BURKE RAMSEY, a minor, by his

next friends and natural parents,:


CASE NO.: 1 03 CV-3976 (TWT) :




Fox News Channel,:

Defendant. :


I, JASON P. CONTI, declare as follows:

1. I am an associate at the law firm of Hogan & Hartson L.L.P., counsel for defendant Fox News Network, LLC (the "Fox News Channel" or "DefendanC') in this action. I have personal knowledge of the facts set forth in this Declaration and, if caIled as a witness, I could and would testify competently to such facts under oath. I submit this Declaration in further support of the Defendant's motion, pursuant to 28 U.S.C. § 1404(a), for an order transferring this action in its entirety to the United States District Court for the District of Colorado.

2. Although plaintiffs John Ramsey, Patsy Ramsey and Burke Ramsey (collectively the "Plaintiffs") filed their complaint in this Court, Plaintiffs have

relocated to Michigan. According to news reports, plaintiff John Ramsey is currently deciding whether or not to nm for political office in Michigan. A true and correct copy of a news article regarding John Ramsey's potential political activity in Michigan is annexed hereto as Exhibit A.

3. The current Boulder County District Attorney, Mary Keenan, has indicated that she is intent on pursuing new leads in the JonBenet case that do not involve Plaintiffs. A true and correct copy of an April 7, 2003 release trom the Boulder County District Attorney's office regarding the JonBenet investigation is annexed hereto as Exhibit B.

4. JonBenet's death also sparked a plethora of news coverage throughout the country. On April 6, 2004 I conducted a search on the LexislNexis site in the national news database "News, All (English Full Text)" for '''John Ramsey' or 'Patsy Ramsey' and 'JonBenet.'" LexislNexis automaticalJy interrupted that search because it yielded more than 3000 results.

5. Several national Internet sites contain pages dedicated to information related to JonBenet's death, including, among others: ;

http://www.courttv .comfnews/ramsey;} ; and


6. Plaintiffs began building a national (if not international) reputation less than a week after JonBenet's death when John and Patsy Ramsey participated in a CNN interview that aired on January 1, 1997. A true and correct copy of the interview is annexed hereto as Exhibit C.

7. John Ramsey has also admitted that prejudice is possible throughout the country. He was recently quoted as stating that during a recent visit to the capitol in his home state of Michigan, some legislative staffers treated him "like a leper." A true and correct copy of the article is annexed hereto as Exhibit D.

I declare under penalty of perjury under the laws of the United States of America and the State of New York that the foregoing is true and correct and that this Declaration was executed on April 22,2004 at New York, New York.







BURKE RAMSEY, a minor, by his

next friends and natural parents,



CASE NO.: 1 03 CV-3976 (TWT)


FOX NEWS NETWORK, L.L.C., d/b/a Fox News Channel,



This is to certify that I have on this date served a true and correct copy of the within and foregoing DECLARATION OF JASON P. CONTI IN FURTHER SUPPORT OF DEFENDANT'S MOTION TO TRANSFER VENUE upon counsel for Plaintiffs by Georgia Messenger courier service for hand delivery on this date, addressed as follows:

L. Lin Wood, Esquire


The Equitable Building

Suite 2140

100 Peachtree Street

Atlanta, Georgia 30303-1913


This 23rd day of April, 2004.


Georgia Bar No. 189329


One Atlantic Center

1201 West Peachtree Street

Atlanta~ Georgia 30309-3424

(404) 881-7000

(404) 881-7777 facsimile

Counsel for Defendant

- 2 -


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Rocky Mountain News: Local

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Rocky Mountain News

To print this page, select File then Print from your browser

URL: http://www.rockymountainnews.comjdrmnjlocaljartlCle/0.1299.DRMN_15_2774047.00.html Word's out on Ramsey as politician

Bid for House seat in Michigan reported

By Charlie Brennan, Rocky Mountain News

April 1, 2004

He's in.

