March 30, 2001
COUNT THREE - INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
130.
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 and Paragraphs 106 through 129 of Count Two of this Complaint as if fully set forth herein.
131.
During the interview on CNN's May 31, 2000 broadcast of Larry King Live, Defendant Thomas stated:
J. RAMSEY:…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…
132.
Defendant Thomas' comment, "I think you're good for this" was directed to Plaintiffs John and Patsy Ramsey.
133.
By his remarks directed to Plaintiffs John and Patsy Ramsey, Defendant Thomas intentionally stated that they were guilty of crimes in connection with their daughter's death in 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.
134.
At the time Defendant Thomas intentionally stated that Plaintiffs John and Patsy Ramsey were guilty of crimes in connection with their daughter's death, Defendant Thomas had actual knowledge that there was no possibility that Plaintiffs John and Patsy Ramsey would ever be arrested, prosecuted or convicted for any crime in connection with their daughter's death, as evidenced by his many public statements to that effect, including, but not limited to, his statements in an interview on CNN's April 18, 2000 broadcast of Burden of Proof:
THOMAS…I agree that, at this point, a criminal prosecution and a beyond-a-reasonable-doubt threshold is unattainable…
135.
The conduct of Defendant Thomas as a former Boulder police officer involved in the JonBenét Ramsey murder investigation was intended by him to inflict emotional distress on Plaintiffs John and Patsy Ramsey as a form of "vigilante justice" because he knew that they would never be charged with any crime in connection with their daughter's death, due to a lack of evidence.
136.
The conduct of Defendant Thomas directed toward Plaintiffs John and Patsy Ramsey was intentional and reckless.
137.
The conduct of Defendant Thomas directed toward Plaintiffs John and Patsy Ramsey was extreme and outrageous.
138.
The conduct of Defendant Thomas directed toward Plaintiffs John and Patsy Ramsey was willful, malicious and wanton misconduct.
139.
The conduct of Defendant Thomas directed toward Plaintiffs John and Patsy Ramsey was of such serious import as to naturally give rise to such intense feelings of humiliation, embarrassment, and extreme outrage as to cause severe emotional distress.
140.
The conduct of Defendant Thomas directed toward Plaintiffs John and Patsy Ramsey was so insulting as to naturally humiliate and embarrass them.
141.
As a direct and proximate result of Defendant Thomas' wrongful conduct, Plaintiffs John and Patsy Ramsey have experienced severe emotional distress.
142.
The conduct of Defendant Thomas demonstrated willful misconduct and that entire want of care that raises a presumption of conscious indifference to consequences.
143.
Plaintiffs John and Patsy Ramsey are entitled to an award of punitive damages from Defendant Thomas in order to punish and penalize him and deter him from repeating his unlawful conduct.
WHEREFORE, Plaintiffs, John Ramsey and Patsy Ramsey, demand:
(a) That judgment be entered against Defendant Steve Thomas on Count Three 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 Three 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 THREE.
Continued on part 7...see below
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