1 IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
2 ATLANTA DIVISION
3 ROBERT CHRISTIAN WOLF,
4 Plaintiff,
CIVIL ACTION FILE
5 vs. NO. 00-CIV-1187(JEC)
6 JOHN BENNETT RAMSEY and
PATRICIA PAUGH RAMSEY,
7
Defendants.
8 ~~~~~~~~~~~~~~~~~~~~~~~~~~
9 VIDEOTAPED DEPOSITION OF
10 CINA L. WONG
11 May 13, 2002
9:45 a.m.
12
Sixteenth Floor
13 191 Peachtree Street, N.E.
Atlanta, Georgia
14
15
Alexander J. Gallo, CCR-B-1332, CRR
16
17
18
19
20
21
22
23
24
25
0002
1 APPEARANCES OF COUNSEL
2 On behalf of the Plaintiff:
3 (via telephonic means)
4 DARNAY HOFFMAN, Esq.
5 Law Offices of Darnay Hoffman
6 Suite 209
7 210 West 70th Street
8 New York, New York 10023
9 (212) 712-2766
10 .
11 EVAN M. ALTMAN, Esq.
12 Law Offices of Evan M. Altman
13 Suite 300-B
14 6085 Lake Forrest Drive
15 Atlanta, Georgia 30328
16 (404) 845-0695
17 .
18 .
19 .
20 .
21 .
22 .
23 .
24 .
25 //
0003
1 On behalf of the Defendants:
2 JAMES C. RAWLS, Esq.
3 ERIC P. SCHROEDER, Esq.
4 S. DEREK BAUER, Esq.
5 Powell, Goldstein, Frazer & Murphy, L.L.P.
6 Sixteenth Floor
7 191 Peachtree Street, N.E.
8 Atlanta, Georgia 30303
9 (404) 572-6600
10 .
11 L. LIN WOOD, Esq.
12 L. Lin Wood, P.C.
13 2140 The Equitable Building
14 100 Peachtree Street
15 Atlanta, Georgia 30303
16 (404) 522-1713
17 .
18 Also Present:
19 David Stevens, Videographer
20 LaShaunda Cass, In-Training Court Reporter
21 .
22 .
23 .
24 .
25 .
0004
1 Videotaped Deposition of Cina L. Wong
2 May 13, 2002
3 THE VIDEOGRAPHER: On the video
4 record at 9:45, May 13, 2002.
5 MR. RAWLS: Very good. Alex, we
6 are on the written record as well, I assume.
7 If I may just briefly state, this is
8 the deposition of Ms. Cina Wong.
9 THE WITNESS: That is correct.
10 MR. RAWLS: And I hope I've
11 pronounced it correctly.
12 THE WITNESS: That's right. Like
13 Tina, but with a C. So you said it correctly,
14 Cina.
15 MR. RAWLS: Good. Thank you. And
16 the deposition is being taken by the defendants'
17 counsel for John and Patsy Ramsey, in a lawsuit
18 filed here in U.S. District Court in Atlanta on
19 behalf of the plaintiff Robert Christian Wolf.
20 The deposition is scheduled by
21 agreement, and the witness has voluntarily
22 appeared pursuant to that agreement and without
23 a subpoena.
24 Am I correct so far, Evan and
25 Darnay?
0005
1 MR. HOFFMAN: That is correct.
2 MR. ALTMAN: That is correct.
3 MR. RAWLS: Good. And we very much
4 appreciate all counsel having reached that
5 agreement and, Ms. Wong, your having been
6 present pursuant to that agreement.
7 The deposition is taken by the
8 defendants for all proper purposes under the
9 Federal Rules of Evidence and the Federal Rules
10 of Civil Procedure.
11 Those purposes, of course, include
12 but are not limited to discovery potential use
13 in evidence if appropriate under the Rules,
14 potential impeachment, et cetera.
15 Is that an agreeable stipulation up
16 to now?
17 MR. HOFFMAN: Yes.
18 MR. ALTMAN: Yes, it is.
19 MR. RAWLS: And may I further
20 propose that all objections except as to the
21 form of the question and the responsiveness of
22 the answer are reserved until the time of trial,
23 hearing, or other use of this evidence?
24 MR. ALTMAN: That is acceptable.
25 MR. HOFFMAN: Yes.
0006
1 MR. RAWLS: Good. Present, if I
2 may say so for the record, are by telephone
3 Darnay Hoffman and present in person Evan
4 Altman, both of whom represent the plaintiff,
5 Mr. Wolf.
6 Ms. Cina Wong, the witness is
7 present.
8 For defendants, Jim Rawls, Lin Wood,
9 and Eric Schroeder are present; and defendant
10 John Ramsey is present. As an observer, Matt
11 Wood is present. We have two court reporters
12 present, Alex Gallo and LaShaunda Cass. And we
13 have a videographer present, Mr. David Stevens.
14 And I was about to call you Steven, but I
15 would have misplaced your last name had I called
16 you Steven. Good. Thank you.
17 Are there any additional preliminary
18 matters we should raise?
19 MR. HOFFMAN: Just one, and we can
20 do this off the record if you want. We can
21 use your decision as to whether you want this
22 on the record or not.
23 I don't know how many of you are
24 aware of the fact that Cina recently just had
25 an operation, and she may need to stop a little
0007
1 bit more than might be the usual simply because
2 there may be some residual discomfort from any
3 of the sutures or -- not sutures, from the
4 incision and the operation.
5 So just please bear with her if she
6 needs to take an occasional break that, you
7 know, might seem a little bit more often than
8 is normal in a deposition.
9 MR. RAWLS: We fully understand.
10 And, Darnay, yes, Ms. Wong and Mr. Altman
11 brought that to our attention.
12 And, Ms. Wong, if at any time you
13 need a break, please say so.
14 THE WITNESS: Thank you.
15 MR. RAWLS: And we will take one.
16 Very good. Mr. Gallo, if you would
17 please keep time, we would appreciate it. And
18 Mr. Schroeder, if you would also keep a backup
19 time. I am certainly hopeful we will not be
20 at the full seven hours permitted under the
21 Federal Rules, but at the start of a deposition
22 one never knows.
23 Would you please administer the oath?
24 CINA WONG, having been first duly
25 sworn, was examined and testified as follows:
0008
1 EXAMINATION
2 BY-MR.RAWLS:
3 Q. Ms. Wong, for the record, would you
4 please state your full name?
5 A. Yes. My name is Cina, that's
6 spelled C-I-N-A. And the last name is Wong,
7 W-O-N-G. I do have a middle initial L.
8 Q. What does the L stand for?
9 A. That is all I have.
10 Q. Like Harry S. Truman, whose S, as I
11 understand it, did not stand for anything?
12 A. Oh, I didn't know that. Yes. I
13 just have an L.
14 Q. You have an L, and only an initial?
15 A. That is correct.
16 Q. And your date of birth, please, for
17 the record?
18 A. 10/26/62.
19 Q. And place of birth?
20 A. California. Mountain View,
21 California.
22 Q. Ms. Wong, do you have any relatives
23 that live in the Atlanta metro area?
24 A. No, I do not. Oh, hold it. Yes.
25 They just moved here. One. A cousin.
0009
1 Q. Who is that?
2 A. His name is Keith Soo.
3 Q. How is that spelled?
4 A. Oh, I'm sorry. I got him mixed up.
5 S-O-O. I'm sorry. Keith Soo.
6 Q. Keith?
7 A. I have two cousins. One is Keith
8 Koo, I'm sorry. K-O-O. He married into the
9 family.
10 Q. And is there a second cousin in the
11 Atlanta area?
12 A. No. His wife and his child will be
13 joining him shortly in the summer.
14 Q. And the person to whom you are a
15 cousin is who?
16 A. His wife.
17 Q. What is her name?
18 A. Her name is Wai-soo, W-A-I, hyphen,
19 S-O-O.
20 Q. Thank you. Do you know the
21 occupation of both of those individuals?
22 A. I believe he is a doctor in the
23 military, and she is taking care of their
24 daughter at home.
25 Q. Ms. Wong, you are here because it is
0010
1 our understanding that you have agreed to serve
2 as an expert witness on behalf of Mr. Wolf.
3 Am I correct?
4 A. That is correct.
5 Q. Would you tell us, please, when you
6 agreed to serve as such an expert witness?
7 A. Well, I met Darnay Hoffman. He
8 contacted me in '97, I believe. And the Chris
9 Wolf situation arose last year sometime, to the
10 best of my memory.
11 Q. How did you meet Darnay Hoffman?
12 A. He contacted our offices.
13 Q. Let us know, if you will, what you
14 recall as the first things that Mr. Hoffman said
15 to you.
16 A. He said that he had a copy --
17 excuse me. I am losing -- sorry.
18 But Mr. Hoffman said that he was
19 interested in finding some handwriting experts
20 who would be interested in examining a ransom
21 note and some handwriting exemplars.
22 Q. Did he tell you why he had selected
23 you?
24 A. No, he did not. He just said he
25 had heard of us and that is why he contacted
0011
1 us.
2 Q. And what did you do, if anything, at
3 that time at Mr. Hoffman's request?
4 A. I told him that I would be more
5 than happy to look at the materials to see if
6 we could do anything for him or not.
7 Q. And what did you then do?
8 A. I had him -- I asked him to please
9 send the documents over and that we would look
10 at them when we received them.
11 Q. Did he send documents?
12 A. Yes, he did.
13 Q. What were they?
14 A. He sent a copy of a ransom note and
15 exemplars which consisted of copies of a
16 greeting card. I believe it started off with:
17 Hi, Bob. I am going from memory here. A
18 photograph of some boxes with Ramsey written on
19 it. A poster that had something written on it
20 to the effect of Welcome to the Northwest
21 Territory. A copy of a photo album page with
22 handprinting. And that is all that comes to
23 mind right now. There might have been another
24 one or two.
25 And there was a Polaroid. And I
0012
1 think it said Rainbow Fish Players underneath.
2 Q. And did you study those materials?
3 A. Yes, I did.
4 Q. Did you do that personally or did
5 someone else in your office do that?
6 A. No. At that time I was working
7 with David Liebman. And I did my own
8 independent analysis, and he did his own
9 independent analysis.
10 Q. What was the question that Mr.
11 Hoffman asked you to answer?
12 A. He wanted to know if -- and by the
13 way, the exemplars, we asked him if they had
14 been reviewed and confirmed by any other parties
15 of them being the handwriting exemplars of Patsy
16 Ramsey; and Mr. Hoffman said, yes, they have,
17 and they were confirmed by the housekeeper. And
18 I believe her name is Linda Hoffman-Pugh. And
19 Mr. Hoffman wanted to know if it was a
20 possibility or not that the person who executed
21 the exemplars known as Patsy Ramsey was the one
22 who wrote the ransom note.
23 Q. He asked if there was a possibility;
24 did you say?
25 A. A possibility or not.

0013
1 Q. What did you tell him, if anything,
2 in answer to that question?
3 A. I told him I would look at it and I
4 would not be able to give him an opinion in
5 any way until I looked at the materials and
6 rendered a systematic analysis.
7 Q. Did you quote him a fee for that
8 analysis?
9 A. I told him that we had a retainer
10 fee at that -- I can't remember what our fees
11 were at that time. And then he mentioned to
12 us that right now he wouldn't be able to pay.
13 He would be able to send us some money to
14 cover expenses, but he would ask us if we would
15 be interested in doing this pro bono.
16 Q. What was your reply?
17 A. I was very interested in seeing the
18 exemplars since this is a case that was widely
19 talked about in the media, so I told him that
20 I would be glad to.
21 Q. So did you agree to handle the
22 matter on a pro bono basis before you had
23 reached any conclusions about the authorship of
24 the ransom note?
25 A. That is correct.
0014
1 Q. And your reason for doing so had to
2 do with publicity surrounding the death of
3 JonBenet Ramsey?
4 A. It was a curiosity since I am a
5 document examiner to be able to see some of the
6 materials involved and to be able to come to my
7 own opinion.
8 Q. But your curiosity was aroused
9 because of the publicity attending the death of
10 JonBenet Ramsey; am I correct?
11 A. I take other cases on a pro bono,
12 but in this case I was curious and I was
13 interested. I don't know of any document
14 examiner in the country who wouldn't want to
15 look at that.
16 Q. And did you, in 1997, reach a
17 conclusion at the request of Mr. Hoffman?
18 A. According to the information that was
19 available to us, there was a good probability
20 that the writer -- that there were quite a few
21 similarities with the exemplars written by Patsy
22 Ramsey linking her to the ransom note. And I
23 told Mr. Hoffman that I would like additional
24 materials if he could obtain those for me to
25 see, additional exemplars. And that is where we
0015
1 left off there for a while.
2 Q. Do you continue to serve pro bono
3 today?
4 A. Yes, that is correct.
5 Q. And would it be correct, then, that
6 the only moneys you have received on behalf of
7 Mr. Chris Wolf, the plaintiff in this case, have
8 been sums to reimburse expenses?
9 A. Since Mr. Wolf came on the scene, I
10 haven't even received those. I have taken this
11 on pro bono, and whatever time or materials I
12 have put in is on my behalf.
13 Q. Is your travel expense to Atlanta
14 being reimbursed by Mr. Wolf?
15 A. That is being reimbursed. Thank
16 you.
17 Q. Ms. Wong, would you please tell us
18 about your educational background?
19 A. I received a Bachelor's degree from
20 San Jose State University. And upon my
21 graduation I wanted to learn -- I've wanted to
22 get in the field of document examination. I've
23 wanted to do that since I was 15. But I had
24 trouble finding information as where to start.
25 But after I graduated someone told me to speak
0016
1 to a Mr. Ted Widmer in San Francisco. He said
2 that he teaches -- he is a document examiner,
3 and he is a graphologist. And I said, well, I
4 am not interested in learning about graphology,
5 and I said I am only interested in learning
6 about document examination.
7 And he said that there are some
8 similarities between the both, but graphology,
9 you tell personality, and with document
10 examination, you identify. And I said, well, I
11 am only interested in identifying.
12 And he said, well, I am giving a
13 course if you want to sit in on the course.
14 It covers some of the similarities between what
15 you need to know in handwriting sciences, which
16 would be proportion, slant, how letters and
17 sentences are in relationship to the baseline,
18 alignment, certain letter formations, pressure
19 patterns, and so forth. So in the end I ended
20 up taking additional courses from Mr. Ted Widmer
21 that were document examination related.
22 And from there I joined the National
23 Association of Document Examiners, which I am
24 also board certified through.
25 There are some groups out there
0017
1 where you are able to receive your certification
2 by paying a fee, and that is not how I
3 received my certification. In this case I had
4 to first qualify to even fill out an
5 application. In order to qualify, you had to
6 have had at least five court testimonies or
7 three court testimonies and two depositions.
8 And then you were able to fill out an
9 application for a certification.
10 From there you have to take a
11 written test, an extensive written test. You
12 have to pass that. After you pass the written
13 test, then you have to go on to, they have
14 like a mock trial; and you have to pass that
15 oral exam where you were sent a case and you
16 present the case in front of a judge and two
17 attorneys, and you are graded on how well you
18 do. If you pass that, then you are certified
19 through the National Association of Document
20 Examiners.
21 And from -- after I joined the
22 National Association of Document Examiners, they
23 offered some mentorship programs with some of
24 their more experienced members. And I was
25 considering one in Philadelphia, and the other
0018
1 one was in Norfolk, Virginia. I decided to
2 take the one in Norfolk, Virginia, and I studied
3 with Mr. David Liebman. And I did a three-year
4 internship with him strictly on document
5 examination, where he taught me how to
6 systematically approach a case, how to analyze
7 it, what to look for, and so forth.
8 And I also took a college course
9 through Larry Zigler, who used to work as a
10 document examiner for the FBI. And that was at
11 Annadale College in Virginia. And I also took
12 a special course through John Hargett, who at
13 that time was the chief document examiner for
14 the Secret Service.
15 So I've trained with a lot of other
16 people. And then I have training from Larry
17 Zigler and John Hargett who teach other
18 government document examiners in the FBI and the
19 Secret Service.
20 Q. Thank you, Ms. Wong. Would you
21 please tell us what was the nature of the B.A.
22 degree that you obtained at San Jose State?
23 A. It is in mass communications, and it
24 was concentrating in advertising. And how that
25 actually helps me in the field of document
0019
1 examination is that when I got into advertising,
2 it was right at the brink of when computers
3 were being put into advertising offices and
4 using it for graphics. I worked in a small
5 firm where a lot of the layout work, when you
6 -- for magazines and ads were still done by
7 hand.
8 My boss was very strict, and I thank
9 her for it now, because she taught me to be
10 sensitive to when certain things are out of
11 alignment. So my specialty is in pasted
12 forgeries and to identifying if something was
13 done as a paste-up job and then photocopied.
14 And people try to pass documents like that off
15 as originals when, in fact, they are not.
16 Q. What was the date of your degree at
17 San Jose State?
18 A. Oh, when I graduated?
19 Q. Yes.
20 A. 1990, I believe.
21 Q. Where had you attended high school?
22 A. Notre Dame Preparatory.
23 Q. And where is that, please?
24 A. In Belmont, California.
25 Q. What year did you complete high
0020
1 school?
2 A. In 1981.
3 Q. What career did you have, if any,
4 between 1981 and your entry into San Jose State?
5 A. I didn't have a career. I am
6 fortunate enough that my parents have worked
7 very hard; and if I wanted to travel, they
8 would allow me to travel. And so I went to
9 school and I traveled. That explains the great
10 time span in between.
11 Q. So when did you begin at San Jose
12 State, approximately?
13 A. Oh, that is a good question. I
14 can't remember. I started up and I stopped,
15 went traveling, came back again, so. I am
16 sorry. I can't give you an exact date on
17 that. But I went part-time through college.
18 Q. And if I am not mistaken, when you
19 were summarizing your degree at San Jose State,
20 you shared with us that as a document examiner
21 your specialty is in pasted up forgeries; am I
22 correct?
23 A. I do all aspects of document
24 examination; but in that area, I am very strong.
25 Q. Is there any element of a paste-up
0021
1 forgery involved in the ransom note, in your
2 opinion, that you reviewed with reference to the
3 death of JonBenet Ramsey?
4 A. As I understand that there were
5 originals available, which I did request and I
6 was told that they weren't available. There
7 were some destructive tests made on them through
8 fingerprinting which would obliterate the writing
9 involved. So in order to have a paste-up
10 forgery, you, for instance, I would have needed
11 an original of your signature. I would cut it
12 out and paste it on another document and make a
13 photocopy of it and try to pass it off as a
14 legitimate document by saying that I am not sure
15 where the original is, but here is a copy.
16 That is not the only indicator.
17 There are times where copies are
18 authentic, but there are some things that people
19 miss when they just cut out a signature and
20 paste it on a document. And not only a
21 signature, but certain paragraphs, if they want
22 to change the text of the document.
23 Q. Let me rephrase my question. What I
24 am interested in --
25 A. Yes.
0022
1 Q. -- is your opinion or conclusion
2 about whether there is any element of a paste-up
3 forgery present in the ransom note that you
4 reviewed in connection with the death of
5 JonBenet Ramsey?
6 A. There is no evidence of that
7 pointing to that fact.
8 Q. You certainly reached no conclusion
9 that anything was pasted up and forged on that
10 ransom note; have you?
11 A. On the copies that I have, is that
12 what you mean?
13 Q. Yes.
14 A. That is correct.
15 Q. And you've reached no conclusion that
16 there was any paste-up forgery on the original
17 ransom note as well; haven't you?
18 A. That is correct.
19 If there is an original, then there
20 would not be any -- you can't have a paste-up
21 forgery with an original handwritten document.
22 I am not sure if I made that clear.
23 Q. Are you, Ms. Wong, a full-time
24 document examiner?
25 A. Yes, I am.
0023
1 Q. How long have you been a full-time
2 document examiner?
3 A. Since, it has been almost 12 years.
4 Q. During that time, have you had any
5 other career or business or professional activity
6 at all?
7 A. Just a short stint. There is a
8 place called the Colorado Pen Company that came
9 to town, and I read about them in the
10 newspaper, and I thought what a better way to
11 learn about different types of pens and ink than
12 being in a pen store. And what a lot of
13 document examiners these days don't do is
14 actually go out in the field and actually
15 experience and observe the certain situations
16 that have to do with our jobs.
17 So at the pen company, I spoke to
18 them. And I said I am interested in learning
19 about the different types of pens, the different
20 types of ink composition and so forth. And
21 they said, well, there are a multitude of
22 different pen companies. They all have their own
23 ink formulas, and you would have to ask the
24 representatives for that information. And
25 normally, as a document examiner, that type of
0024
1 information you would have to learn by going to
2 a conference and, hopefully, that they would
3 have someone there with that knowledge that
4 would be speaking about it.
5 In this case, I decided to go
6 directly to the source. And I said, do you
7 mind if I just, you know, work here on the
8 weekends and I would be able to do study with
9 the pens and speak with the representatives and
10 find out about the pens. So in this case,
11 instead of having me pay for the education, I
12 was actually getting paid to get the education
13 myself. So that was a bit of a benefit.
14 The store wasn't open for very long.
15 They weren't in the right target market in our
16 area in Norfolk, Virginia; and they closed up
17 soon after.
18 Q. When was it that you worked with the
19 Colorado Pen Company in Norfolk?
20 A. Oh, good question. I think they
21 went bankrupt in 2000, in 2000, late 2000. So
22 I was there for probably a year, a little bit
23 over a year. So 1999 is probably when I
24 started.
25 Q. And did you work with them only on
0025
1 weekends?
2 A. Yes, that is correct.
3 Q. When you worked with the Colorado
4 Pen Company, were you paid by the hour or were
5 you paid an annual salary?
6 A. I was paid by the hour. And
7 actually where we worked, we have to pay for
8 parking in the mall. So actually parking per
9 day was about $11, and I was only paid $8 an
10 hour. So I would have to work there over an
11 hour just to pay for the parking. So I was
12 there not for the money but, in fact, for the
13 research and the study of the different inks and
14 pens.
15 Q. During the time, approximately a
16 year, when you were working with the Colorado
17 Pen Company, about what percentage of your total
18 income came from the Colorado Pen Company and
19 what percentage from your work as a document
20 examiner?
21 A. I wouldn't even say 1 percent came
22 from the Colorado Pen Company, and everything
23 else was from strictly document examination.
24 Q. You have told us, Ms. Wong, that at
25 one point you worked with David Liebman?
0026
1 A. That is correct.
2 Q. Do you now work together with Mr.
3 Liebman?
4 A. No, we do not. I have gone off on
5 my own.
6 Q. When did you do that?
7 A. It was approximately three, three and
8 a half years ago.
9 Q. Where is your office now as a
10 document examiner?
11 A. It is in Norfolk, Virginia. It's
12 close to downtown.
13 Q. What's the address, please?
14 A. It's 1131 Granby Street. That's
15 spelled G-R-A-N-B-Y, Street. That is in
16 Norfolk.
17 Q. And what is your home address,
18 please?
19 A. I have an office in my home, and
20 the office is separate from my living space.
21 Q. So your home is at the 1131 Granby
22 Street address in Norfolk?
23 A. That is correct.
24 MR. RAWLS: Mr. Gallo, would you
25 please mark this Exhibit Number 1 for the
0027
1 defendant.
2 And here's a copy, Darnay. For your
3 information, this is a copy of the CV that was
4 furnished to us.
5 (Defendant's Exhibit-1 was marked for
6 identification.)
7 Q. (By Mr. Rawls) Ms. Wong, would you
8 take a moment, please, and look over Defendant's
9 Exhibit 1 and let us know if that is a true
10 copy of your curriculum vitae and general
11 resume?
12 A. Looking over it briefly, it appears
13 to be a correct representation of my CV.
14 Q. And I will say for the record this
15 is what we received from the attorneys for Mr.
16 Wolf, Ms. Wong, as your CV.
17 In your work as a document examiner,
18 do you charge based on hours, for the most
19 part, when you don't take a case pro bono?
20 A. Yes, that is correct.
21 Q. So it is much like many lawyers, you
22 are a professional who charges by the hour?
23 A. Yes.
24 Q. And when you do charge by the hour,
25 what is your hourly rate?
0028
1 A. It is $150 an hour. I have a
2 three-hour retainer. And any court testimony or
3 depositions, it is the day rate, and that is
4 $1200. And that does not include traveling
5 portal to portal and so forth.
6 Q. Do you keep records of the number of
7 billable hours that you are engaged for in a
8 given year?
9 A. Oh, in a given year?
10 Q. Yes.
11 A. Oh, I don't add everything up within
12 in the year. No, I don't do that. I just
13 add them up per case.
14 Q. So as we sit here today in May of
15 2002, you cannot tell me how many hours you
16 billed professionally for in the year 2001; is
17 that correct?
18 A. That is correct.
19 Q. Can you give me an approximation?
20 A. Oh, I don't even know where to
21 start. Some cases take much longer, that I've
22 had to travel to Buffalo, New York for. Other
23 cases are just very simple. I don't even want
24 to begin to pull a number out of the hat. But
25 -- I don't know where to start. I am sorry.
0029
1 Q. Does all of your income come from
2 document examination?
3 A. That is correct.
4 Q. 100 percent of it after the Colorado
5 Pen Company went bankrupt?
6 A. Yes, that is correct. Before and
7 after.
8 Q. So one way you could start, and I
9 don't mean or intend to ask you your annual
10 income, but I expect you know your annual income
11 for the year 2001. And I would think from
12 that, with simple arithmetic, you could give me
13 the approximate number of hours that you billed?
14 A. Okay. Usually I just take
15 everything and send it off to my accountant. I
16 really don't know what to tell you. I am
17 sorry, Mr. Rawls. If I could answer you, I
18 would.
19 Q. Would you please take Defendant's
20 Exhibit 1 and let's start, if we may, on page
21 2. At the top it says Board Certification.
22 What is the board that certified
23 you?
24 A. As I mentioned earlier, it is part
25 of the National Association of Document
0030
1 Examiners. And it consisted first of two
2 founders. They were grandfathered into the
3 organization as being certified. Then the rest
4 of the other people had to go through the
5 written and oral exam to pass their
6 certification. And the board consists, at that
7 time when I was involved, it consisted of five
8 to seven people.
9 Q. And when did you receive your board
10 certification?
11 A. That is a good question. Oh, right
12 there. 1995.
13 Q. Who were the five to seven people on
14 the board that gave you your certification?
15 A. Okay. They are different than the
16 people now. Let me see if I can remember.
17 I believe one was Kathy Koppenhaver,
18 Phyllis Cook, Paul Wease, who is now deceased.
19 And I can't remember the other people that were
20 in the room, but those are the three that I
21 remember. Renee Martin may have been there.
22 Q. Was Mr. Liebman there?
23 A. I believe he was in the room, yes.
24 Q. Who were the two founders of the
25 National Association of Document Examiners?
0031
1 A. First one is Phyllis Cook, and the
2 second one is Renee Martin.
3 Q. Ms. Wong, the resume at the top of
4 the first page has a name Cina L. Wong
5 Associates Limited; does it not?
6 A. Uh-huh (affirmative).
7 Q. And does the title tell us that this
8 is a partnership organization?
9 A. No, it is not. I spoke to my
10 attorney when I incorporated this, and I was
11 just going to put it as Cina Wong Limited, and
12 he recommended it Cina Wong & Associates. He
13 is an attorney, so I didn't argue with him.
14 Q. Who are the associates?
15 A. Every once in a while if I have
16 some additional cases that I am not able to do
17 due to time constraint situations, then I have
18 Mr. Liebman step in.
19 Q. For the most part, there is not an
20 associate; but sometimes you recruit Mr. Liebman
21 to assist?
22 A. That is correct.
23 Q. Does Mr. Liebman also, from time to
24 time, recruit you to assist him with a matter?
25 A. Yes. If there are cases that he
0032
1 has to be out of town, then I take over.
2 Q. Ms. Wong, am I correct that you have
3 received no college degree in forensic science?
4 A. That is correct.
5 Q. Am I correct also that you have
6 received no college degree in document
7 examination?
8 A. I have taken a college course with
9 Mr. Zigler. And when I started there was no,
10 at that time, there weren't any college degrees
11 available in document examination. And this is
12 a field where there is no standard that says
13 that your training or your education has to come
14 from a certain college or have a certain degree.
15 Q. Let me ask Mr. Gallo to re-read my
16 question, please, if you can give me a yes or
17 a no.
18 A. Okay. I am sorry.
19 Q. If you don't mind.
20 (The record was read by the
21 reporter.)
22 THE WITNESS: That is correct. It
23 was not available.
24 Q. (By Mr. Rawls) Thank you. At
25 present what colleges do offer degrees in
0033
1 document examination?
2 A. At this time a new forensic college
3 just opened in Richmond, Virginia. There is an
4 author, her name is Patricia Cornwell, and she
5 put up a large sum of money which is state
6 matched, and they opened up a forensic college.
7 And I believe that you can get a degree in
8 document examination from that college. And
9 there may be a few other ones now, but that
10 was not available at that time to me when I
11 started document examination.
12 Q. When was the forensic college first
13 opened for business in Richmond?
14 A. I believe it was two years ago.
15 That is according to what I have read in the
16 paper.
17 Q. Have you made application to attend?
18 A. I have made an inquiry to the
19 college. And from what I understand is after you
20 graduate from the college, they would like you
21 to work for the government for a certain amount
22 of years. And I asked them, so is this kind
23 of like the military, you sign up and they help
24 you with the education and then you go work for
25 them for a while? And basically the person
0034
1 said to me, something like that. So I wasn't
2 interested in going to the college in that sense
3 and going to work for the government for a
4 certain amount of years. But that was my
5 understanding, that was what was told to me.
6 Q. How many years would a graduate be
7 expected to work with the government?
8 A. I can't remember.
9 Q. Was it the federal government or the
10 state government or just any government?
11 A. That wasn't made clear to me, and I
12 didn't ask.
13 Q. So service for a county or city
14 might have been sufficient?
15 A. I am sorry?
16 Q. Service for a county or a city might
17 have been sufficient to serve as the government
18 work component?
19 A. It may have, but I am not clear on
20 that.
21 Q. Have you ever worked for any
22 government organization?
23 A. No, I haven't. I am private
24 practice.
25 Q. Have you ever been retained by any
0035
1 government organization?
2 A. I have been retained by the
3 Commonwealth Attorney's office.
4 Q. So --
5 A. And by the U.S. Probation Office.
6 That case was a while ago, but it was the U.S.
7 Probation Office.
8 Q. When were you first retained by the
9 Commonwealth Attorney's office?
10 A. This is probably in -- this is a
11 guesstimate -- somewhere between '93 and '95.
12 Q. And how many times?
13 A. I did one or two.
14 Q. And since then have you been
15 retained again by the Commonwealth Attorney?
16 A. No. Usually they have document
17 examiners in the police office, part of their
18 check squad. And when they are overloaded or
19 when they are not able to do the case, that is
20 when the Commonwealth Attorney will go outside
21 and hire someone from the private field.
22 Q. Let me remind you, I had asked you,
23 were you retained since by the Commonwealth
24 Attorney.
25 A. No, I have not.
0036
1 Q. So since approximately 1995, you have
2 not been retained by the Commonwealth Attorney;
3 am I correct?
4 A. That is correct.
5 Q. When were you first hired by the
6 United States Probation Office?
7 A. The best of my memory, it was
8 somewhere around -- anywhere from '96 to '99.
9 That is something I would have to look up.
10 Q. How many times were you retained by
11 the U.S. Probation Office?
12 A. Once.
13 Q. The one or two cases that you
14 assisted the Commonwealth Attorney on, did those
15 involve check forgery?
16 A. I believe they were.
17 Q. What was the matter, the one matter
18 you were engaged by the U.S. Probation Office to
19 assist on?
20 A. That one I can't remember. I am
21 sorry.

