When taken together, the tablet, the Sharpie pen, and the writing formed a powerful base of evidence. And that evidence pointed directly at Patsy Ramsey.

The hardback book at 74, the paperback book at 81 (emphasis added).
…[w]e pointed out that none of the expert document examiners, not even those hired by the defense, could eliminate Patsy Ramsey as the author. The CBI examiner explained that of the seventy-three persons whose writing had been investigated, there was only one whose writing showed evidence that suggested authorship and had been in the home the night of the killing and could not be eliminated by no less than six document examiners - Patsy Ramsey. I followed that up with a lengthy description of the findings by linguist Donald Foster, who had concluded that Patsy wrote the ransom note."

The hardback book at 306, the paperback book at 344.

That made five independent sources that would not rule her out, plus Chet Ubowski at the Colorado Bureau of Investigation, who thought she wrote it but could not say so under oath in a courtroom. And the Speckin Lab was ready to testify that there was only an infinitesimal chance that some random intruder would have handwriting characteristics so remarkable similar to those of a parent sleeping upstairs.

Taken together, the six opinions formed a strong body of evidence, but I wanted more - I wanted someone willing to stand in a court of law and decisively declare who wrote the note. I had no idea where to find such a person."

The hardback book at 200-01, the paperback book at 224 (emphasis added).

I finally heard the magic words while seated in the book-lined office of Don Foster…who just happened to be a hell of a linguistic detective. 'Steve,' said Foster, 'I believe I am going to conclude the ransom note was the work of a single individual: Patsy Ramsey.'
The hardback book at 261, the paperback book at 291 (emphasis added).
70.
Prior to the publication of the statements set forth in paragraph 69 above, Defendant Thomas had actual knowledge that the credible analysis of Plaintiff Patsy Ramsey's handwriting and the ransom note conducted by the Boulder Police Department did not identify Plaintiff Patsy Ramsey as the author of the ransom note, finding significant differences between her handwriting and the handwriting of the author of the note.
71.
Prior to the publication of the statements set forth in paragraph 69 above, Defendant Thomas had actual knowledge that the opinion of Don Foster, the so-called "linguistic detective," had been totally rejected by Boulder law enforcement officials in part based on the fact that on June 18, 1997, Foster had written a letter to Plaintiff Patsy Ramsey stating that after his review of the ransom note, he was "absolutely and unequivocally" convinced that she was innocent and did not write the note.
72.
The books contain the following libelous statements, among others, falsely conveying that Plaintiff Patsy Ramsey killed her daughter, JonBenét Ramsey, by fictionalizing Plaintiff Patsy Ramsey's background:

From a very young age, Patsy appeared determined to rise above her West Virginia upbringing to succeed, and showed that she appreciated the value of a good appearance. You could almost plot her progression from high school sweetheart to glamorous beauty queen to well-to-do hostess in the pretty front rooms of an expensive home. Her history showed she understood the value of drama and staging. The FBI would tell us that the disposal of the body of JonBenét had the classic elements of a staged crime, complete with a Hollywoodized ransom note.

The hardback book at 75, the paperback book at 82 (emphasis added).
73.
Prior to the publication of the statements set forth in paragraph 72 above, Defendant Thomas had actual knowledge that there was no evidence that Plaintiff Patsy Ramsey had any experience or understanding of crime scene "staging."
74.
The books contain the following libelous statements, among others, falsely conveying that Plaintiff Patsy Ramsey killed her daughter with a blow to her head during a rage or loss of temper over bed-wetting:

Nedra was chatty about almost everything else but became evasive when asked about the bed-wetting history of JonBenét…Could there have been a bed-soiling accident that night? Patsy was the only person who could tell us, and she wouldn't.

It is not unusual for a parent to lash out in unreasoning anger after becoming extremely frustrated with a child over toileting issues. It is also not unheard of for children to dirty themselves as a defense against sexual abuse and incest, intentionally making themselves unattractive to the offender. We let Nedra's evasiveness go for now but would later become convinced that bed-wetting played a significant role in whatever happened to the child.

The hardback book at 91-92, the paperback book at 102 (emphasis added).
75.
Prior to the publication of the statements set forth in paragraph 74 above, Defendant Thomas had actual knowledge that there was no physical evidence that JonBenét Ramsey wet her bed prior to her murder on December 25 or 26 and he had actual knowledge that the sheets on her bed were dry and not soiled with urine stains.
76.
Prior to the publication of the statements set forth in paragraph 74 above, Defendant Thomas had actual knowledge that there was no credible evidence that JonBenét Ramsey was sexually abused at any time other than the brutal sexual assault inflicted upon her in connection with her murder.
77.
Prior to the publication of the statements set forth in paragraph 74 above, Defendant Thomas had actual knowledge that there was no evidence that JonBenét Ramsey was a victim of incest.
78.
The books contain the following libelous statements, among others, falsely conveying that credible evidence existed in April of 1997 proving Plaintiff Patsy Ramsey was involved in the death of her daughter, JonBenét Ramsey:

The interviews with Patsy and John Ramsey produced no earthshaking revelations… But at the end of the day, I concluded that as investigators, we had reached our goal - we had established probable cause. And when Patsy Ramsey left that room, I believe she could have been in handcuffs and charged with involvement in the death of JonBenét.

The hardback book at 164, the paperback book at 184 (emphasis added).
79.
The books contain the following libelous statements, among others, falsely conveying that in the police interview of April of 1997, Plaintiff Patsy Ramsey was close to confessing involvement in the death of her daughter, JonBenét Ramsey:

The only time her composure broke was when she was asked to describe the discovery of her daughter's body. She dissolved into weeping, and although it was touching, it was also her weakest point of the session and the time for me to press harder, to really exploit the opportunity. But just as I was about to allow an opening by suggesting, "It was an accident, wasn't it? You didn't mean for this to happen, did you?" Pat Burke and Pete Hofstrom ruined the moment, consolingly saying "Let's take a break." Our own DA's chief trial deputy helped destroy what in my opinion was the best opportunity of the day. By the time the interview resumed, Patsy Ramsey had gotten her wind back. I felt she knew she had dodged a bullet.

The hardback book at 167-68, the paperback book at 188 (emphasis added).
80.
The books contain the following libelous statements, among others, falsely conveying that Plaintiff Patsy Ramsey killed her daughter because Boulder District Attorney Alex Hunter allegedly believed she was the killer:

Chief Koby would also tell me later that District Attorney Alex Hunter thought "from day one that Patsy did it"...
The hardback book at 176, the paperback book at 197 (emphasis added).
81.
The books contain the following libelous statements, among others, falsely conveying that Plaintiff Patsy Ramsey killed her daughter because Boulder Chief of Police Mark Beckner allegedly believed she was the killer:

I asked Beckner point-blank if he thought the Ramseys did it, and he took a deep breath. Yes, he said, one or both were involved.
The hardback book at 232, the paperback book at 258 (emphasis added).
82.
The books contain the following libelous statements, among others, falsely conveying that Plaintiff Patsy Ramsey killed her daughter:
Only a few hours later a letter arrived from Patsy Ramsey, written in flowing script, dated almost two weeks before, and delivered to the police department by a Team Ramsey lawyer. The contents would have been startling had we not been so familiar with her empty promises.

They were ready to work closely with Beckner "in any way," the letter said, and meet anytime "in the spirit of cooperation to achieve a common goal." But the letter contained the large caveat that they would speak with the "capable professionals" in the district attorney's office. It was bogus. How could they pledge to help a police commander in any way while simultaneously refusing to meet with his detectives? We warned Beckner to be wary.

"Don't let Patsy fool you with that letter," Wickman said. Detective Harmer added, "Patsy is in total denial. She's rationalized this in her mind and can probably even visualize an intruder."

The hardback book at 243-44, the paperback book at 270-71 (emphasis added; italics in original).
83.
The books contain the following libelous statements, among others, falsely conveying that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime by allegedly removing evidence from the scene of the murder on the day after the death of his daughter:

…John was overheard to ask someone quietly, "Did you get my golf bag?" When I learned of that statement, it seemed totally out of order. There had been two golf bags in the house, but he had not specified which one he wanted. Neither bag was collected by police. Moreover, it was winter in Colorado, Michigan, and Georgia, not exactly optimal golfing conditions. Why would a man whose daughter had just been murdered be wanting his golf clubs anyway? I wondered what else might have been in the bag that was so important that Ramsey would even think to ask about it.
The hardback book at 48, the paperback book at 53 (emphasis added).
84.
The books contain the following libelous statements, among others, falsely conveying that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime because he allegedly did not ask police officials for information on December 27, the day after his daughter's body was discovered:

The session lasted only forty minutes, during which time the detectives learned little. Ramsey asked no questions about the murder, the autopsy, or how JonBenét was killed. I later considered this very peculiar behavior. Parents usually want to provide information as soon as possible to help police find who harmed their child before the trail goes cold.
The hardback book at 48, the paperback book at 53.
85.
The books contain the following libelous statements, among others, falsely conveying that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime because the books falsely state that he lied in his statements to the police:

I had always considered that [John] Ramsey might have known something before he entered, and with this new admission of going to the basement earlier, I was sure of it. By the time he went back downstairs with Fleet White, I thought he knew exactly where the body was.