That's the word in Michigan on John Ramsey's surprise leap back into the spotlight, this time in the political arena.


An on-line political journal, Michigan Information & Research Inc., reported Tuesday that the father of murder victim JonBenet Ramsey is a "go," practically certain to make a bid for that state's House of Representatives, running as a Republican.

The publication stated that after a recent candidate interview with Michigan Chamber of Commerce members, when asked to rate his likeliness to run on a scale of one to 10, Ramsey responded, "I'm a 10."

The journal attributed that anecdote to John Yob, a spokesman for Friends to Elect John Ramsey, which has registered with the Michigan secretary of state.

Yob did not return several telephone calls seeking comment.

Ramsey, along with wife Patsy and son Burke, moved last fall from Atlanta to Charlevoix, Mich., a small resort community where they had long owned a vacation home.

Now 60, Ramsey would be a candidate for Michigan's 105th House district, a Republican stronghold where the incumbent is barred from seeking another term.

John Haggard, chair of the Charlevoix County Republicans and a Ramsey backer, was not surprised to hear that Ramsey had rated the probability of his candidacy a "10."

"But I would say '11,' " said Haggard.

Ramsey's youngest child, 6-year-old JonBenet, was found murdered in the basement of the family's home Dec. 26, 1996, when they lived in Boulder.

Boulder Police Chief Mark Beckner once said the girl's parents were under an "umbrella of suspicion," but a 13-month grand jury probe into her death concluded in October 1999 without issuing an indictment. The crime remains unsolved.

The Michigan House is dominated by Republicans, and the four- county north Michigan district in which Ramsey lives has also been in Republican hands for many years.

Candidates must formally declare by May 11. yrint/l,1983.DRMN _] 5_2774047_ AR TICL.. 4/1/2004

Rocky Mountain News: Local

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Jennifer Duffy, a political analyst for the Washington, D.C.-based Cook Political Report, said Ramsey would be sure to become a campaign lightning rod, should he run.

Asked if she could recall a more unlikely political candidacy, Duffy didn't pause for a second in responding, "Arnold Schwarzenegger." or 303-892-2742

Copyright 2004, Rocky Mountain News. All Rights Reserved.

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D.A. Keenan concurs with order of District Court Judge Carnes

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Boulder County Colorado Govermmmt OnLine

BC Home Services County Government News Employment Search


7 April 2003

Contact: James Burrus, Media Information Officer, 303-441-1622

D.A. Keenan concurs with order of District Court Judge Carnes

From: Boulder County District Attorney Mary Keenan

I have carefully reviewed the Order of United States District Court Judge Julie Carnes in the civil case of Wolf v. John Ramsey and Patricia Ramsey. I agree with the Court's conclusion "the weight of the evidence is more consistent with a theory that an intruder murdered Jon Benet than it is with a theory that Mrs. Ramsey did so."

Although issued in the context of a civil case, the Court's ruling is a thoughtful and well-reasoned decision based on the evidence that was presented by the parties in that case. It should be read in its entirety.

John and Patricia Ramsey have been the focus of an exhaustive investigation with regard to the murder of their daughter, JonBenet, for more than six years. People charged with a crime are presumed to be innocent until proven guilty in court. Since Mr. and Mrs. Ramsey have not even been charged, much less convicted, they must be presumed innocent and must be treated accordingly.

For several months, my office has been investigating new and other unpursued leads, most of which involve the possibility that an intruder committed this crime. We are proceeding with the full cooperation of the Ramseys, Detective Lou Smit and the Boulder Police Department. We are all focused on the apprehension and successful prosecution of the killer of Jon Benet.


BC.Home I Services I County Government I News I Employment I Search

© Copyright 2002-2004 Boulder County. All rights reserved.

Questions or Comments email webmaster



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Copyright 1997 Cable News Network

All Rights Reserved



January 1, 1997; Wednesday 4:34 pm Eastern Time

Transcript # 97010101 V 16


SECTION: News; Domestic

LENGTH: 2158 words

HEADLINE: Interview With Parents of Slain Child Beauty Queen

GUESTS: LEXIS-NEXIS Related Topics Full Article Related Topics Overview

This document contains no targeted Topics.