22 Q. Apart from the one or two cases with
23 the Commonwealth Attorney and the one case with
24 the U.S. Probation Office, have you ever been
25 retained by any government agency at the federal
0037
1 level, at the state level, or the county or
2 city level?
3 A. No. Usually they have their own
4 document examiners. Like I say, it is only
5 when they can't have anybody within their system
6 do it do they go outside.
7 Q. Have you ever been employed as a
8 document examiner by any government agency?
9 A. No, I have not.
10 Q. Ms. Wong, can you give us a
11 definition of graphology, please?
12 A. Yes. Graphology is when -- where
13 people study handwriting specifically for the
14 purpose of learning how to determine someone's
15 personality from their handwriting.
16 Q. And on your resume, if you would
17 turn with me to page 2, under Training, the
18 first thing you list is the, quote,
19 International School of Handwriting Sciences, end
20 quote; is it not?
21 A. Yes, that is correct. There are two
22 portions to that school. There is a portion to
23 the school where Mr. Widmer teaches document
24 examination, and there is a second portion of
25 his school where he does teach graphology.

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jameson
Member since 5-8-02
08-15-02, 04:19 PM (EST)

2. "3 Cina Wong depo"
In response to message #1


0038
1 Q. And Mr. Widmer is a graphologist; is
2 he not?
3 A. He is a document examiner and a
4 graphologist.
5 Q. And by whom is he certified as a
6 document examiner?
7 A. He is not certified. He doesn't
8 belong to any of the document examination
9 groups. He's read all the texts in the field,
10 the leading texts that all document examiners
11 read.
12 Q. And are you a graphologist?
13 A. No. Certainly not.
14 Q. Why do you say certainly not?
15 A. I have looked into it because, as
16 anybody who deals in the field of handwriting
17 sciences, you should look into all aspects of
18 handwriting and study all of it in order to
19 give a comprehensive analysis or speak about it.
20 There are lots of document examiners, I should
21 say, out there who say things about graphology
22 when they don't even know anything about it.
23 How can you speak about something fluently
24 without knowing? So I looked into it. I
25 don't see that there is any validity to it. A
0039
1 lot of people disagree with me. But my area
2 is strictly in document examination.
3 Q. You refer in your CV, this again is
4 Defendant's Exhibit 1 on page 2, and this is
5 immediately under the International School of
6 Handwriting Sciences, you refer to, quote, a
7 six-month program --
8 A. Yes.
9 Q. -- in Handwriting Sciences, end
10 quote.
11 Did you get a diploma?
12 A. I don't think he issued a diploma,
13 no.
14 Q. Did you get a degree?
15 A. Not a degree, no.
16 Q. Did you get a grade?
17 A. No. Probably I have a certificate
18 of completion, but that would be about what we
19 received.
20 Q. So in those six months, was this a
21 full-time educational curriculum?
22 A. It was once a week.
23 Q. Once a week. Which day of the
24 week?
25 A. You are asking me to think back 12
0040
1 years. I can't remember. I am sorry. I know
2 it was a weekday.
3 Q. And in that once-a-week program, how
4 long were you there the day you were there each
5 week?
6 A. Anywhere from four to five hours.
7 Q. What did you pay for that course?
8 A. I can't remember. It was a while
9 ago.
10 Q. Did you do a term paper in that
11 program?
12 A. No, we did not.
13 Q. Did you submit handwriting analyses
14 for feedback?
15 A. I am sorry. I don't understand your
16 question.
17 Q. Well, in the course of this
18 six-month program, which we've learned was a
19 once-a-week program, four to five hours on that
20 one day a week, were you asked to complete a
21 document analysis and to submit it for review
22 and feedback?
23 A. I am not quite sure what you are
24 saying. But we were asked to bring in
25 handwriting samples; and we would look at them
0041
1 and study them for slant, proportion, placement,
2 letter forms; and that is what we did.
3 Q. Did you demonstrate to Mr. Widmer or
4 anyone else your analysis so that you could
5 obtain feedback and his judgment on whether you
6 were right or wrong?
7 A. Oh, you mean like a personality
8 analysis? I didn't partake in that. I was
9 there for the information with regards to
10 learning the basics, because I was -- there is
11 certain overlap with graphology and document
12 examination strictly with the fact that it has
13 to do with the formations and angles and initial
14 strokes and terminal strokes and letter
15 formations. And otherwise, that is where it
16 stops.
17 Q. Now, the second entry under Training
18 in your resume, and again I am still on page 2
19 of Defendant's Exhibit 1, you list again
20 International School of Handwriting Sciences.
21 And this time your CV tells us of your
22 completion of an advanced course in Questioned
23 Document Examination.
24 A. Uh-huh (affirmative).
25 Q. And according to your resume, this
0042
1 involved forgery detection, case studies,
2 hands-on equipment operation technique, and court
3 qualification procedures.
4 Have I accurately read your CV?
5 A. Yes, that is correct.
6 Q. How long was this advanced course?
7 A. I believe it was over four days,
8 three or four days. It was all day. Or it
9 was eight or ten hours. It was a very intense
10 course.
11 Q. And since Mr. Widmer has no
12 certification as a document examiner, I assume
13 this course was taught by someone else?
14 A. No. There is no standard in this
15 field where you need certification, but Mr.
16 Widmer has studied all the texts in document
17 examination, and he was the one that was
18 teaching the course.
19 Q. So Mr. Widmer taught the six-month
20 program in handwriting sciences as well as the
21 advanced course for three to four days in
22 questioned document examination; am I correct?
23 A. That is correct.
24 Q. Was there anyone that came in to
25 assist Mr. Widmer as a faculty member for those
0043
1 three to four days?
2 A. If my memory serves me right, I
3 think he had assistance from Mr. Marcel Matley.
4 Q. Can you spell that, please?
5 A. Yes, Matley, M-A-T-L-E-Y.
6 Q. Was Mr. Matley a certified document
7 examiner?
8 A. He is certified now through the
9 National Association of Document Examiners.
10 Q. When you say he is certified now,
11 does that mean he was not certified at the time
12 he assisted in teaching this course in 1991?
13 A. That is correct. But he is well
14 read in the field, and he is also well
15 published in the field.
16 Q. What has he published?
17 A. He has published an index that
18 covers all the articles that deal with document
19 examination. He has a book on sequential
20 handwriting. He has a book on forgery
21 detection. Quite a few others that I have in
22 my library that are all document examination
23 related.
24 Q. Now, in 1991, according to the next
25 entry under Training in your CV, you have
0044
1 experience or had a course of study in Signature
2 Identification also in San Francisco; am I
3 correct?
4 A. Yes, that is correct.
5 Q. And according to your resume, this
6 was a study of various techniques used to verify
7 signatures, recognizing different forms of forged
8 signatures, use of equipment to aid in
9 handwriting ID. Am I correct?
10 A. That is correct.
11 Q. How long was this course?
12 A. This course, I believe, it was three
13 days.
14 Q. Who taught that course?
15 A. That was taught by Marcel Matley.
16 Q. Were those full days?
17 A. Yes, definitely.
18 Q. The next course listed is the
19 Effects of Health on Handwriting. This is said
20 to have taken place in Sunnyvale, California.
21 A. That's correct.
22 Q. Is that correct?
23 A. It is near San Jose, Silicon Valley.
24 Q. How long was that course?
25 A. That was a day, full day.
0045
1 Q. And according to your resume, this
2 was taught by Patricia Wellingham-Jones?
3 A. Yes. She is a nurse.
4 Q. And your resume says she is an
5 expert in identifying health related conditions
6 and medications affecting handwriting?
7 A. Yes. She has written a book about
8 that. The course that she taught that day, she
9 had done some research work with regards to how
10 someone with an IV in their arm would affect
11 their signature or not, and different hospital
12 forms when people fill them out where they may
13 look like it is not their signature when, in
14 fact, it is, due to stress conditions or
15 medication.
16 Q. Then, according to your resume, you
17 had advanced training with David Liebman, whose
18 name you have mentioned before as formerly
19 someone with whom you worked?
20 A. That is correct.
21 Q. And according to your resume, this
22 was, this advanced training was in a mentorship
23 program offered by the National Association of
24 Document Examiners.
25 Can you describe, please, how that
0046
1 association offered a mentorship program?
2 A. Yes. There were certain senior
3 members who often -- NADE is an association that
4 is open to all people of all levels of document
5 examination. So whether a person who has been in
6 the field for a long time or if someone is
7 just a student or if someone is just interested
8 in the field of document examination can join
9 NADE. And from there -- there are very few
10 organizations that are open to students where
11 they can receive more information and learn
12 about the field of document examination. And at
13 that time, NADE did offer an advanced mentorship
14 program in document examination where you work
15 hands-on with a document examiner.
16 Q. And how long was this advanced
17 training that you took with Mr. Liebman?
18 A. It was three years, all practically
19 five days a week.
20 Q. Was this more or less on-the-job
21 training?
22 A. Yes, that is correct.
23 Q. Were you paid for that work?
24 A. No, I was not.
25 Q. Did you pay Mr. Liebman for that
0047
1 training?
2 A. No, I did not.
3 Q. Would you receive advanced training
4 by assisting Mr. Liebman in his work as a
5 document examiner? Is that what that program
6 was all about?
7 A. No. I did not assist him with his
8 work. We would -- when cases would come in, I
9 would work on it independently. And then after
10 I finished all my work, I would hand the folder
11 to him with the documents, and he would do his
12 work independently.
13 And then afterwards, he would look
14 at my notes to see how I went through my
15 systematic analysis, and he would critique what
16 I did.
17 And sometimes there were cases that
18 came in that we would need infrared lighting and
19 so forth, and that is something I didn't know
20 at the time, and I learned that through Mr.
21 Liebman.
22 Q. Were you yourself, from 1992 to 1995
23 when you were in this advanced training
24 mentorship, were you taking assignments yourself
25 for a fee from clients?
0048
1 A. I was not working by myself at that
2 time. Towards the end of the program, Mr.
3 Liebman, he was satisfied with my work, and he
4 felt very comfortable with everything that I
5 have learned and how I was proceeding, so I was
6 receiving some money from certain cases.
7 Q. And then you sought and received
8 your board certification from NADE; am I
9 correct?
10 A. That is correct.
11 Q. Is the International School of
12 Handwriting Sciences an accredited university?
13 A. No, it is not.
14 Q. Does it have any accreditation from
15 any organization?
16 A. Not that I am aware of.
17 Q. Is it accredited by the NADE?
18 A. NADE does not accredit any schools
19 or associations, so it wouldn't.
20 Q. What are the entrance requirements
21 for the International School of Handwriting
22 Sciences?
23 A. If you have an inteher -- you know, if someone is interested in
25 the graphology portion, they can pay a fee and
0049
1 learn that portion. And if you are interested
2 in their document examination section, then you
3 take those courses and pay a fee to learn that
4 information.
5 Q. So the entrance requirements are none
6 except payment of a fee?
7 A. I am sorry?
8 Q. The entrance requirements for the
9 international School of Handwriting Sciences --
10 A. Yes.
11 Q. -- involves simply the payment of a
12 fee?
13 A. If you are interested in it at
14 first, yes. And then you pay a fee to learn;
15 that is correct.
16 Q. No one is going to pay a fee who is
17 not interested?
18 A. I hope not.
19 Q. And there is no application process?
20 A. No, there is not.
21 Q. The payment of a fee is all that is
22 required for entrance into the course?
23 A. That is correct.
24 Q. And to the best of your knowledge,
25 no one is rejected from the course of study who
0050
1 has paid the fee?
2 A. Not that I am aware of.
3 Q. How many people were present with
4 you in this once-a-week program for approximately
5 six months?
6 A. Good question. Probably, I would
7 say, ten to 15.
8 Q. How many of them had a college
9 degree?
10 A. Oh, I am not sure about that.
11 Q. The six-month program which was
12 attended once a week for four to five hours
13 each week, is that the graphology part of your
14 education?
15 A. No. It is part graphology, and it
16 is part that has to do with document
17 examination.
18 Q. Am I correct that the word
19 graphology is not found on your resume?
20 A. That is correct, because I am not a
21 graphologist. I would not be able to tell
22 anyone's personality from their handwriting if my
23 life depended on it, so you would have to just
24 shoot me.
25 Q. Ms. Wong, I am going to try to
0051
1 avoid --
2 A. Shooting me.
3 Q. -- shooting you, regardless of any
4 reaction we may have to your testimony.
5 A. All right. Thank you.
6 Q. Am I correct that for purposes of
7 your effort to obtain credibility as a document
8 examiner you prefer to disassociate yourself from
9 your graphology studies?
10 A. There are many things -- I am not
11 quite sure how to answer that, what you are
12 asking. But there are many things I have
13 learned in the past. Just because I learned
14 gardening and I don't do it very well or I
15 don't practice it doesn't mean that, oh, well,
16 since I studied it at one time, then I must be
17 a gardener. I don't practice graphology. I
18 don't use it.
19 And I am strictly a document
20 examiner, and I identify and authenticate
21 handwriting.
22 Q. And graphology does not have a lot
23 of credibility among document examiners; does it?
24 A. That is correct.
25 Q. And consequently, to be a or to seek
0052
1 to be a credible document examiner, I am
2 correct, am I not, that you wish to disassociate
3 yourself from your graphology study?
4 A. That is not true. I don't deny it.
5 To be anybody who -- as I mentioned, to be
6 well versed in the field of document
7 examination, you should look at everything that
8 deals with handwriting sciences, because if you
9 don't then you are missing and lacking in a
10 certain area of your studies.
11 In order to be a good scientist, you
12 have to research all areas. And that is what
13 I did in this case. It doesn't mean I believe
14 it, but I researched it.
15 (Defendants' Exhibit-2 was marked for
16 identification.)
17 Q. (By Mr. Rawls) Ms. Wong, Mr. Gallo
18 has just handed you a brochure which has been
19 marked Defendants' Exhibit 2, and I have given
20 Mr. Altman a copy of that and I am looking at
21 a copy.
22 Can you identify that, please, for
23 the record?
24 A. Yes. I haven't seen this before.
25 It is a brochure. I assume it is new. It is
0053
1 titled the International School of Handwriting
2 Sciences.
3 Q. As you look at that, please, would
4 you tell me whether any of these lessons -- and
5 you will see the lessons listed as the ten
6 lessons.
7 A. Okay.
8 Q. Do you see that column?
9 A. Yes.
10 Q. This is essentially, for the record,
11 of course, the video is showing you looking at
12 the brochure. But it is a fold-up paper that
13 contains about eight columns, four on one side
14 and four on the other; am I correct?
15 A. You mean on this side or the back?
16 Q. Four on each side?
17 A. Oh, four on each side. Yes, that
18 is correct.
19 Q. And the ten lessons, do you see that
20 list on the far left side of what I take to be
21 the back page?
22 A. Yes.
23 Q. And tell us if you had any of those
24 ten lessons, please, where you took the courses
25 in 1990 and 1991 out in California.
0054
1 A. Okay. The first one is Use of
2 Space. And that covers how a person uses a
3 piece of paper in regards to margin area, which
4 is something that's used in document examination.
5 How far they start from the top of the paper
6 and how they use this -- how much margin they
7 leave on the side.
8 The Size of the Writing. That is
9 common sense, large and small.

