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  the golf bag story
Posted by: jameson245 - 03-25-2017, 11:53 AM - Forum: Disproving Myths - Replies (4)

from Steve Thomas' deposition - -  how myths get going

Thomas depo 34 - golf bag story"
Well, here it is - the "source" for the BORG myth (John denies he ever asked after his golf clubs and no one has stepped forward to testify against him - - and now we get to hear the story started when...
Q. Page 48, the first full paragraph. "John was overheard to ask someone quietly, 'Did you get my
golf bag?'" Did I read that correctly?

A. Yes.
Q. Who overheard him ask that question?
A. I believe that was either John or Barbara Fernie.
Q. Who did they overhear him ask that question to? Who was the someone?
A. They could not identify that party.
Q. And when did that statement, was it allegedly made?
A. The did you get my golf bag statement?
Q. Yeah.
A. I think in the days following the murder.
Q. Do you know how many days after the murder?
A. No.

... some days after the murder someone (either John or Barbara, Thomas isn't sure) was not being spoken to but overheard a conversation to someone who they can't identify and they heard John asking after his golf clubs.
That sure doesn't sound like documented fact to me - not at all.

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  Steve Thomas depo
Posted by: jameson245 - 03-25-2017, 11:41 AM - Forum: Polygraphs - No Replies

Q. Page 75 of your book. The second paragraph "The FBI would tell us that the disposal of the
body of JonBenet had the classic elements of a staged crime, complete with a Hollywoodized ransom
note." Was there any specific member of the FBI that you attribute that statement to?

A. The meeting in I believe it was August or September of 1997.
Q. Quantico?
A. In Quantico at a big, many, many people in the room.
Q. If I hear you throughout this testimony and it seems to me and from your book, the FBI was
heavily involved in this investigation from early on; wouldn't you agree?
A. They were very supportive of us and involved, yes.
Q. Yeah, I mean, they were heavily involved for a case that really was not a federal jurisdiction
case, a murder?
A. Arguably.
Q. I mean when I was out there saying, you know, I didn't think the FBI is objective because they've
been involved in this case to a significant amount, whether you agree or not with my objectivity
conclusion, I was right about the fact that the FBI had been significantly involved in the case, wasn't I?
A. For the record I don't agree with the objectivity conclusion but, yeah, they were significantly
involved in the case.
Q. It seems like from what you're telling me that they were of the mind that you were, that Patsy
Ramsey they thought was involved in the death of her daughter?
A. That certainly seemed to be my impression.
Q. So whether that was an objective decision by then I certainly was right to have some concerns
about whether or not they had formed such a conclusion before I submitted John or Patsy to the FBI
examination, wasn't I?
A. Well, twofold. One, I don't think they would have -- I don't think there was anything
inappropriate with their polygraph unit or that they would have conspired in any way with their
Q. I also comment to you the ruse interview that was attempted on Richard Jewell by the FBI might
be enlightening about FBI tactics, legal and illegal

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  BORG vision on Ramsey family history
Posted by: jameson245 - 03-25-2017, 11:21 AM - Forum: BORG theories and BORG people of note - Replies (2)

From Steve Thomas' depo in Wolf v Ramsey

Q. I didn't think it did. I mean, you know you all were looking to see if there was any pathology in
this family on either John Ramsey's part or Patsy Ramsey's part, right?

