149.
In furtherance of the Boulder Police conspiracy, as admitted by Defendant Thomas in the Author's Note to the books, the unknown Boulder Police co-conspirators were actively involved in the preparation of Defendant Thomas' book:
To certain members of the Boulder Police Department, cops who still cannot speak out publicly and who know this story all too well, I appreciate your continued support and the confidences you provided me in the preparation of this book.
150.
In furtherance of the Boulder Police conspiracy, prior to resigning from the Boulder Police Department, Defendant Thomas, with the active assistance of the unknown Boulder Police co-conspirators, unlawfully copied, confiscated and obtained documents and materials from confidential law enforcement files of the JonBenét Ramsey murder investigation and unlawfully obtained confidential law enforcement information about the JonBenét Ramsey murder investigation (hereinafter collectively "confidential law enforcement information").
151.
In furtherance of the Boulder Police conspiracy, after he resigned his position as a City of Boulder police officer, Defendant Thomas continued to receive confidential law enforcement information from the unknown Boulder Police co-conspirators.
152.
The information upon which Defendant Thomas relies in his book and in his media interviews as the basis for his false accusations that Plaintiff Patsy Ramsey killed her daughter, JonBenét Ramsey, and Plaintiff John Ramsey engaged in a criminal cover-up of her crime, is almost exclusively the product of, or directly derived from, the confidential law enforcement information.
153.
Much of the information upon which Defendant Thomas relies in his book and in his media interviews to support his false accusations that Plaintiff Patsy Ramsey killed her daughter, JonBenét Ramsey, and wrote the 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, is information that could not have been obtained by him or by the unknown Boulder Police co-conspirators except for the exercise of the state police power to investigate crimes under color of state law, including obtaining information through search warrants and consent forms.
154.
But for his former position as a Boulder, Colorado Police officer and the efforts of the unknown Boulder Police co-conspirators, Defendant Thomas would not have had access to confidential law enforcement information that was essential to his ability to write and publish the books.
155.
The Boulder Police Department obtained personal and private information from Plaintiffs John and Patsy Ramsey under color of state law and Plaintiffs John and Patsy Ramsey had a right to expect that Boulder police officers and officials would not unlawfully disclose confidential law enforcement information to the public and members of the media and that the information would not be utilized by Boulder police officers to write and publish a book about the investigation into their daughter's murder during an ongoing murder investigation.
156.
The illegal copying, confiscation, obtaining and misuse of confidential law enforcement information by Defendant Thomas and by the unknown Boulder Police co-conspirators deprived Plaintiffs John and Patsy Ramsey of their constitutional right to privacy under the Fifth, Ninth and Fourteenth Amendments to the U.S. Constitution, as it allowed for public disclosure of their private financial information, their private medical information and private facts about their personal lives that were only obtained by Defendant Thomas and the unknown Boulder Police co-conspirators through the exclusive state police power to investigate crimes under color of state law.
157.
Defendant Thomas and the unknown Boulder Police co-conspirators conspired to unlawfully copy, confiscate and obtain confidential law enforcement information for the purpose of making that information public and thereby making it available to private litigants for use in civil litigation against Plaintiffs John and Patsy Ramsey.
158.
The confidential law enforcement information published by Defendant Thomas, with the active assistance of the unknown Boulder Police co-conspirators, has been used to support essential elements of two civil lawsuits filed against Plaintiffs John and Patsy Ramsey, Linda Hoffman-Pugh v. Patricia Ramsey and John Ramsey, Civil Action File No. 1:01 CV-0630, U.S.D.C. (N.D Ga) and Robert Christian Wolf v. John Bennett Ramsey and Patricia Paugh Ramsey, Civil Action No. 1:00-CV-1187, U.S.D.C. (N.D Ga), which include accusations that Plaintiff Patsy Ramsey killed her daughter JonBenét Ramsey, and wrote the 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.
159.
Plaintiffs John and Patsy Ramsey's ability to defend themselves against these civil lawsuits that seek to put them on trial for the murder of their daughter is prejudiced by the fact that the plaintiffs in those actions have the benefit of the confidential law enforcement information published by Defendant Thomas with the active assistance of the unknown Boulder Police co-conspirators.
160.
Plaintiffs John and Patsy Ramsey's ability to defend themselves against these civil lawsuits that seek to put them on trial for the murder of their daughter is prejudiced by the fact that they do not have the ability to obtain relevant confidential law enforcement information about the investigation of their daughter's murder that would be strong and compelling evidence establishing their innocence.
161.
The illegal copying, confiscation, obtaining and misuse of confidential law enforcement information by Defendant Thomas and by the unknown Boulder Police co-conspirators deprived Plaintiffs John and Patsy Ramsey of their constitutional rights to due process of law and equal protection of laws under the Fifth and Fourteenth Amendments to the U.S. Constitution as it prejudiced them by subjecting them to civil lawsuits and by denying them the ability to fairly and fully defend themselves in said civil litigation.