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jameson
Member since 5-8-02
08-15-02, 04:19 PM (EST)

3. "4 Cina Wong depo"
In response to message #2


10 Q. As you tell us about each of these
11 ten --
12 A. Yes.
13 Q. -- tell us whether you took that
14 course of study.
15 A. Well, it is interesting, because what
16 he writes underneath is nothing I remember.
17 It says Use of Space, how these
18 principles alone can give you a surprising
19 in-depth analysis.
20 On what I am not sure.
21 The Size of the Writing, how people
22 feel about themselves and others.
23 I don't remember that. I just know
24 size of writing with regards to document
25 examination.
0055
1 The Zonal Principle. How to tell
2 how self actualized someone is.
3 I don't remember that. But I
4 remember zones with regards to upper zones of
5 the handwriting, which would include the upper
6 portions of the lower case H's, top portions of
7 L's and so forth. Lower zones would be the
8 bottom parts of small G's and small Y's.
9 Left and Right Tendencies with Slant.
10 In documentation examination we study different
11 types of slants. His explanation is: Universal
12 concepts that allow you to develop insights in
13 any writing.
14 I don't remember that, and it
15 doesn't make any sense to me.
16 Connective Forms. That is very
17 important in document examination. It shows if
18 something is -- a connection stroke is if it is
19 curved or if it is angular or if it is arcade.
20 Mr. Widmer writes on here: How these show
21 strong indications of personality types and
22 attitudes towards the people and other people.
23 I don't know what to make of that.
24 Pressure. That is something document
25 examiners study. An example is someone who,
0056
1 when they write, when they press very hard into
2 a paper when they write leave deep impressions
3 as opposed to when someone writes with a lighter
4 hand. Mr. Widmer says here: With pressure, a
5 third dimension of handwriting and even what the
6 choice of writing implement can tell about
7 someone.
8 I don't remember covering that, but
9 I remember the heavy and light pressure and
10 medium pressure and varied pressure within
11 writing.
12 Let's see, For Those Who Print, he
13 writes: For those of you that thought you
14 could not analyze printed writing, you better
15 know this because most people today print.
16 All I remember from that course were
17 some unusual printing styles, but I don't
18 remember what the personality aspect that was
19 derived from printing.
20 Specific Letter Formations, he
21 mentions Alphabet from A to I -- A to some --
22 well, some totally different approach to
23 individual letter formations, the most important
24 letter in the alphabet.
25 I don't know what that is about, but
0057
1 I saw some very unique -- he has an array of
2 samples in his file of interesting letter
3 formations that as a document examiner you need
4 to be exposed to a lot of handwriting in order
5 to figure out what exactly is part of a class
6 characteristic or an individual characteristic of
7 writing.
8 Specific Letter Formations. Doesn't
9 say anything about that. But that also had to
10 do with different letter formations.
11 And Form Level. Form level has to
12 do with the capability in document examination
13 how if they write in the higher form level or
14 a lower, more, I hate to use the word,
15 uneducated form level, someone who is not adept
16 at using the pen or pencil very well. And
17 someone who writes very poorly can't write
18 better than they can write. And not only that
19 was taught in this class, and that is also
20 taught in document examination.
21 And Mr. Widmer has here under Form
22 Level: Taking intuition out of handwriting
23 analysis and putting it all together.
24 So, I don't know.
25 Q. Thank you. We have been going just
0058
1 over an hour. Is this a convenient time for a
2 short recess?
3 A. Yes. I have been trying to hold
4 the best I can. So, yes, this would be great.
5 Q. Good.
6 A. Thank you.
7 THE VIDEOGRAPHER: Going off the
8 video record at 10:56.
9 (A recess was taken.)
10 THE VIDEOGRAPHER: Back on the video
11 record at 11:11.
12 MR. RAWLS: Evan and Darnay, I had,
13 I believe in an exchange of e-mails, advised you
14 all that at the deposition we would have a
15 check in payment of the expense sum of money
16 which you all had told us about for Ms. Wong's
17 expenses. And, Evan, if I may deliver that
18 check to you now.
19 MR. ALTMAN: Thank you. Sure.
20 MR. RAWLS: I had intended to bring
21 it earlier today.
22 MR. HOFFMAN: Thank you. And just
23 while we're on that subject, I just received
24 your costs on that other case involving Linda
25 Hoffman-Pugh, and that is being sent out to you.
0059
1 And I am assuming that should be sent to your
2 office or to Lin's.
3 MR. RAWLS: My office is fine,
4 Darnay. Thank you.

5 MR. HOFFMAN: Should it be made to
6 your firm or to an individual?
7 MR. RAWLS: To the firm.
8 MR. HOFFMAN: Thank you.
9 MR. RAWLS: Alex, would you please
10 mark this as Defendants' Exhibit 3?
11 Evan, here is a copy for you.
12 (Defendants' Exhibit-3 was marked for
13 identification.)
14 Q. (By Mr. Rawls) Ms. Wong, Mr. Gallo
15 has just handed you a copy of what we have
16 marked Defendants' Exhibit 3. And I will tell
17 you that we received, we had these printed off
18 of the internet, and they are pages on what we
19 understand to be the website of the
20 International School of Handwriting Sciences.
21 Are you familiar with any of these pages?
22 A. No. I haven't seen these before,
23 but I know Mr. Widmer is no longer teaching
24 document examination. He found that it wasn't
25 lucrative. There weren't many people interested
0060
1 in learning about document examination, and he
2 is strictly teaching graphology now. I haven't
3 seen any of the literature. But I had heard
4 from him that he had put together a course,
5 which is what you presented to me today in the
6 brochure and in the internet, what you printed
7 out from the internet.
8 Q. Would you please turn to the second
9 page of the Defendants' Exhibit 3 which Mr.
10 Gallo just gave you. And this is a page that
11 at the top says it is about ISHS.
12 A. Okay.
13 Q. If you would look with me, please,
14 at a sentence that begins in the second
15 paragraph. And the sixth line of the second
16 paragraph --
17 A. Starting with?
18 Q. -- there is a sentence beginning,
19 quote, The introductory class emphasizes basic
20 principles of graphology.
21 Did you take such a class?
22 A. He spoke about graphology within the
23 course that I took.
24 Q. Okay. And --
25 A. But I am not sure if this is the
0061
1 class.
2 Q. You don't know if it is going to be
3 the same class as described here?
4 A. Like, because he has a whole new
5 program, so I am not sure what it is. I am
6 not familiar with this.
7 Q. Then going on in the same sentence,
8 this paper states: The intermediate class
9 stresses the relationship of graphology to
10 psychology.
11 Did you take such a class?
12 A. No, I don't remember -- I took
13 advanced document examination class. I don't
14 remember taking anything like this.
15 Q. And the same sentence goes on to
16 say: And the advanced class introduces the
17 student to a system called the personality
18 flowchart --
19 A. Okay.
20 Q. -- end quote. Did you take a
21 class, any class at all about the personality
22 flowchart?
23 A. I don't remember that. That must be
24 new. I see the copyright symbol there also.
25 Q. Yes, and the personality flowchart
0062
1 has a small copyright symbol near it which
2 indicates that perhaps ISHS has copyrighted that
3 name or course?
4 A. Probably.
5 Q. But that is new to you; is that
6 correct?
7 A. Oh, yes, it is.
8 Oh, he still offers his questioned
9 document class. Good.
10 Q. Did you take the course of study
11 with the ISHS in person or from home study?
12 A. In person. I lived in the San
13 Francisco Bay area. I heard that this home
14 study is something new within the past year or
15 so.
16 Q. And if you would turn with me for a
17 moment, please, back to Defendant's Exhibit 1,
18 which is, again, your resume?
19 A. Yes.
20 Q. We spoke briefly earlier about the
21 course in Sunnyvale taught by Patricia
22 Wellingham-Jones, who you had told us is a
23 nurse, on effects of health on handwriting?
24 A. Right. And she also is involved in
25 handwriting, and she is a nurse.
0063
1 Q. Was that course on effects of health
2 on handwriting, was that part of the ISHS
3 school?
4 A. No. That is separate.
5 Q. Was this something that you paid
6 for?
7 A. Yes, that is correct.
8 Q. And would you say that Ms.
9 Wellingham-Jones gave a course on graphology to
10 you during that one-day program?
11 A. No. She just spoke about her
12 studies and her research with regards to the
13 effects of health on handwriting and about her
14 IV research. I did find out, actually just
15 recently I was posed a question whether she was
16 a graphologist or not, and I didn't realize
17 that, and someone had informed me that she was.
18 But I did not know that at the time when I
19 took her course.
20 Q. Okay. Let's, and with further
21 reference to your resume, Defendant's Exhibit 1,
22 let's move on down to page 2 to the last group
23 of entries on the page. And this has to do
24 with what your resume states is, quote,
25 Completion of college level course in questioned
0064
1 documents, end quote, at Northern Virginia
2 College?
3 A. That's correct.
4 Q. Did you enroll in Northern Virginia
5 College in order to take this course?
6 A. Yes.
7 Q. And for how long did you enroll?
8 A. Oh, it is just specifically for this
9 course. I filled out papers. I am not sure.
10 I can't remember. You mean enroll and I had
11 to send in my transcripts from my previous
12 college and so forth?
13 Q. Yes.
14 A. Yeah. I can't remember if I had to
15 do that. I just remember signing up for the
16 course. I am not sure what type of application
17 I had to fill out. I may have.
18 Q. So whatever enrollment or application
19 you did with Northern Virginia College, it was a
20 one-course effort only?
21 A. That is correct.
22 Q. And this was the course, that is,
23 Mr. Zigler's course on questioned documents?
24 A. Yes. I was specifically interested
25 in his course. And Mr. Zigler is a well
0065
1 respected document examiner in the whole field.
2 Q. How many days a week did you attend
3 this class with Larry Zigler?
4 A. Actually, in the usual course where
5 it took place actually on the weekends. I
6 think it was Friday, Saturday or Saturday,
7 Sunday. I can't remember.
8 But it went on for two or three
9 weeks. And though graphology was not taught in
10 this class, because it was strictly document
11 examination, Mr. Zigler has taught courses to
12 FBI and Secret Service agents with regard to
13 graphology because he knows it is important for
14 all the agents that are involved in document
15 examination to have a well-rounded information in
16 handwriting sciences.
17 Q. And on the weekends, how long each
18 day did you spend in this course?
19 A. It was a full day.
20 Q. So this was two full days during how
21 many weekends?
22 A. It was either two, three, or four.
23 I can't remember exactly.
24 Q. So this was a total, this class with
25 Larry Zigler took a total of either four, six,
0066
1 or eight days --
2 A. That is correct.
3 Q. -- to complete?
4 A. Yes.
5 Q. And were you graded in this course?
6 A. I don't believe we were, but we
7 received a certificate of completion.
8 Q. Did you receive college credit for
9 this course?
10 A. Good question. I don't know. I
11 wasn't interested in the college credit. I was
12 just interested in taking the course.
13 Q. Northern Virginia College's exact name
14 is Northern Virginia Community College; am I
15 right?
16 A. That could be correct. I am sorry.
17 You said it was Northern --
18 Q. Virginia Community College.
19 A. Okay. It could be. I just know
20 they call it Annadale College.
21 Q. Did you receive at any time any
22 degree from that college?
23 A. No, I did not.
24 Q. When you say that Mr. Zigler's
25 course was a college level course, what do you
0067
1 mean by that?
2 A. He taught it at the college to --
3 there were other college students involved.
4 There were about 25, 25 or 28 college students
5 in there along with some document examiners.
6 Q. And there were some people there
7 such as yourself who were not college students
8 at all?
9 A. That is correct.
10 Q. Were the students that were, in
11 fact, trying to get some form of a degree from
12 Northern Virginia Community College who attended
13 this course, were they given course credit
14 toward their graduation for that course?
15 A. I am not sure. I didn't speak with
16 them about it. But as a college student, I
17 wouldn't want to take anything I wasn't going to
18 getting credit for.
19 Q. Were they graded?
20 A. I can't remember. I am sorry.
21 Q. Was this pass/fail?
22 A. I don't even remember that.
23 Q. Was there any paper involved?
24 A. No, there was no paper involved.
25 Q. Was there a test involved?
0068
1 A. There was some testing involved with
2 regards to form blindness and to -- he handed
3 out a piece of paper with a bunch of signatures
4 on it we were supposed to identify from another
5 -- we were supposed to categorize which writer
6 wrote certain signatures, and we had to combine
7 those signatures.
8 Q. Did Mr. Zigler give you feedback if
9 he didn't give you a grade?
10 A. Yes. Well, we turned in the form
11 blindness test. He made comments. And also --
12 I believe he made comments about that one test,
13 he should have, with regards to matching up
14 signatures.
15 Q. So you had a few minutes of
16 individualized comments from Mr. Zigler on your
17 own performance?
18 A. In front of the class he made
19 comments.
20 Q. So you did not have any
21 individualized feedback yourself from Mr. Zigler?
22 A. That is correct.
23 Q. He simply commented to the class as
24 a whole on some of what the students turned in?
25 A. That is correct. And, of course, I
0069
1 spoke to him afterwards about certain portions
2 of the class.
3 Q. So it would not be accurate to say
4 that Mr. Zigler trained you, would it; it would
5 be accurate simply to say that you sat through
6 his course?
7 A. It was a course instructed by Mr.
8 Zigler.
9 Q. The class would, if I understand
10 your testimony correctly, have been a basic
11 overview of the field of questioned document
12 examination; am I right?
13 A. Yes. It included that.
14 Q. And do you recall that Mr. Zigler
15 told his students and the non-students attending
16 the class that these few days of study were not
17 designed to teach them to be practicing forensic
18 document examiners; didn't he?
19 A. I don't remember him mentioning that,
20 but that is true about that course. I mean,
21 you can't take that and go out and be a
22 document examiner; that is correct.
23 Q. Did you ever take any other courses
24 with Mr. Zigler?
25 A. No, I have not.
0070
1 Q. I want to direct your attention back
2 to Mr. Dave Liebman whose name has come up in
3 this deposition up to now several times and who
4 is, of course, also named in your resume on
5 page 2 and with whom you have been in practice
6 regarding questioned documents at times during
7 your career.
8 Does Mr. Liebman teach a course at
9 Old Dominion University?
10 A. He used to at one time.
11 Q. What is the subject of that course?
12 A. Good question. I don't know. When
13 I met Mr. Liebman, I think he was no longer
14 teaching that course.
15 Q. And you met Mr. Liebman when?
16 A. At a conference at the National
17 Association of Document Examiners, a NADE
18 conference. And it was a conference they had
19 in California, which would be in 1991.
20 Q. So he had already stopped teaching
21 that course at Old Dominion, to the best of
22 your knowledge, by 1991?
23 A. I am not sure when.

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jameson
Member since 5-8-02
08-15-02, 04:25 PM (EST)

4. "5 Cina Wong depo"
In response to message #3


24 Q. Did you learn that the subject of
25 that course taught by Mr. Liebman was
0071
1 determining whether an individual had cancer by
2 examining the person's handwriting?
3 A. No, I was not aware of that. It
4 was taught at a college? Old Dominion or --
5 Q. I am not here to answer. I am
6 trying to obtain what information you have about
7 that.
8 A. Oh, okay. If it was taught at Old
9 Dominion University, that is an accredited
10 college.
11 Q. But you don't know the subject
12 matter and you don't know whether he taught
13 about determining the existence of cancer by
14 looking at a person's handwriting; am I correct?
15 A. No. He could have taught something
16 about bug larva and I wouldn't know.
17 Q. Was Mr. Liebman asked, to your
18 knowledge, to be an expert witness on behalf of
19 Chris Wolf in this case that brings you here
20 today?
21 A. I am sorry. What was that question?
22 Q. Was Mr. Liebman asked to be an
23 expert witness in the Chris Wolf case, the same
24 case that you are assisting Mr. Darnay Hoffman
25 and Mr. Evan Altman in today?
0072
1 A. I am not sure. At that time when I
2 was asked Mr. Liebman and I no longer had a
3 business. We still talked, but that isn't an
4 issue that comes up.
5 Q. So Mr. Liebman has not told you that
6 he was or was not asked to be an expert
7 witness by Mr. Hoffman or Mr. Altman?
8 A. That is correct.
9 Q. Do you keep in touch with Mr.
10 Widmer, Ted Widmer?
11 A. I spoke to him recently because I
12 heard that, through the grapevine, he had
13 recently gotten married, and I wanted to wish
14 him my best.
15 Q. Are you aware of some legal issues
16 that Mr. Widmer encountered in about 1995?
17 A. No, I am not. What type of legal
18 issues are you talking about?
19 Q. Are you aware that Mr. Widmer signed
20 a stipulation with the San Francisco District
21 Attorney's office that he falsified in court his
22 questioned document credentials?
23 A. No, I did not. To what degree?
24 Q. I am sorry?
25 A. To what degree?
0073
1 Q. I, again --
2 A. I was curious. I didn't know.
3 Q. I am just here to ask you questions
4 and probe your knowledge.
5 A. Okay.
6 Q. And as I understand your testimony,
7 you have no knowledge of that; am I correct?
8 A. No, I do not.
9 Q. It would not be appropriate, of
10 course, ever to falsify one's credentials as a
11 questioned document examiner?
12 A. That is correct. But his actions
13 have no bearing on my actions.
14 (Discussion ensued off the record.)
15 Q. (By Mr. Rawls) Ms. Wong, would you
16 please turn back to Defendants' Exhibit 3 to
17 your deposition. And on the, I guess this is
18 the third page from the back --
19 A. Third page from the back. Okay.
20 Q. -- there is a section under the bold
21 caption: Other graphologists rave.
22 Do you see that?
23 A. Uh-huh (affirmative).
24 Q. And there is the quoted phrase:
25 Ted, thanks for giving me my start, end quote.
0074
1 And under that is the name C. Wong, Norfolk,
2 Virginia.
3 A. Uh-huh.
4 Q. Did you, in fact, make that
5 statement about Mr. Widmer's course?
6 A. I did not make it with regards to
7 the graphology course. I made that comment with
8 regards to the document examination course. So
9 I am surprised to see it here today underneath
10 graphology, because actually I first learned
11 document examination through Ted. So this is
12 surprising to me. But I did say that to him,
13 but in a different context.
14 Q. So the fact is you do not consider
15 yourself a graphologist?
16 A. Of course not.
17 Q. And the website page that we've just
18 discussed seems to label you a graphologist?
19 A. That is what it appears to be here,
20 but it is incorrect.
21 Q. And would you, therefore, likely
22 intend to ask Mr. Widmer to please remove your
23 name and your quote from this page?
24 A. Yes. I will ask him to remove the
25 quote or I will have to ask him to put it in
0075
1 the correct context, which is with regards to
2 his document examination course.
3 Q. And, Ms. Wong, if you learn that, in
4 fact, Mr. Widmer did, in 1995, enter a
5 stipulation that he had falsified his own
6 credentials on questioned documents, would you
7 ask him to take your name out of his materials
8 altogether?
9 A. Yes, if that is the truth. Are you
10 saying he -- I don't understand your question
11 clearly. He falsified information with regards
12 to documents at hand or with regards to his CV?
13 Q. His credentials.
14 A. Okay.
15 Q. His credentials?
16 A. Thank you for bringing that to my
17 attention. I didn't realize this.
18 Q. Certainly.
19 Let's move to page 3 of your resume,
20 and this is back, of course, to Defendant's
21 Exhibit 1. You state that, under Continuing
22 Education, you attended Andrew Bradley's Forensic
23 Document Examination course.
24 A. Oh, I didn't attend it. That is a
25 course that is through correspondence through
0076
1 mail. And you send the course and you work on
2 the course when you find the appropriate time
3 to. And there is testing at the end of each
4 chapter is how it works. It gives you a test.
5 And after you answer the questions, you send it
6 back into his office, and they send you a
7 critique back.
8 Q. How much did you pay for that
9 correspondence course?
10 A. I don't remember. I am sorry.
11 Q. How much time did you spend on each
12 of the 20 lessons?
13 A. Actually, I haven't finished all the
14 courses, that is why it is under Continuing.
15 But I can't give you a number right off the
16 top of my head.
17 Q. How many of the 20 lessons have you
18 completed?
19 A. I have been through either the first
20 three or four.
21 Q. On your resume, you state that the
22 course entails subjects such as the mechanics of
23 handwriting, proper procedures for obtaining
24 exemplars, identification of handprinting,
25 disguised writing, forgeries, photocopy
0077
1 examination, typewriter identification, anonymous
2 letters, document photography, examination of ink
3 and paper, writing instruments, erased and
4 obliterated writing, and use of ESDA.
5 Have I read correctly?
6 A. That is correct.
7 Q. And which of those subjects have you
8 yet completed?
9 A. I, just to be -- this is right off
10 the table of contents, so it would be, like,
11 the first three or four. And actually, I have
12 knowledge of all the ones that you've mentioned;
13 I have knowledge in all those areas already.
14 Q. So your continuing education has
15 taken you through the first three or four?
16 A. That is correct.
17 Q. And exactly three or exactly four?
18 A. I can't remember. I am sorry.
19 Q. So you don't know if you have gotten
20 to disguised writing yet, which is number four
21 on this list?
22 A. That is correct. As I mentioned, I
23 have knowledge in all these areas.
24 Q. Is Mr. Bradley certified by the
25 American Board of Forensic Document Examiners?
0078
1 A. I am not sure of that.
2 Q. Is Mr. Bradley certified by the
3 American Society of Questioned Document
4 Examiners?
5 A. I am not sure. All I know of Mr.
6 Bradley is he used to be a document examiner
7 with the sheriff's department in, I believe,
8 whatever state he lives in. I forgot. I am
9 sorry.
10 Q. So he worked for the sheriff's
11 office in a county or a city of a state that
12 you don't now recall?
13 A. That is correct. That is my
14 understanding.
15 Q. And back to Mr. Liebman for a
16 moment. Is Mr. Liebman certified by the
17 American Board of Forensic Document Examiners?
18 A. No. But he is certified through
19 NADE, N-A-D-E; and he was also past president of
20 NADE, which I am also a past vice president of.
21 Q. And is Mr. Liebman certified by the
22 American Society of Questioned Document
23 Examiners?
24 A. No. A lot of those organizations
25 that you are mentioning are open to just
0079
1 government or government document examiners who
2 have retired and are now in the private field.
3 So since I have not been in the government
4 field, or anybody that is not in the government
5 field, they are not allowed membership.
6 And certification through some of
7 those associations that you did mention are
8 voluntary.
9 Q. Ms. Wong, back to page 3 of your
10 resume, under Related Education, you state, you
11 list Private Investigator Licensing Course in
12 Virginia Beach, Virginia. And your resume
13 describes this as an in-depth, state-accredited,
14 60-hour course taught by Vince Tortomasi, former
15 Norfolk, Virginia police officer. Am I correct?
16 A. That is correct.
17 Q. Did that private investigator
18 licensing course cover forensic document
19 examination?
20 A. It touched upon it.
21 Q. It touched upon it?
22 A. It touched upon many subjects.
23 Q. About how much time was devoted to
24 document, forensic document examination in that
25 course?
0080
1 A. I wouldn't be able to give you an
2 exact number. I wouldn't remember. But it
3 covered a little bit about fingerprinting; it
4 covered a little bit about ballistics; covered
5 investigation procedures and so forth, including
6 a little bit on document examination.
7 Q. So was it something of an overview
8 of what private investigators need to know?
9 A. That is correct.

