wise of how many times percentage-wise you think you may have prepared reports with meetings with Fleet White or Priscilla White, half the time, 75 percent of the time, 90 percent of the time, what is your best estimate?
A. I don't know how many reports I completed and I don't know how many times I met with them, but completed several reports I'm sure concerning the Whites and met with them a number of more times in which I didn't. So half, a quarter, I don't know.
Q. So there may be as many as half to 75 percent or 25 to 50 percent of the times you met with them where we couldn't find a report and find out what you all discussed or what they said to you?
A. As I said, I don't know. I'm trying to answer your question as far as a percentage goes.
Q. I take it if they gave you any 9 significant information as it would apply to the investigation of JonBenet's murder you would have prepared a report, true?
A. And I did at times.
Q. So we can at least know that any meeting you had with Priscilla White or Fleet White by phone, in person or otherwise, if there was any significant information about the case, you would have prepared a report, true?
A. Most likely, yes.
Q. Why would you not, if they had given you significant information about the case, why would you not prepare a report?
A. Well, again at the time and standing in those shoes, you know, three, four years ago, if it was significant at the time and I brought it back to the police department and it was significant, yes, absolutely I think I would prepare a report.
Q. Fleet White tell you that when he was downstairs in the basement with John Ramsey that John Ramsey went into the wine cellar room and turned on what he called a neon light and then cried out, my baby; did 0 Fleet White tell you that?
A. As to the matter of flipping on the light --
Q. Yes, sir.
A. -- yeah, I don't recall that.
Q. Do you have any knowledge as you sit here today to deny it?
A. I would look at my report before I gave you a definitive answer.
Q. Whose idea was it to go down to the basement first after Linda Arndt suggested to Fleet White that she ought to keep John busy and they could go search the house. And as I recall, Fleet White didn't really want to go tell John that himself and asked Linda Arndt to suggest it to him. Does that scenario sound familiar to you and accurate?
A. No.
Q. Not at all?
A. No, sir.
Q. How is it inaccurate?
A. Detective Arndt's description of that was that she gathered Fleet White to occupy a distracted John Ramsey to keep his mind busy and instructed him to search the 1 house in her words from top to bottom. Upon which time Arndt's recollection to me was that it was Ramsey who led the two men downstairs.
Q. What was Fleet White's recollection to you about who made the decision to start down in the basement?
A. I don't know that -- again, without reviewing my reports and my interview with Fleet, but that's not today, consistent -- no, Fleet White hasn't indicated to me that he was the leader going downstairs.
Q. Are you telling me if Linda Arndt says, listen, I want you two guys to go over here and I want you to search this house from top to bottom, you think that was -- is to be interpreted as saying I want you to start at the top and go to the bottom or does that really say I want you to search this entire place? What do you think is the more reasonable way to interpret that statement search the house top to bottom?
A. You would have to ask Linda Arndt --
Q. You said you did?
A. -- but her -- I did and her comment to me was, quote, From top to bottom and the indication I took away from it was that her instruction was to search the house from top to bottom.
THE DEPONENT: Chuck, can we take a break?
MR. DIAMOND: When you get to a convenient stopping point.
MR. WOOD: If he wants it take a break I'm fine. We will take it right now.
THE DEPONENT: Thank you.
MR. WOOD: Any time you want to do that, Mr. Thomas, don't hesitate to ask.
VIDEO TECHNICIAN: The time is 2:57. We're going off the record. (Recess taken from 2:57 p.m. to 3:05 p.m.)
VIDEO TECHNICIAN: The time is 3:05. We're back on the record.
Q. (BY MR. WOOD) Mr. Thomas, were the sheets on JonBenet's bed collected on the 26th of December for forensic testing?
A. I was told they were.
Q. And what tests were performed on them?
A. I don't know. Detective Trujillo had that assignment.
Q. Was there any test that you're aware of that indicated the presence of urine on those sheets?
A. Detective Trujillo imparted to me that he had learned or believed that there was not a presumptive test for urine according to the CBI.
Q. Were they wet?
A. When?
Q. That morning. Did you ask? Did you ask any of the officers there, hey, by the way, were the sheets on JonBenet's bed wet? Did you ask that question of anybody?
