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Quote:Steve Thomas Deposition (Atlanta, Georgia)
Wolf vs Ramsey Civil Action File No. 00-CIV-1187(JEC)

(Grand Jury Discussion)

48
17 Q. Did you ever receive any
18 information about grand jury testimony or
19 evidence in the case?
20 A. Never.



(SNIP)



53
7 Q. Do you have any other documents
8 about this investigation, other than those
9 documents? Do you?
10 A. Oh, I'm sorry. If I understand
11 the question correctly, no, as I said, not
12 that I recall because post-August '98 began
13 the grand jury. And certainly I don't have
14 any information from the grand jury room.



(SNIP)



202
4 Q. (BY MR. WOOD) You said very
5 clearly to Mr. Hoffman you do not know the
6 state of the evidence with respect to the
7 JonBenet Ramsey investigation, as you sit here
8 today, the state of the evidence as of
9 September 2001, true?
10 A. After leaving the police
11 department, yes, that concluded my official
12 participation. I have followed the case
13 through the media, but as far as being privy
14 to anything that occurred in the grand jury
15 or continued evidence testing, I'm unaware of
16 that.
17 Q. You knew the state of the evidence
18 as it existed in the case as of March 2001,
19 true?
20 A. That was during the period which
21 -- no, the grand jury had concluded -- no, I
22 -- no, I wasn't inside the police department
23 reviewing evidence at that time either.

24 Q. But what you did know and you had
25 actual knowledge of was that a grand jury had


203

1 met for some 13 months and had not issued an
2 indictment against John and Patsy Ramsey,
3 right?
4 A. I don't know that. Do you know
5 that?
6 Q. Sir, was an indictment issued? Do
7 you have information there was an indictment
8 of my clients that nobody has bothered
9 telling them or me about?
10 MR. HOFFMAN: Actually, Lin,
11 Patrick Burke has information that he should
12 have told you about which he announced to the
13 media that according to him the grand jury
14 actually took a straw poll. Why don't you
15 ask Patrick Burke.
16 MR. WOOD: Let me tell you,
17 Darnay, that won't count against my time.
18 MR. HOFFMAN: Okay.
19 MR. WOOD: But you're right, it
20 was a straw poll; it was a vote not to
21 indict. Thank you for bringing something to
22 my attention that I already knew.
23 MR. HOFFMAN: Okay.

24 Q. (BY MR. WOOD) Would you answer
25 my question, sir? It's pretty simple. You

204
1 know that no indictment was issued by the
2 grand jury, true?
3 A. I don't know what the grand jury
4 did.
5 Q. I'm not asking you what they did
6 in terms of whether they voted or not, sir.
7 MR. DIAMOND: I think he's asking
8 you --
9 Q. (BY MR. WOOD) I'm asking you
10 whether they issued an indictment to indict
11 John and/or Patsy Ramsey?
12 MR. DIAMOND: -- are you aware of
13 any public report of such an indictment.
14 A. No.
15 Q. (BY MR. WOOD) You also know that
16 after the grand jury was dismissed that Alex
17 Hunter stated publicly that all seven of the
18 prosecutors in the case unanimously agreed
19 that this was not a case where they felt
20 that evidence was sufficient to justify at
21 that time a prosecution. You know that, too,
22 don't you, sir?
23 A. That Hunter --
24 Q. Made that statement publicly?
25 A. Made the statement that his

205
1 advisors supported that decision?
2 Q. Seven prosecutors, not his
3 advisors, seven prosecutors, you know that,
4 don't you, sir?
5 A. I know that statement was made.

.

Quote:
Steve Thomas Deposition - 09-21-2001
Chris Wolf vs Ramsey Civil Case

(Grand Jury Discussion)




(SNIP)



391
24 Q. Do you know of any prosecutor who
25 is familiar with the evidence that has

392
1 concluded that the evidence shows beyond a
2 reasonable doubt that Patsy Ramsey is guilty
3 of the homicide of her daughter?
4 A. No, because the prosecutors privy
5 to that evidence are bound by grand jury
6 secrecy and none have violated that with me.



(SNIP)



394
13 Q. Why did you not, when you had old
14 Barry Scheck, a nice guy, Henry Lee, all
15 these VIPs there, why did you not include the
16 intruder evidence in the presentation to
17 objectively give those individuals both sides
18 of the case?
19 A. Because the Boulder Police
20 Department's position was, as I understood it
21 and understand it, the VIP presentation was
22 to show that there was sufficient probable
23 cause to arrest Patsy Ramsey and for the DA's
24 office to move it forward through the use of
25 a grand jury with that end in mind.

395
1 Q. Of an indictment which is a
2 finding by a grand jury of probable cause to
3 charge or arrest, right?
4 A. Yes.
5 Q. You've been in the business long
6 enough to know that the grand jury can, as
7 they say, indict a ham sandwich, right? It
8 doesn't take much evidence to indict or
9 arrest, does it, sir?
10 A. My understanding of probable cause
11 is facts and evidence and circumstances that
12 are within the knowledge of a police officer
13 that would lead a reasonable person to
14 conclude that, A, a crime was committed and
15 B, that a particular individual was involved.
16 Sometimes, depending on the case,
17 that can sometimes be a great threshold.



(SNIP)



424
24 Q. You state in your book there were
25 27 reasons for a grand jury and it's at page

425
1 309. But my question is, were those 27
2 reasons for a grand jury correlate to the 27
3 remaining tasks that were referred to in that
4 June '98 press release by the Boulder Police
5 Department?
6 A. Let me look at 309 real quickly.
7 308, 309?
8 Q. It's on 309 and I've got a copy
9 of that press release where he says there
10 were 27 tasks remaining. I'm just wondering
11 if that's the correlation.
12 A. Oh, if I understand you correctly,
13 did these 27 reasons correspond with the 27
14 tasks left on the to-do list?
15 Q. Yes.
16 A. No.



(SNIP)



439
6 Q. What I want to know is if you can
7 date that for me? "'The case is not being
8 handled well,' said the CASKU agents."
9 A. Shortly before I believe the
10 Ramseys' April 30, 1997 interview.
11 Q. Can you identify the three agents
12 for me?
13 A. Supervisory special agent Bill
14 Hagmaier, special agent Mike Morrow, and their
15 partner and the third special agent, his name
16 just escapes me at the moment.
17 Q. And those three agents prior to
18 April 30, 1997 said that the intruder theory
19 was absurd, Hofstrom needs to act like a
20 prosecutor not a public defender. Don't do
21 tomorrow's interview and get a grand jury as
22 soon as possible, right?
23 A. Yes.