10 Q. Did you receive or ever apply for a
11 private investigator license?
12 A. We -- I like to call it
13 certification. I received my certification
14 through the state. And every two years I have
15 to go -- in order to get a renewal, I have to
16 go for a continuing education course.
17 Q. So are you a licensed private
18 investigator?
19 A. In the State of Virginia. It is a
20 licensing course, but what we receive is a
21 registration or a certification.
22 Q. So you have a certification and not
23 a license?
24 A. Right. It is strange. It is a
25 licensing course; but as a private investigator,
0081
1 you receive a certification or a registration.
2 And I am not practicing as a private
3 investigator.
4 Q. And you have no registration as a
5 private investigator?
6 A. Yes, I do. I am registered as a
7 private investigator, but I am not practicing as
8 one.
9 Q. We then move in sequence on your
10 resume to Specialized Course on Document
11 Examination in Bend, Oregon; and you describe a
12 handwriting analysis course instructed by John W.
13 Hargett, the Chief Document Examiner for the
14 U.S. Secret Service, and you go onto describe
15 Mr. Hargett.
16 Would you please tell us when it is
17 that you completed that course?
18 A. Well, I have here that it was in
19 1998. And what --
20 Q. How many classes did you attend?
21 A. He -- what he was -- the reason why
22 I was interested in taking his course, it was
23 promoted by the Northwest Fraud Investigator's
24 Association out on the West Coast, and this was
25 in the State of Washington. And what he was
0082
1 going to be teaching there, what I was told,
2 was exactly what he was teaching in the Secret
3 Service school that is usually taught over a
4 two-week period. And he was teaching a
5 condensed course for this group in document
6 examination.
7 Mr. Hargett is highly regarded, and
8 I knew that was a course that I definitely
9 would want to take.
10 Q. And I believe I asked you how long
11 you --
12 A. It was over a three- to four-day
13 period, I believe.
14 Q. A three- to four-day period?
15 A. That is correct.
16 Q. And how many hours per day?
17 A. It was a full day each day.
18 Q. Is there a course syllabus for that
19 condensed course?
20 A. I can't remember. I just know that
21 what he was teaching he said this is what I
22 teach at the Secret Service school.
23 Q. And --
24 A. And he took us through different
25 exercises, and we worked out certain problems,
0083
1 and he taught us certain basics and some
2 advanced techniques in document examination.
3 Q. You refer to this course as, quote,
4 Specialized, end quote. What was specialized
5 about it?
6 A. Well, that it was not often do you
7 get to take a course by a well respected person
8 like a John Hargett or a Larry Zigler, and I
9 was very fortunate to be able to get this
10 course. And it's specialized because he taught
11 the Secret Service handwriting school, document
12 examination school, and he was also teaching it
13 here.
14 Q. So it was specialized because he was
15 a special individual?
16 A. Well, no. Usually in order to take
17 the Secret Service handwriting course, you have
18 to be a document examiner in the government or
19 someone that is related to the field, and that
20 is when they allow you into that school.
21 Otherwise, you are not able to attend that
22 school.
23 Q. I notice on page 4 of your resume,
24 which is the very next page --
25 A. Yes.
0084
1 Q. -- that you attended the NWFIA
2 conference in 1998 in Bend, Oregon. Was Mr.
3 Hargett's course in document examination offered
4 as part of that particular NWFIA conference in
5 1998?
6 A. Yes. As I mentioned earlier, NWFIA
7 sponsored that course.
8 Q. What were the requirements to take
9 that course?
10 A. If you had an interest in taking the
11 course, then you could sign up for the
12 conference and attend.
13 Q. Was there a fee?
14 A. Yes, there was.
15 Q. How much was that?
16 A. I can't remember. I am sorry.
17 Q. How many people attended that course?
18 A. Wow. It appeared to be 80 or 100
19 or more people there.
20 Q. Were you graded in that course?
21 A. No, we were not graded.
22 Q. Was it a pass/fail course?
23 A. No, it was not.
24 Q. Did you receive a certificate or a
25 diploma or any indication you had taken that
0085
1 course?
2 A. There may have been a certificate of
3 completion, but I am not sure.
4 Q. Did you submit samples of your work
5 to Mr. Hargett?
6 A. No, I did not.
7 Q. Did you take a test?
8 A. We all were given some work to do,
9 just as in Mr. Zigler's class, to compare
10 handwritings and to see how many writers wrote
11 different signatures and so forth and to match
12 them up. And he also gave us group projects
13 also where a group of us got together, and we
14 decided whether certain documents had one or two
15 writers.
16 Q. Did you receive any individual
17 feedback personally from Mr. Hargett?
18 A. I spoke with him afterwards; that is
19 about it.
20 Q. So he did not comment on your work
21 or your conclusions?
22 A. That is correct.
23 Q. And, Ms. Wong, may I ask you to
24 move backwards and to the top again of page 3
25 of your resume briefly --
0086
1 A. Sure.
2 Q. -- back to Mr. Andrew Bradley's
3 forensic document examination course.
4 A. Yes.
5 Q. Mr. Bradley is the person you
6 understood to be a former sheriff from
7 somewhere?
8 A. That is correct.
9 Q. When did you take that 20 -- excuse
10 me. I beg your pardon.
11 When did you begin to take Andrew
12 Bradley's course?
13 A. I think I started, I purchased the
14 course in '92 or something, and I was still in
15 California and then moved over here to -- moved
16 over to Norfolk, Virginia. And as I was
17 unpacking, it just kept getting moved around, so
18 I haven't had a chance to finish it.
19 Q. And down to the private investigator
20 licensing course you took in Virginia Beach --
21 A. Yes.
22 Q. -- when did you take that course?
23 A. Good question. I've had it for a
24 while. I have taken that at least four -- four,
25 five, or six years ago. It has been a while.
0087
1 Q. Was that a correspondence course?
2 A. No, it was not.
3 Q. Did you pay a fee to take that
4 course?
5 A. Yes, that is correct.
6 Q. Was there any degree offered or any
7 grade offered in that course?
8 A. We had to pass a test. And if we
9 didn't pass, we didn't get our registration.
10 Q. Your resume states that the course
11 was an in-depth course. What was in-depth about
12 it?
13 A. He went through all the specifics on
14 investigation, how to handle an investigation and
15 so forth, went into a lot of that.
16 Q. I want to now ask you to tell me
17 some more about the NADE, the National
18 Association of Document Examiners. Earlier you
19 gave us the names of the two founders, Phyllis
20 Cook and Renee Martin.
21 A. That is correct.
22 Q. Does Ms. Cook have an accreditation,
23 please, with the American Board of Forensic
24 Document Examiners?
25 A. I am not familiar with what her
0088
1 background is in that field.
2 Q. Does she have a certification with
3 the American Society of Questioned Document
4 Examiners?
5 A. I don't have any knowledge of her
6 being associated with them or not.
7 Q. And do you know about whether Ms.
8 Renee Martin is certified by the American Board
9 of Forensic Document Examiners?
10 A. I don't have any knowledge on her
11 background with that regard either.
12 Q. Or the American Society of Questioned
13 Document Examiners?
14 A. I don't have any information.
15 Q. The fact is, is it not, that they
16 are graphologists?
17 A. I know that they do have a
18 graphology background, but the National
19 Association of Document Examiners, it is a
20 strict organization of just purely document
21 examination and no graphology.
22 Q. Would I be correct to characterize
23 the National Association of Document Examiners as
24 an organization that is principally comprised of
25 individuals with graphology backgrounds who would
0089
1 like to be document examiners?
2 A. Well, that is not true. We have
3 people there in the police force who are part
4 of our group. We have an ex -- I think he's
5 FBI, an ex-FBI person that is with us.
6 Actually two, or one may be Secret Service. We
7 have some government people, and we have lots of
8 students also.
9 But, no, the large graphology
10 background and then wanting to be is not true.
11 They've -- a lot of the people that attend our
12 conferences are strictly interested in the field
13 of document examination; and we do not teach
14 graphology there.
15 Q. Aren't most members of the NADE
16 individuals who have graphology backgrounds?
17 A. I know there are individuals there
18 with graphology background. To what degree and
19 how many, I am not sure what that number is.
20 Q. And people tend to come to the NADE
21 for accreditation when they cannot get
22 accreditation as a document examiner through some
23 other organization; am I not correct?
24 A. That is not true. There are other
25 organizations that are open to document examiners
0090
1 also. And even Mr. Zigler has a graphology
2 background. Like I said, he taught it to other
3 agents.
4 Q. Who accredits the NADE?
5 A. What do you mean by that?
6 Q. Does it have any accreditation, the
7 organization itself?
8 A. We are an organization. I don't
9 know --
10 Q. The NADE, that organization --
11 A. Yes.
12 Q. -- does it have any accreditation
13 from any place at all?
14 A. We are our own group, and we are
15 not a branch from another group where we need
16 to be accredited or separately. We are not
17 with a large group where we have a document
18 examination section and a fingerprint section.
19 No. We are just strictly document examination.
20 MR. RAWLS: Okay. We need a short
21 pause, I am told, for the benefit of changing
22 the videotape, so let's go off the record.
23 THE WITNESS: Sure.
24 THE VIDEOGRAPHER: Going off the
25 video record at 11:54.
0091
1 (A recess was taken.)
2 THE VIDEOGRAPHER: Back on the video
3 record at 11:57.
4 Q. (By Mr. Rawls) Ms. Wong, is the
5 NADE accredited by any forensic science
6 organization?
7 A. No, not that I am aware of.
8 Q. By any law enforcement group?
9 A. No. I didn't realize law
10 enforcement groups accredited other organizations
11 like document examination.
12 Q. Is there any state or federal
13 government certification or an accreditation of
14 the NADE?
15 A. No, not that I am aware of.
16 Q. There are a -- there are more than
17 just a few organizations that claim to be
18 questioned document examiner organizations; are
19 there not?
20 A. Not claim to be. They say they are
21 document examination organizations.
22 Q. And apart from the NADE, what other
23 ones have you applied to?
24 A. I haven't applied to any other ones.
25 I am happy with the National Association of
0092
1 Document Examiners. But I have heard some good
2 things about AFDE lately, AFDE; and I am
3 interested in finding out more about that group.
4 Q. What is AFDE?
5 A. American Forensic Document Examination
6 group.
7 Q. And, Ms. Wong, with respect to your
8 own board certification you told us about, of
9 the five to seven people in the room when you
10 took the oral portion of the accreditation test,
11 how many of those individuals were, to your
12 knowledge, accredited by some organization other
13 than the NADE?
14 A. I am not aware of what their
15 backgrounds are except for Mr. Liebman. I
16 should say when I mean people in the room,
17 those were the people in the room in charge of
18 making comments and notes with regard to my
19 certification.
20 Q. You joined NADE in 1991, if I am
21 correctly reading your resume; did you not?
22 A. Yes, that is correct.
23 Q. What was required in order for you
24 to be accepted into the NADE as a member?
25 A. As I mentioned, NADE is open to
0093
1 people who are practicing document examiners.
2 They are open to students, and they are open to
3 people who have been interested in the field.
4 So I filled out an application, and I joined
5 NADE.
6 Q. So essentially an application and a
7 fee were all that was required?
8 A. As so it is with most groups.
9 Q. Is the answer yes?
10 A. I am sorry?
11 Q. Is the answer yes to my question?
12 A. Which is, I am sorry?
13 Q. An application and a fee --
14 A. For NADE, yes.
15 Q. -- were all that NADE required?
16 A. Oh, I am sorry. Application and
17 three letters of reference or recommendation.
18 Q. And who wrote yours?
19 A. One was from Victoria Mertes, who is
20 also past vice president of NADE. And I can't
21 remember who the other two came from. It has
22 been a while.
23 Q. To join NADE, did you have to take
24 any form of test?
25 A. No, I did not.
0094
1 Q. Did you have to get a certain score
2 on anything?
3 A. No, I did not.
4 Q. And what is required for you to
5 continue to be a member of NADE?
6 A. To be a member or a certified
7 member?
8 Q. Well, first a member.
9 A. First a member, you pay your dues.
10 And what the dues include is a newsletter every
11 month, and you receive a professional journal
12 with articles with regard to document examination
13 and notifications of coming conferences, which
14 are reported.
15 Q. And what needs to happen for you to
16 continue to be a certified member of NADE?
17 A. You must attend so many conferences
18 to show that you have continuing education,
19 participate with writing articles for the
20 journal, or a combination of both.
21 Q. Are you a diplomate of the NADE?
22 A. A diplomate, no, I am not.
23 Q. What is a diplomate?
24 A. That -- usually that is held for
25 people who are held in high regard in the
0095
1 association. I haven't applied for it, but
2 there are certain requirements that you have to
3 meet in order to become a diplomate.
4 Q. So you are a past vice president of
5 NADE --
6 A. That is correct.
7 Q. -- but you have not applied?
8 A. No, I have not.
9 Q. What is required for you to be a
10 diplomate?
11 A. As I mentioned, I am not quite sure
12 what the details are with that.
13 Q. Where is the home office of NADE?
14 A. It is incorporated, I believe, in
15 Delaware or New Jersey, but usually it follows
16 around where the current president is. And the
17 current president at this time is Kathy
18 Koppenhaver, and she is in Maryland.
19 Q. Well, I am sure it has a
20 headquarters office; does it not?
21 A. Oh, I see what you are saying.
22 Usually it is with one of the founders, and I
23 believe it is with Renee Martin.
24 Q. I don't understand your use of the
25 word usually. Is there a headquarters or not?
0096
1 A. I guess I am not sure what you mean
2 by headquarters. But it is with Renee Martin,
3 and I believe she lives in Princeton, New
4 Jersey. Because when you look up the
5 association for NADE, the contact person is
6 Renee Martin, who is past founder.
7 Q. Let me put it this way. Is there a
8 physical office that is the national headquarters
9 of NADE that I could go visit and see people
10 and talk to people and get their brochures,
11 obtain their literature, talk to their
12 receptionist, be escorted to the employees'
13 offices? Is there such a place?
14 A. Oh, we don't have a main office just
15 for that. But Ms. Martin handles all that.
16 Q. Well, do you have any office?
17 A. Yes. Ms. Martin has an office, and
18 also the headquarters of NADE is from that. If
19 anybody needs a brochure on NADE, she would
20 recommend them to contact the membership
21 chairman, or if they would like to speak to the
22 president, then she will direct the call to the
23 president.
24 Q. And is this office in Ms. Martin's
25 professional office?
0097
1 A. Yes, that is correct.
2 Q. And is that in her home?
3 A. I am assuming. I am not sure.
4 Q. You have not visited this office of
5 NADE?
6 A. No, I have not.
7 Q. So are you assuming there is one,
8 but you couldn't tell me for sure?
9 A. I just know from what I am told.
10 Q. Have any of the NADE conferences
11 that you have attended been held in a home
12 office or headquarters office of NADE?
13 A. No, it has not. It is usually held
14 in a location at a hotel with enough conference
15 area to hold all of the members that do attend.
16 Q. How many members does NADE have?
17 A. Last time I checked, which has been
18 a while, it was somewhere between 85 and 89.
19 I believe it is higher now. I believe it is
20 over 100, probably.
21 Q. Once a person is certified by NADE,
22 is there a peer review mechanism within the
23 organization?
24 A. For instance, before the person
25 applies or --
0098
1 Q. No. After the person is certified.
2 A. Yes.
3 Q. What kind of peer review organization
4 is there or mechanism?
5 A. Well, we have an ethics committee.
6 For instance, if anybody, if it is reported to
7 the ethics committee, they will do an
8 investigation if they find that a member is not
9 behaving within the ethical guidelines. This is
10 for within the organization if we have any
11 complaints.
12 Q. Has anyone ever been expelled from
13 NADE for violating the ethical requirements?
14 A. I believe it was done in a very
15 polite way where the person did not come back.
16 Q. Was the person stripped of his or
17 her board certification?
18 A. This is to the best of my knowledge;
19 I am not sure if these are actual facts of the
20 event.
21 From what I understand, someone
22 claimed to have certification with NADE when, in
23 fact, they did not. So they were not welcome
24 back into the association, and they never had
25 certification to begin with.
0099
1 Q. And that is the only expulsion of a
2 member you are familiar with?
3 A. That I am familiar with. There may
4 be others, but I am not familiar with those.
5 Q. Are there any of the 85 to 89, or
6 possibly more now, members of NADE employed by
7 the FBI?
8 A. Not currently. Some are -- they are
9 retired FBI. We still have some people who
10 work for the state government.
11 Q. Are any of the 85 to 89 or perhaps
12 more members of the NADE employed by the United
13 States Secret Service?
14 A. No, not currently.
15 Q. If I correctly understand your
16 testimony, you yourself have not applied for
17 membership in the American Academy of Forensic
18 service -- excuse me, Forensic Sciences?
19 A. As I mentioned, a lot of those
20 organizations are open to people who work for
21 the government or have come from government
22 jobs. And in that sense, it is a little
23 discriminatory; and I am not able to apply.
24 Q. And have you not applied for the
25 American Board of Forensic Document Examiners?
0100
1 A. I am sorry, which one?
2 Q. The American Board of Forensic
3 Document Examiners.
4 A. That is another group that
5 discriminates against people who are not
6 government employed.
7 Q. Let me ask my question again.
8 A. Sure.
9 Q. It is a yes or no question.
10 A. I am sorry.
11 Q. You have never applied for
12 certification by the American Board of Forensic
13 Document Examiners; have you?
14 A. No. They discriminate.
15 Q. And you also have never applied for
16 certification from the American Society of
17 Questioned Document Examiners; am I correct?
18 A. That is correct. I believe they
19 have the same rules.
20 Q. Have you looked at the requirements
21 for certification by the American Board of
22 Forensic Document Examiners?
23 A. Let's see. I believe so, and I
24 believe it says that is voluntary. A lot of
25 people were grandfathered in early on in the
0101
1 beginning. And I am not sure if it is their
2 group or a different group that their board
3 certification test is sent to them. So it is
4 not taken in a public area where it is
5 proctored.
6 Q. Are you aware that for certification
7 by the American Board of Forensic Document
8 Examiners there are a number of qualifications?
9 Do you know that?
10 A. No. Go ahead.