A. I did not.
Q. Do you know if anybody else did?
A. I don't know.
Q. You don't know the answer to whether they were wet or not?
A. I have been told that they were urine stained.
Q. Who told you they were urine stained?
A. Detective Trujillo, Detective Wickman.
Q. Have you seen the photographs of the sheets?
A. It depends on which photographs you're talking about.
Q. Of her sheets, of the bed.
MR. DIAMOND: Have you seen any.
A. Crime scene photographs, yes.
Q. (BY MR. WOOD) Did they say they could smell urine?
A. I have been told that CBI says, yes, those sheets which are still in evidence smell urine stained.
Q. And did they stain because -- well, you don't have kids, but I don't know if you've ever had a bed-wetting accident but when you have children one day you'll probably know this to be true, urine stained sheets, were these stained, have you seen them?
A. I have not seen the sheets.
Q. I mean, you write -- you have written in your book that JonBenet wet the bed. What I want to know is what evidence supports that statement that you are aware of and that you found out about?
A. Urine stained sheets, the plastic bed fitting and the diapers halfway out of the cabinet.
Q. The diapers had urine on them?
A. That's not what I said.
Q. Well, I'm -- diaper halfway out of the cabinet shows that the sheets were wet or that she wet the bed?
A. No, I think you asked me what led me to believe that she may have wet the bed.
Q. Well, I mean it seems to me that the answer is pretty simple. Did you ever go look at the sheets? They were there for your viewing if you wanted to, weren't they?
A. No, they were at CBI.
Q. You could have picked up the phone and asked somebody at CBI about the test on them, couldn't you?
A. No, Detective Trujillo told us.
Q. Did you ever see the written report on that finding by CBI?
A. I don't know that CBI did a report on whether or not the sheets were urine stained.
Q. Surely you're not telling me that the CBI's forensic testers performed, the only test was to smell and look at the sheets?
A. As I said, I have been told that there is not a presumptive test for urine.
Q. How about for the substances that make up or are found in urine?
A. I have no training or knowledge of that.
Q. How big was the area of the sheets where they were urine stained or wet?
A. I don't know.
Q. Isn't there something that describes that, a report?
A. Urine stained sheets according to Trujillo.
Q. Take a look at page 146 of your book, please. Down at the paragraph that starts "John Meyer." Do you follow me?
A. Yes.
Q. "John Meyer, the Boulder County coroner, had barely begun his autopsy findings 7 before Lee questioned the urine stains found on the crotch of the long-john pants and the panties beneath them." Have I read that correctly?
A. Yes.
Q. To put this into context, this would have been during the VIP explanation or conference, right?
A. No, I don't believe so.
Q. I'm sorry, when do you believe this event took place where Meyer was going through the autopsy findings where Henry Lee was present?
A. I believe this was in 1997 at the Boulder Police Department.
Q. Do you know when in 1997?
A. My best guess would be maybe March, February.
Q. Reading on. "Were there corresponding stains on the bed sheets? We didn't know, although when the crime became a murder instead of a kidnapping, those sheets should have been promptly collected for testing." Have I read that correctly?
A. Yes.
Q. Well, you didn't know in February, are you telling me that you found out subsequent in time that the sheets were wet? When did you find out, Mr. Thomas --
MR. DIAMOND: Go ahead.
Q. (BY MR. WOOD) Let me -- why don't you just tell me, when did you first find out that the sheets were wet?
A. I do not think the sheets were collected promptly. I think it was after the fact. And one of the questions of this investigation was that no one had checked the bed on the morning of the 26th prior to a wet bed possibly drying whether or not the bed was wet. But the sheets nonetheless were collected and described to me as being urine stained and just recently saw something corroborating that when Mr. Smit appeared on the Today Show and there was a comment from the CBI about that.
Q. Traces of creatinine were found; is that what you're talking about?
A. I don't think that is what they said on the NBC show.
Q. What did they say?
A. I think it said a CBI source said the sheets were or appeared to be urine stained.
Q. Let's go back and find out not so much what NBC was talking about. Let's find out what the police knew. Were the sheets collected on December 26th, 1996 or not?
A. They were -- I don't know. I wasn't there.
Q. What did you find out about it?
A. That at some point during the ten days subsequent to December 26, 1996, when the house was a crime scene, those sheets were collected.
Q. At such time as they would have, if wet, been dry; is that what you're telling me?
A. Possibly.
Q. What was your understanding as to Chris Wolf's employment at the time you first began to investigate him in January of 1997?
