August 2000 Patsy Ramsey Atlanta Interview (Fibers on Patsy's jacket)
0153
16 Q. You were shown, I believe,
17 photographs that were taken -- and this is
18 during your '98 interview -- photographs that
19 were taken at the White's house Christmas
20 night at dinner. In that you are wearing a
21 red coat, kind of a wool, wool jacket. Do
22 you recall seeing that?
23 A. It is kind of a black and red
24 and gray fleece.
25 Q. Cut more like a blazer than --
0154
1 A. Like a peacoat.
2 MR. WOOD: Well, the picture is
3 the picture, isn't it?
4 Q. (By Mr. Levin) Right, like a
5 peacoat. I just want to make sure we are
6 talking about the same thing. Do you
7 remember that jacket?
8 A. Uh-huh (affirmative).
9 Q. I would like you to give us a
10 little background on that coat, and again I
11 am not going to hold you to days of the
12 week, but do you recall, first of all, where
13 you purchased it?
14 A. Well, Priscilla had had one like
15 it that I admired. And she told me, I
16 believe she told me she got hers at EMS.
17 So I went there to look. And they didn't
18 have one or I didn't want to get one exactly
19 like hers. So I think I got that one at
20 Marshals in Boulder.
21 Q. Do you recall what year you
22 purchased it?
23 A. No.
24 Q. Let's -- I can understand that.
25 Now I am going to -- we will take a time
0155
1 frame. Was it a fairly, by your
2 recollection, was it a fairly recent purchase
3 that you had or was this a coat you'd had
4 for some period of time prior -- and, of
5 course, I am using it as the date of
6 JonBenet's murder.
7 A. Well, I can't remember. I am
8 sure I bought it in -- as it was getting
9 colder. So it was either probably fall of
10 '96 or '95.
11 Q. That, the coat that you wore the
12 night to the Whites, was it something that
13 was -- I mean, the primary color is red.
14 MR. WOOD: Well, don't fight over
15 -- excuse me, Patsy. Don't you have a
16 picture?
17 MR. LEVIN: I don't have a
18 picture with me.
19 MR. WOOD: Why characterize it.
20 It is what it is.
21 THE WITNESS: There is a picture.
22 MR. WOOD: It is in the picture.
23 Let's look at that.
24 MR. LEVIN: Just to expedite
25 things, because I am not fighting over the
0156
1 color, what I want to know is --
2 MR. WOOD: I think she said it
3 was red and black and gray.
4 THE WITNESS: A red and black and
5 gray check
6 Q. (By Mr. Levin) What I am, what
7 I am interested in is, I am certainly not
8 going to debate concentration of colors. It
9 is irrelevant. What I am interested in, is
10 it something that you wore exclusively during
11 the Christmas season or is this a coat that
12 you wore anytime it was appropriate for the
13 weather?
14 A. Anytime it was appropriate.
15 Q. So it is not like a special
16 Christmassy type, type of Christmas sweater,
17 I know you talked about Christmas?
18 A. (Witness shook head negatively).
19 MR. WOOD: Your answer is not,
20 because you are nodding your head.
21 THE WITNESS: No, it is not.
22 MR. WOOD: So the record is
23 clear.
24 Q. (By Mr. Morrissey) We were
25 provided that coat by, I believe, Ellis
0157
1 Armistead.
2 MR. TRUJILLO: Correct.
3 Q. (By Mr. Levin) What I would like
4 you to help us with is to understand how the
5 coat got from you to Ellis, if you know.
6 A. The -- I think you all requested
7 it.
8 Q. That is correct.
9 A. So I went to my closet, dug it
10 out, put it in a box, and sent it to Ellis.
11 Q. Was that coat something that was
12 taken -- you didn't wear that coat out of
13 the house when the police took you out of
14 the house the afternoon of the 26th. Do you
15 recall?
16 A. No, I don't think I did.
(SNIP)
0177
23 MR. MORRISSEY: Mrs. Ramsey, I am
24 sorry to interrupt you. Before you get
25 going too far, when was the last time you
0178
1 remember using the paint set?
2 THE WITNESS: Oh, god. Oh, you
3 know, probably that fall sometime, I --
4 MR. WOOD: Do you remember that,
5 Patsy? Be sure of your answer.
6 THE WITNESS: No, I don't
7 remember the last time I used it.
8 Q. (By Mr. Morrissey) Right. I am
9 not asking for a date.
10 A. Yeah.
11 Q. A season.
12 A. Yeah.
13 Q. And you indicate the fall? I
14 don't want to put words in your mouth.
15 A. Well, the last time I used it was
16 in conjunction with this art class that I
17 signed up to, and I can't remember when that
18 was exactly from CU. And all of my stuff
19 was there in the butler's pantry. But then
20 the holidays came, we needed that space, and
21 we moved all of the junk to the basement.
22 Q. Once it was moved to the
23 basement, you never hauled it up and painted
24 or anything? You never used it again?
25 A. No.
(SNIP)
0183
13 Q. (By Mr. Levin) Now, Mrs. Ramsey,
14 you -- are you aware, I should say, that
15 your paint kit was found very close to the
16 wine cellar door?
17 A. I have heard that.
18 Q. Did you recall at any time that
19 you were shown photographs in that regard?
20 A. No.
21 Q. We have found, and I want you to
22 help us, maybe you can offer an explanation
23 for this. We have found fibers in the paint
24 tray that appear to come off of the coat in
25 the photograph we showed you.
0184
1 A. In the paint tray?
2 Q. Yes.
3 A. What's a paint --
4 MR. WOOD: Hold on. Let him ask
5 you his question and then answer his
6 question. What is your question?
7 MR. LEVIN: I did.
8 MR. WOOD: You got your answer?
9 MR. LEVIN: Well, I got, she said
10 what's a paint tray.