162.
High-ranking Boulder Police officials believed to be among the unknown Boulder Police co-conspirators, as a matter of custom, policy and practice, have allowed members of the Boulder Police Department, including Defendant Thomas and the unknown Boulder Police co-conspirators, to leak confidential law enforcement information to the media and to allow for personal use of confidential law enforcement information by Boulder Police officers and officials in conjunction with seminars, presentations and various publications.
163.
High-ranking Boulder Police officials believed to be among the unknown Boulder Police co-conspirators were fully aware that Defendant Thomas and the unknown Boulder Police co-conspirators intended to utilize confidential law enforcement information in order to publish a book about the JonBenét Ramsey murder investigation while the investigation was still active and no charges had been filed against any individual in connection with the crime.
164.
In furtherance of the Boulder Police conspiracy, high-ranking Boulder Police officials, who are members of the unknown Boulder Police co-conspirators, deliberately and consciously took no administrative or legal action in an effort to prevent Defendant Thomas from illegally utilizing confidential law enforcement information in the books.
165.
In publishing his libelous book, Defendant Thomas and the unknown Boulder Police co-conspirators acted under color of state law and abused their status as a law enforcement officers by substantially contributing to an unlawful and unconstitutional "trial-by-media in the court of public opinion" of Plaintiffs John and Patsy Ramsey, individuals not charged with any crimes, who have been deprived by Defendant Thomas and the unknown Boulder Police co-conspirators of fundamental constitutional protections in criminal prosecutions, including the priceless right to a presumption of innocence.
166.
As a direct and proximate result of the Boulder Police conspiracy to deprive them of their constitutional rights of privacy, due process and equal protection of the laws, Plaintiffs John and Patsy Ramsey have suffered and continue to suffer damage to their reputations, incurred attorneys' fees and expenses in defending civil litigation and have suffered and continue to suffer severe mental anguish and emotional trauma in connection with the deprivation of the their constitutional rights under the Fifth, Ninth and Fourteenth Amendments to the Constitution of the United States and protected by 42 U.S.C. § 1983.
167.
The acts and/or omissions of Defendant Thomas and the unknown Boulder Police co-conspirators were committed under color of state or local law.
168.
In violation of 42 U.S.C. § 1983, the acts and/or omissions of Defendant Thomas and the unknown Boulder Police co-conspirators under color of state law, deprived Plaintiffs John and Patsy Ramsey of their rights, privileges, and immunities under the laws and Constitution of the United States, including the right of privacy, the right to due process and the right to equal protection of the laws secured by the Fifth, Ninth and Fourteenth Amendments to the United States Constitution.
169.
Defendant Thomas and the unknown Boulder Police co-conspirators acted with deliberate indifference to the constitutional rights of Plaintiffs John and Patsy Ramsey.
170.
Pursuant to 42 U.S.C. § 1988, Plaintiffs John and Patsy Ramsey are entitled to recover reasonable attorney fees as the result of the violations of 42 U.S.C. § 1983 by Defendant Thomas and the unknown Boulder Police co-conspirators as set forth herein.
WHEREFORE, Plaintiffs, John Ramsey and Patsy Ramsey, demand:
(a) That judgment be entered against Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four 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 Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four of this Complaint for punitive damages in an amount not less than Ten Million Dollars ($10,000,000.00) to punish and penalize said Defendants and deter said Defendants from repeating their unlawful conduct;
(c) That judgment be entered against Defendants, Steve Thomas and Unknown Officials of the Boulder, Colorado Police Department, including, but not limited to, Officer John Doe 1, Officer John Doe 2, Officer John Doe 3 and Officer Jane Doe, on Count Four of this Complaint for attorneys' fees and expenses in an amount shown to be reasonable and just by the evidence; and
(d) That all costs of this action be assessed against said Defendants.
TRIAL BY JURY DEMANDED ON COUNT FOUR.

L. LIN WOOD, P.C.

L. Lin Wood
Ga. State Bar No. 774588

Brandon Hornsby
Ga. State Bar No. 367680
Suite 2140
The Equitable Building
100 Peachtree Street, NW
Atlanta, Georgia 30303
404/522-1713 Attorneys for Plaintiffs
John Ramsey and Patsy Ramsey

Of Counsel: