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 a