A. Again, as I said, just what Jackie Dilson had supplied verbally.
Q. What was that?
A. And that was, I think she described him as either a current or a one-time exotic dancer.
Q. What did she say that meant? Did you say what does an exotic dancer do, Ms. Dilson; did you ask her that?
A. No; I assumed it was a stripper.
Q. Did you ever to your knowledge with the Boulder Police Department while thoroughly investigating Mr. Wolf ever obtain any indication that he might have been involved in illegal sexual acts for money?
A. Again, he wasn't cooperative with me and Gosage in our attempt, so I don't know that.
Q. But you stayed on him for a year according to your book?
A. He remained on this list, if you will, for approximately a year.
Q. And you stayed on him because you put up with Jackie Dilson for a year you said in your book, didn't you?
A. Two parts, yes, I put up with Jackie Dilson for a year, but Chris Wolf was -- that assignment was reassigned.
Q. Well, but again relying on your other police officers, did you ever learn anything about any information compiled by the thorough investigation efforts on Chris Wolf that would in any way indicate that Mr. Wolf might have performed such acts as, let's say, go into an all-male strip party and allowing members at the party, men, to perform oral sex on him?
A. No, if you're suggesting if I was aware that there were allegations that Mr. Wolf was engaged in male prostitution or hustling, I was unaware of that until now.
Q. I'm not making an allegation. I'm asking you what your investigation found. I am asking you if there was any indication of any such conduct by Mr. Wolf. Any indication that Mr. Wolf ever worked at a photography company where he took pictures of children, team sports ages as young as four to 15, 14, 15 years of age; did you get any information about that?
A. Again, I was not successful with my attempts at interviewing Mr. Wolf, so, no, I did not know that.
Q. Did you ever ask -- in the thorough investigation, though, that your officers that you rely on conducted, did you ever find out whether there was any indication that Mr. Wolf might be a user of illegal drugs at the time frame of '94, '95, '96?
A. Again, I have told you, I don't know the breadth or depth of Weinheimer's investigation prior to clearing him.
Q. But relying on Weinheimer in this case and others as you did, right --
A. (Deponent nods head.)
Q. -- you would have fully expected Detective Weinheimer in a thorough investigation to get those kinds of information, or at least to get details about Mr. Wolf's lifestyle and prior employment and questions about whether he used drugs. Those would be part of a thorough investigation into this man's background, wouldn't they, sir?
A. He may have.
Q. Isn't that what you expected him to do?
A. Possibly unless he had other reasons to discount Mr. Wolf.
Q. Well, sir, if you had been in charge of Mr. Wolf's investigation that you say you were not, if he had been assigned to you, you would have gone back and done that type of a thorough background investigation, wouldn't you?
A. Not necessarily, Mr. Wood. If, for example, in the first day, a detective was able to corroborate an alibi for Mr. Wolf, then you likely would not have gone to all this extra trouble.
Q. Except here you know that would be impossible since the only alibi he could have offered would be to have been in the house with a woman who thought he was involved in the murder?
A. No. Because Ms. Dilson made that allegation. I did not have his side of the story. He may very well have put himself at a different location with an independent witness.
Q. Apparently that hadn't happened here because you know that into 1998 Mr. Wolf 4 was still being investigated by the Boulder Police Department as a suspect in this case giving non-testimonial evidence, hair, fiber, handwriting, right?
A. Correct.
Q. That would indicate the alibi didn't get him off the hook in terms of investigation for over a year, wouldn't it, sir?
A. Correct.
MR. DIAMOND: You're assuming there was an alibi. I don't know if there is any mention of that --
MR. WOOD: Yeah, I'm just following up on the question of whether he speculated there might be an alibi. Listen, we don't need to waste time, you know. You've got somewhere to be at 6:30 in terms of some friends picking you up. Let's go ahead.
MR. DIAMOND: Thank you.
MR. WOOD: I'm trying to make that time frame.
Q. (BY MR. WOOD) Did you interview Linda Arndt at any time subsequent to the murder of JonBenet Ramsey?
A. Successfully and at times unsuccessfully, yes.
Q. In the successful interviews, did you prepare reports?
A. No.
Q. Would that be because there was nothing significant said to you during those interviews by her?
A. Typically police don't prepare, at least it's been my experience, prepare reports when simply speaking to or asking for a clarification from a fellow officer.
