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Deposition of Steven Thomas - September 21, 2001
APPEARANCES For the Plaintiff: DARNAY HOFFMAN, ESQ. (By telephone) Law Office of Darnay Hoffman 210 West 7th Street, Suite 209 New York, NY 10023 (212) 712-2766 . For the Defendants: JAMES C. RAWLS, ESQ. Powell, Goldstein, Frazer & Murphy, L.L.P. 191 Peachtree Street, N.E. Sixteenth Floor Atlanta, GA 30303 (404) 572-6600 L. LIN WOOD, ESQ. The Equitable Building 100 Peachtree Street Suite 2140 Atlanta, GA 30303 (404) 522-1713 -and- For the Deponent: CHARLES P. DIAMOND, ESQ. O'Melveny & Myers 1999 Avenue of the Stars Los Angeles, CA 90067-6035 (310) 553-6700 SEAN R. SMITH, ESQ. Dow, Lohnes & Albertson One Ravinia Drive Suite 1600 Atlanta GA 30346-2108 (770) 901-8800 Also present: JAY R. REN, CLVS TODD TOMPKINS, Videographer Intern O.M. "Ollie" Gray VIDEO TECHNICIAN: The time is 9:07. We're on the record. This is the deposition of Steve Thomas for the case of Robert Christian Wolf versus John Bennett Ramsey and Patricia Paugh Ramsey, Case Number 00-CIV-1187 in the U. S. District Court, Atlanta Division, State of Georgia.
Today is September 21st, 2001. We are located at 1100 Fourteenth Street, Denver, Colorado. The court reporter is Kelly Mackereth of Boverie, Jackson, Busby and Speera. The videographer is Jay R. Ren, certified legal video specialist for Ren Video Services.
The attorneys will identify themselves beginning with the attorney on the left and the deponent's right. MR. WOOD: My name is Lin Wood. I represent John and Patsy Ramsey. MR. RAWLS: I'm Jim Rawls. I'm co-counsel with Lin Wood representing John and Patsy Ramsey. MR. GRAY: My name is Ollie Gray. I'm an investigator in this case. MR. DIAMOND: I am Chuck Diamond of O'Melveny & Myers representing the witness, Steve Thomas. MR. SMITH: I'm Sean Smith, and I also represent Steve Thomas. VIDEO TECHNICIAN: Also, on the phone. MR. WOOD: Your turn, Darnay. MR. HOFFMAN: I'm Darnay Hoffman, and I represent the Plaintiff, Robert Christian Wolf. VIDEO TECHNICIAN: The reporter will now swear in the witness. MR. WOOD: You ready for us? VIDEO TECHNICIAN: Yes, we're ready to swear in the witness. MR. WOOD: Would you swear the witness, please. STEVEN THOMAS, having been first duly sworn, was examined and testified as follows: EXAMINATION BY-MR.WOOD: Q. This will be the deposition of Steve Thomas. The deposition is taken pursuant to the Federal Rules of Civil Procedure and the Federal Rules of Evidence. The deposition is taken pursuant to subpoena duly served and notice duly filed and also pursuant to the order and rulings of Judge Jewell Carnes in denying Mr. Thomas' motion to quash the subpoena. And I would also note for the record that within the ruling of Judge Carnes' counsel for Mr. Thomas and for the parties have agreed as to the date and the location of the deposition. I understand that Mr. Thomas will read and sign the deposition. We would agree that can be undertaken before an authorized notary public. Everybody set? MR. DIAMOND: Go ahead. Q. (BY MR. WOOD) All right. Mr. Thomas, you've been sworn. Let me ask you for the record, please, to state your full name. A. My full name is William Steven Walton Thomas. Q. You go by Steve? A. I do. Q. Do you have any preference? I'll probably call you Mr. Thomas but if you would rather I call you Steve or something you just let me know? A. Steve, Mr. Thomas. Q. All right. I may bounce back and forth. What is your – MR. DIAMOND: Let's stay on a last-name basis. It is a sworn testimony. MR. WOOD: Yeah.