The Lawsuit
#7
C. Key Facts About the Murder of JonBenét and Law Enforcement’s Investigation

108. Twenty years after JonBenét’s death, the perpetrator of her brutal murder has
never been identified, and no indictment has ever been filed by law enforcement prosecutors
against any individual in connection with her death.
109. JonBenét was six-years-old when she was brutally tortured, assaulted, and
murdered. Burke was just nine-years-old.
110. JonBenét competed in beauty pageants. In 1995, she held the title of Little Miss
Colorado Sunburst and on December 6, 1996, appeared in the Lights of December Parade at the
Boulder Mall.
111. On the night of December 25, 1996, the Ramsey family attended a Christmas
dinner at the home of their friends Fleet and Priscilla White.
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112. After the family returned home, John and Patsy put their children to bed and went
to bed themselves soon after.
113. The Ramsey family intended to rise early the following morning because they
were flying to Charlevoix for a family vacation.
114. John and Patsy awoke at approximately 5:30 a.m. on the morning of December
26, 1996, to prepare for their trip to Charlevoix.
115. John and Patsy were not awakened during the night.
116. Burke was not awakened during the night.
117. Burke did not leave his bedroom during the night.
118. Shortly after waking up, Patsy went down two flights of stairs from her room to
the main floor. On a step near the bottom of the stairs, she discovered a two-and-a-half-page
handwritten ransom note stating that JonBenét had been kidnapped (the “Ransom Note”).
119. Patsy screamed and rushed to check JonBenét’s bedroom, which was empty.
120. John heard the scream and rushed to find Patsy.
121. John and Patsy checked on Burke, who appeared to them to be sleeping in his
room.
122. Panicked and frightened, Patsy dialed 9-1-1 at approximately 5:52 a.m.,
breathlessly imploring the operator to send help (the “9-1-1 Call”).
123. After she hung up with 9-1-1, Patsy telephoned family friends, who promptly
came to the Ramsey home.
124. Police arrived shortly thereafter, but failed to properly secure the crime scene, a
failure that seriously compromised the crime scene.
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125. The Ransom Note stated that the kidnappers would call between “8 and 10 a.m.
tomorrow,” but the call never came.
126. To keep John occupied, Boulder PD Detective Linda Arndt instructed him to
search the home for anything unusual.
127. The Ramsey home had previously been searched by Boulder PD officers and
John’s family friend, Fleet White.
128. John and Fleet White began their search in the basement.
129. John and Fleet White first searched the playroom and observed, among other
things, a broken ground-level window and a suitcase beneath that window that was normally
stored in a different place.
130. John eventually searched what is often called the “wine cellar” in the basement
that served as a storage area (the “Wine Cellar”).
131. A Boulder PD officer had previously observed that the door to the Wine Cellar
was locked from the outside and did not open the door to inspect the room. Fleet White had
previously opened the door to the Wine Cellar but did not turn on the light in the room.
132. Despite prior searches by Fleet White and the Boulder PD, nobody had yet found
JonBenét’s body.
133. John opened the door to the Wine Cellar, turned on the light, and discovered
JonBenét’s body.
134. Duct tape covered JonBenét’s mouth, her wrists were tied above her head, and she
had a garrote embedded in her neck.
135. John scooped his daughter up in his arms and carried her body upstairs, crying out
for help.
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136. Detective Arndt observed JonBenét’s body and informed John that his daughter
was dead.
137. JonBenét was strangled to death with a torture and bondage device known as a
garrote.
138. The garrote was made from a nylon cord and a wooden handle fashioned from the
middle of a paintbrush discovered in Patsy’s paint tray in the boiler room in the basement. The
end of the nylon cord was tied to this wooden handle and, on the other end, was a loop with a
slipknot, with JonBenét’s neck within the loop.
139. Until her autopsy, it was not visually apparent that JonBenét also suffered a
massive blow to her head that fractured the right side of her skull – an injury that has been
described as the equivalent to an injury resulting from a fall from the third floor of a building.
140. The pathologist performing the autopsy on JonBenét’s body discovered that she
was sexually assaulted by being vaginally penetrated, including penetration with the broken
wooden handle of the garrote.
141. Defendant Spitz concurred during his examination in the 1990s that JonBenét was
penetrated with the broken wooden handle of the garrote.
142. JonBenét’s body showed many signs of a struggle with her attacker.
143. Although John and Patsy found themselves under suspicion by the Boulder PD in
connection with the investigation into JonBenét’s murder, the Boulder PD’s focus was on Patsy.
144. During the course of the investigation, John and Patsy sought repeatedly to
cooperate with investigators, including signing more than one hundred releases for information
requested by the police, and providing all evidence and information in their possession requested
by the police.
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145. John and Patsy gave the Boulder PD historical handwriting samples and
supervised written exemplars.
146. John and Patsy gave hair, including pubic hair, and DNA samples to police.
147. Burke also gave a DNA sample to the police.
148. John, Patsy, and Burke each consented to multiple interviews by law enforcement.
149. Burke was interviewed regarding JonBenét’s death on at least three occasions
outside the presence of his parents.
150. On December 26, 1996, John gave the Boulder PD handwriting exemplars for
himself and Patsy.
151. On December 26, 1996, John voluntarily provided police with a note pad Patsy
had previously used in their home. Law enforcement subsequently determined that the Ransom
Note was written on that pad.
152. Law enforcement consulted six qualified and highly respected experts in the field
of handwriting analysis, who performed extensive analysis of Patsy, John, and Burke’s
handwriting samples to the original Ransom Note.
153. All six experts conclusively eliminated John and Burke as authors of the Ransom
Note.
154. None of the six experts concluded that Patsy wrote the Ransom Note. Although
they could not determine with 100% certainty that Patsy did not author the Ransom Note, the
handwriting experts’ consensus was that the chances she wrote the Ransom Note were “very
low”:
During the investigation, the Boulder Police Department and Boulder County District Attorney’s Office consulted at least six handwriting experts. . . . All six experts agreed that Mr. Ramsey could be eliminated as the author of the Ransom Note. None of the six consulted experts identified Mrs. Ramsey as the author of
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the Ransom Note. Rather, the experts’ consensus was that she “probably did not” write the Ransom Note. On a scale of one to five, with five being elimination as the author of the Ransom Note, the experts placed Mrs. Ramsey at a 4.5 or a 4.0. The experts described the chance of Mrs. Ramsey being the author of the Ransom Note as “very low.”