Q. I was talking about an interview more than a clarification.
A. No, did I ever sit down with her for a formal interview? No.
Q. Did you ever try to?
A. No, when I had questions, it was fairly routine just to go to the detective in question and make your inquiry.
Q. Has Fleet White ever made any statement to you about his opinion on who killed JonBenet Ramsey?
A. Mr. White has always been very careful with his language around me, as is his wife and I don't know that I could sit here and say today that he has come out and made a declaration as to who he believes killed JonBenet Ramsey. But the tone and inferences of some of these conversations made it fairly clear to me.
Q. You think you understood from the tone and inferences what he was trying to say but not saying directly; is that your testimony?
A. I think I believe that I know who Fleet has in mind as the offender in this case.
Q. Why don't you just ask him?
A. I did not, that I recall, ask him outright who he thought did it.
Q. I mean, you've talked to him since you left the Boulder Police Department, haven't you?
A. Yes.
Q. When is the last time you talked with Fleet White?
A. I think I last saw them in probably July or August of 2000 and then again had a pleasant hallway conversation in Jefferson County, Colorado, outside a courtroom in the last couple months.
Q. What was the nature of your seeing him in July of 2000?
A. A personal visit.
Q. Personal, but tell me, please, if you would, the nature of the visit?
A. I think I had finished a carpentry job up on -- in that part of the world and in the late afternoon or early evening, drove by their house to say hello and they invited me to stay for dinner.
Q. Drinks?
A. I don't really drink.
Q. Whether you really drink or not -- most people either drink or they don't drink. I don't know about I don't really drink. That sounds like you might occasionally take a glass of wine or drink, I don't know. Do you?
A. I won't drink three beers in a year's time.
Q. Did you have a glass of wine with the Whites that night you had dinner?
A. No.
Q. Did they?
A. I don't know whether or not they had alcohol.
Q. How many times do you think you've seen them on a social basis since you left the department in August of 1998?
A. Two or three maybe.
Q. And one was the dinner in July of 2000. What were the other two occasions?
A. Post resignation in August of '98, maybe a time or two in 1999, I'm not sure.
Q. What were the occasions? You had dinner one time. What were the other social occasions; do you recall what they were?
A. That was the only time I ever ate with the people.
Q. What were the other social occasions, sir, what did you do with them?
A. Probably just stopped by their house and said hello. I didn't meet them at other locations.
Q. Do you consider Fleet and Priscilla White personal friends of yours?
A. I don't know how I would characterize these people who I have a lot of compassion for.
Q. Do you know what you consider someone -- do you know what it is to consider someone a personal friend of yours?
A. Yes.
Q. Do they fall in that category or not?
A. It's an unusual characterization. I have never had a relationship with somebody that I met wearing one hat and continued that in this context. So if you're asking me am I friendly and would I consider myself friends with these people, yes.
Q. Look at page 25 of your book for me if you would, please, Mr. Thomas. Right here (indicating) kind of give you a visual.
MR. DIAMOND: Do you see that, Darnay?
Q. (BY MR. WOOD) "In the sun room Patsy Ramsey examined a second-generation photocopy of the ransom note, a smeary version that showed little more than the dark printed words. Rather than commenting on the words and contents, she told one of her friends that the note was written on the same kind of paper she had in her kitchen." Have I read that correctly?
A. Yes.
Q. Who was the friend that she told that to?
A. This was from Barb Fernie.
Q. And then "Police would wonder how she could tell since they saw no similarities." Have I read that correctly?
A. Yes.
Q. You're talking about police saw no similarities between the second-generation photocopy and the actual ransom note itself?
A. No, trying to source a Xerox copy back to a particular note pad in the kitchen.
Q. The police couldn't tell the -- couldn't see the similarity of the Xerox copy and the note pad, right?
A. Right.
Q. They would wonder how Patsy could tell there was a similarity, right?
A. How one would make that suggestion, how a Xerox photocopy of a rather bland, generic piece of paper on which the ransom note was written may have had its genesis from a tablet in the kitchen.
Q. Not that it had its genesis, but that it was similar, right? It was written on the same kind of paper?
A. The Xerox copy did not leave me with that impression, that it did not strike me that way.
Q. Did that seem suspicious to you of Patsy Ramsey?
A. A bit.
Q. Did you ever stop and consider that she might have made the comment about the similarity because she, sir, had seen the original of the ransom note prior in time?