A. We did.
Q. And you didn't find any, did you?
A. What do you mean by pathology, Mr. Wood?
Q. Mr. Thomas, please, you know what pathology means.
MR. DIAMOND: Don't give him that tone of voice or I'm going to pick him up and walk him out of
MR. WOOD: If you want to pick him up and walk him out of here, if you think you're justified, do so.
MR. DIAMOND: Cut out the sarcasm. If you have a problem with his answer, move on to another
MR. WOOD: All right. May I ask my question without your interruption, please?
MR. DIAMOND: You may.
Q. (BY MR. WOOD) Mr. Thomas, please, do you, sir, not know what I mean when I asked you
whether there was any pathology on the part of John or Patsy Ramsey from a criminal investigation
A. I simply asked you to explain to me what you mean by pathology.
Q. As used by the people that discuss that very term in your investigation. You knew what they
meant, didn't you?
A. I don't think, to answer your question, that there was anything remarkable or outstanding as far as
what you're inquiring about. Although, Pitt and others would describe to us their concerns about the
beauty pageant world and child beauty pageants, et cetera, if that's what we're talking about as far as
family history.
Q. Drug use, illegal drug use would be pathology, child abuse would be pathology, domestic violence
would be pathology, right?
A. Yes.
Q. You didn't find anything about that with respect to this family, did you, sir, John and Patsy
A. Drug use, child abuse, or spousal abuse, not that I'm aware of.
Q. Anything along the lines of pathology that you believe you heard the investigation found, other
than Pitt and others you say commenting about beauty pageants?
A. No, there wasn't any sort of untoward history or certainly no criminal history that I was made
aware of.
Q. When you were in these presentations, either one or both, wasn't it discussed that the experts
hired by the Boulder Police Department did not believe that there was pathology?
A. I don't know to which experts you're referring.
Q. Well, Dr. Krugman, do you remember him?
A. Yeah, certainly. Dr. Krugman was the one who put forth the bed-wetting, toileting, and rage
Q. Ken Lanning of the FBI?
A. I remember Mr. Lanning from Quantico.
Q. What did Mr. Lanning say with respect to his expectation in a case like this in terms of whether
you would expect to find serious pathology or not?
A. I don't recall. I'll refresh myself at some point I hope with that report.

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  Steve Thomas on the garrote
Posted by: jameson245 - 03-25-2017, 11:08 AM - Forum: Cord ligature - Garrote - Replies (2)

Q. You would tell me, too, that if JonBenet Ramsey was alive when she was strangled and alive
when she was molested and that there is evidence of a struggle in her neck area, that if you assume
those facts to be true, that that would be inconsistent with staging of a crime, correct?

A. I don't agree with the premise. I agree with the expert Dr. Spitz' conclusion on that.
Q. I'm asking you, though, sir. You're talking about staging the crime. If JonBenet were struggling
to try to get the garrote loose, that certainly would be inconsistent with the parent staging a crime
thinking her child was dead, true?
A. Mr. Smit did present to the police department that theory.
Q. But I'm not asking about Mr. Smit with all due respect.
A. I'm trying to answer the question.
Q. I'm asking you about the concept itself. If the child is found to be struggling to get at the garrote,
that would be totally inconsistent with the idea of staging by a parent who thought the child was dead. I
mean, that's just one and one equals two, doesn't it, sir?
A. Two different concepts. I disagree. I think that, as I've have said, I think parents have killed
their children in a variety of ways.
Q. I'm talking about staging where you think your child is dead or your child is dead and you're trying
to stage a crime scene. After the fact that's staging, right, to make it look like something that it's not,
A. Staging, my understanding is just that, recreating or messing with a crime scene to divert
attention, making it appear something that it's not.
Q. Then if you've got a child that is trying to pull at the garrote, that would not be consistent at all
with the parent placing a garrote and tightening it around the child's neck to make it appear that the
child was strangled as part of staging a crime, would it, sir, can't you --
A. No.
Q. -- acknowledge that --
A. I'm not going to go along with that and agree to it.
Q. Why not?
A. I just don't agree with it.
Q. So Patsy Ramsey theoretically had JonBenet Ramsey there pulling at this garrote around her
neck, scratching at it and you still believe that the garrote would have been placed there by Patsy
Ramsey to stage the crime; is that what your testimony is?
A. If that's what you're telling me, I won't dispute that's what happened.
Q. Do you believe that is what happened?
A. No. I've offered a hypothesis that I believe was consistent with the evidence as I knew it, that
possibly what happened.
Q. Let me ask you something about the use of the word hypothesis. Where did you come up with
that word? You use it in almost every interview.
A. I don't know, in school somewhere.
Q. As it applies to your book?
A. No, you asked me where I learned the word hypothesis.
Q. Are you prepared to state as a fact, sir, that Patsy Ramsey murdered her daughter?
A. No, I'm prepared --
Q. Thank you.
A. -- to say, as I have in the past, that that's my belief.

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  So where was the DNA-X?
Posted by: jameson245 - 03-25-2017, 11:06 AM - Forum: DNA-X - Replies (2)

Q. There was a pocket knife found on the basement counter?
A. Which I learned later, right.
Q. And was that ever sourced, to your knowledge?
A. No. My recollection of that is terribly vague because I don't know when we talked about those
thousand-plus pieces of evidence collected, those were potential pieces of evidence, I think that the
pocket knife may have been collected, but I don't know. There was the suggestion that I overheard
that that belonged to Burke.
Q. Was that ever sourced to Burke?
A. Not prior to me leaving.