Wolf Decision, 253 F. Supp. 2d at 1334; see Exhibit C.

155. The Ramsey home was not secure on the night of December 25, 1996. They had
not turned their security alarm on, and at least seven windows and one door were found unlocked
on the morning of December 26, 1996. A door from the kitchen to the outside was found open.
156. On the ground level of the Ramsey home, there was a removable grate over three
windows that opened into the playroom area of the basement.
157. The center window had a broken pane.
158. Law enforcement found scuffmarks and a suitcase positioned upright beneath the
center window leading to the playroom area of the basement (the “Window”).
159. The area around the Window showed clear evidence of a disturbance.
160. Leaves and white Styrofoam packing peanuts that had pooled in the Window area
appeared to have been cleared from, or brushed to either side of, the Window sill.
161. A shard of glass was found on the suitcase beneath the Window.
162. Green foliage was found tucked under the movable grate over the Window well.
163. Leaves and debris consistent with that found in the Window area were found on
the floor of the basement underneath the Window.
164. A leaf and white Styrofoam packing peanuts like those in the Window area were
found in the Wine Cellar where JonBenét Ramsey’s body was found.
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165. The end portion of the wooden handle and the cord used to construct the garrote
were never found in the Ramsey home; i.e., the perpetrator removed these items from the home
after killing JonBenét.
166. The duct tape covering JonBenét’s mouth was never sourced to the Ramsey
home.
167. Fiber evidence suggests that the cord and duct tape were, at one time, in the
second-floor area of the home near JonBenét’s bedroom.
168. Fibers consistent with those of the cord used to make the slip knots and garrote
were found on JonBenét’s bed.
169. Other items not belonging on the second floor of the Ramsey home were found
there on the day after the murder.
170. A rope was found inside of a brown paper sack in the guest bedroom on the
second floor.
171. Small pieces of the material of this brown sack were found in JonBenét’s bed and
in the body bag that was used to transport her body.
172. John and Patsy disclaimed ownership and knowledge of that rope.
173. An unidentified baseball bat was found on the north side of the house containing
fibers consistent with fibers found in the carpet in the basement where JonBenét Ramsey’s body
was found.
174. Brown cotton fibers found on JonBenét’s body, the garrote handle, the duct tape,
and the wrist ligatures were not sourced to and do not match anything in the Ramsey home.
175. Recently-made and unidentified shoeprints containing a “HI-TEC” brand mark
were found in the basement imprinted in mold growing on the basement floor.
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176. Neither John, Patsy, nor Burke owned any HI-TEC brand shoes at the time of the
murder.
177. The DNA of an unidentified male was found under JonBenét’s fingernails.
178. The DNA found under JonBenét’s nails did not match John, Patsy, or Burke’s
DNA.
179. The DNA of an unidentified male was found in the crotch of JonBenét’s
underwear.
180. The DNA found in JonBenét’s underwear did not match John, Patsy, or Burke’s
DNA.
181. The DNA found in JonBenét’s underwear was likely from saliva.
182. The DNA of an unidentified male was found on the left and right sides of the
waistband of the pajama bottoms worn by JonBenét at the time of her death.
183. The DNA found on JonBenét’s pajama bottoms does not match John, Patsy, or
Burke’s DNA.
184. The DNA found on JonBenét’s pajama bottoms was touch DNA.
185. The saliva DNA found on JonBenét’s underwear was consistent with the touch
DNA found on JonBenét’s pajama bottoms.
186. An unidentified Caucasian pubic or auxiliary hair was found on the blanket
covering JonBenét’s body and did not match hairs of John, Patsy, or Burke.
187. The medical examiner found the cause of JonBenét’s death was asphyxia by
strangulation with the garrote associated with craniocerebral trauma.
188. The medical examiner found physical evidence that conclusively established that
JonBenét was alive at the time she was asphyxiated.
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189. There were physical findings on her body that strongly suggested that JonBenét
struggled with her attacker and was conscious at the time she was garroted.
190. JonBenét’s neck had fingernail abrasions and scrapes in the area where the garrote
was embedded in her neck.
191. JonBenét had burn like marks on her face and back consistent with the application
of a stun gun. These marks were not present on JonBenét’s face in photos taken Christmas
morning.
192. The autopsy report revealed that although no head injury was visible when
JonBenét’s body was found, she received a severe blow to her head shortly before or after the
time of her death.
193. JonBenét was sexually assaulted shortly before her death.
194. Wood fragments from the paintbrush used to create the garrote were found in
JonBenét’s vagina.
195. JonBenét’s hymen was injured during the sexual assault, causing her to bleed onto
her underwear.
196. The City of Boulder recorded the 9-1-1 Call on a recycled tape that had
previously been used to record an unknown number of unrelated, prior 9-1-1 calls (the “9-1-1
Recording”).
197. After Patsy hung up her wall phone from the 9-1-1 Call, the 9-1-1 Recording
contains six seconds of inaudible background noise consistent with the sounds of computer
keystrokes being made by the 9-1-1 operator.
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