BYLINE: Brian CabelL Natalie Allen: Lou Waters

HIGHLIGHT: An interview with the parents of the six-year-old girl who was found murdered in her basement on Christmas. The parents, John and Patricia Ramsey. say they will be hiring their own team of investigators, working in concert with Colorado officials, to find the killer.


NATALIE ALLEN. CNN ANCHOR: And Brian is here, he conducted an exclusive interview today with the child's parents, John and Patricia Ramsey.

BRIAN CABELL, CNN CORRESPONDENT: First of all, from a newsstand point, a couple of item's came out, the Ramsey are going to be putting together their own investigative team, they say. private investigates. This is not meant as any disrespect, they say, for the Colorado authorities. They just want the best mind possible, they say, looking into this cnme.

Secondly, they will be offering a reward perhaps as much as $50.000 starting next \'leek. It has been a very difficult week as you might expect for the Ramsey family, a very difficult interview as well, we talked to them for about 45 minutes.


CABELL (off-camera): Why did you decide you wanted to talk now?

JOHN B. RAMSEY, JONBENET'S FATHER: Well we have been pretty isolated -- totally isolated -- for the last five days, but we've sensed from our friends that this tragedy has touched not just ourselves and our friends but many people. And we know that there's many people that are praying for us, that are grieving with us. And we want to thank them. to let

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CNN EARLY PRlME, January 1, 1997

them know that we are healing, and that we kllOw in our hearts that JonBenet is safe and with God and that the grieving that we all have to do is for ourselves and for our loss, but we want to thank those people that care about us.

PATRlCIA RAMSEY, JONBENET'S MOTHER: We have just been overwhelmed by the cards and letters and visits and people we haven't seen for years have come to call and be supportive in their -- many of them are parents, and they know and can feel our grief.

RAMSEY, J: But the other -- the other reason is that -- for our grief to resolve itself we now have to find out why this happened.

CABELL: There has been some question as to why you hired a defense anomey.

RAMSEY, J: I know. Well, we were fortunate from almost the moment that we found the note to be surrounded by

friends, our minister, our family doctor. a personal friend of mine who is also an attomey, and we relied on their guidance almost from that moment on and my friend suggested that it would be foolish not to have knowledgeable counsel to help both us and with the investigation.

RAMSEY, P: And if anyone knows anything, please, please help us. For the safety of all of the children, we have to find out who did this.

RAMSEY, J: Not because we're angry, but because we have got to go on.

RAMSEY, P: We can't -- we can't -

RAMSEY, J: This -- we cannot go on until we know why. There's no answer as to why our daughter died.

CABELL: Are you fully convinced that your daughter was kidnapped by some outsiders outside your family or circle of friends?

RAMSEY, J: Yes. I -- we don't -- you know, it's just so hard to know. but we are -- our family is a loving family. It's a gentle family. We have lost one child. We know how precious their lives are.

CABELL: Mrs. Ramsey -- you found the note. Was it a handwritten note, three pages?

RAMSEY. P: I didn't -- I couldn't read the whole thing I -- I just gotten up. We were on our -- it was the day after Christmas, and we were going to go visiting, and it was quite early in the morning, and I had got dressed and was on my way to the kitchen to make some coffee, and we have a back staircase from the bedroom areas, and I always come down that staircase, and I am usually the first one down. And the note was lying across the -- three pages -- across the run of one of the stair treads, and it was kind of dimly lit.

It was just very early in the morning, and I started to read it, and it was addressed to John. It said "Mr. Ramsey," And it said, "we have your daughter." And I -- you know, it just was -- it just wasn't registering. and -- I may have gotten through another sentence. I can't -- "we have your daughter." and I don't know if I got any further than that. And I immediately ran back upstairs and pushed open her door, and she was not in her bed, and I screamed for John.

