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from Steve Thomas depo
"Thomas depo 41 - Stun Gun"
Q. 154, right here, second blocked out, second paragraph, "Experts engaged by the police concluded
there was no stun gun involved at all, but the DA's team never relinquished their claim that such
weapon an exotic weapon was used to subdue JonBenet." Have I read that correctly?

A. Yes.
Q. Who were the experts engaged by the police that you're referring; would you identify those for
A. I know at least one was Dr. Werner Spitz, and Detective Trujillo would be able to identify
Q. Did any of those -- any police department consultants discuss at either of the presentations in
terms of what they thought about stun guns whether there was consistency. For example, Dr.
A. I'm sorry, run it back by me, Mr. Wood.
Q. Was Dr. Deters -- the Larimer County coroner involved in the investigation by the Boulder Police
A. No, I'm not familiar with that name.
Q. How about Sue Kitchens of the CBI?
A. I am familiar with her name, but I do not know what extent she may have been involved in the
Q. How about Dr. Doberson?
A. I believe Trujillo and Wickman initially visited Dobersen on behalf of the police. But that was
later followed up by investigators Smit and Ainsworth.
Q. Dr. Doberson who I think you have a great deal of respect for?
A. I don't know Dr. Doberson.
Q. Do you recognize him, though, to be respected in the law enforcement community in Colorado?
A. I have no opinion. I don't know anything about Dr. Doberson.
Q. Do you know that he has stated within reasonable medical certainty that the marks on JonBenet's
face and back were caused by a stun gun. Are you aware of that?
A. Well, if you're telling me that's true --
Q. I'm just asking if you're aware of it. You said --
A. I saw that on --
Q. -- you watched some of the stuff. I'm just asking if that's what he said there?
A. Right.
Q. Did you watch the Tracy Mills documentary, two?
A. The second one, two?
Q. Yeah.
A. Two, as in the number two?
Q. Yeah, the second, there was one back a couple years ago, it's one that came out in the last
several months, haven't seen --
A. No, I haven't seen that.
Q. So you don't know what Dr. Doberson said in that, do you?
A. No.
Q. But he wasn't employed by the Boulder Police Department, among other things, to look at the
stun gun issue, true?
A. I don't know that he was employed but they went to him. Trujillo and Wickman I know did.
Q. What did the Boulder Police Department conclude caused these marks found on JonBenet
Ramsey's back?
MR. DIAMOND: Do you want to identify what you're putting in front of him just for --
MR. WOOD: I'm going to mark it and I'll do it by copy. I don't want to mark on this color copy but
this will be Defendants' 4.
MR. DIAMOND: Will you identify what it is for the record?
MR. WOOD: It's an autopsy photograph of JonBenet Ramsey.
MR. DIAMOND: Does it have a number on it or something?
MR. WOOD: I just put a number on it, a 4 just so I can copy it and mark it later. If you'll just hang on
to it. I don't want you to be flipping through there. There is one picture I am going to ask him about in a
(Exhibit-4 and Exhibit-5 marked.)
Q. (BY MR. WOOD) What did the Boulder Police Department determine caused those marks on
JonBenet Ramsey's back as shown on Defendants' Exhibit 4?
A. I don't know that the Boulder Police Department as an entity formed a consensus opinion, but
relying on the experts in this case, and Detective Trujillo specifically who was assigned to the stun gun
investigation told us and I remember seeing it that Werner Spitz concluded, I believe, what was believed
to be stun gun marks may have been a patterned object, if I recall correctly, or I think another
explanation was on her back lying on some sort of object.
Q. That was Dr. Spitz only?
A. Well, Dr. Spitz completed a report on that. I think Dr. Lee had some opinion on it. Certainly
Trujillo filed information about that.
Q. I'm going to show you defense Exhibit Number 5, which two photos, one is obviously Number 4
and then 5 is a picture of JonBenet's side of her face. There were two marks on her face. The marks
on her face and the marks on her back were the same distance apart, right?
A. I don't know that those were identical. I have heard --
Q. Do you deny that?
A. I have heard Mr. Smit say that they were identical. I have heard Trujillo say they're not.
Q. That the marks were not -- shouldn't one just measure this, sir?
A. Unfortunately you would have to, I think, triangulate it off of a photo because they weren't
measured, my understanding, at autopsy.
Q. Do you choose to believe Dr. -- Mr. Smit or Mr. Trujillo in terms of that issue or do you just not
have a position one way or the other in terms of the distance part of the two set matched pairs?
A. I don't believe necessarily either of them. But I have heard Mr. Smit and Mr. Trujillo had
conflicting measurements on that picture.
Q. But one thing for sure, you believe, I think you would say and have said before, that if a stun gun
was used on JonBenet that that is significant evidence that would point away from a family member or
parent, right?
A. I don't know where I have said that.
Q. You have never said that?
A. I don't know where I have said that, Mr. Wood.
Q. Do you deny that?
A. Refresh my memory. Where do you think I have said that?
Q. Do you deny that or is that accurate?
A. I think, and for the record let me just say, one other expert that I know the Boulder Police
Department consulted were I think stun gun reps, manufacturers or people in the stun gun industry.
Q. Do you know their names?
A. I don't. I think somebody from Air Tazer.
Q. Were there reports filed?
A. There certainly should be. As far as do I deny -- well, let me put my answer this way. I would
agree to an extent that it may be or would be less likely that a parent would be involved in the stun
gunning of a child. Maybe I'm naive in that thinking, as the FBI agents told us they have seen children
murdered in the most horrendous of ways, but I won't dispute you on that point today.
The coroner, John E. Meyer, M.D., had no experience with stun guns and the marks they leave.
When the BPD first went to Coroner Dobersen, they didn't show him all the photos and he was unable to identify the marks as being from a stun gun - - but when he later saw more photos, curtesy of Lou Smit - he thought testing was indicated to prove the marks WERE from a stun gun.
He later went on TV and said - “Unless some other evidence is presented to me, the most likely explanation for those injuries is that they were caused by a stun gun.”
Now what does Dobersen say? He says - - - well, I will let him say it:
MIKE DOBERSEN - "My experiments, and the observations that we made and all the work that's been done, I feel that I can testify to a reasonably degree of medical certainty that these are stun gun injuries."

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