11 Q. Do you know that one of those
12 qualifications is training at a forensic
13 laboratory?
14 A. For that group, that is a
15 requirement.
16 Q. So you do know of that requirement.
17 And have you yourself ever trained
18 at a forensic laboratory?
19 A. There is no standard in this field
20 that dictates where or when --
21 Q. Excuse me. Do you recall the
22 question: Have you yourself ever --
23 A. Oh, okay.
24 Q. -- trained at a forensic laboratory?
25 A. No, I haven't.
0102
1 Q. Thank you. So the American Board of
2 Forensic Document Examiners discriminates against
3 people like yourself who do not have forensic
4 laboratory training; am I correct?
5 A. No, that is different. That is not
6 discriminatory. That is a requirement in, as
7 they put it, for their group.
8 Q. And it is a requirement that you
9 have not met?
10 A. I have had an internship or a
11 mentorship program. But they believe in for
12 three years. But, as I mentioned, where my
13 work is corrected and it's been supervised. But
14 I have also received additional training from
15 Larry Zigler and also from John Hargett.
16 Q. Mr. Liebman did not run a forensic
17 laboratory; did he, Ms. Wong?
18 A. No, he did not.
19 And even the FBI didn't pass their
20 standards for their FBI laboratory at one time
21 either. And so there are difficulties in this
22 field and in the laboratory field with regards
23 to standards.
24 Q. Have you ever applied for training
25 at a forensic laboratory?
0103
1 A. You don't apply for training at a
2 forensic laboratory. How that works is if you
3 are in the field of document examination with
4 the government, then you are able to work within
5 that type of laboratory.
6 Q. Do you know that for certification
7 by the American Board of Forensic Document
8 Examiners a person needs to supply three
9 references from recognized forensic document
10 examiners recognized by the American Board of
11 Forensic Document Examiners? Are you aware of
12 that requirement?
13 A. Yes, I am. That is -- so you
14 actually have to know people to get in. Kind
15 of like nepotism.
16 Q. Actually, you have to obtain
17 references.
18 A. That's right, but from three people
19 you know that are members. So you kind of
20 have to know people in order to get in.
21 Q. Have you --
22 A. You can't -- sorry.
23 Q. Have you any references from American
24 Board of Forensic Document Examiners, recognized
25 forensic document examiners?
0104
1 A. I am sorry.
2 Q. Are there any such individuals who
3 would supply you with a reference if you were
4 to seek certification from the American Board of
5 Forensic Document Examiners?
6 A. I can't answer for them. But if I
7 -- I wouldn't know until I asked.
8 Q. Who are you closest to?
9 A. With regards to?
10 Q. Of recognized ABFDE forensic document
11 examiners?
12 A. Oh, I am not sure. I think Mr.
13 Zigler is a member of it, but I have never
14 asked him for a recommendation. I would only
15 need to ask him for a recommendation if I were
16 to apply to ABF -- American Board of Forensic
17 Document Examiners.
18 Q. Ms. Wong, your resume mentions from
19 time to time the NWFIA, which is said to be
20 the Northwest Fraud Investigators Association; am
21 I correct?
22 A. That is correct.
23 Q. And that is said to be out in
24 Tukwila, Washington?
25 A. Okay. I am not sure how to
0105
1 pronounce it, but, yeah.
2 Q. I am not either, so.
3 A. Sounds good to me.
4 Q. Is that group a forensic document
5 examination group?
6 A. Not strictly a forensic document
7 examination group, but they did sponsor that one
8 course with John Hargett.
9 Q. And that group is principally
10 concerned about check fraud; is it not?
11 A. That is correct. Well, fraud that
12 affects retail. It involves checks. It
13 includes credit cards. All types of areas
14 of --
15 Q. Does that group, the NWFIA, does it
16 certify questioned document examiners?
17 A. No, not that I am aware of.
18 MR. RAWLS: I will show you a
19 document we will mark as Defendants' Exhibit 4.
20 (Defendants' Exhibit-4 was marked for
21 identification.)
22 Q. (By Mr. Rawls) Do you recognize
23 this as a collection of two pages from the
24 NWFIA website?
25 A. I haven't been on their website
0106
1 personally, so this is the first time I am
2 looking at this.
3 Q. So it either -- it may or may not
4 be accurate?
5 A. I am not sure.
6 Q. Do you know that the organization
7 was formerly known as the Northwest Check
8 Investigators Association?
9 A. I am sure I read it at one time,
10 but it wasn't something I remembered.
11 Q. Why do you belong to the Northwest
12 Fraud Investigators Association?
13 A. Oh, I belong to them to receive
14 updates about their upcoming conferences, and to
15 see if there is anything that relates to my
16 field which I would want to attend. Check
17 fraud does involve handwriting and so does
18 credit card fraud. A lot of documents in
19 business involve handwriting and money. So I am
20 always interested in keeping abreast of what is
21 happening in the field, and so I stay a member
22 of the NWFIA.
23 Q. Ms. Wong, I would like now to talk
24 a little about your employment.
25 A. Okay.
0107
1 Q. Have you ever worked for a crime
2 lab?
3 A. No, I have not.
4 Q. Apart from the one or two
5 engagements that you received from the
6 Commonwealth Attorney's office and the one
7 engagement you had with the U.S. Probation
8 organization, have you ever been employed in any
9 law enforcement capacity?
10 A. No, I have not.
11 Q. Did you ever apply for a position
12 with the FBI?
13 A. One time a long time ago.
14 Q. When?
15 A. Good question. Many, many, many
16 years ago. I can't remember. I am sorry.
17 Q. What was the result?
18 A. Let's see, I decided not to pursue
19 it. I was contacted by the FBI that they had
20 received my lengthy application. There was a
21 lot to fill out. I can't remember at that time
22 why I decided not to pursue it.
23 Q. Did you apply -- well, for what
24 position in the FBI did you apply?
25 A. It was for a document examination
0108
1 job.
2 Q. Was it after you had received your
3 1991 training from Mr. Ted Widmer, graphologist?
4 A. It would not have been before that.
5 It was way, way after that. It was when I was
6 living at -- at least after '95.
7 Q. So it was after 1995, and you
8 applied for a questioned document examination
9 position --
10 A. That is correct.
11 Q. -- with the FBI?
12 A. That is correct.
13 Q. And were you advised that you did
14 not have the necessary credentials for the job?
15 A. No, I was not.
16 Q. No one ever told you that?
17 A. That is correct.
18 Q. Am I not correct that your
19 application was rejected by the FBI?
20 A. I was not told that.
21 Q. Did you ever receive an acceptance?
22 A. I neither received an acceptance or
23 a rejection. All I received, I think it was
24 verbally, that they had received my application.
25 Q. You told us that your office is in
0109
1 your home; have you not?
2 A. That is correct.
3 Q. How large is the space in your home
4 that is your office?
5 A. It is approximately 350 or
6 400-something square feet.
7 Q. Do you have your own forensic
8 document examination laboratory?
9 A. It's -- the office and the
10 laboratory are all in that one room, and they
11 are on separate sides of the room.
12 Q. And what equipment is located right
13 there in that office in your home?
14 A. Not including office equipment? You
15 are specifically asking for document examination
16 equipment?
17 Q. Yes.
18 A. Okay. I have a stereoscopic
19 microscope. I have reticles. I have
20 magnification devices. I have your basic
21 rulers. I have your -- I have a light table.
22 I have a gooseneck lamp to examine indented
23 writing. And I out-source if I need anything
24 that needs to be done on ESDA or on a VSC.
25 Q. If we could turn, please, to your
0110
1 resume. And this, again, is back to Defendant's
2 Exhibit 1. On page 5 there is a list of
3 accessible handwriting identification equipment.
4 A. Uh-huh (affirmative).
5 Q. The first of these is the Apollo
6 18-inch by 12.5-inch light table. Is that the
7 one that is the light table in your office?
8 A. That is correct.
9 Q. Then there is Leica 2000 Zoom
10 Stereoscopic Microscope. Is that the one that
11 is in your office?
12 A. That is correct.
13 Q. There is an indication that there is
14 forensic photography equipment including Nikon
15 6006. Is that in your office?
16 A. That is correct.
17 Q. Then the next bullet point says
18 magnification loupes. Are those in your office?
19 A. That is correct.
20 Q. Measuring devices, caliper; are those
21 in your offices?
22 A. Correct.
23 Q. Grids and gauges; are they in your
24 office?
25 A. That is correct.
0111
1 Q. And the next bullet point is UV
2 light for determination of paper substitutions
3 and authentication. Is that in your office?
4 A. Yes.
5 Q. Next it says various oblique lighting
6 apparatuses for identifying indented writing,
7 inks and obliterated writing. Are those
8 apparatuses in your office?
9 A. Yes.
10 Q. And you said you out-sourced certain
11 things. What are those things?
12 A. It would be for an ESDA machine or
13 sometimes it goes underneath the name of
14 Kinderprint or Vaccubox. It is an equipment
15 that is used to bring up indented writing.
16 Q. All right. And was there anything
17 else that you out-sourced?
18 A. That is if I need anything for a
19 VSC, which is a videospector comparator. And
20 some of the items I have do some of the things
21 that VSC does. For instance, it has oblique
22 writing; it has UV lighting and so forth. But
23 you are able to use -- to bring something up
24 on your computer and actually print it out, what
25 that has that-- is usually sent out.
0112
1 What you can tell by different
2 lighting is with different filters and
3 wavelengths you're able to tell the different
4 types of inks that may be on a piece paper,
5 but it is not ink chemistry.
6 Q. Okay.
7 A. And the VSC can run up to $60,000,
8 so that would be quite an expensive piece of
9 equipment. And they have some older versions
10 that are less expensive.
11 Q. Ms. Wong, have you published any
12 papers on forensics document examination?
13 A. No, I have not. I have some in the
14 works, but I have not published yet.
15 Q. Have you published any of your
16 results or your conclusions on document
17 examinations so that they may be reviewed by
18 other document examiners?
19 A. No, I have not. As I said, I have
20 some of those items in the works.
21 Q. Are you tested annually to see if
22 your skills and your methods are reliable?
23 A. No, I am not tested annually; but
24 there are some proficiency tests that you can be
25 a part of. You just have to be aware of when
0113
1 they are happening and so forth.
2 Q. Ms. Wong, does Defendant's Exhibit 1,
3 that is your CV, does this include all of the
4 education that you have received that you
5 consider pertinent to the subject of document
6 examination and your credentials for document
7 examination?
8 A. As far as I know.
9 Q. Are you still on page 5 of your
10 resume? And if you are not, would you mind
11 turning to page 5, please.
12 A. Yeah. The last page?
13 Q. Yes. Do you see an entry for print
14 media, another for radio appearances, and another
15 for broadcast media?
16 A. Yes. And those are just for
17 advertising for business.
18 Q. You say under print media that you
19 were the subject or mentioned in articles in
20 "USA Today," the "Virginian Pilot," the "Boulder
21 Camera," the Boulder Daily, the "Progress Index"
22 and the "New York Post." Am I correct?
23 A. Yes. That is correct.
24 Q. What was the case that brought about
25 the mention of you in "USA Today"?
0114
1 A. It was a case with regards to
2 examining the ransom note for the JonBenet
3 murder.
4 Q. So it was the Ramsey matter, the
5 JonBenet Ramsey murder matter --
6 A. That is correct.
7 Q. -- that brought you to the attention
8 of those who read "USA Today" the time that you
9 were named?
10 A. That is correct.
11 Q. And what case was it that led to
12 your being mentioned in the "Virginian Pilot"?
13 A. The same case.
14 Q. And the "Boulder Camera"?
15 A. The same case.
16 Just to make it easier for you, it
17 is all the same case.
18 Q. Okay. So the "Boulder Daily," the
19 "Progress Index" and the "New York Post," all of
20 that got you -- got your name in newspapers
21 based on one case, the case of the death of
22 JonBenet Ramsey?
23 A. Yes.
24 Q. Is the same true of the radio, all
25 of the radio appearances listed?
0115
1 A. Yes. That is correct.
2 Q. Is the same true of all of the
3 broadcast media listed?
4 A. Yes, that is correct.
5 Q. So nothing that you, Cina Wong, have
6 ever done has obtained you any newspaper or
7 radio or television publicity other than the
8 connection that you have with the JonBenet
9 Ramsey murder matter?
10 A. That is correct. I am not as
11 popular as Mr. Wood.
12 Q. May I say, Ms. Wong --
13 A. Yes.
14 Q. -- you certainly are as glamorous.
15 A. Oh, thank you. Well, I think --
16 Q. If Mr. Wood will not strangle me.
17 MR. WOOD: We will take that up off
18 the record.
19 MR. RAWLS: Let's go off the record
20 just a moment, if we could.
21 THE VIDEOGRAPHER: Going off the
22 video record at 12:30.
23 (A recess was taken.)
24 THE VIDEOGRAPHER: Back on the video
25 record at 12:43.
0116
1 (Defendants' Exhibit-5 was marked for
2 identification.)
3 Q. (By Mr. Rawls) Ms. Wong, let me
4 show you, please, a document Mr. Gallo has
5 marked as Defendants' Exhibit 5. Do you
6 recognize that?
7 MR. ALTMAN: Jim, do you have a
8 copy?
9 MR. RAWLS: Yes, I do.
10 MR. ALTMAN: Thank you.
11 THE WITNESS: Yes.
12 Q. (By Mr. Rawls) What is that,
13 please?
14 A. This is a compilation of my expert
15 witness testimony in court and in depositions.
16 It includes hearings also.
17 Q. Is it accurate?
18 A. There are two that I just -- two
19 cases that I've just testified on that aren't in
20 here.
21 Q. So this is a full and correct list
22 of all of your expert witness testimony, except
23 for two matters that are recent; and because
24 they are recent they have not yet been listed
25 on this document?
0117
1 A. That is correct.
2 Q. Would you first, please, tell us of
3 the two recent matters?
4 A. Let's see. It was -- the date was
5 January, and I can't remember what date.
6 Actually, let me check something. January, and
7 it was a case Considine versus Considine. The
8 attorney on my side was Robert Kantas,
9 K-A-N-T-A-S, I believe it was. And there was no
10 opposing attorney. Mr. Considine represented
11 himself, and it was in Sandston, Virginia. And
12 it was a hearing, a commissioner's hearing.
13 Q. And the other one?
14 A. And the other one is -- it was a
15 disputed will of Henry Hazelwood. It was in
16 May, just passed. And the judge's name is
17 Judge Powell. The attorney on my side was
18 Chuck Lollar, L-O-L-L-A-R. And the attorney on
19 the other side was Tommy Normant; and that was
20 in Williamsburg, Virginia, the circuit court.
21 Q. All right. Thank you. I want to
22 go through Defendants' Exhibit 5 and ask several
23 questions about these matters. Let's start with
24 page 1 and the first item, the testimony June
25 15 through 17, 1993. Were you testifying in
0118
1 court or in a deposition?
2 A. In court.
3 Q. In court. Was Mr. Liebman with you?
4 A. Yes. I believe he testified in that
5 also.
6 Q. What was the nature of the case?
7 A. It says it was a disputed will of
8 Mr. Painter.
9 Q. Which side were you on?
10 A. I can't remember.
11 Q. Which side was Mr. Liebman on?
12 A. The same side.
13 Q. And did the matter come out in favor
14 of the side you and Mr. Liebman were on?
15 A. I can't remember. I am sorry.
16 Some of these I remember, and some of them I
17 don't. And some of them I don't even know
18 what the outcome was.
19 Q. Was your testimony in that case
20 about the verification or authentication of the
21 genuineness of a signature?
22 A. Yes, that is correct.
23 Q. Was that the sole matter you gave an
24 opinion about in that case?
25 A. Yes, that is correct. All the cases
0119
1 I listed here has to do with document
2 examination, my testimony concerning document
3 examination.
4 Q. And let's go to the second entry,
5 testimony, August 8, 1993. And this was a
6 matter called WSB of Norfolk, Inc., Radio
7 Station Z104 versus Plaka, P-L-A-K-A,
8 Enterprises, Inc. What was the nature of that
9 case?
10 A. I believe it had to do with an
11 advertising contract that the radio station had
12 that was signed by whoever the gentleman was who
13 owned Plaka Enterprises. And the gentleman at
14 Plaka Enterprises said that he did not sign the
15 document. And there was an opposing document
16 examiner in that case.
17 Q. So, again, the question in that case
18 that you gave an opinion about was the
19 authenticity or genuineness of the signature by
20 someone with Plaka Enterprises; am I correct?
21 A. That is correct.
22 Q. And whose side were you on?
23 A. I was on the side for the radio
24 station.
25 Q. And who won?
0120
1 A. My side did.
2 Q. Was Mr. Liebman also involved?
3 A. Yes, but I am not sure if he
4 testified or not.
5 Q. Let's go to the next testimony,
6 March 29, 1994. Was this in court?
7 A. Yes, it was.
8 Q. I mean to ask whether your testimony
9 in the radio matter for WSB in the Norfolk
10 matter, was that in court or just in a
11 deposition?
12 A. Oh, right above it you will see I
13 mention in court. It was in Virginia Beach,
14 Virginia Circuit Court. And if it is a
15 deposition, then I will write that it is a
16 deposition.
17 Q. So on March 29, 1994, this was in
18 court?
19 A. Yes, that is correct, circuit court
20 in Norfolk.
21 Q. And GMAC was going after one Mr.
22 Otis Green for a sum of money of just over
23 $4,000?
24 A. That is correct.
25 Q. And you gave testimony in that case
0121
1 about what?
2 A. It was a disputed signature on
3 something. I can't remember what it was. I
4 guess it was some money that Mr. Green owed
5 GMAC.
6 Q. Whose side were you on?
7 A. I think I was for GMAC.
8 Q. And Otis Green said a certain
9 document did not contain his signature?
10 A. I believe that was the case.
11 Q. And you concluded it did?
12 A. I believe that was the case.
13 Q. Who won?
14 A. Our side did.
15 Q. And we will go to April 5, 1994.
16 Was this in court?
17 A. No, that was a commissioner's
18 hearing. It is written on the next page.
19 Q. Okay. And what was that about?
20 Was that a will signature authentication?
21 A. I can't remember. It just says
22 Estate of Virginia Burton versus Athalia
23 Robinson. So it may have been.
24 Q. Might have been a signature. Whose
25 side were you on?
0122
1 A. I was doing Mr. -- Mr. Walton hired
2 me. I can't remember.
3 Q. Do you know if your side won?
4 A. Usually with commissioner hearings,
5 they don't render an opinion until weeks,
6 sometimes months down the road, so we never even
7 hear.

8 Q. So you did not, to the best of your
9 knowledge, inquire who won the case?
10 A. That is correct.
11 Q. In this case, the April 5, 1994,
12 case, was David Liebman involved?
13 A. I can't remember.
14 Q. In the previous case, the GMAC
15 versus Otis Green, was Mr. Liebman involved?
16 A. He may have been involved in that
17 one.
18 Q. And let's turn to June 1994. Was
19 this also in court?
20 A. It says that it's here in Yorktown,
21 in Virginia Circuit Court.
22 Q. And the matter is Commonwealth versus
23 James W. Malone. What was that about?
24 A. I don't remember anything about that
25 one, sorry.
0123
1 Q. It appears possible that that was a
2 criminal prosecution.
3 A. Yes. I believe that was one of the
4 cases where the Commonwealth Attorney retained
5 us. Let me think.
6 Q. But you're just not sure?
7 A. But I believe the -- I think the
8 judge had to give permission for our fee.
9 Q. And do you know whether your side
10 won?
11 A. I don't know.
12 Q. Was David Liebman involved in that?
13 A. He may have been involved in that
14 one.
15 Q. Do you know if the question in that
16 case involved a signature authentication?
17 A. I can't remember if it was a
18 signature or a body of writing. I am not
19 sure.
20 Q. Was it a forgery case?
21 A. I can't remember. I am sorry.
22 Q. And let's turn to September 14,
23 1994. This was testimony in court?
24 A. Yes.
25 Q. And do you recall the case of
0124
1 Worrell versus Worrell?
2 A. Uh-huh (affirmative).
3 Q. What was that about?
4 A. It was a disputed will.
5 Q. Was your role to authenticate a
6 signature --
7 A. Yes.
8 Q. -- or not?
9 A. To authenticate it or not, that is
10 correct.
11 Q. Do you recall whose side you were
12 on?
13 A. One of the Worrells.
14 Q. Were you opposing the genuineness of
15 the signature on the will or in favor of it?
16 A. I was in favor of it.
17 Q. Who won?
18 A. On technicality, the other side
19 because someone took forever to take the will to
20 the courthouse to submit there -- to probate the
21 will.
22 Q. So the delay cost one side the case?
23 A. That is correct.
24 Q. And was David Liebman involved in
25 the September 14, 1994, estate matter?
0125
1 A. Yes.
2 Q. Did he testify?
3 A. Yes.
4 Q. Were you there as a testifier or as
5 a --
6 A. I was there as a -- everything I
7 write here is only if I had testified.
8 Q. So you were not simply an assistant
9 to Mr. Liebman in that matter; you gave
10 testimony?
11 A. That is correct.
12 Q. Did Mr. Liebman represent the same
13 client that you represented?
14 A. Yes, that is correct.
15 Q. Let's move to November 7, 1994. The
16 Juvenile and Domestic Relations Court in
17 Fredericksburg, Virginia, Hicks versus Hicks.
18 What was that about?
19 A. I can't remember. It's J&DR Court.
20 I guess it was a husband and wife fighting over
21 something.
22 Q. So you don't recall what your
23 assignment was or your testimony in that case
24 was?
25 A. That is correct. I know it was
0126
1 handwriting related, document examination related.
2 Q. Was David Liebman involved?
3 A. I believe he was. I am trying to
4 think. He may have been.
5 Q. You gave testimony November 16, 1995?
6 A. Yes. That was a deposition. It is
7 stated right after the date. It says
8 deposition.
9 Q. A deposition. And that was in the
10 case of Gee, or Ghee, versus Elizabeth Nelson,
11 and you gave testimony in Norfolk?
12 A. That is correct.
13 Q. What was that matter about?
14 A. It was a disputed will case.
15 Q. And were you testifying about the
16 genuineness of a signature?
17 A. That is correct. It was a signature
18 and I think it was a will also. It was, like,
19 a two- or three-page will.
20 Q. Was it a handwritten will?
21 A. That is correct, a holographic will.
22 Q. And which side were you on?
23 A. Elizabeth Nelson.
24 Q. Was she contesting the will or was
25 she in favor of the will?
0127
1 A. She was in favor of the will.
2 Q. And who won?
3 A. Well, after I did a deposition, they
4 saw my exhibits, they settled the case.
5 Q. Was David Liebman involved?
6 A. Yes, he was involved in that one.
7 Q. Did he give a deposition also?
8 A. Yes, I believe he did.
9 Q. How much was paid in that
10 settlement?
11 A. Oh, I don't know.
12 Q. You gave testimony in court October
13 30, 1995, according to the next entry on page
14 3. You were hired by Neil Dilloff with Piper
15 and Marbury, and this was in U.S. District Court
16 in Baltimore.
17 A. That is correct. That was federal
18 court, yes.
19 Q. Yes, U.S. federal court. The case
20 was Baltimore Life Insurance versus Alex
21 Knopfler. Do you remember the matter?
22 A. Yes.
23 Q. What was that about?
24 A. Mr. Knopfler was an insurance agent,
25 and there were a lot of spurious signatures on
0128
1 -- there were a lot of applicants that were
2 questionable whether they existed or not. And
3 in each file there were many signatures to
4 examine from signatures on documents to
5 signatures on beneficiary forms and so forth.
6 And Baltimore Life obtained me and David Liebman
7 to go through all the files to determine if any
8 were or were not authentic.
9 Q. How many did you determine were not?
10 A. Wow. We had a case file somewhere
11 between 100 to 200 something files. I remember
12 there were some that were genuine, but the
13 majority were not.
14 Q. And did you so testify?
15 A. Yes, I did.
16 Q. Who won the case?
17 A. Actually, it ended up being settled
18 before it was over.
19 Q. And as you testified, David Liebman
20 was also involved in that?
21 A. That is correct.
22 Q. Did he give testimony in court too?
23 A. No, he did not.
24 Q. Then you testified in the office of
25 Thomas Wood in Baltimore on November 1. Was
0129
1 that a deposition?
2 A. That is correct.
3 Q. So you had given court testimony on
4 October 30 before a judge?
5 A. They were hearing some sort of
6 motion. I can't remember what it was. And
7 then they took our depositions, as you see
8 later, and then the case was settled.
9 Q. Okay. So you gave a deposition on
10 November 1, and you gave another deposition
11 November 7 and 8?
12 A. That is correct.
13 Q. All in the Baltimore Life versus
14 Alex Knopfler case; is that correct?
15 A. That is correct.
16 Q. Then we move to January 1996. You
17 testified in court?
18 A. Yes, that is correct. Circuit
19 court.
20 Q. In the matter of Joseph Antich
21 versus Bruno Antich?
22 A. Uh-huh (affirmative).
23 Q. Was that a will matter?
24 A. I can't remember a darn thing about
25 this case. I am sorry.
0130
1 Q. Did Mr. Liebman testify also?
2 A. I don't remember. Actually, by that
3 time probably, I don't think so.
4 Q. Probably not because of the timing?
5 A. Yes.
6 Q. Do you know which side was your
7 side?
8 A. No, I don't remember.
9 Q. Whichever side Carl Schmidt was on
10 was the side you were on?
11 A. That is correct.
12 Q. And you don't know who won?
13 A. That is correct. I don't remember.
14 Q. Then in June of 1996, you testified
15 in Virginia Circuit Court in Virginia Beach in a
16 criminal matter, Commonwealth versus Kenneth
17 Leigh Montgomery; is that correct?
18 A. That is correct.
19 Q. The attorney you have named here was
20 Philip Liebman. Is he related to David?
21 A. Yes, he is.
22 Q. Brother?
23 A. That is correct.
24 Q. Was David Liebman hired in that
25 case?
0131
1 A. No, he was not.
2 Q. And what was that case about?
3 A. It was a disputed signature on some
4 sort of document. I remember Mr. Montgomery
5 worked in the construction business. That is
6 all I remember.
7 Q. So you testified that it was his
8 signature?
9 A. I can't remember whether it was or
10 it wasn't. I can't remember.
11 Q. But the whole question was whether
12 it was his signature?
13 A. That is correct.
14 Q. Do you know who won?
15 A. I know our side did.
16 Q. Your side won. And it was David
17 Liebman's brother who hired you, correct?
18 A. Well, it was -- Mr. Montgomery had a
19 different attorney before, and he asked me if I
20 knew of any other attorneys, and I knew Mr.
21 Philip Liebman. And so he called Mr. Liebman
22 and told him I was already on the case. So in
23 that sense, I was hired.
24 Q. You were hired first by Mr.
25 Montgomery?
0132
1 A. That is correct. Or probably Mr.
2 Montgomery's previous attorney. I can't remember
3 who that was.
4 Q. You gave testimony then, June 4,
5 1996, the very next day, in a commissioner's
6 hearing in Norfolk, Virginia --
7 A. That is correct.
8 Q. -- in the case of Susanne P. Jones
9 versus Estate of Charles J. Waterfield, Jr., et
10 al.
11 A. Uh-huh (affirmative).
12 Q. What was that about?
13 A. I can't remember. It might have
14 been a will case.
15 Q. Do you recall what the issue was
16 that you testified about?
17 A. No, but it was document related.
18 Q. And was David Liebman involved?
19 A. No, he was not.
20 Q. Then three days later, you testified
21 in court in the General District Court for
22 criminal matters in Chesapeake, Virginia in the
23 case of Commonwealth and Cheryl Manning versus
24 Marie Estelle Skyles. And this was a
25 prosecution for forgery and, quote, uttering, end
0133
1 quote. Is that correct?
2 A. That is correct.
3 Q. And the uttering was a check?
4 A. I think there were multiple checks.
5 Q. So this person was accused of
6 forging checks and issuing bad checks; is that
7 correct?
8 A. That is correct.
9 Q. And whose side were you on?
10 A. The Commonwealth and Cheryl Manning.
11 Q. Who prevailed?
12 A. Actually, the day I testified, it
13 was a motion for something. I can't remember.
14 And then a year or something, a long time went
15 by, and I think it was settled out of court.
16 Q. The next entry on page 4 skips
17 almost two years to May of '98?
18 A. Uh-huh (affirmative).
19 Q. Did you give any testimony in 1997
20 at all?
21 A. No. Actually, a quiet year. Most
22 cases are settled out of court, and it actually
23 is very rarely that I do go to court and
24 testify.
25 Q. So here June of 1996 had you in
0134
1 court three different times, and you were not in
2 court again until almost two years later, May 28
3 of '98?
4 A. That is right. It is all at once
5 or nothing at all.
6 Q. And this was Pauze versus Pauze in
7 Gloucester, Virginia Circuit Court. What was
8 that one about?
9 A. I don't remember that one.
10 Q. Do you know whether your side won?
11 A. I don't remember. I don't even know
12 if I -- sometimes after I testify, I leave
13 before the decision is rendered.
14 Q. And it is your habit never to
15 inquire?
16 A. Sometimes I do. Sometimes I don't.
17 Q. Then in June, on June 11, 1998, you
18 gave a deposition in a case of Liebman versus
19 Liebman.
20 A. That is correct.
21 Q. In the office of Liebman. Were the
22 parties, Liebman versus Liebman, related to David
23 Liebman?
24 A. That is correct.
25 Q. Was David Liebman one of them?
0135
1 A. Part of them.
2 Q. I am sorry?
3 A. Part. There are, like, three
4 Liebmans.
5 Q. Well, which Liebman was suing which
6 other Liebman?
7 A. David and Michael Liebman were suing
8 Philip Liebman.
9 Q. For what?
10 A. It was over a disputed will.
11 Q. Of a father or mother?
12 A. That is correct.
13 Q. Which?
14 A. Father.
15 Q. And the question was what?
16 A. Whether the signature was authentic
17 or not.
18 Q. And was David the individual that
19 hired you?
20 A. Actually, no. All three of the
21 brothers at one point collectively hired me to
22 look at the case.
23 Q. You were hired by the two plaintiffs
24 along with the one defendant?
25 A. That is correct. They had all
0136
1 signed an agreement that they wanted me to
2 examine the will.
3 Q. And what was your conclusion?
4 A. That the whole document was printed
5 off of an ink jet printer from a computer and
6 that when you looked at the signature through a
7 magnification device you could see that, though
8 the signature looked like it was written from
9 blue ink, it was composed of red and blue dots,
10 so it came from an ink jet printer.
11 After I rendered that opinion,
12 another will mysteriously appeared. There were
13 three wills that appeared in this case.
14 Q. And you, therefore, testified that
15 the signature on the will which you studied was
16 not genuine, at least not a signature made by a
17 human on that document?
18 A. That is correct.
19 Q. And what was the result of the case?
20 A. It was heard at a later date. If
21 you skip down to September 20-- no. I'm sorry.
22 Yes. Okay. September 25th. But you want me
23 to go in order here?
24 Q. Well, let's skip down to Liebman
25 versus Liebman in court.
0137
1 A. All right.
2 Q. Did you give essentially the same
3 testimony?
4 A. Then I gave -- then I was not
5 allowed to testify about the signature on the
6 will that was composed from an ink jet printer.
7 I was only allowed to keep my testimony to the
8 new will, the third will that had popped up.
9 And there were signs of trace marks on that
10 will and a fake notary stamp and other
11 situations in that will.
12 Q. So you testified that there was a
13 fake notary stamp and there were other
14 suspicious matters?
15 A. There were trace lines surrounding
16 the signatures of the father, which is Walter
17 Liebman, on every single page of the document.
18 Q. What did those marks mean?
19 A. Trace marks show that someone traced
20 a signature either -- there are certain ways you
21 can do it. A simple way is that you can take
22 a piece of paper and put it over someone's
23 signature or hold it up to the window so you
24 get a transmitted light, and you can transmit
25 the signature onto the document. Some people do
0138
1 it in pen, but other people do it in pencil to
2 give them a guideline. Or other people just
3 use a stylus. Something like, the best thing I
4 can think of a stylus would be a sharp knitting
5 needle where you would make indentation marks
6 onto the signature line or onto the document
7 where you want the signature to appear. And
8 after you place your guidelines onto the
9 document, then you can go over that with an ink
10 pen. But the problem is we can't write the
11 same way twice. We have lots of variation
12 within our own handwritings. So when you go
13 over the tracing lines, you can't get the ink
14 line into the groove exactly and you will see
15 trace marks coming outside of the signature.
16 Q. And who prevailed in that case?
17 A. Actually Philip Liebman did. It was
18 on a technical matter, but he prevailed.
19 Q. Were you on his side in the trial?
20 A. I was hired by all three, so I just
21 went up there and gave my testimony, so.
22 Q. Now, we temporarily skipped over the
23 August 5, 1998, court appearance in the case of
24 Martin Man versus Karl Kaufman.
25 A. Oh, yes, okay.
0139
1 Q. Whose side were you on?
2 A. Karl Kaufman's.
3 Q. And what was that about?
4 A. It was a signature. And it was in
5 sort of a document where Mr. Kaufman sold a
6 plane or something, some signature that had --
7 on a document.
8 Q. And what was your testimony?
9 A. My testimony was that the signature
10 -- I believe Mr. Kaufman said that was not his
11 signature on the form.
12 Q. And --
13 A. And there were -- my -- according to
14 what my testimony was, Mr. Kaufman did not sign
15 that signature.
16 Q. And did he win the case?
17 A. It was strange. It was split. He,
18 Mr. Kaufman, went on the fact that that was not
19 his signature. Both sides were suing each other
20 at the same time, so each one won something.
21 I can't remember what it was about. It was
22 complicated.
23 Q. Was David Liebman involved in that
24 matter?
25 A. No, he was not.
0140
1 MR. RAWLS: Let me suggest since it
2 is now about 10 or 12 minutes after 1:00 that
3 we break here for lunch if that is okay with
4 everybody. I am getting hungry.
5 MR. ALTMAN: I think everybody is.
6 MR. RAWLS: May we go off the
7 record?
8 THE VIDEOGRAPHER: Going off the
9 video record at 1:13.
10 (A recess was taken.)
11 THE VIDEOGRAPHER: Back on the video
12 record at 2:22.
13 Q. (By Mr. Rawls) Ms. Wong, in just a
14 moment I will go back to your list of
15 testimony, of court and deposition testimony, but
16 for now may I ask you a question I forgot to
17 ask you earlier. And that is, have you ever
18 met Chris Wolf?
19 A. No, I have not.
20 Q. Have you ever spoken to Chris Wolf?
21 A. No, I have not.
22 Q. At the time you first spoke with
23 Darnay Hoffman, had you ever heard of Chris
24 Wolf?
25 A. I may have. Mr. and Mrs. Ramsey
0141
1 wrote a book, and in there they -- not only do
2 they mention me, but I think they mention Chris
3 -- I believe they mention Chris Wolf; that's
4 correct.
5 Q. But you had spoken with Mr. Hoffman
6 long before the Ramseys wrote a book; had you
7 not?
8 A. That is correct.
9 Q. And before you spoke first with Mr.
10 Darnay Hoffman, had you ever heard of Chris
11 Wolf?
12 A. I might have come across his name in
13 an article or something, but that is the best
14 of my memory.
15 Q. Have you ever seen Mr. Wolf in any
16 of his performances?
17 A. I don't know -- is he an actor?
18 Q. You would have remembered, I am
19 sure.
20 A. Oh. No, I've never met him. And
21 if he were sitting there across the table from
22 me and no one introduced me to him, I wouldn't
23 know who he was.
24 Q. And let me also, having called your
25 attention again to the first time you spoke with
0142
1 Darnay Hoffman, let me ask you to be as exact
2 as possible in telling us when that was in
3 1997?
4 A. I can't remember the month or the
5 date of when it was in '97.
6 Do you know, Darnay?
7 Q. Can you tell us if it was spring,
8 summer, fall?
9 A. No.
10 MR. RAWLS: Darnay, can you help?
11 MR. HOFFMAN: Yeah. It was either
12 late October or early November of 1997. It was
13 certainly after the ransom note had actually
14 been released to the media, which was -- that
15 was in September. So it was very late October,
16 early November.
17 MR. RAWLS: Darnay, thanks. I
18 appreciate that.
19 THE WITNESS: Thank you.