CABELL: John, you subsequently read the note. Was there anything in there that struck you in any sense?

RAMSEY, J: Well, no. I mean, I read it very fast. I was out of my mind. And it said "Don't call the police." You know, that type of thing. And I told Patsy, call the police immediately. And I think I ran through the house a bit.

RAMSEY, P: We went to check our son.

RAMSEY, J: Checked our son's room. Sometimes she sleeps in there. And we just were

RAMSEY, P: We were just frantic.

CABELL: How did you happen later to look in the basement?

RAMSEY, J: Well, we'd waited until after the time that the call was supposed to have been made to us, and one of the detectives asked me and my friend who was there to go through every inch of the house to see if there was anything unusual or abnormal that looked out of place.

RAMSEY, P: Look for clues I guess.

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CNN EARLY PRIME, January 1,1997

RAMSEY, J: Look for clues, asking us to do that, give us something more to do to occupy our mind, and so we started in the basement, and -- and we were just looking, and we -- one room in the basement that -- when I opened the door -there were no windows in that room, and I turned the light on, and I -- that was her.

RAMSEY, P: She was-


CABELL (on camera): Mr. Ramsey did confirm that duct tape was found on his daughter's mouth. I asked him about a cord found around her neck, that was a report out of Colorado today, he said he didn't see, it could have been there but he was panicked at that point. He picked up the body, ran screaming upstairs, hoping she was still alive, of course she was


There was also a reference to another child that was lost. They lost his daughter -- his adult daughter -- about four years ago in an auto accident. This is the second child they have lost.

Coming up in just a few minutes, we address the question -- I address the question -- to them of their being suspects themselves. That's natural in a case like this and we’ll ask them about that coming up.


LOU WATERS, CNN ANCHOR: At this hour we're concentrating on the murder of JonBenet Ramsey which has shocked and saddened many in her home town of Boulder, Colorado.

ALLEN: CNN’s Brian Cabell this afternoon had exclusive interview with her parents and he's here again with more of the emotional interview after the killing.

CABELL: As you know in cases like this it's very normal police procedure to look at the family first of all as possible suspects in this case. The Ramsey's say they understand this, they're well aware of the Susan Smith case a couple of years ago, they understand that possibly they would be looked at suspiciously and they say they accept this.


CABELL (off camera): You were asked shortly thereafter for a hair sample and writing sample, blood sample. Who else was asked for this?

RAMSEY, J: Well, Patsy and I, Burke, our son, who is nine, every family member.

CABELL: Including your two elder children?

RAMSEY, J: Uh-huh.

CABELL: Any friends?

RAMSEY, J: I don't know.

CABELL: Now, did you give the samples?

RAMSEY, J: Uh-huh.

CABELL Oh, really'? Because the word was that they thought you were too grief stricken. So both of you, you gave samples?


CABELL: Were you offended by that?


RAMSEY, P: It was difficult. But, you know, they need to know -- I mean our hand prints are all over our home, so they need to know if there's -- if there are other ones --

CABELL: The police said a couple of days ago, to assure other residents of Boulder there is no killer on the loose here, you can be assured everything is under control. You believe it's someone outside your home.

RAMSEY, P: There is a killer on the loose.

RAMSEY, J: Absolutely.

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CNN EARLY PRIME. January I, 1997

RAMSEY, P: I don't know who it is. I don't know if it's a he or a she. But if I were a resident of Boulder, I would tell my friends to keep -- keep your babies close to you, there's someone out there.

CABELL An FBI spokesman was quoted as saying at this point they don't regard it necessarily as a kidnapping. You think that's a wrong assumption?

RAMSEY, J: I don't know. I mean, there is a -- a note that said -- your daughter has been kidnapped. We have your daughter. We want money. You give us the money; she'll be safely returned.

RAMSEY, P: It seemed like kidnapping to me.