If it was not on her body or clothes - - - I wonder.

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  What did YOU hear?
Posted by: jameson245 - 03-25-2017, 10:47 AM - Forum: 911 call - Replies (4)

When I listened to the 911 tape that was sent to me by the DA's office, I heard Patsy calling in and the dialog between her and The 911 operator, Kim Archuletta.  I heard the 911 operator calling Patsy's name and it was clear Patsy had hung up.  I fully believe at that time Patsy was still hysterically speaking.  I don't think you end that call and go silent - she was likely speaking to John and he would have been talking back.  But I note that none of that is heard - - and if the phone had not been hung up completely, well, the volume wouldn't have been cut down - the conversation would have been taped.

But there was nothing there.

I believe the noises heard are the reel to reel tape recorder running the tape at Archuletta's end.

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  INTERESTING - from Steve Thomas' deposition
Posted by: jameson245 - 03-25-2017, 10:27 AM - Forum: 911 call - Replies (4)

Q. (BY MR. HOFFMAN) All right. That's really all I need to know. Now, I want to ask you about
the 911 tape which was -- became controversial because of alleged background noise and voice,
possible voice identifications. Did you ever have occasion to listen to the 911 tape analysis that was
done by a lab in Los Angeles or somewhere in California purportedly to show that Burke's voice was
on the back of that tape?

A. Yes.
MR. WOOD: He listened to the analysis?
Q. (BY MR. HOFFMAN) Did you ever have occasion to hear the tape and actually hear what the
people were reporting as being Burke's voice in the background?
A. Not on the aerospace engineering equipment but on lesser equipment inside the Boulder Police
Department, yes.
Q. So it was actually audible on that equipment at the Boulder Police Department?
A. No, Mr. Hoffman, let me make sure I understand you. What are you -- what was audible?
Q. Burke's or the voice of someone who could have been Burke Ramsey talking in the background
at the very end of Patsy Ramsey's, you know, conversation with 911.
A. Well, you're cutting right to the punch line. There is a long story behind it but, yes, myself and
others listened to that tape and heard this third voice.
Q. So do you -- were you able to identify that third voice, you personally?
A. Well, I don't have any training in voice identification, but certainly it sounded to me to be a young
male voice.
MR. WOOD: Are you asking him, Darnay --
Q. (BY MR. HOFFMAN) Were you able to draw based on your own personal experience of
hearing this tape that there was a voice of somebody who sounded like a young boy?
A. Yes, that was my personal observation coming away from that.
Q. Do you have any reason to believe that that voice could have been the voice of Burke Ramsey?
A. That's what I believe.
Q. Is it based on ever having heard Burke Ramsey speak?
MR. WOOD: You're talking about just listening to the child speak, whether or not he has done a --
that's a sufficient voice exemplar for testing purposes?
MR. HOFFMAN: No, no. I just want to know in the same way that you can look at handwriting for,
you know, purposes of article 9 -- article 900 in the Rules of Evidence, that whether or not based on
own personal experience if he's ever heard Burke Ramsey and whether or not he thought that was
Burke Ramsey based on his own knowledge of what Burke Ramsey sounded like.
MR. WOOD: I understand. I'm not -- he can answer. But I'm certainly notacceding to your
interpretation of rule, whatever you're talking about, article 900.
MR. HOFFMAN: Okay. Well, I'm not asking you to accede. Actually, Lin, you don't really even
have to be involved in this, so quite frankly it's my question --
MR. WOOD: I will because I represent --
MR. HOFFMAN: And I don't know if it's appropriate for you to always to be trying to clarify it and
put your spin on it. I'm asking Mr. Thomas whether or not --
MR. WOOD: Why don't you ask him a question --
MR. HOFFMAN: -- he could identify the voice as being that --
MR. WOOD: -- that makes some sense and I might not have to try to clarify it.
MR. HOFFMAN: -- of Burke Ramsey.
MR. WOOD: Why don't you just ask him a straight-up question. I want to make sure and I have a
right to make sure that the record is understandable. You may not like that and I'm not trying to spin
it. I'm trying to make sure we understand because candidly and respectfully some of your questions
are difficult to follow which apparently --
MR. HOFFMAN: Okay. Well, you know, you have that problem yourself, Lin. So and I've --
MR. WOOD: I agree.
MR. HOFFMAN: -- heard Mr. Diamond have to go in and ask for clarification; lawyers sometimes
have that problem --
MR. WOOD: I agree.
MR. HOFFMAN: -- not personal to you or to me.
MR. WOOD: I don't disagree with you.
MR. HOFFMAN: The fact is --
THE REPORTER: One at a time, please.
MR. HOFFMAN: I would like to be able to ask Steve Thomas this question without your helping with
the clarification of it.
MR. WOOD: Well, just as long as the record -- go ahead and ask him the question. I just want to
make sure that I have the right to understand what you're asking, too. But go ahead and ask him and
let's get an answer.
Q. (BY MR. HOFFMAN) Okay. Do you have any reason to believe that the voice was Burke
Ramsey that you heard on the tape?
A. Yes, that's my belief and, absent there being other parties of whom or which I'm unaware in the
house that morning, this third party to me is believed to have been Burke Ramsey.
Q. What do you base that belief on --
MR. WOOD: I think your time is up, Darnay.
Q. (BY MR. HOFFMAN) -- that that voice is Burke Ramsey?
MR. WOOD: Darnay, I think your time is up. Is it up?
MR. WOOD: Go ahead and ask your last question. I didn't mean to cut you off.
MR. HOFFMAN: Given the fact, Lin, that you've interjected and eaten a little of my time up, I think
you should allow me that. Thank you.
MR. WOOD: As long as it doesn't cut into my time of what I know today to be 3 hours and 50
Q. (BY MR. HOFFMAN) Mr. Thomas, can you answer that?
MR. DIAMOND: It cuts into my time, Darnay.
MR. WOOD: I don't think you have time today.
MR. DIAMOND: I've got time to go home. Go ahead, ask your question.
Q. (BY MR. HOFFMAN) Yes. Mr. Thomas, is there any -- what is the basis for your concluding
that the voice that you heard on the 911 tape was the voice of Burke Ramsey?
A. The basis of that and very -- having to synopsize this for you, Mr. Hoffman --
Q. Um-hum.
A. -- was Detective Hickman's travel to the Aerospace Corp. in Southern California, their
enhancement of that garbled noise at the end of that 911 call, those engineers preparing a report and
making findings I think identical to the detective who was there with the tape, her returning to the
Boulder Police Department with this information and then each of the detectives listening on
lesser equipment inside the Boulder Police Department to these findings, I concurred with others that
there was a third voice on that tape that I believed to be Burke.
MR. HOFFMAN: Thank you very much, Mr. Thomas.
THE DEPONENT: Thank you, Mr. Hoffman.