20 Q. (By Mr. Rawls) And, Ms. Wong, are
21 you able to -- does that refresh your
22 recollection on the time?
23 A. It made me remember that usually
24 during Christmastime or Thanksgiving time, I go
25 home to visit my parents in California. And I
0143
1 remember looking at the documents and then
2 getting on a plane going home. So that helped
3 ring a bell.
4 Q. Good.
5 A. That would make sense.
6 Q. Good. Now, let's turn back, please,
7 to Defendants' Exhibit 5, which is your list of
8 court and deposition testimony. I would like to
9 ask you, please, to stay with us on page 5.
10 And I am turning now to the February 3, 1999,
11 testimony before Judge Leafe in Norfolk, Virginia
12 Circuit Court, in the case of Jettie Menzies
13 versus Jean Derricott. Do you recall that?
14 A. Yes.
15 Q. Whose side were you on?
16 A. It was Jettie Menzies.
17 Q. And what was the nature of the case?
18 A. There was a signature -- there was a
19 signature that was allegedly signed by Ms.
20 Menzies' mother. And, in fact, the signature
21 was a -- the signature was created with a
22 rubber stamp. So it wasn't a signature where
23 you would write out by hand in ink. It was a
24 reproduction with the method of using a rubber
25 stamp.
0144
1 Q. And was the question whether it was
2 a real signature or a rubber stamp?
3 A. It was a question of whether it was
4 a real signature or not.
5 Q. What was your testimony?
6 A. That the signature was created from
7 a rubber stamp. And I pointed out some
8 similarities as to why it was rubber stamped:
9 How the ink sat on top of the paper and
10 absorbed in, not pushed into the paper as
11 opposed to when you are writing with a pen, the
12 ballpoint pen that's pushing the ink into the
13 paper. And sometimes with rubber stamps when
14 they cut your signature from the rubber stamp
15 they don't always do a very good job and they
16 leave trails of loose rubber material that also
17 picks up the ink, and you will see that on the
18 paper when you push down using a rubber stamp.
19 Q. And did your side win?
20 A. I can't remember in that case.
21 Q. Was David Liebman involved?
22 A. No, he was not.
23 Q. Then you testified June 3, 1999,
24 before Judge Byrd in Monterey, Virginia Circuit
25 Court in the case of The Blue Grass Valley Bank
0145
1 versus Robert B. Ralston. Do you recall that?
2 A. Yes, I do.
3 Q. Whose side were you on?
4 A. Mr. Ralston's family.
5 Q. And what was your testimony?
6 A. That the signature of Mr. Ralston, I
7 believe, was authentic on the will.
8 Q. And who won?
9 A. Well, I am sorry. It was not a
10 will. It was something from a -- oh, it was
11 from a bank. That's why. It was a document
12 from a bank. And they said that Mr. Ralston
13 signed the paper. And, in essence, I think he
14 didn't. That was the best of my memory.
15 Q. Did your side win?
16 A. Yes, we did.
17 Q. Was Mr. Liebman involved?
18 A. No, he was not.
19 Q. You then testified in September 1999
20 in two different matters, one a deposition and
21 one in a court case, all involving the case of
22 Tanisa Kawesa and Andrew Kawesa versus Loizou,
23 Inc. Do you recall that?
24 A. Yes.
25 Q. Who hired you?
0146
1 A. Mr. Eason did.
2 Q. Which side did you represent?
3 A. I represented Kawesa.
4 Q. And what was the issue?
5 A. I think Loizou, Incorporated is the
6 -- they own a car dealership. And something
7 happened with an exchange with the Kawesas,
8 about the Kawesas signing a signature, and they
9 owed Loizou some money.
10 Q. Did you testify the signature was
11 genuine?
12 A. Yes, I did.
13 Q. And who won?
14 A. My side did.
15 Q. Was David Liebman involved?
16 A. Yes, he was.
17 Q. Did he testify also?
18 A. Yes, he did.
19 Q. Then in March of 2000, you testified
20 before Judge Glover?
21 A. Uh-huh (affirmative).
22 Q. In a case in Queens, New York
23 Circuit Court?
24 A. Yes.
25 Q. The case of Joy Management versus
0147
1 Imperial Management Corp. And unless I am
2 mistaken, that is the first time you testified
3 outside Virginia; is that right?
4 A. Yes, that is correct.
5 MR. HOFFMAN: Just one point --
6 THE WITNESS: Well, no, Maryland
7 County, a different state.
8 Q. (By Mr. Rawls) I beg your pardon.
9 So you testified out of state one time before
10 this, and that was in Maryland?
11 A. That is correct.
12 Q. In Baltimore.
13 MR. ALTMAN: It was federal court.
14 Q. (By Mr. Rawls) So this was your
15 second testimony out of state?
16 A. That's correct.
17 Q. And what was this case about?
18 A. It was a dispute between the two
19 companies whether someone had signed a stock
20 certificate or not, I believe.
21 Q. And which company did you represent?
22 A. Joy Management.
23 Q. Did you testify it was a genuine or
24 not signature?
25 A. That it was genuine.
0148
1 Q. Who won?
2 A. Don't know. The last time I spoke
3 to the attorney, the judge had still not
4 rendered an opinion.
5 Q. And was David Liebman involved?
6 A. No, he was not.
7 Q. Then in March of 2000, you testified
8 in the circuit court in Fairfax, Virginia in the
9 matter of Quantum Communications, Inc., versus
10 Brian Bird versus Michael Hardy; is that
11 correct?
12 A. Mr. Hardy actually belongs to Quantum
13 Communications. I am trying to think. Yes, it
14 was Quantum Communications who is owned by
15 Michael Hardy against Brian Bird.
16 Q. Which was your side?
17 A. Quantum Communications.
18 Q. What was that question?
19 A. It was a document that Mr. Bird said
20 that Mr. Hardy allegedly signed. Mr. Hardy had
21 caught Mr. Bird on videotape stealing from his
22 office and stealing certain documents. So Mr.
23 Hardy had to let Mr. Bird go. And on the day
24 Mr. Hardy let Mr. Bird go -- well, I mean, he
25 let Mr. Bird go and the months went by. And
0149
1 then Mr. Bird said that on the day Mr. Hardy
2 let him go, he signed over a third of his
3 multi-million dollar company over to him.
4 Q. And it was Mr. Hardy's position he
5 had not done so?
6 A. That is correct.
7 Q. Was it your testimony Mr. Hardy's
8 signature was forged?
9 A. In all appearances, it appeared that
10 Mr. Hardy had signed the signature; but upon a
11 closer examination, it was a cut and paste job.
12 The original was missing. And I could tell
13 from the signature of Michael Hardy and from the
14 line underneath it, it said something like
15 Quantum Communications, Inc., that that was of
16 probably something like a further generation. I
17 am not sure if you are familiar with it.
18 You make a copy from an original, it
19 is a first generation; and a copy from that is
20 second generation. So the document we were
21 dealing with was a second or third generation.
22 But then the signature of Mr. Hardy's was of,
23 like, an eighth generation.
24 Q. And am I correct that you testified
25 the signature of Mr. Hardy was forged?
0150
1 A. It was cut and paste. It was his
2 signature, but it was not intended for that
3 purpose.
4 Q. Who won the case?
5 A. I am trying to think. I believe we
6 did, but then it was going -- oh. We did, and
7 then it went for appeal and then they settled
8 out of court.
9 Q. Was David Liebman involved?
10 A. No, he was not.
11 Q. Then in June of 2000, you testified
12 before a hearing officer, Mark Hamilton, in the
13 matter of Norfolk Southern versus Sutherland, and
14 this testimony was in Chicago; is that correct?
15 A. That is correct.
16 Q. So that was your third trip out of
17 state to testify, true?
18 A. Yes.
19 Q. What was that about?
20 A. Usually it has to do with a
21 signature on some sort of form they have to
22 fill out when they go from -- when they go
23 from one railroad station to another. I am
24 trying to think. He was supposed to have
25 signed something, but they believe it was signed
0151
1 by someone else. It was a little more detailed
2 than that, but that is all I remember.
3 Q. But your testimony was about a
4 particular signature?
5 A. I think it was a couple of
6 signatures.
7 Q. And did your side win?
8 A. Yes, we prevailed.
9 Q. Was David Liebman involved?
10 A. No, he was not.
11 Q. You gave testimony, then, in
12 September 2000 before Judge Burgess in the
13 Chesterfield, Virginia Juvenile and Domestic
14 Relations Court in the case of Commonwealth
15 versus Karen Hoover; is that right?
16 A. That is correct.
17 Q. What was that about?
18 A. I don't remember that case, but I
19 remember that's a court area I don't want to be
20 in. There are too many people having arguments
21 about their children, so. I don't remember
22 anything about that case.
23 Q. Do you remember if the question was
24 about a signature?
25 A. It was either a signature or a
0152
1 document.
2 Q. Was David Liebman involved in that?
3 A. No, he was not. Oh, it might have
4 had to do with a check, I think. That is the
5 best of my memory.
6 Q. Then in January 2001 you testified
7 in a deposition in Alexandria, Virginia in the
8 case of Pafels versus Tugado. Do you recall
9 that?
10 A. Faintly.
11 Q. What was that about?
12 A. I don't remember. Sorry.
13 Q. Do you know if that was about a
14 signature?
15 A. It was either about a signature or
16 handwriting. All the work I do is related to
17 document examination.
18 Q. Did that case go to trial?
19 A. I believe it did.
20 Q. It looks like --
21 A. Yes.
22 Q. -- you were in court five days
23 later --
24 A. Okay.
25 Q. -- in Fairfax, Virginia Circuit Court
0153
1 in that case. Does that help you recall what
2 it was about?
3 A. No, it doesn't. Sorry.
4 Q. Do you recall which side you were
5 on?
6 A. Well, Mr. Steinmetz retained me. I
7 can't remember which side. Sorry.
8 Q. Was David Liebman involved in that?
9 A. No, he was not.
10 Q. And you still can't recall the
11 issue?
12 A. No. I am trying. If I remember
13 later, I will let you know.
14 Q. Then in the following month you
15 testified in an arbitration. The court was in
16 Buffalo, New York. Where was the testimony?
17 A. Oh, I am sorry. It shouldn't say
18 court. It should say where the hearing was held.
19 Excuse me. And it was held in --
20 Q. It says arbitration.
21 A. Yeah, arbitration, so. It should --
22 it was held up, excuse me, the arbitration in a
23 hotel somewhere in a conference room.
24 Q. And in what state?
25 A. In New York.
0154
1 Q. So this was your fourth trip out of
2 state to testify?
3 A. Is that what the count is?
4 Q. Last one I had was Chicago, and this
5 seems to be --
6 A. Chicago, New York, Maryland. Okay.
7 So this would be the fourth time, yes.
8 Q. And it seems to be another Norfolk
9 Southern case. Is that a repeat client of
10 yours?
11 A. Yes. That is correct.
12 Q. What was this Norfolk Southern versus
13 Penfield matter about?
14 A. Allegedly someone had written a
15 defamatory note, and I can't remember if it was
16 posted somewhere or what. Oh, it was a
17 defamatory note sent to one of their other
18 workers.
19 Q. Did you give testimony about the
20 author of the note?
21 A. Yes, I did.
22 Q. Who did you testify was the author?
23 A. A high probability that was Mr.
24 Penfield.
25 Q. Was there an opposing handwriting
0155
1 witness on the other side?
2 A. Yes. He came in last minute. He
3 had not looked at any of the other documents;
4 and he rendered an opinion, which was strange.
5 Q. And who won that case?
6 A. We did, and they filed for appeal,
7 but it stayed the same.
8 Q. Then in August 2001 you appeared in
9 Stafford, Virginia in the offices of Locklear &
10 Saller in the case of Dona Hall versus John
11 Hall. Was that a deposition?
12 A. No. That was a testimony.
13 Q. Testimony before the --
14 A. Before a commissioner.
15 Q. -- commissioner?
16 A. Yes. That is correct.
17 Q. What was that about?
18 A. Mrs. Hall allegedly wrote on some
19 documents. She said she didn't write those
20 phrases. She said Mr. Hall did. And Mr. Hall
21 said that he didn't and that it was actually in
22 Mrs. Hall's handwriting.
23 Q. Who was your client?
24 A. My client was Mr. Hall.
25 Q. And you testified that she had
0156
1 written the phrases?
2 A. That it was in her own natural
3 handwriting.
4 Q. Whose side won?
5 A. My side won. And there was an
6 opposing expert that was from the Secret
7 Service. He wasn't from the Secret Service at
8 that time. He was ex Secret Service, I should
9 clarify.
10 Q. Was David Liebman involved in that?
11 A. No, he was not.
12 Q. Was David Liebman involved in the
13 Norfolk Southern matter in New York?
14 A. No, he was not.
15 Q. And off of this list are two more
16 recent items that you had told us about. One
17 Considine versus Considine, and that was a
18 hearing before the commissioner. What was the
19 question in Considine versus Considine?
20 A. Well, Mr. Considine was a
21 stockbroker. He invested some money for his wife
22 at that time, April Considine. And in the
23 midst of their divorce, some papers popped up
24 because Mr. Considine had lost, from what I
25 understand, quite a few dollars from Ms.
0157
1 Considine. And she said she never signed, I
2 think it was, three documents.
3 Q. What was your testimony?
4 A. That it definitely was not her
5 signature.
6 Q. And did your side win?
7 A. Yes -- let me think.
8 No. An opinion has not been
9 rendered yet.
10 Q. Then in a will dispute involving the
11 will of Henry Hazelwood, you testified this very
12 month before Judge Powell. That was in the
13 Williamsburg, Virginia Circuit Court. What was
14 the question in that case?
15 A. Whether the signature of Mr.
16 Hazelwood was authentic or not. It appeared on
17 a will. He had Parkinson's.
18 Q. What was your testimony?
19 A. That it was authentic.
20 Q. Who won?
21 A. There were technical difficulties with
22 the case, but the other side won.
23 Q. Was there an opposing expert in the
24 case?
25 A. Yes, there was.
0158
1 Q. Who was that?
2 A. That was Mr. Farmer, and his opinion
3 was -- he did eyeball analysis, and he said it
4 was not his signature.
5 Q. About how many cases are you hired
6 in for every one that you ultimately testify in?
7 A. There is no rule of thumb. As you
8 saw, there was, like, a year I didn't testify.
9 There are a lot of times, as I said, cases are
10 settled out of court, may never even get there.
11 Q. And what you have shown us are,
12 let's see, a total of, (counting), 32 different
13 matters that have involved your testimony.
14 A. Does that include the new ones?
15 Q. That includes the two new ones.
16 A. Okay.
17 Q. And 33 if you include today. Is
18 that about half of your total engagements in the
19 history of your career?
20 A. Oh, I do a lot more case work than
21 what shows up there.
22 Q. Than twice the 33?
23 A. More than twice.
24 Q. Do you?
25 A. Yes.
0159
1 Q. I want to get back briefly to
2 approximately how much of your time in a year
3 is paid for. Do you have 1,000 billable hours
4 in a year?
5 A. I am trying to think. Like, my
6 last case I just had a lot of hours on that.
7 It shouldn't be more than that.
8 Q. I am sorry?
9 A. I am thinking. I am sorry. If you
10 want to go with an approximate, I will just
11 give you -- you know, I really can't give you
12 a good answer. I am sorry.
13 Q. And what approximate answer would you
14 give me?
15 A. No, I said if that is a number you
16 want to pull out of the hat, I really can't
17 help you. If you want to take a break, I can
18 sit here and fiddle and guess.
19 Q. Most weeks, do you bill 20 hours a
20 week, 30, 40, 10?
21 A. It varies. Sometimes I am working
22 seven days a week, and other times I may only
23 work twice a week. So that is why it is so
24 difficult for me to give you an approximate
25 number because my work is varying.
0160
1 Q. What is the largest total income you
2 have had from handwriting analysis in any
3 calendar year?
4 A. Probably in the high -- like, 28.
5 MR. WOOD: You said $28,000.
6 THE WITNESS: Yes. I am giving you
7 a guesstimate.
8 Q. (By Mr. Rawls) And, Ms. Wong, at
9 the present time, we know one matter you are
10 working on, and that is the engagement on behalf
11 of Chris Wolf by Darnay Hoffman and Evan Altman
12 that brings you here today. How many other
13 matters are you engaged in as a questioned
14 document examiner at present?
15 A. I probably have eight or ten cases
16 right now that are pending.
17 Q. Eight or ten others?
18 A. Yeah, eight or ten, 15. They just
19 -- sometimes they sit dormant for a while and
20 then they come back up.
21 Q. Are any of those eight or ten cases
22 that are pending cases we've already spoken
23 about because they were on your list?
24 A. Oh, these are the ones that I have
25 testified that I've finished with.
0161
1 Q. So the answer is no, those eight or
2 ten other cases you are working on now are not
3 matters we've spoken about earlier?
4 A. That is correct.
5 Q. In any of the cases that we've have
6 talked about today, those that, the 30, I
7 believe, that you listed in Defendants' Exhibit
8 5 and the two others we talked about here
9 today, have you given testimony about disguising
10 handwriting?
11 A. Yes, I have.
12 Q. How many?
13 A. The Norfolk Southern one on February
14 3. The April Considine case. And out of just
15 this list here I think it would be about two
16 of them.
17 Q. The two you mentioned?
18 A. Yes.
19 Q. Norfolk Southern and Considine?
20 A. That's correct. I mean, there might
21 be other ones that I don't remember.

