36.
As of the date of the filing of this Complaint, the murder of JonBenét Ramsey has not been solved and no criminal charges have been filed against any individual in connection with her brutal murder.
37.
At the time of the murder of JonBenét Ramsey, Defendant Thomas was employed by the City of Boulder Police Department (hereinafter "the Boulder Police Department") as a police officer working undercover narcotic assignments.
38.
On December 28, 1996, Defendant Thomas was assigned to the JonBenét Ramsey murder investigation.
39.
The JonBenét Ramsey murder investigation was the first murder case investigated by Defendant Thomas in his law enforcement career.
40.
Defendant Thomas worked on the JonBenét Ramsey investigation from December 28, 1996 until June 26, 1998 when he took a leave of absence from the Boulder Police Department due to alleged health problems.
41.
Defendant Thomas resigned from the Boulder Police Department on August 6, 1998.
42.
Subsequent to Defendant Thomas' resignation, a grand jury was convened in Boulder County, Colorado in September of 1998, assigned the primary tasks of investigating the JonBenét Ramsey murder, hearing and obtaining evidence concerning the murder and determining whether probable cause existed under the evidence to justify filing a criminal indictment or charge against any individual in connection with the murder of JonBenét Ramsey.
43.
The grand jury investigation ended in October of 1999 without a criminal indictment or charge being filed against any individual in connection with the murder of JonBenét Ramsey.
44.
Prior to resigning from the Boulder Police Department, Defendant Thomas formulated a plan to publish a book about the JonBenét Ramsey murder investigation.
45.
Subsequent to his resignation, Defendant Thomas signed a book-publishing contract with Defendant St. Martin's Press to co-author with Defendant Davis a book about the JonBenét Ramsey murder investigation.
46.
As part of the financial consideration for the book-publishing contract, Defendant Thomas received an advance payment from Defendant St. Martin's Press estimated to be in the amount of several hundred thousand dollars.
47.
Defendant Thomas received the large advance payment from Defendant St. Martin's Press based in part on the fact that in an effort to increase book sales, Defendant Thomas agreed to publish confidential law enforcement information about the JonBenét Ramsey murder investigation that had not previously been disclosed to the public.
48.
Defendant Thomas received the large advance payment from Defendant St. Martin's Press based in part on the fact that, in an effort to increase book sales, Defendant Thomas agreed to publish confidential law enforcement information about Plaintiffs John and Patsy Ramsey and their family members.
49.
Defendant Thomas received the large advance payment from Defendant St. Martin's Press based in part on the fact that in an effort to increase book sales, Defendant Thomas agreed to state in his book that Plaintiff Patsy Ramsey killed her daughter, JonBenét Ramsey, and wrote a ransom note found in her home on the morning of December 26, 1996, and that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime.
50.
On April 10, 2000, Defendant Thomas, Defendant Davis and Defendant St. Martin's Press published the hardback book entitled JONBENÉT: INSIDE THE RAMSEY MURDER INVESTIGATION (hereinafter "the hardback book," said book being filed under separate cover as "Exhibit A" to Plaintiffs' Complaint).
51.
In December of 2001, Defendant Thomas, Defendant Davis and Defendant St. Martin's Press published the paperback book entitled JONBENÉT: INSIDE THE RAMSEY MURDER INVESTIGATION (hereinafter "the paperback book," said book being filed under separate cover as "Exhibit B" to Plaintiffs' Complaint) and included in it a "new update" in the Epilogue (the hardback book and the paperback book shall hereinafter be collectively described as "the books").
52.
Unknown officials of the Boulder Police Department, including, but not limited to, Defendants, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, actively participated in the publication of the book by providing Defendant Thomas with confidential law enforcement information about the JonBenét Ramsey murder investigation.

Continued on part 3...see below