A. But I think in this context she was looking at a photocopy.
Q. So you're telling me that she was trying to say that from the photocopy she thought that it was similar. You don't think that she might have had the benefit of knowing what the actual note looked like in terms of the paper? Would you concede that maybe that might be an inaccurate assumption on your part, sir, you know, what you thought was suspicious wasn't suspicious at all?
A. No, I'm simply stating what struck the detectives in wonder is we thought that Barb Fernie's statement was unusual, given this context.
Q. On pages 26 and 27 of your book, starting with Detective Arndt -- well, actually it starts at page 25 "Time was passing swiftly." For the next couple of pages, and the content is not so much what I'm focusing on. I just want to know, you talk a lot about Arndt and observations that she made. Was the basis for those comments that you made about her reports?
A. Primarily, because at one point she discontinued talking to some of us.
Q. She actually did more than that. She told you that she didn't have any recollection anymore about what she saw that day, didn't she?
A. She made that statement or something very close to that.
Q. Page 35, Linda Hoffmann-Pugh, do you know who -- did you ever interview Linda Hoffmann-Pugh?
A. No, sir.
Q. You never had the opportunity to judge her credibility yourself to see whether she might, in your opinion, like Jackie Dilson might be somewhat unstable or not credible?
A. I don't know that I've ever met Linda Hoffmann-Pugh, no.
Q. Do you know how many days a week Linda Hoffmann-Pugh worked for the Ramsey family?
A. Without reviewing reports, no, I don't.
Q. Do you know what time of the morning she would get there and how long she would stay?
A. Again, without reviewing reports concerning Ms. Hoffmann-Pugh, I do not.
Q. Do you think you had some of those reports about Ms. Hoffmann-Pugh in your materials that you copied and after you left the department or received from the Boulder Police Department after you left the department?
A. I don't know.
Q. We can only tell when we find them, right, that would tell us more information about what you know about Linda Hoffmann-Pugh, true?
A. Or again if we can work our way into the police department.
Q. Did you ever interview Shirley Brady, who had been a housekeeper for the Ramseys for almost four years?
A. The name sounds familiar and if it's the person I'm thinking of who resided in Georgia I think Harmer or Gosage conducted that interview.
Q. They would have prepared a report?
A. I would think so.
Q. Shirley Brady tells me that she got a phone call and about a five-minute interview and when she said she made it pretty clear that the Ramseys weren't in any way the type of people that could be involved in this, that the interview ended and she never heard from anybody again. Does that sound like a thorough investigation if that's true?
A. It depends on what the detectives were doing. I don't know what they were doing.
Q. Well, you know if you have got to -- if you're spending a lot of time with Linda Hoffmann-Pugh who had worked for them less than two years and only worked part time and you want to know all about this family's background, a thorough investigation, wouldn't you believe, sir, from your experience as a police officer that you're going to spend more than five minutes on the phone with someone who was a housekeeper for three years?
A. For some reason in my mind, and I may be wrong, I don't think Mrs. Brady was ever in Colorado with the family. There was apparently nothing that the detective who interviewed her felt was worth more than their five minutes. You would have to ask them.
Q. So you had to be in Colorado with the family in order to be a significant witness as to their background?
A. No, not to their background.
Q. That doesn't make any sense, does it?
A. No.
Q. I didn't think it did. I mean, you know you all were looking to see if there was any pathology in this family on either John Ramsey's part or Patsy Ramsey's part, right?
A. We did.
Q. And you didn't find any, did you?
A. What do you mean by pathology, Mr. Wood?
Q. Mr. Thomas, please, you know what pathology means.
MR. DIAMOND: Don't give him that tone of voice or I'm going to pick him up and walk him out of here.
MR. WOOD: If you want to pick him up and walk him out of here, if you think you're justified, do so.
MR. DIAMOND: Cut out the sarcasm. If you have a problem with his answer, move on to another question.
MR. WOOD: All right. May I ask my question without your interruption, please?
MR. DIAMOND: You may.
Q. (BY MR. WOOD) Mr. Thomas, please, do you, sir, not know what I mean when I asked you whether there was any pathology on the part of John or Patsy Ramsey from a criminal investigation standpoint?
A. I simply asked you to explain to me what you mean by pathology.
Q. As used by the people that discuss that very term in your investigation. You knew what they meant, didn't you?
A. I don't think, to answer your question, that there was anything remarkable or outstanding as far as what you're inquiring about. Although, Pitt and others would describe to us their concerns about the beauty pageant world and child beauty pageants, et cetera, if that's what we're talking about as far as family history.