MR. WOOD: If we can go for about five or a few minutes I want to just kind of touch on a few things
that you brought up, Darnay, and then we will break for lunch.Is that okay guys?
MR. DIAMOND: That's fine.
Q. The FBI analyzed the 911 tape and they did not find any such language, true?
A. I don't know what the FBI and Secret Service did because it was my understanding there may
have been equipment that was incompatible to conduct this testing or for whatever reason but bottom
line is the Secret Service and --
Q. The FBI?
A. Federal Bureau -- yeah, were unable to --
Q. They didn't hear the voice that Aerospace heard, right?
A. I don't know what they did or didn't hear or what they did or didn't test. I don't -- I think one of
those agencies didn't even have equipment to test the tape.
Q. So you think the FBI didn't reach a conclusion with respect to the 911 tape; is that your
A. I don't know what the FBI or Secret Service concluded, I know what Aerospace did.
Q. And you also know that the tape was taken to a fourth group and they came up with different
words from the tape than what Aerospace had come up with, true?
A. I know that Mr. Hofstrom took the tape to his brother-in-law for enhancement.
Q. Are you suggesting that his brother-in-law somehow falsified a report?
A. Did I say anything like that?
Q. No, sir, I'm just asking you're not suggesting that, are you?
A. No, you mentioned a fourth testing facility and I simply replied that Mr. Hofstrom took the tape to
his brother-in-law.
Q. So for whatever reason the FBI doesn't hear the third party, the Secret Service doesn't hear the
third party, Aerospace claims to hear it and then the fourth group hears something different; is that a
fair generalization of the 911 tape?
A. I'm not sure that the first two agencies ever heard anything because I'm not sure they ever
listened to the tape. I'm just --
Q. Did you not bother to ask the FBI, I mean, you -- please, Mr. Thomas?
MR. DIAMOND: Two questions.
Q. (BY MR. WOOD) Did you ever bother to call the FBI and say, gentlemen, what did you find
about the 911 tape?
A. I'm sure Detective Hickman, whose assignment this was, may have done that.
Q. Well, what, did you ask Hickman what did the FBI say? You know, we've spent a lot of time
with the FBI, Tom, what did they say? Did you ask him?
MR. DIAMOND: Did he ask him what?
Q. (BY MR. WOOD) What the FBI had to say about the 911 tape?
A. Again, as I've said it's my understanding, Mr. Wood, that I don't know whether or not the FBI or
Secret Service even tested the tape. The first testing that was done on it, to my knowledge, was
through the Aerospace Corporation.
Q. And did you -- have you ever tried at any time as you sit here today to make any efforts to find
out about whether the FBI or the Secret Service even tested the tape and if so, what their results
A. I don't know that.
Q. Have you made any efforts is my question?
A. No.
Q. As we sit here today, you've never made any effort to find that out --
A. No.
Q. -- right? Am I right? Sometimes the no comes out differently. The question is you've never
made any such efforts to find out about the FBI or the Secret Service testing of the tape?
A. I have not made calls or efforts trying to determine that to the FBI or SecretService.
Q. As we sit here today you have not done that?
A. That's right.