22 Q. And in those that you have told us
23 about, with reference again to the same 30 cases
24 listed on Defendants' Exhibit 5 and the two
25 other recent cases in which you have testified
0162
1 that you told us about, have you given testimony
2 about similarities in an extended document to
3 other exemplars of a person's handwriting?
4 A. I am sorry. You said extended
5 documents?
6 Q. Yes.
7 A. I am not quite sure -- can you ask
8 me that again?
9 Q. Do you know what I mean by extended
10 document?
11 A. No, I am not quite sure how you are
12 using that.
13 Q. Then that is the problem, and let me
14 do without that.
15 A. Okay.
16 Q. How many times have you given
17 testimony about the authorship of a particular
18 document based upon similarities between that
19 document and other handwriting exemplars?
20 A. In saying that the writer is -- with
21 regards to similarities?
22 Q. Yes.
23 A. Out of these cases here?
24 Q. Yes.
25 A. Oh, good question.
0163
1 Q. One was the defamatory note, correct?
2 A. That is correct.
3 Q. You did testify that because of
4 similarities which you found comparing the
5 defamatory note to other exemplars --
6 A. Right.
7 Q. -- you testified about a conclusion
8 of authorship of --
9 A. Right.
10 Q. -- the defamatory note?
11 A. Right. I am trying to go through
12 all of the cases trying to figure out which
13 one.
14 Q. Exactly.
15 A. And some of these I don't even
16 remember what happened in the case.
17 Q. Tell me any other such examples of
18 testimony that you know of, please.
19 A. With just anonymous notes or it's
20 similar because it is an authentic signature and
21 that's why it would have similarities?
22 Q. Good question. Let's go with
23 anonymous notes.
24 A. Okay. So we were just down to
25 those two.
0164
1 Q. Well, I only know of one so far,
2 apart from the ransom note in JonBenet Ramsey.
3 A. I'm sorry. You are referring to the
4 Norfolk Southern case. And then you are saying
5 just with anonymous notes; is that what you are
6 saying?
7 Q. Yes.
8 A. Oh, okay. The Norfolk Southern
9 case.
10 Q. That one is the only one you can
11 recall today that involved your comparison of an
12 anonymous notes' handwriting with exemplars of
13 other handwriting; is that correct?
14 A. Oh, with many exemplars from many
15 people.
16 Q. And then the only other time you
17 have compared an anonymous note with handwriting
18 exemplars to reach a conclusion about the
19 authorship of the anonymous note was involving
20 the JonBenet Ramsey ransom note?
21 A. Well, you asked me just about the
22 cases in Exhibit 5. I have worked on other
23 cases also, but I did not testify about those.
24 Q. And I am limiting this to your
25 testimony.
0165
1 A. Okay. So, yes, that one.
2 Q. And apart from the ransom note in
3 connection with the death of JonBenet Ramsey,
4 have you ever been hired to attempt to determine
5 the identity of the author of a ransom note?
6 A. There are very few cases where there
7 are ransom notes, so I have not looked at one
8 that was specifically about a ransom note.
9 Q. So the only ransom note you have
10 ever been hired to attempt to determine the
11 authorship of is the ransom note found in
12 connection with the death of JonBenet Ramsey; is
13 that correct?
14 A. Right. And a ransom note is
15 anonymous writing.
16 Q. Yes. You agree with me that the
17 ransom note left at the Ramsey home in
18 connection with the death of JonBenet was
19 anonymous; do you not?
20 A. That is correct. As with any
21 writing that you send to someone, if someone
22 leaves a note on your door saying something not
23 very nice, of course, you don't know those,
24 those are all considered anonymous notes, too.
25 Q. Now, of the cases that are listed in
0166
1 Defendants' Exhibit 5, would you take a look
2 through there and tell me if any of those were
3 done by you pro bono?
4 A. Yeah, on page 2, I know I did one.
5 I believe this one was it. It was in
6 Fredericksburg. It is Hicks versus Hicks.
7 Q. Okay.
8 A. And the case below it, the attorney
9 never paid us; so I guess that is pro bono,
10 but not of my choosing.
11 Q. Well, pro bono is one --
12 A. I agree with that.
13 Q. -- in which you agree to testify for
14 free. So we won't call that pro bono by that
15 definition.
16 A. That's right.
17 Q. Are you finished?
18 A. Oh, yes. I was waiting for you.
19 Were you waiting for me?
20 Q. I am waiting for you to tell me if
21 there were any other pro bono --
22 A. No. That was it. I knew there was
23 one.
24 Q. That was the only one?
25 A. Yes, that's correct.
0167
1 Q. Thank you.
2 A. I am sorry.
3 Q. I am sorry. I did not understand you
4 were finished.
5 That one that was pro bono that
6 you've just told us about, the matter of Hicks
7 versus Hicks, did David Liebman charge in that
8 case?
9 A. Not that I am aware of.
10 Q. So you had earlier told us that Mr.
11 Liebman may have been involved in that case.
12 If he was involved, is it your understanding
13 that was also pro bono?
14 A. Well, it must have been. I remember
15 that gentleman didn't have any money, but he was
16 correct in the situation.
17 Q. And, Ms. Wong, how many times has a
18 judge heard your credentials, a judge or an
19 arbitrator or a hearing officer or a
20 commissioner, because I know you testified before
21 all of those kinds of people? How many times
22 has the judge or the hearing officer or the
23 arbitrator or the commissioner said I refuse to
24 permit you, Ms. Wong, to testify as an expert
25 in these proceedings?
0168
1 A. I always have been allowed to
2 testify. I have always qualified in court.
3 Q. So no one as of yet has said that,
4 thank you for being here, but I will not permit
5 you to testify about your expert conclusions?
6 A. That is correct.
7 Q. No one has yet done that?
8 A. Not yet, that is correct.
9 Q. Do you know what a Daubert challenge
10 is?
11 A. Yes. That is before you go into
12 federal court.
13 Q. Yes. And has anyone ever made a
14 Daubert challenge to your own credentials?
15 A. No, they have not.
16 Q. And how many times have you
17 testified in the U.S. District Court, which is
18 commonly referred to, and I think referred on
19 your paper to as federal court?
20 A. Once in Maryland.
21 Q. Once in Maryland, and that was the
22 Baltimore Life Insurance case?
23 A. That is correct.
24 Q. And if you do testify as a witness
25 in court in this case, are you aware that would
0169
1 be in the federal court here in Atlanta?
2 A. Yes, I understand.
3 Q. Ms. Wong, what was -- let me start
4 by saying, what is the nature of your
5 relationship today with Mr. David Liebman?
6 A. We no longer are working together,
7 but we are on friendly terms. And as I said,
8 every once in a while if I have to go out of
9 town and there is no one to handle a case, I
10 will refer the case to David Liebman.
11 Q. Have you discussed your testimony or
12 your expert opinion with respect to the ransom
13 note involving the death of JonBenet Ramsey with
14 Mr. Liebman?
15 A. During which time period?
16 Q. At any time.
17 A. Early on in the beginning when we
18 both received the case.
19 Q. In 1997?
20 A. Yes. I did my own analysis. He
21 did his own analysis.
22 Q. Did you compare notes with him then?
23 A. After we were through with our own
24 independent analysis, that's correct.
25 Q. And thereafter did you discuss the
0170
1 ransom note with Mr. Liebman?
2 A. With regards to specifics or --
3 Q. At any time.
4 A. We've -- generalizations about the
5 ransom note; but after we did our analysis, we
6 didn't do any more work with that, that aspect
7 of it.
8 Q. Did Mr. Liebman review your expert
9 witness report that Mr. Hoffman and Mr. Altman
10 have shared with us in this case?
11 A. I haven't shared that report with
12 anybody. I've only sent that off to Mr.
13 Hoffman. And where it has gone from there, I am
14 not sure.
15 Q. So you yourself have not given David
16 Liebman an opportunity to review it or to
17 comment upon it; is that true?
18 A. That is correct.
19 Q. And if he has seen it, it would
20 have been because someone else furnished it to
21 him?
22 A. That is correct.
23 Q. From 1992 through 1995, what was
24 your relationship with David Liebman?
25 A. Oh, I was still going through the
0171
1 mentorship program; and towards the end I was
2 finishing up and we were working as partners.
3 Q. And was your relationship with Mr.
4 Liebman professional only?
5 A. Oh, it's professional, yes.
6 Q. Only professional?
7 A. Yes. I mean, I might have gone out
8 with him for dinner or lunch a few times the
9 first few months, but that was about it.
10 Q. Of the eight to ten other cases that
11 you are working on now, how many of them
12 involve something other than the question of the
13 authenticity of one or more signatures?
14 A. They all do.
15 Q. They all involve more than
16 signatures?
17 A. There might be one case that might
18 be an obliteration case, but I haven't received
19 that yet.
20 Q. So what do these eight to ten cases
21 involve that you are working now?
22 A. Identify if someone has written on a
23 certain document or if they wrote a certain
24 phrase, and other ones are to authenticate the
25 signature or the writing.
0172
1 Q. Now, referring back, please, to your
2 Norfolk Southern case that involved the question
3 of who wrote a particular defamatory letter, how
4 many exemplars were you given that you compared
5 with the defamatory note?
6 A. Of the suspect, I am trying to think
7 back. I can give you an estimate. Somewhere
8 around 30 to 40 or 50 documents. And then we
9 also looked at the handwriting of anywhere from
10 23 to 30 other people.
11 Q. Why did you do that?
12 A. I wanted to be sure that, in --
13 they suspected a certain person, but I wanted to
14 know if there were any people around that were
15 involved in that area at that time frame, if
16 there was a possibility they could have been
17 involved also.
18 Q. And was it your conclusion that the
19 particular suspect of whose handwriting you were
20 given 30 to 50 exemplary documents was, in fact,
21 the author of the defamatory note in question?
22 A. Yes. It was highly probable that he
23 was the writer of the note.
24 Q. But to make sure of that, it was
25 your request to have lots of other documents
0173
1 authored by lots of other people around the
2 circumstances of the event?
3 A. That is correct.
4 Q. So you looked at not only samples of
5 the handwriting of the suspect but also of some
6 23 to 30 other people in that case?
7 A. That is correct.
8 Q. In connection with analyzing the
9 ransom note that was found at the Ramsey home
10 in connection with the death of JonBenet Ramsey,
11 you looked at the handwriting exemplars of how
12 many people?
13 A. Three people.
14 Q. Who were those three?
15 A. Mr. Ramsey, Mrs. Ramsey, and Mr.
16 Wolf.
17 Q. Did you ask to have other exemplars
18 of the handwriting of other people presented to
19 you so that you could analyze similarities
20 between those other persons' handwriting and the
21 ransom note?
22 A. Yes. I asked Mr. Hoffman that if
23 there were any other people available that were
24 connected with the event if he were able to get
25 their handwriting samples; and he told me that
0174
1 those samples had already been gone through by
2 the document examiners at the CBI and that they
3 had been ruled out. So, for the moment what I
4 had available to me were those three people that
5 I named there.
6 Q. Do I understand correctly that Mr.
7 Hoffman told you that every other potential
8 author had been eliminated by the CBI?
9 A. By the document examiners involved
10 over there, that's correct; that's what I was
11 told.
12 Q. And eliminated based on comparing
13 their handwriting?
14 A. That they weren't suspects for
15 writing the ransom note.
16 Q. Have you written a report concerning
17 your comparison of the handwriting of Chris Wolf
18 to the handwriting of the ransom note?
19 A. Have I written a report?
20 Q. Yes.
21 A. No, I have not.
22 Q. Why was that?
23 A. I wasn't asked to write a report.
24 Q. Sorry?
25 A. I wasn't asked to write a report.
0175
1 Q. What was your conclusion about Mr.
2 Wolf?
3 A. I found a few similarities, but they
4 weren't anything like I found between Patsy
5 Ramsey's handwriting and the ransom note writer.
6 I found a multitude of similarities between her
7 handwriting and the ransom note writer, and
8 they're quite glaring.
9 Q. Did you put on paper a list of
10 similarities between Mr. Wolf's handwriting and
11 that in the ransom note?
12 A. Not on paper like in that form, no.
13 Q. Well, in any form did you put
14 similarities on paper between Mr. Wolf's
15 handwriting and that you found in the ransom
16 note?
17 A. I made notations.
18 Q. Where are those notations?
19 A. I don't have them here with me
20 today, but I may have circled certain letters or
21 underlined certain letters that corresponded with
22 certain items that I saw in the ransom note.
23 (A telephone rings.).
24 I'm sorry. I thought I turned that
25 off.
0176
1 MR. ALTMAN: Go off the record.
2 THE VIDEOGRAPHER: Going off the
3 record at 3:10.
4 (A recess was taken.)
5 THE VIDEOGRAPHER: Back on the video
6 record at 3:22.
7 Q. (By Mr. Rawls) Ms. Wong, I wanted
8 to make sure I understand correctly exactly what
9 Mr. Darnay Hoffman told you about why you were
10 furnished handwriting exemplars of three people
11 and why you were not given any more when you
12 asked Mr. Hoffman for handwriting exemplars of
13 others who might have been associated with the
14 events of the death of JonBenet.
15 First, in your words, can you tell
16 me exactly what Darnay Hoffman told you?
17 A. Oh, it was just my understanding
18 that they were going to be available and that
19 the CBI document examiners had already ruled out
20 a lot of the suspects. So in this case, he
21 wanted me to look at the three handwriting
22 samples that were sent to me of Mr. Wolf, Mr.
23 Ramsey and Mrs. Ramsey. And actually,
24 basically, I think that is what your experts
25 looked at also, according to their reports.
0177
1 Q. Did Mr. Hoffman tell you that the
2 CBI had eliminated all other suspects based upon
3 their handwriting?
4 A. That is what I am assuming because
5 of the document examiners looking at them.
6 Q. Did you assume that -- excuse me.
7 Let me start over. Did you rely on that
8 assumption when you formulated your own report
9 comparing Patsy Ramsey's handwriting to the
10 ransom note?
11 A. I am sorry? Ask me that again.
12 Q. Sure. Did you rely in formulating
13 your own conclusions about similarities between
14 Patsy Ramsey's writing and the ransom note, did
15 you rely on the understanding that the CBI had
16 eliminated many other suspects based on their
17 handwriting?
18 A. I kept that in my mind, but I
19 realized in this case that I had three different
20 exemplars to look at. And I looked at them.
21 If I felt that I needed more, then I would
22 have said something; but in this case the
23 similarities were just so overwhelming with
24 regard to Patsy Ramsey's handwriting linking her
25 to the ransom note that I can't see that there
0178
1 is any other possibility unless there is someone
2 out there, who, I don't know, in some foreign
3 country with writing like that. But there is
4 so many unique similarities to her handwriting.
5 I have over 130 points, items on my exhibits,
6 and 157 went to similarity.
7 And In order to find that in any
8 other person's handwriting would be quite, quite,
9 quite rare.
10 Q. But you have looked for those
11 similarities only in the handwriting of three
12 different individuals?
13 A. In this case, that is correct.
14 Q. And when you first decided that
15 Patsy's handwriting appeared to you to be very
16 similar to the handwriting in the ransom note,
17 at that time you had only looked at Patsy's
18 handwriting; am I correct?
19 A. That is correct. There were a lot
20 of unique similarities.
21 Q. So Chris Wolf's handwriting exemplars
22 were furnished to you for the first time when?
23 A. It has been a while ago. You might
24 have to ask Darnay for help on this.
25 Q. Can you tell me the year?
0179
1 A. Last year sometime?
2 Q. Are you telling me or asking me?
3 A. Oh, I am thinking. I think it is
4 last year sometime. That is the best of my
5 memory.
6 Q. Well, the case was filed by Chris
7 Wolf in the year 2000.
8 A. Uh-huh (affirmative).
9 Q. And it was only 2001 when you looked
10 at handwriting exemplars furnished by Chris Wolf?
11 A. I believe so. That is the best
12 time frame I can think of. I don't know why
13 last year sticks in my head.
14 Q. When this complaint was filed in the
15 year 2000, it attached, or at least the
16 mandatory disclosures filed with the complaint
17 attached an opinion of yours that it was
18 probable that Patsy was the author of the ransom
19 note. So is it your testimony that it was
20 months after Chris Wolf's suit was filed and
21 months after you committed professionally to
22 having an opinion that Patsy Ramsey wrote the
23 note that you then made an unbiased analysis of
24 Chris Wolf's hand and found only a few
25 similarities, fewer than those of Patsy Ramsey's
0180
1 hand?

