[Copy furnished courtesy Justice Watch Forum]


Answer to Wolf's Amended Complaint Defenses

1-5 (In summary) the Wolf complaint "fails to state a claim" unpon which relief may be granted, for actual, compensatory or punitive damages, for presumed or inferred damages or for special damages.

6. Patsy did not killer her daughter

7. Patsy did not write the ransom note

8. John Ramsey knows Patsy did not kill their daughter and is not an accessory to the murder

9. Neither John nor Patsy did anything to "cover up" any crime connected to the murder

10. John and Patsy don't know who murdered their daughter or who wrote the ransom note.

11. The Ramseys have not tried to direct suspicion from themselves but sought information and evidence to find the intruder

12. The information in DOI is true

13. In the book, Wolf was described as one of numerous suspects, not as the murderer.

14. The police named Wolf a possible suspect and Wolf spoke on TV about being a suspect BEFORE the Ramseys book was published.

15. The lawsuit is not being brought because of real injury but as "a publicity stunt".

16. If anyone other than the ramseys had written those same things about Wolf, Wolf would not be suing. He is only sung because the authors are the Ramseys and that violates their first amendment rights.

17. Wolf's claim that the Ramseys killed their daughter is not supported by the actions of the authorities -- the Ramseys have never been charged, the gj didn't indict them.

18. As a limited public figure, Wolf has to prove the book was written with "actual malice", that the Ramseys knew it was false and didn't care. Wolf can't prove that.

19. To prove "actual malice", Wolf has to prove the Ramseys had serious doubts about the accuracy of their statements and he can't do that.

20. To prove "actual malice", Wolf has to prove the Ramseys knew their statements were probably false and he can't do that.

21. DOI is substantially accurate.

22. DOI is, in part, a "good faith report based on information received from police."

23. DOI is protected by the legal doctrine of fair comment.

24. Some of the claims are barred by the statute of limitations.

25. Some or all of the statements in DOI about Wolf are stated as opinion and are privileged.

26. The statements in DOI were made in good faith.

27. The statements in DOI were not made with any ill will or malice.

28. Wolf never demanded a retraction so his claim for punitive damages is barred.

29. Statements in DOI about Wolf were "made in good faith and in pursuit of a public duty."

30. Statements in DOI about Wolf were "made in good faith and in pursuit of a private duty."

31. Statements in DOI were made "bona fide and in good faith in the intent to protect the interests of the defendants."

32. The statements in DOI are not defamatory.

33. Wolf was injured by third parties, not the Ramseys.

34. The actions of the Ramseys were not the "proximate cause of any injury to the plaintiff."

35. Wolf suffered no severe emotional distress because of the Ramsey actions.

36. A reasonable person would not be offended by the Ramseys hiring private investigators to follow leads in in connection with the murder of their daughter.

37. Wolf admits to being limited public figure here so being investigated by those investigators was not "outrageous."

38. Neither John NOR Patsy told their investigators to take any action in regard to Wolf

39. The Ramseys hired investigators to obtain truthful information, not to inflict emotional distress on anyone.

40. Deals with Wolf's suit.



1-6 - admitted

7-9 - admitted

10 and 11 - denied

12 - Denied as stated.

13 - denied EXCEPT that "the death of JonBenét Ramsey has been the subject of massive international media coverage."

14 - J&P Ramsey did give the police names in response to police inquiries - the rest of the paragraph is denied.

15 - defendants can't deny or confirm - - they don't have enough information.

16 - admit all but the last sentence - - deny that

17 - admit JR believes patsy is innocent and has said so publicly JR did publish a profile of the killer. It does not fit Wolf. No reasonable person would think JR was describing Wolf. The rest of the paragraph is denied.

18 - admit ramseys hired investigators to follow leads - -rest of paragraph denied

19 - JBR was the victim of a homicide, was 6 years old and may have been sexually assaulted - the rest of the paragraph is denied

20 and 21 - denied

22 - Ramsey investigators did give information on Wolf to Boulder law enforcement -- rest of paragraph is denied

23 and 24 - the quotes are correct, the rest denied

25 and 26 - denied27 - Quote correct, broadcast accurately described, the rest denied

28 - denied

29 - Ramseys admit they wrote the book and spoke out to help find the killer and to keep the investigation alive - - deny the rest.

30 through 33 - "Defendants incorporate the responsive averments to paragraphs 1-29 and deny the rest.

Signed by James Rawls and Lin Wood