RAMSEY, J: J guess that's what concerns me because if we don't have the full resources of all the law enforcement community on this case, I am going to be very upset.

CABELL: Inevitably, speculation on talk shows will focus on you. It's got to be a sickening-

RAMSEY, J: It's nauseating beyond belief.

RAMSEY, P: You know, America has just been hurt so deeply with the -- this -- the tragic things that have happened. The young woman who drove her children into the water, and we don't know what happened with the 0.J. Simpson -- and I mean, America is suffering because have lost faith in the American family.

We are a Christian. God-fearing family. We love our children. We would do anything for our children.

CABELL: Do you truly think the perpetrator will be found?

RAMSEY, J: Yes. Yes. Has to be found.

CABELL: Do you think it's a single individual?

RAMSEY, J: Yes. In my heart I do.

CABELL: Do you take some comfort in believing that John JonBenet Ramsey is in a better place.

RAMSEY, J: Yes. That's the one thing we want people dealing with us to know, to believe that, we know that in our heart.

RAMSEY. P: She'll never have to know the loss of a child. She will never have to know cancer or death of a child.

RAMSEY, J: We learned when we lost our first child that people would come forward to us, that sooner or later everyone carries a very heavy burden in this life. And JonBenet didn't carry any burdens.


CABELL: The Ramseys are staying here in the Atlanta area with family right now. They say they intend to go back to Boulder within a few days, precisely when they're not quite sure. They say when they go back they will sit down with the Boulder police. They will talk. They will tell them anything they want to know.

ALLEN: Brian, are police saying anymore about the investigation? Leads or evidence from the home?

CABELL: Police have not been particularly forthcoming about leads perhaps deliberately so. but they have said very little as to forced entry, anything like that we simply do not know. The police are keeping that to themselves at this point.

WATERS: What's intriguing to me is the Boulder cop said -- assured the public -- there was no killer on the loose. Now, that suggests they may have a line on who did this. Isn't that what

CABELL: You start to question that, but keep in mind this was the first and only murder in Boulder this year so there was a bit of panic, a bit of alarm in the community. I think the police were simply trying to tell them: Don't worry we have everything under control, we have police out in the streets. They did step up their surveillance, so perhaps that's the way to explain that.

ALLEN: When was the last time they saw JonBenet Ramsey?

CABELL: When they put her to bed Christmas night, as a matter of fact, and sometime between the time they put her to bed and 5:50 or so the following morning she was apparently abducted from her bed.

WATERS: Did I hear the Ramseys are putting out some money to hire private investigators'!

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CNN EARLY PRlME. January I, 1997

CABELL: They will be assembling their own private investigative team, exactly how many individuals we don't know. but private investigators, attorneys, they say they want the best investigative minds in the country. They want to coordinate this with the authorities in Boulder and the Colorado Bureau of Investigation. But they are hiring their own people and offer a reward starting next week.

WATERS: What kind of reward?

CABELL: Fifty-thousand dollars was the figure he tossed out there. He wasn't absolutely certain but he thought it would be at least $50,000.

ALLEN: Was there something that struck you the most from your conversation with them?

CABELL: It's just looking at two parents, myself being a parent. It's very difficult to conduct an interview, very difficult to be interviewed about losing a six-year-old child especially in such a violent way.

WATERS: Did you try hard to get them to sit down and talk? Most folks, in this kind of situation, I would think, would be very reluctant to sit in front of a television camera.

CABELL They said that they had to get over this five of six days of grieving and burying their daughter, now they want to get on with this new stage of their life, and that is: finding the killer. They wanted to get this off their chest, they want to get this in motion.

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Traverse City Record-Eagle

March 16, 2004

CHARLEVOIX: Ramsey is ready to serve public

Record-Eagle/Douglas Tesner

John and Patsy Ramsey discuss John's plans to run for the Michigan House of Representatives in their Charlevoix living room.

JonBenet's death has helped him see others differently, he says


The Associated Press

CHARLEVOIX - John Ramsey acknowledges he forever will be known as the father of JonBenet - and that some people still consider him a suspect in the death of the child beauty queen whose unresolved murder became a tabloid sensation.

But Ramsey says he hopes voters in northern Michigan will focus instead on his business

experience and positions on the issues as he considers a bid for the state House.

"I'm not doing this for an ego trip or publicity or to see my name in the paper - I've already had

my fair share of that," he said Monday.

Instead, he said, the tragedy and its aftermath have inspired him to seek a way to contribute to


"I would like to make a difference," said Ramsey, sitting beside wife Patsy in the living room of the house they bought last fall in this Lake Michigan resort town, where the family previously spent summer vacations.

"We've taken a lot of abuse ... but we've been overwhelmed by the compassion, the sympathy, the anger at what was done to us. We've also seen what I guess I was a little bit blind to before all this, and that is that everybody's struggling, everybody's got a burden."

Although reluctant to invite another media onslaught by entering politics, Ramsey, 60, said his name recognition could prove helpful. "Like it or not, we've been given a voice that people listen to, if their only reason is out of curiosity.

The Ramseys were living in Boulder, Colo., when 6-year-old JonBenet was found beaten and

strangled in the basement of their home Dec. 26, 1996. A contestant in child beauty contests, she

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had won the titles of Little Miss Colorado and Little Miss Charlevoix.

The girl's parents insisted she had been killed by an intruder, but Boulder police described John and Patsy Ramsey as under an "umbrella of suspicion." A grand jury investigation ended without charges in 1999.

Last year, a federal judge said there was no evidence showing the parents killed JonBenet and considerable evidence pointing to an intruder. The district attorney in Boulder, Mary Keenan, agreed and took control of investigation from the local police.

The Ramseys' attorney, Lin Wood, said in December that a male DNA sample found on the

child's underwear had been submitted to an FBI database.

During the interview Monday, the Ramseys said they were optimistic the case would be solved

but knew the cloud of suspicion over them would never disappear.

"There will be people that think we were responsible after the killer is caught, convicted and executed," John Ramsey said. "That's just a fact of life, that's the way the world works. People that know us know the truth."

After spending several years in Atlanta, Ga., the Ramseys decided last fall to make Charlevoix their full-time residence so their youngest son, 17-year-old Burke, could finish high school there. John Ramsey lived in Michigan as a teenager and attended Michigan State University.

His wife has started a Web site development and promotion company. John Ramsey is assisting the project but not working full-time as he explores a legislative campaign. He said he was leaning toward running and would decide before the May 11 filing deadline.

Ramsey said he would emphasize his business background while seeking support in Michigan's 105th House District, a mostly rural area that includes Antrim, Charlevoix and Otsego counties and part of Cheboygan County. The incumbent, Rep. Ken Bradstreet, R-Gaylord, cannot seek re-election because of term limits.

Among Ramsey's ventures was Access Graphics, a billion-dollar company later acquired by Lockheed Martin. He said his experience was mostly with smaller high-tech firms that would do well in northern Michigan.

Describing himself as an "independent-minded Republican" who opposes abortion and gun control, Ramsey said he expected opposition from some within the party establishment. During a recent visit to Lansing, he said, some legislative staffers treated him "like a leper."

Jeff Storm, spokesman for the state GOP, declined conm1ent beyond noting that the party

doesn't take sides in primaries.

The Ramseys said more than a decade of hard times had strengthened their religious faith and

made John Ramsey more compassionate, and thus better suited for politics.

Another daughter, Elizabeth, was killed in a 1992 car crash. The next year Patsy Ramsey, now 47, was diagnosed with ovarian cancer. It went into remission but recurred three years ago, and she continues to undergo chemotherapy.

"We are deeper, more soulful," Patsy Ramsey said, clutching a family photograph from 1990

that shows her cradling baby JonBenet on her lap.

"I'm not afraid of dying like I used to be, because wherever JonBenet went, that's where I'm


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