11 MR. WOOD: No, she didn't. She
12 was following your question, in the paint
13 tray because you said we have found, and I
14 want you to help us, maybe you can offer an
15 explanation for this. We have found fibers
16 in the paint tray that appear to come off of
17 the coat in the photograph we showed you.
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August 2000 Patsy Ramsey Atlanta Interview (Fibers on Patsy's jacket)
0184
18 What is the question?
19 Q. (By Mr. Levin) Can you explain
20 for us how the fibers from the coat got in
21 the paint tray?
22 MR. WOOD: Are you stipulating as
23 a fact that the fibers that you say are in
24 the paint tray, in fact, came from that coat
25 that we earlier discussed, or is it simply a
0185
1 matter that you say they may have? Because
2 I am not going to let her answer
3 argumentative, hypothetical opinions. I will
4 let her answer if you are going to state it
5 as a matter of fact that that fiber came
6 from that jacket.
7 MR. LEVIN: I can state to you,
8 Mr. Wood, that, given the current state of
9 the scientific examination of fibers, that,
10 based on the state of the art technology,
11 that I believe, based on testing, that fibers
12 from your client's coat are in the paint
13 tray.
14 MR. WOOD: Are you stating as a
15 fact that they are from the coat or is it
16 consistent with? What is the test result
17 terminology? Is it conclusive? I mean, I
18 think she is entitled to know that when you
19 ask her to explain something.
20 MR. KANE: It is identical in all
21 scientific respects.
22 MR. WOOD: What does that mean?
23 Are you telling me it is conclusive?
24 MR. KANE: It is identical.
25 MR. WOOD: Are you saying it is
0186
1 a conclusive match?
2 MR. KANE: You can draw your own
3 conclusions.
4 MR. WOOD: I am not going to
5 draw my own conclusions.
6 MR. KANE: I am saying it is
7 identical.
(SNIP)
15 MR. KANE: Well, I am telling
16 you, it is -- is it conclusive in the sense
17 that, that there is something unique about it
18 that could only come from a particular item,
19 then the answer is no.
20 Is it that it is identical in all
21 respects to the fibers off of the jacket,
22 then the answer is yes.
23 Now, does that mean it is
24 conclusive?
25 MR. WOOD: It doesn't sound like
0188
1 it to me.
2 MR. KANE: Then you have got your
3 answer.
(SNIP)
0191
13 MR. WOOD: What if we left out
14 the fiber problem altogether and just simply
15 ask her whether or not she ever had the
16 jacket, the red and black, gray jacket in
17 the proximity of the paint tray. We don't
18 have to fight the question of what the fiber
19 is or isn't. Isn't that what you really
20 want to find out?
21 CHIEF BECKNER: Well, I think
22 that is probably what Bruce and Mike were
23 trying to get to is is there an explanation.
24 MR. WOOD: Well, but again, I am
25 not trying to prevent there from being an
0192
1 explanation as to the question of the jacket
2 in proximity to the paint tray, but I am
3 very much concerned about her trying to
4 explain something that may or may not be the
5 case scientifically based on opinion.
6 MR. LEVIN: I will rephrase the
7 question and maybe this will satisfy you.
8 MR. WOOD: Okay.
9 Q. (By Mr. Levin) Mrs. Ramsey, I
10 have scientific evidence from forensic
11 scientists that say that there's fibers in
12 the paint tray that match your red jacket.
13 I have no evidence from any scientist to
14 suggest that those fibers are from any source
15 other than your red jacket.
(SNIP)
0194
11 MR. MORRISSEY: Lin, if we charge
12 an intruder in this case, this is a question
13 that is going to get asked her.
(SNIP)
0195
16 MR. MORRISSEY: The problem is,
17 even if it is somewhat in dispute, it is
18 going to get asked. I mean, a judge is,
19 would, would allow that. And, and these are
20 questions, these kinds of questions are the
21 things we need to know the answer to if we
22 are confronted with a scenario where we have
23 to put Mrs. Ramsey on the witness stand and
24 subject her to, explain to us how is it that
25 fibers that are identified back to your,
0196
1 quote, coat as the source. Now, you know --
2 MR. WOOD: But her answer may be,
3 you know, did you check anything else?
4 MR. MORRISSEY: Well --
5 MR. WOOD: I mean, you know, the
6 intruder, what was, if you find the intruder
7 and you find clothing there, did you check
8 the intruder's clothing to see if it matches
9 the same, better, or whatever. I mean,
10 there are so many hypotheticals there that we
11 just have to know what we are talking about,
12 in all fairness, Mitch.
(SNIP)
0200
3 MR. LEVIN: I think that is
4 probably fair. Based on the state of the
5 art scientific testing, we believe the fibers
6 from her jacket were found in the paint
7 tray, were found tied into the ligature found
8 on JonBenet's neck, were found on the blanket
9 that she is wrapped in, were found on the
10 duct tape that is found on the mouth, and
11 the question is, can she explain to us how
12 those fibers appeared in those places that
13 are associated with her daughter's death.
14 And I understand you are not going to answer
15 those.
(SNIP)
0202
8 MR. LEVIN: I understand your
9 position.
10 In addition to those questions,
11 there are some others that I would like you
12 to think about whether or not we can have
13 Mrs. Ramsey perhaps in the future answer. I
14 understand you are advising her not to today,
15 and those are there are black fibers that,
16 according to our testing that was conducted,
17 that match one of the two shirts that was
18 provided to us by the Ramseys, black shirt.
19 Those are located in the
20 underpants of JonBenet Ramsey, were found in
21 her crotch area, and I believe those are two
22 other areas that we have intended to ask
23 Mrs. Ramsey about if she could help us in
24 explaining their presence in those locations.
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