Out of respect for the grand jury process, and because Ramsey could be called to testify, questions directly related to the murder had to wait until after Ramsey's testimony before the grand jury. HERRINGTON: Matt Herrington on behalf of 19 the National Enquirer, John South and David Wright. CRAVER: Also present is Bryan Morgan also 21 counsel for John Ramsey. 10 Nobody has indicated otherwise; is that correct? Hill said his intentions at the time of the deposition were to build a rapport with Ramsey and subtly develop leads that could be used during a second interview. 22 This morning we're taking -- the plaintiff is 23 taking the videotape deposition of John Ramsey. Basically, we must let everyone 16 complete their sentences before someone else begins to 17 speak.
I will be 25 trying to ask questions that are understandable and Page 7 1 coherent. So I ask for 2 your help in making sure that you understand my questions 3 before you respond. As I mentioned earlier, if at any point during 13 the deposition you need to take a break, please just let 14 us know and we'll accommodate you, no problem.
19 I don't know, for example, whether you might be 20 under the influence of any medication or alcohol or 21 anything else? No alcohol certainly, but I've been under 23 doctor's care for almost two years now and take Prozac.
14 Sometimes, as infallible as they generally are, 15 court reporters may make a mistake. You'll have an opportunity to correct the final 17 record. 19 However, if you were to make a sweeping change, a 20 substantive change -- for example, changing a yes to a no, 21 we might have an opportunity to comment upon that later if 22 this matter were to go to trial.
As we go through the questions, eventually 11 you'll have an opportunity to review the written 12 transcript of what we've said here today and at that time 13 you'll have the opportunity to make corrections.
The second interview never came; a federal judge dismissed Miles' lawsuit after not finding sufficent proof against the Enquirer. We are 24 taking this deposition pursuant to a stipulated protective 25 order entered into between the plaintiff and Mr. Page 4 1 I want to make sure that everybody in the room 2 acknowledges that the court has ordered this deposition 3 sealed and therefore the content of any testimony or 4 activities within this room are to be maintained 5 confidential.