March 30, 2001
COUNT TWO - SLANDER
106.
Plaintiffs John and Patsy Ramsey hereby incorporate, adopt and re-allege Paragraphs 1 through 28 of the Jurisdictional Statement of this Complaint, Paragraphs 29 through 52 of the Factual Statement of this Complaint and Paragraphs 53 through 105 of Count One of this Complaint as if fully set forth herein.
107.
Subsequent to the publication of the hardback book on April 10, 2000, Defendant Thomas has at various times participated in numerous media interviews in which he has verbally stated that Plaintiff Patsy Ramsey killed her daughter, JonBenét Ramsey, and wrote the ransom note and that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime.
108.
Plaintiff Patsy Ramsey did not kill her daughter, JonBenét Ramsey, and did not write the ransom note found in her home on the morning of December 26, 1996.
109.
Plaintiff John Ramsey did not engage in a criminal cover-up of any crime in connection with the murder of his daughter.
110.
A false statement made to the media imputing to another a crime punishable by law constitutes slander per se pursuant to O.C.G.A. § 51-5-4 (a).
111.
During ABC's April 10, 2000 broadcast of Good Morning America, Defendant Thomas slandered Plaintiff Patsy Ramsey by stating that she killed her daughter:
ELIZABETH VARGAS: You think Patsy Ramsey killed her daughter? STEVE THOMAS: I do.
112.
During CNN's April 14, 2000 broadcast of Larry King Live, Defendant Thomas slandered Plaintiff Patsy Ramsey by stating that Plaintiff Patsy Ramsey wrote the ransom note and, therefore, killed her daughter:
KING: Is it, in your opinion, if she wrote the note, she's the killer?
THOMAS: Absent some conspiracy, I don't think that's a tremendous leap to make.
113.
In the April 14, 2000 interview on Larry King Live, Defendant Thomas slandered Plaintiffs John and Patsy Ramsey by stating that Plaintiff Patsy Ramsey killed her daughter, JonBenét Ramsey, and that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime:
THOMAS: [A]nd people always ask, what kind of motivation is this? And I say in law enforcement circles, this is - under this hypothesis that I purport, that this was not an intentional killing, that this was accidental, initially, which, by definition, lacks motive, but then what happened, I think, a panicked mother instead of taking that next step, went left and covered this thing up. I don't think that - this isn't rocket science here…
KING: Well, you're saying they - you're saying one of them murdered their kid and the other is covering.
THOMAS: Certainly. And I think there's evidence to support that.
114.
During CNBC's April 17, 2000 broadcast of Rivera Live, Defendant Thomas slandered Plaintiff Patsy Ramsey by stating that she killed her daughter:
DAN ABRAMS: So the theory is that Patsy did it.
THOMAS: My theory - I certainly offer a hypothesis in this book - a couple of pages out of a 360-and-some-odd page book…
DAN ABRAMS: Well you know, that's what, that's the thing everybody's waiting to hear.
THOMAS: Certainly, and I think Patsy Ramsey committed this crime. I make no bones about it.
115.
During FOX News' April 17, 2000 broadcast of The Edge, Defendant Thomas slandered Plaintiff Patsy Ramsey by stating that she was involved in the killing of her daughter because she wrote the ransom note:
MODERATOR PAULA ZAHN: [Y]ou say the most compelling piece of evidence is the ransom note. You are 100% convinced she wrote that note?…
THOMAS: [T]he writer of the note is involved in the killing of the child. And I'm convinced, as are others, that she authored that note.
116.
During FOX News' April 24, 2000 broadcast of The O'Reilly Factor, Defendant Thomas slandered Plaintiff Patsy Ramsey by stating that she killed her daughter:
BILL O'REILLY: On a scale of 1% to 100%, how convinced are you that Patsy Ramsey is the killer here.
THOMAS: I'm convinced beyond a reasonable doubt, having seen all the evidence that I saw.
117.
During a May 11, 2000 interview on FOX-TV's Bookmark, Defendant Thomas again slandered Plaintiff Patsy Ramsey by stating that she killed her daughter and wrote the ransom note:
FOX BOOKMARK [PATRICK RILEY]: Assuming the readers haven't read the book yet, who killed JonBenét Ramsey?
