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