The hardback book at 172, the paperback book at 193 (italics in original).
86.
In addition to restating verbatim the libelous statements initially published in the hardback copy, the paperback book on its back cover states specifically that it provides the reader with "the information you've been waiting for: Who really killed JonBenét?"
87.
Like the hardback book, the paperback book viewed as a whole, as well as specific false and defamatory statements published therein, falsely conveys to the average reader that Plaintiff Patsy Ramsey "really" killed her daughter, JonBenét Ramsey.
88.
Defendant Thomas and Defendant Davis jointly authored the books.
89.
The acts and omissions of Defendant Thomas and Defendant Davis are imputed to Defendant St. Martin's Press as a matter of law.
90.
The state of mind of Defendant Thomas and Defendant Davis with respect to the publication of the false and defamatory statements about Plaintiffs John and Patsy Ramsey, including their knowledge or lack of knowledge regarding the truth or falsity of those statements, is imputed to Defendant St. Martin's Press as a matter of law.
91.
The false and defamatory statements about Plaintiffs John and Patsy Ramsey were negligently published by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press and were published with a reckless disregard for the truth or falsity of the statements.
92.
Defendant Thomas, Defendant Davis and Defendant St. Martin's Press wrote, edited and published libelous statements about Plaintiffs John and Patsy Ramsey with actual knowledge that they had not been arrested or charged with any crime in connection with the death of their daughter, JonBenét Ramsey, and that they would not be arrested, prosecuted or convicted for any crime in connection with her death.
93.
Defendant Thomas, Defendant Davis and Defendant St. Martin's Press wrote, edited and published libelous statements about Plaintiffs John and Patsy Ramsey with actual knowledge that no criminal charges had been filed against Plaintiffs John and Patsy Ramsey and no criminal charges would be filed against them in connection with their daughter's death, despite almost three and one-half years of intensive investigation by the Boulder Police Department and the Boulder County District Attorney's Office, aided by four veteran district attorneys and two assistant district attorneys from nearby Colorado counties and an alleged grand jury prosecution specialist from Pennsylvania, in addition to the 13-month investigation by the Boulder County grand jury.
94.
Despite his actual knowledge that Plaintiffs John and Patsy Ramsey would not be charged with any crime in connection with their daughter's death, and that they would not be arrested, prosecuted or convicted for any crime in connection with her death, Defendant Thomas, intentionally and with constitutional and common law malice toward Plaintiffs John and Patsy Ramsey, engaged in a public campaign of character assassination designed to convince the public that Plaintiffs John and Patsy Ramsey were criminally responsible for the death of their daughter.
95.
As a proximate result of the libelous statements by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press, members of the public were led to believe that Plaintiff Patsy Ramsey killed her daughter.
96.
As a proximate result of the libelous statements by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press, members of the public were led to believe that Plaintiff Patsy Ramsey authored the ransom note found in her home on December 26, 1996.
97.
As a proximate result of the libelous statements by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press, members of the public were led to believe that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime.
98.
As a proximate result of the libelous statements by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press, members of the public were led to believe that Plaintiffs John and Patsy Ramsey were individuals who were guilty of criminal involvement in the death of their daughter, JonBenét Ramsey.
99.
As a proximate result of the libelous statements by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press, Plaintiffs John and Patsy Ramsey's reputations have been permanently damaged.
100.
As a proximate result of the libelous statements by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press, Plaintiffs John and Patsy Ramsey have suffered adverse physical consequences from stress, emotional distress and mental pain and suffering.
101.
As a proximate result of the libelous statements by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press, Plaintiffs John and Patsy Ramsey have suffered public hatred, contempt and ridicule.
102.
As a proximate result of the libelous statements by Defendant Thomas, Defendant Davis and Defendant St. Martin's Press, Plaintiffs John and Patsy Ramsey have suffered a permanent impairment to their ability to obtain or maintain gainful employment.