I need to ask you a couple of other questions 17 that might sound awkward, but it's my attempt to insure 18 that we're getting your best testimony today. That doesn't affect your ability to 25 recall though, does it? I don't know whether it's that or just the 5 trauma we've been through, but -- 6 Q. Basically, we must let everyone 16 complete their sentences before someone else begins to 17 speak.

If you 6 don't remember, "I don't remember" is perfectly fine. I am asking you 8 to do your best to be as complete and as candid and as 9 truthful as possible, and I trust that you'll abide by 10 that.

4 If you don't know the answer to a question, "I 5 don't know" is a perfectly understandable answer.

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.

So with that in mind, if corrections occur to 25 you as the deposition proceeds, please feel free to Page 9 1 interject and help us tidy up the record before we 2 conclude today.

HILL: Does anyone need to take a break at 5 this point?

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.

As I introduced myself earlier, my name is Lee 11 Hill.