STEVE THOMAS: Well it's my belief that the child's mother, Patsy, was involved in the death of her daughter. I'm not the sole voice or opinion that believes that, [but] I'm the first one from the government's position - this government that failed this case so miserably of which I was a part, that wouldn't even call her a suspect…
STEVE THOMAS: In a nutshell…I'm not a conspiracy theorist, [but] absent some great conspiracy, whoever wrote the note killed the child, and I am convinced beyond a reasonable doubt that [Patsy] wrote that note.
118.
During CNN's May 31, 2000 broadcast of Larry King Live, Defendant Thomas slandered Plaintiffs John and Patsy Ramsey by stating that Plaintiff Patsy Ramsey killed her daughter, JonBenét Ramsey, and that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime:
KING: Your theory is?
THOMAS: My theory is that Patsy, in a violent confrontation with her daughter . . .
KING: Accidentally killed her?
THOMAS: No, not - accidental, I hypothesize, in the sense that it lacked motive, not unlike . . .
KING: No motive.
THOMAS: Accidental in that sense. Excuse me, John, did you have something else?
J. RAMSEY: I've got lots else, but go ahead.
THOMAS: At that point, instead of making a right turn, she made a left turn and covered this up…
J. RAMSEY: I want to hear your theory, Steve. Let me ask you this: Are you prepared to state that Patsy killed JonBenét, that I covered it up, and that you can prove that in a court of law? Are you prepared to say that tonight?
THOMAS: I've written a book, and I stand by my book…
P. RAMSEY: What can you imagine? I can't imagine. I want to…you look at me and tell me what you think happened.
THOMAS: Actually, I will look you right in the eye. I think you're good for this…
119.
The slanderous statements uttered by Defendant Thomas were heard by tens of millions of Americans and citizens of other countries viewing the broadcasts of his media interviews.
120.
As a proximate result of the slanderous statements by Defendant Thomas, members of the public were led to believe that Plaintiff Patsy Ramsey killed her daughter.
121.
As a proximate result of the slanderous statements by Defendant Thomas, members of the public were led to believe that Plaintiff John Ramsey engaged in a criminal cover-up of his wife's crime.
122.
As a proximate result of the slanderous statements by Defendant Thomas, 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.
123.
As a proximate result of the slanderous statements by Defendant Thomas, Plaintiffs John and Patsy Ramsey's reputations have been permanently damaged.
124.
As a proximate result of the slanderous statements by Defendant Thomas, Plaintiffs John and Patsy Ramsey have suffered adverse physical consequences from stress, emotional distress and mental pain and suffering.
125.
As a proximate result of the slanderous statements by Defendant Thomas, Plaintiffs John and Patsy Ramsey have suffered public hatred, contempt and ridicule.
126.
As a proximate result of the slanderous statements by Defendants, Plaintiffs John and Patsy Ramsey have suffered a permanent impairment to their ability to obtain or maintain gainful employment.
127.
Defendant Thomas possessed actual knowledge of the falsity of certain of his slanderous statements made against Plaintiffs John and Patsy Ramsey and he acted with a reckless disregard for the truth or falsity of all of the false and defamatory statements uttered by him.
128.
The conduct of Defendant Thomas demonstrates willful misconduct and that entire want of care that raises a presumption of conscious indifference to consequences.
129.
Plaintiffs John and Patsy Ramsey are entitled to an award of punitive damages from Defendant Thomas in order to punish and penalize Defendant Thomas and deter Defendant Thomas from repeating his unlawful conduct.
WHEREFORE, Plaintiffs, John Ramsey and Patsy Ramsey, demand:
(a) That judgment be entered against Defendant, Steve Thomas, on Count Two of this Complaint for compensatory damages in an amount not less than Five Million Dollars ($5,000,000.00);
(b) That judgment be entered against Defendant, Steve Thomas, on Count Two of this Complaint for punitive damages in an amount not less than Ten Million Dollars ($10,000,000.00) to punish and penalize said Defendant and deter said Defendant from repeating his unlawful conduct; and
(c) That all costs of this action be assessed against said Defendant.
TRIAL BY JURY DEMANDED ON COUNT TWO
Continued on part 6...see below
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