Q. (BY MR. WOOD) Mr. Thomas -- yeah, I've got it -- the 911 tape. Did you ever hear any
explanation as to why that tape was garbled in part?
A. At some point during the investigation I recall the tape coming to Detective Sergeant Wickman's
attention initially because the 911 operator who took that call thought there may have been
something at
the end of the conversation that was unintelligible.
Q. I appreciate that information. But I would like to get to my question because my time is limited
today at least and whether we finish or not is another issue. But my question is, did you ever, sir, hear
any explanation as to why a portion of the 911 tape was garbled?
A. I'm not sure I understand your question. Are you asking me why --
Q. Yeah, was anybody trying to figure out why -- the 911 tape is a tape in realtime, isn't it?
A. Yes.
Q. And one would think that you would hear in realtime voices that are on the tape. You say there is
something garbled. Was there ever any attempt to find out why this portion of the tape might be
garbled and not discernible to the human ear without some scientific analysis? That's my question.
A. I don't think that it was garbled in the sense that there was a defect in the tape or something,
that's certainly not my understanding. I think the description of garbled was meant to include the fact
that as this phone was apparently being attempted placed back into the cradle, there was some
conversation that was not as clear as Patsy Ramsey speaking directly into the phone, to the 911
Q. You knew the phone from your investigation was a wall phone, didn't you?
A. Yes.
Q. Can you hear any effort on the tape to try to hang the phone up, a banging or a tapping or
anything of that nature?
A. The call obviously concludes with the line disconnecting but, no, not that I recall today without
listening to the tape of the phone banging.
Q. Do you know whether the 911 tapes that were being utilized at the time were recycled in the
sense that they might be taped over after a period of time?
A. I don't know.
Q. Was any effort made by the Boulder Police Department, to your knowledge, to try to ascertain
that information?
A. I would certainly think they did.
Q. But do you know the answer?
A. I don't have any knowledge of that.
Q. Secondhand or otherwise?
A. No.
Q. Take a look at your book, if you will, for me, page 15. Are you with me?
A. Yes.
Q. "In preliminary examinations, detectives thought they could hear some more words being spoken
between the time Patsy Ramsey said 'Hurry, hurry, hurry' and when the call was terminated." Have I
read that correctly?
A. Yes.
Q. Is that the truth, is that accurate?
A. Yes.
Q. "However, the FBI and the United States Secret Service could not lift anything from the
background noise on the tape." Have I read that correctly?
A. Yes.
Q. Is that the truth?
A. As we discussed earlier, yes.
Q. I thought you said you didn't know what efforts, if any, they had made earlier?
A. I said in one case at least I don't know that they had the proper or necessary compatible
equipment to try to enhance this tape, nor did I know of them ever submitting a report.
Q. All I would like to know is did the FBI to your knowledge or the Secret Service to your
knowledge ever send the tape back and say we don't have the proper equipment to see if we can lift
anything from the background noise on this tape?
A. Again, we have discussed that and that's my testimony, that not being my assignment, it was my
understanding that the tape came back from the FBI and the Secret Service without anything
but I recall there being an issue that somebody didn't have proper equipment to do the testing.
Q. Well, you don't say anything like that here. This is definitive. The FBI and the United States
Secret Service could not lift anything from the background noise on the tape. Is that a true statement
or not?
A. Whether, because they didn't have the correct machine or because they didn't lift anything if they
did do some testing, yes, that's a true statement.
Q. Why wouldn't you -- I mean with all due respect I don't think you were trying to do the Ramseys
any favors in this book. Why wouldn't you have said here that they couldn't lift anything from the
background noise on the tape but that may have been the result of inappropriate equipment. You
say that or discuss that in your book, did you?
A. If we're talking about the production of the book, it was certainly limited. I couldn't put
everything in this case into the content of the book.
Q. The bottom line is we're confident that someone in the Boulder Police Department can answer
the question about the findings by the United States Secret Service and the FBI about this 911 tape.
That's in the case file, isn't it?
A. Undoubtedly.
Q. Good. And I don't believe I asked you this; I wanted to. Are you aware of any attempts to take
a voice exemplar from Burke Ramsey and have it analyzed against the voice you think your human ear
tells you or because it's a third-party voice that it's Burke Ramsey, any efforts to do a scientific
by way of a voice exemplar between Burke Ramsey's voice and the voice you think might have been
his on the 911 tape?
A. I certainly never received an assignment like that, nor do I recall hearing or knowing of anyone
else who did.