Q. Drug use, illegal drug use would be pathology, child abuse would be pathology, domestic violence would be pathology, right?
A. Yes.
Q. You didn't find anything about that with respect to this family, did you, sir, John and Patsy Ramsey?
A. Drug use, child abuse, or spousal abuse, not that I'm aware of.
Q. Anything along the lines of pathology that you believe you heard the investigation found, other than Pitt and others you say commenting about beauty pageants?
A. No, there wasn't any sort of untoward history or certainly no criminal history that I was made aware of.
Q. When you were in these presentations, either one or both, wasn't it discussed that the experts hired by the Boulder Police Department did not believe that there was pathology?
A. I don't know to which experts you're referring.
Q. Well, Dr. Krugman, do you remember him?
A. Yeah, certainly. Dr. Krugman was the one who put forth the bed-wetting, toileting, and rage scenarios.
Q. Ken Lanning of the FBI?
A. I remember Mr. Lanning from Quantico.
Q. What did Mr. Lanning say with respect to his expectation in a case like this in terms of whether you would expect to find serious pathology or not?
A. I don't recall. I'll refresh myself at some point I hope with that report.
Q. When you, sir, with all due respect when you're sitting down to write a book to state your, as you call it, hypothesis that Patsy Ramsey murdered her daughter, I'm just operating under the assumption that you would have thoroughly familiarized yourself with the investigation before committing that type of a statement to word for profit. Is my assumption wrong?
MR. DIAMOND: This deposition is not about the authorship of his book.
MR. WOOD: No, it's about his knowledge of the investigation, sir.
MR. DIAMOND: You can ask him questions about that.
MR. WOOD: I just did.
Q. (BY MR. WOOD) Is my assumption wrong?
MR. DIAMOND: I direct you not to answer the pending question. The next question.
Q. (BY MR. WOOD) Did you or did you not prior to April of 2000 familiarize yourself fully with the significant findings of the investigation of John Ramsey and Patsy Ramsey in connection with the death of JonBenet, yes or no?
A. I tried to.
Q. Did you feel confident that you had in fact that familiarity?
A. Was I familiar with the case? Yes, absolutely.
Q. Well, did all the experts agree that JonBenet Ramsey was alive at the time of the injury to her vagina?
A. Again, I don't know what experts you're referring to but we had --
Q. The ones that you listened to.
A. Let me finish, Mr. Wood.
Q. The ones that your department hired?
A. At times there was, among experts, as was to be expected, there was conflict of opinion. But regarding the prior vaginal trauma if that's what you're asking about, this blue ribbon panel of pediatric medical experts they brought in seemed to me to be in agreement on some other conclusions.
Q. I'm talking about the acute vaginal trauma she suffered at the time of her murder. The agreement was unanimous that she was alive at the time that that vaginal trauma was inflicted, true?
A. Yes, I believe that's correct.
Q. Now, tell me who the members were of what you call the blue ribbon panel of pediatric experts, give me their names, please.
A. I think the FBI recommended --
Q. Just their names, not the recommendation?
A. -- and tried to -- and he participated, was a doctor from California, Dr. John McCann, from Miami was Dr., I believe it's, Valerie Rau and the third gentleman from St. Louis, I think he was the Dean of the Children's Hospital or the pediatrics at Glenn Cannon and I don't recall his name offhand.
Q. Anybody else on this panel?
A. On and off, we saw one of Hunter's advisors, which was Krugman.
Q. Was he on the blue ribbon panel that you keep referring to?
A. Krugman?
Q. Yeah, the blue ribbon panel of pediatric experts that I asked you about. Was Krugman on that panel?
A. No.
Q. Okay.
A. I think that panel consisted of those three individuals.
Q. Take a look, if you would, at page 45 of your book. Second -- actually, first full paragraph. "An acquaintance said that JonBenet was rebelling against appearing in the child beauty contests. She was being pushed into the pageants by her mother and grandmother, said the witness." Who is that individual?
A. I believe that was Judith Phillips.
Q. Did you find Judith Phillips to be credible?
A. At times.
Q. At times she was not credible?
A. No, I think Judith Phillips, like many others in Boulder, were devastated by this crime and she had tough moments, I'm sure.
Q. Do you think John and Patsy Ramsey had tough moments because they would have been devastated by the death of their daughter?
A. They certainly may have.

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