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  possibly into porn
Posted by: jameson245 - 03-25-2017, 10:25 AM - Forum: THE KILLER - No Replies

Many pedophiles look for kiddie porn for excitement, easier to get porn than a living child.  So police got a search warrant and looked for porn on the Ramsey computer.  This is from Steve Thomas' deposition and supports what we now know - - there was no porn on any Ramsey computer.

VIDEO TECHNICIAN: The time is 6:23. We're going on the record.

Q. (BY MR. WOOD) Mr. Thomas, in terms of the search of the Ramseys' hard drive and their
computer, was anything found that was viewed as suspicious or incriminating in August?

A. There were, I think reams of documents that came off that recovered hard drive, but I think as
far as, I don't knowif the search included pornography, I think it did, nothing like that, but there was
other documents that were later used for Foster. But I --
Q. For handwriting analysis, I'm talking about beyond use for analysis of handwriting, anything --
A. You mean suspicious?
Q. Or incriminating?
A. I would have to flip back through it.
Q. Anything that jumps out at you as we sit here today?
A. No.
Q. And certainly there is never any finding despite a fairly extensive search that in any way linked
the Ramseys to any type of pornography; am I right about that?
A. Not that I'm aware of.

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  Jayelles wrote
Posted by: jameson245 - 03-25-2017, 05:46 AM - Forum: DNA-X - No Replies

There was a time when a few brave BORG joined Webbsleuths and dared try (unsuccessfully) to make their case against the parents.

I came across an old post by BORG Jayelles and have to share it here.  She had not like a post I made, said I read it wrong or interpreted it wrog - - then she wrote this interesting thought:

NOWHERE did I say that I doubted they could link DNA-x to the crime. I said it WOULD point to an intruder IF it was found at the crime scene AND matched the markers from the other DNA found in her underwear and under her fingernails. We don't know where it was found or whether it matched the other DNA, but it would be an indisputable fact pointing to an intruder if it did.     


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  BORG evidence
Posted by: jameson245 - 03-25-2017, 05:30 AM - Forum: BORG theories and BORG people of note - Replies (4)

first a bit from Steve Thomas' deposition in the Wolf case:

Q. At page 232 of your book -- I apologize, I apparently have gotten the wrong cite in my record.
Oh, 236, I'm sorry, 236 where you say first paragraph under the line right here "With our Dream Team,
we tallied the points supporting probable cause and found more than 50 items."

A. Yes, I'm with you.
Q. When was that tally made? Date that for me.
A. Mr. Wood, I can't date it specifically but they assisted us in our preparation for the VIP
presentation and just a quick reading of this was maybe spring or late spring of '98. But no, it was
before that because later in the paragraph it talks about the Title-3, which was way back before
Christmas '97. So this was, I would guess, late '97, early to spring of '98.
Q. Can I -- I don't have the time today, at least, to ask you to go through and list those 50 items. But
can I be reasonably confident that if I set about myself in your book that I could find reference to those
50 items in this book, that you have included those somewhere in here?
A. No, I can't commit to that because of what was, I remember there was an easel that was used in
which everybody in the room put out evidence, information, that sort of thing that went on to this
50-plus point probable cause board.
Q. So it may have been all of your points, you may have --
A. It certainly wasn't.
Q. You may not agree with all of them?
A. Right.

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