2 A. Actually, my opinion with Patsy
3 Ramsey writing the note back then, after
4 receiving the exemplars, the extensive exemplars
5 that were taken by the CBI more than confirms
6 my opinion with that regard.
7 Q. But you didn't look at the
8 handwriting of Chris Wolf until last year?
9 A. That is the best of my memory.
10 Q. To compare it to the ransom note?
11 A. That is correct. I wanted to make
12 sure and look at -- Mr. Hoffman asked me to
13 compare it to the ransom note.
14 Q. And you knew if you determined that
15 Chris Wolf had done it, you probably would never
16 get on radio or television again?
17 A. That is not what was important to
18 me. What was important to me is that the
19 evidence that I found is quite overwhelming that
20 Patsy Ramsey wrote the note. And it is
21 important for people to know. Someone has to
22 speak up for JonBenet, and that is why I am
23 here doing this pro bono. And if my opinion
24 had changed, well, so be it, then I would
25 rather clear somebody of something. It is quite
0181
1 horrible to think that a mother was involved in
2 some way.
3 Q. You told us about your media
4 appearances earlier?
5 A. That is correct.
6 Q. In print, on radio, and on
7 television?
8 A. That is correct.
9 Q. On all of those occasions, in all of
10 those media, the subject of the article or the
11 broadcast was your conclusion that Patsy Ramsey
12 authored the ransom note; was it not?
13 A. Actually, I will make an addition
14 there. I remember that is another -- I was
15 interviewed recently -- not recently, earlier
16 this year with regards to the anthrax letters.
17 The station had copies of it; they wanted me to
18 look them over, and I did.
19 Q. So you were once in the media on
20 something other than the JonBenet Ramsey death?
21 A. That is correct. And most all of
22 us involved in this case have been mentioned in
23 one way or another in some form in some part
24 of the media.
25 Q. Back to my question about the other
0182
1 media appearances involving you.
2 A. Sure.
3 Q. Those that involve the JonBenet
4 Ramsey matter, did all of those media
5 appearances or quotes involve your assertion that
6 Patsy Ramsey was the author of the ransom note?
7 A. I am not sure if they all included
8 that. Some of these I didn't even see.
9 Sometimes they just interview me and I don't see
10 the interview.
11 Q. But every time you were interviewed,
12 you expressed your opinion that Patsy Ramsey
13 authored the ransom note; did you not?
14 A. Oh, I showed on my exhibits how I
15 came to my opinion; and that was my opinion.
16 Q. And when you came to your opinion
17 the first time that Patsy was probably the
18 author of the note, had you even studied the
19 handwriting of John Ramsey?
20 A. I saw certain portions of Mr.
21 Ramsey's handwriting, but I was not given
22 specific samples.
23 Q. And were you given an assignment to
24 compare John Ramsey's handwriting to that of the
25 ransom note?
0183
1 A. During what time period?
2 Q. The first time you reached the
3 conclusion that Patsy was probably the author?
4 A. They were not given to me. But I
5 was able to obtain some.
6 Q. What is SERAPH, S-E-R-A-P-H?
7 A. S-E-R-I-F. Oh, S-E-R-A-P-H. You
8 are talking about the organization?
9 Q. Yes.
10 A. Yes. That is owned by Mr. Dale
11 Yeager, and he has an organization. And he
12 wanted to know if he could put my name on his
13 website so if any of his clients needed document
14 examination work that he could refer them to me.
15 Q. Have you ever been affiliated with
16 or associated with SERAPH?
17 A. In what way?
18 Q. You tell me.
19 A. Oh, I haven't done any work -- he
20 hasn't had the occasion to call -- oh, yes, he
21 has. He had a client that needed document
22 examination work, and so Mr. Yeager had his
23 client contact me.
24 Q. Is that the only association you
25 have ever had with SERAPH?
0184
1 A. Yes, that is correct.
2 Q. SERAPH, you understand to be most
3 involved in the JonBenet Ramsey matter; do you
4 not?
5 A. To a small degree, but that is all
6 I know.
7 Q. And what do you understand the
8 involvement of SERAPH to be in connection with
9 the JonBenet Ramsey death?
10 A. I just know that Mr. Yeager was
11 involved and it had to do with the note, but
12 it had nothing to do with document examination.
13 (Defendants' Exhibit-6 was marked for
14 identification.)
15 Q. (By Mr. Rawls) Ms. Wrong, this is
16 Defendant's Exhibit 6. This consists of pages
17 we have taken from the website of SERAPH.
18 Would you please turn to page 8, Ms. Wong. It
19 is the last page of that exhibit.
20 There is on the website of SERAPH a
21 page which at the top says Handwriting and
22 Document Analysis, and on that page is your
23 name --
24 A. That is correct.
25 Q. -- and some of your training. Did
0185
1 you furnish this information to SERAPH?
2 A. Some of the information, and then he
3 retyped it in his form and put it on here.
4 Q. Did you provide your client list to
5 Dale Yeager?
6 A. Yes. That is something that is
7 listed in some of my papers.
8 Q. Okay. Did you provide the client
9 list that included Fortune 500 companies such as
10 Norfolk Southern, IBM, and John Grisham, Junior?
11 A. Yes. To Mr. Yeager?
12 Q. Yes.
13 A. Yes, that is correct.
14 Q. What have you done for IBM?
15 A. IBM, I taught a document examination
16 course to their investigators in Raleigh, North
17 Carolina.
18 Q. How long was that course?
19 A. That was a day, and it was in the
20 fall sometime. And in the fall, that is all I
21 can remember.
22 Q. What were you paid for that?
23 A. Good question. I can't remember.
24 It was through the Certified Fraud Examiners.
25 They asked me to teach a course on document
0186
1 examination to the IBM investigators.
2 Q. When were you hired by John Grisham?
3 A. That would be 19 -- it is my memory
4 1996 or 1997.
5 Q. Did you give any testimony with
6 respect to that --
7 A. No, I did not.
8 Q. -- engagement?
9 Is this the author, John Grisham?
10 A. That is correct.
11 Q. What was your engagement by John
12 Grisham?
13 A. I am sorry. What?
14 Q. What was the nature of your
15 engagement by John Grisham?
16 A. With regards to what the case was?
17 Q. Yes.
18 A. I am limited to what I can say, but
19 it had to do with anonymous writing. And the
20 date, I am sorry. The date I said was -- what
21 did I say? '96, '97. It could be anywhere
22 from'96 to '98. I just can't remember exactly
23 when.
24 Q. You just told me you were limited to
25 what you can say. Why is that?
0187
1 A. Mr. Grisham asked us not to discuss
2 that case.
3 Q. What was the anonymous writing that
4 you were hired by John Grisham to study?
5 A. What do you mean?
6 Q. I --
7 A. I guess I --
8 Q. I can't be more specific than that.
9 My question is what was --
10 A. What did it say or--
11 Q. -- the anonymous document that you
12 were hired to study?
13 A. Oh. A multitude of anonymous
14 letters.
15 Q. Was it your purpose to determine who
16 wrote the letters?
17 A. That is correct.
18 Q. Did you reach such a decision?
19 A. I reached a probability.
20 Q. And you decided that -- well, were
21 you given a number of suspects by Mr. Grisham?
22 A. We asked how many people he
23 suspected. And we received, I am trying to
24 think, handwriting exemplars of one or two
25 people.
0188
1 Q. So he gave you handwriting exemplars
2 on one or two suspects?
3 A. Yes. I am trying to think. Yes.
4 That is the best of my memory right now.
5 Q. Did you ask him for more suspects?
6 A. I asked him, you know, as many as
7 he thought; and he narrowed it down to one or
8 two.
9 Q. And did you decide that one or two
10 -- that one of the one or two had probably
11 authored the multitude of anonymous letters?
12 A. That probably that one person was
13 involved.
14 Q. And what is the -- what was the
15 outcome of all of that?
16 A. I told him that I would need to
17 obtain additional handwriting exemplars, and I
18 haven't received any additional handwriting
19 exemplars from him, so.
20 Q. The fact is you got sued about that
21 case; did you not?
22 A. That woman is suing everybody,
23 everybody that --
24 (Telephone busy signal.)
25 MR. RAWLS: Let's go off the record.
0189
1 THE VIDEOGRAPHER: Going off the
2 record at 3:39.
3 (A recess was taken.)
4 (Discussion ensued off the record.)
5 THE VIDEOGRAPHER: Back on the
6 record at 3:41.
7 Q. (By Mr. Rawls) Ms. Wong, did we,
8 when we went off the record, did we interrupt
9 your answer or have you finished?
10 A. If you want to ask the last
11 question, then that will help refresh my memory.
12 Q. The fact is that you were sued in
13 connection with the work you did for John
14 Grisham; were you not?
15 A. That woman sued everybody, anybody's
16 name who was involved in that case.
17 Q. So the answer is yes --
18 A. Yes.
19 Q. -- you were sued?
20 A. Uh-huh (affirmative). Not just
21 me --
22 Q. And In addition --
23 A. -- though.
24 Q. In addition, your client, John
25 Grisham, was sued also, correct?
0190
1 A. That is correct.
2 Q. Several other defendants were also
3 sued?
4 A. Yes, that's correct.
5 Q. The person who sued is the woman
6 that you concluded had probably written the
7 anonymous letters; am I correct?
8 A. That is correct.
9 Q. Her name is Katherine Almy?
10 A. I believe that is correct.
11 Q. A-L-M-Y?
12 A. Uh-huh (affirmative).
13 Q. And Ms. Almy took a polygraph test
14 at her own insistence; did she not?
15 A. As far as I understand, yes.
16 Q. And according to Ms. Almy, the
17 polygraph test indicated that she was truthful
18 and had not written the anonymous notes,
19 correct?
20 A. From what I understand; but I am not
21 a polygraph expert, so I don't know what
22 happened in that test. And there was also a
23 document examination report done by a state
24 document examiner, and he could not eliminate
25 her as a writer either.
0191
1 Q. Do you have counsel assisting you in
2 that lawsuit?
3 A. Yes, I do.
4 Q. Is that the same counsel that is
5 assisting John Grisham?
6 A. No, it is not.
7 Q. Who is your attorney?
8 A. Mr. Morin.
9 Q. Would you spell that, please?
10 A. M-O-R-I-N.
11 Q. And what is his full name and
12 location?
13 A. Donald Morin in Charlottesville,
14 Virginia.
15 Q. Is he defending anybody else in that
16 case?
17 A. No.
18 Q. Do you have, Ms. Wong, any liability
19 insurance that is providing you coverage for
20 your opinion in that case?
21 A. No, I do not.
22 Q. When you were hired by Mr. Grisham,
23 did you handle that matter pro bono?
24 A. No, I did not.
25 Q. So you charged him a fee for your
0192
1 work?
2 A. That is correct.
3 Q. Did you provide John Grisham a
4 written report about your conclusion regarding
5 Ms. Almy?
6 A. Yes.
7 Q. Do you have a copy of that?
8 A. No, I do not.
9 Q. I don't mean with you here today.
10 Do you have a copy anywhere?
11 A. Oh, yes, I do.
12 Q. And I asked you earlier, Ms. Wong,
13 about your look at the handwriting exemplars of
14 Mr. Chris Wolf's handwriting which were furnished
15 to you by Mr. Darnay Hoffman.
16 A. That is correct.
17 Q. And you told me that you made
18 notations. You would underline some letters.
19 Where are those notations that show your
20 conclusions about Mr. Wolf?
21 A. Those are back in Norfolk, Virginia.
22 Q. How many similarities did you find?
23 A. Off the top of my head, I can't
24 remember exactly how many; but I did see some
25 similarities, but way more dissimilarities.
0193
1 Q. So you looked at dissimilarities in
2 connection with Mr. Wolf?
3 A. Not just dissimilarities. I looked
4 at both, and I found some similarities, but I
5 found a greater amount of dissimilarities.
6 Q. How many dissimilarities did you find
7 of Patsy Ramsey?
8 A. What I found in her handwriting were
9 variations. And we all have a certain range of
10 variations. And actually, in one of your --
11 the reports of Mr. Cunningham, what he shows is
12 certain variations notated as the person who
13 wrote the ransom note actually are in Patsy
14 Ramsey's handwriting.
15 Q. Ms. Wong, do you remember the
16 question that I asked you?
17 A. I am sorry.
18 Q. How many dissimilarities did you find
19 between Patsy Ramsey's handwriting exemplars and
20 the ransom note?
21 A. Any of what I found were variations.
22 And every once in a while you will find an
23 accidental, which can be considered -- some
24 people see it as a difference, but sometimes it
25 just happens once in every two to 300 samples
0194
1 when you write.
2 Q. Ms. Wong, again, do you remember the
3 question that I asked you?
4 A. I keep thinking I am answering it
5 the best I can. I am sorry if I am not
6 answering it correctly. I don't know how many
7 exactly, but --
8 Q. So the answer is you don't know how
9 many dissimilarities between Patsy Ramsey's
10 handwriting and those in the ransom note?
11 A. Very, very, very few, and they are
12 considered variations in her handwriting.
13 Q. By you?
14 A. That is my opinion.
15 Q. You don't know how many
16 dissimilarities, and you didn't count them
17 because you decided you would treat them all as
18 variations, not as dissimilarities?
19 A. Oh, that's not true. Because they
20 are all within the realm of her handwriting and
21 skill. Now, if she were not capable of it, then
22 there would be significant dissimilarities.
23 Q. How many pages of notations do you
24 have back in your office about the similarities
25 or dissimilarities between Chris Wolf's
0195
1 handwriting exemplars and the ransom note?
2 A. How many pages?
3 Q. Yes.
4 A. I am not sure. It is just in a
5 file.
6 Q. Will you agree to furnish those to
7 us if you are so advised by Mr. Hoffman and
8 Mr. Altman?
9 MR. ALTMAN: No objections. Darnay?
10 MR. HOFFMAN: I have no objections.
11 THE WITNESS: I would be happy to.
12 MR. ALTMAN: We will get that to
13 you.
14 (Defendants' Exhibit-7 was marked for
15 identification.)
16 Q. (By Mr. Rawls) This is Defendant's
17 Exhibit 7, Ms. Wong. Do you recognize that?
18 A. Uh-huh (affirmative).
19 Q. Is that, in fact, a true copy of a
20 document which you authored and presented to
21 John Grisham?
22 A. That appears to be.
23 Q. And this appears to have been signed
24 by yourself as well as by David Liebman --
25 A. That's correct.
0196
1 Q. -- is that correct?
2 A. That is correct.
3 Q. Did he make his examination separate
4 from yours?
5 A. Yes. Always.
6 Q. So as you go through this letter,
7 which of those opinions were yours and which
8 ones were his?
9 A. I don't understand what you are
10 saying.
11 Q. Well, I assume since you made
12 separate and independent analyses, you and Mr.
13 Liebman, some of these findings were yours and
14 some of these findings were his?
15 A. Actually, both came to the same
16 conclusions.
17 Q. I see. And that conclusion is
18 worded in the paragraph on page 2 that begins
19 with the language, quote, Based upon thorough
20 analysis of these items?
21 A. Uh-huh (affirmative).
22 Q. And is this the opinion that
23 resulted in your being sued by Ms. Almy?
24 A. Mr. Grisham took this opinion to a
25 detective, and the detective wanted -- which
0197
1 warranted a further investigation. And Ms. Almy
2 was not pleased with the investigation, which is
3 my understanding is how this whole lawsuit came
4 up.
5 Q. Now, that document that is in front
6 of you, Defendant's Exhibit 7, and on page 2 in
7 the paragraph beginning: Based upon thorough
8 analysis, you describe the fact that there are
9 similarities, but you do not mention differences.
10 Is that correct?
11 A. There appears to be some
12 similarities.
13 Q. And you base --
14 A. So, obviously, there are some things
15 that are different but are within the realm of
16 her handwriting skill.
17 Q. So you based your opinion on the
18 number of similarities; did you not?
19 A. In this case, the similarities
20 outweighed the differences in variations.
21 Q. This case being the matter of John
22 Grisham and Katherine Almy?
23 A. That is correct.
24 Q. And you went on in your conclusion
25 to say: Anonymous letters by their very nature
0198
1 are often written in a disguised manner to hide
2 the identity of the writer.
3 Did I correctly read that sentence
4 in your conclusion?
5 A. Yes.

6 Q. Was that sentence that I have just
7 read about anonymous letters often written in a
8 disguised manner, was that sentence written in
9 order to account for the fact that there were
10 many differences between the exemplars that you
11 were given from Ms. Almy and the anonymous
12 letters that you were comparing the exemplars
13 to?
14 A. Was that the specific reason? No.
15 Q. What was the specific reason?
16 A. I just remember that --
17 That doesn't sound very good.
18 MR. ALTMAN: Just a four o'clock
19 rain.
20 THE WITNESS: Oh, that is thunder?
21 MR. RAWLS: That is thunder. We
22 will stipulate that that is thunder.
23 Q. (By Mr. Rawls) Could we proceed
24 with your answer?
25 A. Yes. Sorry. Sorry. That threw me
0199
1 off guard there.
2 I am sorry. Your question again?
3 MR. RAWLS: Mr. Gallo, would you
4 read that back, please.
5 (The record was read by the
6 reporter.)
7 THE WITNESS: Mr. Grisham said he
8 wanted an explanation about anonymous letters.
9 He told Mr. Liebman that, and Mr. Liebman wrote
10 -- he told me to include that in the letter,
11 and I agreed with it.
12 Q. (By Mr. Rawls) But you don't
13 mention any differences in your letter to John
14 Grisham at all; do you?
15 A. This is a basic letter of opinion.
16 And if they want to know more information, that
17 is usually when they depose us. This is just
18 a basic opinion letter.
19 Q. Was it your opinion that all of the
20 differences between the handwriting exemplars of
21 Ms. Almy and the handwriting in the anonymous
22 notes were the product of disguise?
23 A. Yes, that is correct.
24 Q. And that is your conclusion in the
25 case of JonBenet Ramsey and the ransom note in
0200
1 this case as well; is it not?
2 A. In this case, it could be disguised,
3 but it could normally have been -- well, I
4 guess I am not sure exactly what you are asking
5 me.
6 Could it be disguised or is it or
7 is it not? Is that what you are asking?
8 Q. You reached the same conclusion in
9 connection with Patsy Ramsey that you reached in
10 connection with Katherine Almy; did you not?
11 A. No. My opinion is stronger in the
12 Ramsey case.
13 Q. I see. But again, in the Ramsey
14 case, just like the case of Katherine Almy, you
15 conclude that any differences are accounted for
16 by disguise; do you not?
17 A. I am not quite sure what differences
18 you are talking about in the ransom note. If
19 you can point one out.
20 Q. Did you find any differences in the
21 ransom note and Patsy Ramsey's exemplars?
22 A. I found some variations within the
23 ransom note and Patsy Ramsey's handwriting that
24 are in her handwriting.
25 Q. Did you find any differences?
0201
1 A. There might be one or two areas
2 where I couldn't find anything to match it
3 exactly; but I could -- comparing it to Patsy
4 Ramsey's exemplars, it was within the realm of
5 her handwriting.
6 Q. You are telling me there were no
7 differences and there were just a small number
8 of variations; is that your testimony?
9 A. Not a small number of variations.
10 It was an incredible number of similarities.
11 There were some variations. And what you want
12 to call differences could be coined as
13 accidentals that happen, as I mentioned, once in
14 every hundred, 200 or 300 writings, were there.
15 But that is only if we have an additional
16 sample of handwriting taken over time will we
17 see that.
18 Q. And you account for the variations
19 by saying they were either accidental or the
20 product of disguise in the case of the ransom
21 note in this case?
22 A. Let me clarify myself. Variations
23 aren't differences. They are just different
24 ways of writing something within someone's
25 handwriting. May I show you?
0202
1 In your own expert's report, for
2 instance, let me just get the page. I believe
3 this is Mr. Cunningham's report. And he shows
4 the different types of P's. He shows that it
5 has a tendency to flatten on the face of the
6 bulge. Now, as you can see, there are five
7 examples here. And, you know, these all came
8 from the ransom note and came from one person.
9 But when you compare this to a page of my
10 writing, you will see -- let me see if I can
11 juggle here. Can you hold this? I'm sorry.
12 MR. ALTMAN: Sure.
13 THE WITNESS: Thank you.
14 And on my exhibit here, as you can
15 see, the letter P that starts out on this side,
16 the range where it gets extremely square, this
17 is within the range of her handwriting. That
18 is what I mean by range. It shows a range.
19 And this shows it is right within the range.
20 And so Mr. Cunningham shows it over
21 and over again that -- I will just take this
22 one. He talks about the lower case n-g
23 combination. Thank you. And he says that the
24 back leg of the N enters into the bottom
25 portion of the G. And that is also located in
0203
1 Patsy Ramsey's handwriting in page 12.
2 On this side, it is her handwriting.
3 And if you look at the N, it comes underneath
4 the G. It also appears on 13.
5 You notice on this one, the n-g
6 combination, how the G comes out, just outward
7 towards the right and goes in. And you see
8 that example down here in the lower portion,
9 excuse me, of this right here.
10 So there is, like, a certain range
11 that you go by because we can't write the same
12 way twice. We are not computers and we're not
13 typewriters, and we don't produce the same
14 written letter or combination exactly the same
15 every time. So that is why we have variations
16 because it is variable for people.
17 Q. (By Mr. Rawls) Ms. Wong, I am at a
18 loss to understand how what you just told us
19 had any relationship to the question that I
20 asked you.
21 A. I am sorry. I was trying to
22 explain variation to you.
23 Q. And what you have said, however, is
24 that you found no differences between the Patsy
25 Ramsey exemplars and the authorship of the
0204
1 ransom note; but you did find some things you
2 consider variations.
3 A. That is correct.
4 Q. Am I correct?
5 A. That is correct.
6 So what your expert, Mr. Cunningham,
7 he had some exhibits showing what he thought
8 were consistencies within the ransom note which
9 were not found in Mrs. Ramsey's handwriting,
10 which, in fact, they were found in her
11 handwriting.
12 Q. And, Ms. Wong, I had not even asked
13 you a question when you gave me that lecture
14 just now, which I will move to strike.
15 A. Okay. I am sorry.
16 Q. Because it is your job to answer
17 questions only after they are asked.
18 A. Okay. I thought I was trying to
19 explain variations to you, so I was trying to
20 help you understand. My apologies if I
21 misunderstood the question.
22 Q. Do you examine both handprinting and
23 cursive writing, Ms. Wong?
24 A. Yes, I do.
25 Q. What is the difference between
0205
1 examining handprinting and examining cursive
2 writing?
3 A. Cursive writing is the script, and
4 printing can usually be the letters which aren't
5 connected. And then sometimes you are dealing
6 with handwritten, with writing that is a
7 combination of both.
8 Q. Do you compare one to the another,
9 handprinting with cursive writing?
10 A. It is difficult. It is hard to
11 find the same letter formations in cursive as in
12 print. But what you can use sometimes if there
13 are numbers involved, punctuation marks, or usage
14 of the paper if you want to look at the
15 marginalia, how the usage is.
16 Q. How does a document examiner make a
17 decision between a true difference in handwriting
18 which disqualifies a person as an author of a
19 questioned document on the one hand and a
20 disguise by the author on the other hand?
21 A. Okay. The first question is how do
22 you differentiate what is a difference in a
23 handwriting?
24 Q. What is a true difference that is a
25 disqualifying difference?
0206
1 A. If something is written that is
2 structurally and how the letter is constructed
3 is very different than the way it is done.
4 For instance, if you are comparing two
5 handwritings, if, for instance -- may I
6 demonstrate just with the letter D?
7 Q. Sure. Do you need a piece of
8 paper?
9 A. Yes, please. That would be nice.
10 MR. ALTMAN: I will give her one.
11 THE WITNESS: Thank you.
12 So, for instance, what I mean by
13 construction and structure of a letter D, come
14 forward with the stem first, and the lower part,
15 portion of it, which, for the sake of
16 explanation looks like a lower case C. For
17 other people, the construction will be this
18 first and the stem second. That would be
19 something that is a major difference since the
20 construction of the two letters are composed
21 differently even though they may appear to be
22 the same, because this is something that is
23 subconscious where you just write and you don't
24 think about what stroke to make next and so
25 forth.
0207
1 Q. (By Mr. Rawls) And go on.
2 A. Oh, okay. Sorry.
3 Q. With how you determine what is a
4 true difference --
5 A. Okay.
6 Q. -- that is disqualified?
7 A. I didn't want to go on. You
8 scolded me earlier. I didn't want to over step
9 my bounds.
10 Other differences you may find is
11 that the letter forms are very different from
12 the questioned writing to the known handwriting
13 samples. If line placement, you look at how
14 certain letter combinations are formed, how
15 certain letters are formed, dots of the I's, the
16 placement of that, the placement of the T bars,
17 if those are varied.
18 You look for usage of space on the
19 paper. And when originals are available, you
20 look at the pressure. And you look at slant.
21 You look at angles. There are many items
22 involved. So it is all the document examination
23 going down the list and looking for what it is
24 you are comparing.
25 Q. And how do you differentiate finding
0208
1 differences that are disqualifying from finding
2 differences that you consider a disguise?
3 A. Oh, disguised handwriting is usually
4 written very slow and arduous and carefully.
5 Sometimes there are shakes involved. Sometimes
6 there are touch-up marks and patches and so
7 forth. And so when someone is disguising their
8 handwriting, they usually either, some of the
9 ways, of course, changing letter forms. But
10 other ways would be changing the speed of the
11 writing where the writer believes that they are
12 actually disguising their handwriting. But the
13 problem is with disguised writing, your natural
14 habits come out sooner or later if you write
15 too much.
16 Q. Have you found in the literature any
17 test results showing the known rates of error
18 for determining the authority of unknown
19 writings?
20 A. Specifically with unknown writings?
21 No, I have not.
22 Q. Are you aware of tests showing how
23 good a job forensic document examiners do when
24 compared to lay persons at determining the
25 authorship of unknown writings?
0209
1 A. What do you mean unknown? You are
2 talking anonymous writings or are you talking --
3 Q. Yes, anonymous writings.
4 A. Just specifically anonymous writings?
5 Because I read studies, but I am not sure if
6 they dealt with anonymous writings. I know they
7 were asked to match up certain writings to see
8 if they were written by certain people.
9 Q. How good a job did the forensic
10 document examiners do relative to lay persons in
11 those study results you have looked at?
12 A. To the best of my memory, that the
13 document examiners did better than the lay
14 persons. And there was actually a Mr. Bryan
15 Found, who is actually Dr. Bryan Found. He has
16 a Ph.D., out of Australia. Mr. Found with
17 another professor released a proficiency test,
18 and I think it encompassed about 50 document
19 examiners. Some of those were government and
20 some of those were private. And the eight high
21 scores actually belonged to private document
22 examiners.
23 Q. How many of those were NADE
24 certified?
25 A. I am not sure how many of them
0210
1 were, but I know definitely one, and that is
2 our current president. She had the highest
3 score, I believe.
4 Q. You mentioned earlier that the NADE
5 had 85 to 89 members last time you checked and
6 that the membership, of course, might have
7 changed after that.
8 A. That's correct.
9 Q. How many NADE certified document
10 examiners are there?
11 A. That is a good question. I don't
12 have the answer to that.
13 Q. Have you kept a track record of
14 whether your opinions have proven to be accurate
15 or in error?
16 A. My test -- how I was tested was
17 that my work was supervised through Mr. Liebman
18 when I worked with him through the mentorship
19 program. And from there I also took the
20 certification test with NADE. So I had the
21 mentorship program where I was supervised, and I
22 had to take the written and oral exam through
23 NADE to receive that certification.
24 Q. What is your own known rate of error
25 in your own conclusions?
0211
1 A. I am not sure what that would be.
2 Q. Did you make an error in the case
3 of Katherine Almy?
4 A. No. What I did is I submitted an
5 opinion there that it appears to be which is
6 probable, and it was up to -- what I write
7 after that is up to Mr. Grisham, and he handed
8 it to an investigator. And after he read it, he
9 seemed to believe that there was enough
10 information to pursue an investigation.
11 Q. And you don't know yet whether Ms.
12 Almy is correct or not when she says she did
13 not author the anonymous notes in that case?
14 A. You said I don't know whether she is
15 correct or not?
16 Q. Yes.
17 A. Well, after I look at the evidence
18 and the state document examiner that she hired,
19 they were not able to eliminate her. I asked
20 for additional handwriting samples, and the state
21 document examiner asked the same. But she has
22 not supplied either of us with any additional
23 samples.
24 Q. So you don't know yet whether she is
25 right in her case or not?
0212
1 A. That is right. She hasn't been very
2 cooperative in giving us information we need.
3 Q. Ms. Wong, when did you first become
4 aware of the case involving the death of
5 JonBenet Ramsey?
6 A. When did I become aware of it?
7 Q. Yes.
8 A. When it was broadcasted in the
9 media.
10 Q. And as best you recall, when was
11 that?
12 A. I am guessing. I will say December
13 1996.
14 Q. When did you first come to any
15 conclusions, however tentative, about who
16 committed the murder?
17 A. Well, I don't have any opinion as to
18 who committed the murder back then or today.
19 Q. Have you ever had any tentative
20 conclusions?
21 A. About who committed the murder?
22 Q. Yes.
23 A. No, I do not.
24 Q. When did you first view the ransom
25 note?
0213
1 A. Mr. Liebman received a call from a
2 newspaper person, and then Mr. Liebman told me
3 that someone was sending a copy of the note and
4 some handwriting samples of Patsy Ramsey.
5 Q. When was that?
6 A. That's a good question. I can't
7 remember. The note had already been released in
8 the media, and it was way after that. That is
9 all I can remember.
10 Q. Who was the newspaper person?
11 A. I can't remember his name, but he
12 was actually with the Enquirer.
13 Q. Have you ever seen the original
14 ransom note?
15 A. No, I have not. I did ask to see
16 it, but I hear it is not available.
17 Q. When did you ask to see it?
18 A. When the newspaper reporter called, I
19 asked him. And then at a later date when Mr.
20 Hoffman called, I also asked. And then again
21 when this case arose, I asked again if it was
22 available.
23 Q. And approximately when did you first
24 see a copy?
25 A. As I said, it was way after the
0214
1 date that the ransom note was released to the
2 media, whenever that may have been.
3 Q. What type of copy did you see?
4 A. A copy was sent to us in the mail.
5 Q. What generation copy was it?
6 A. That is what we asked, and we
7 weren't sure. So we are assuming it is a
8 later generation.
9 Q. When you first saw it, did you take
10 any action? Did you make a study of it?
11 A. Of the ransom note?
12 Q. Yes.
13 A. When we received it, of course I
14 looked at it.

15 Q. Did you make a study of it?
16 A. In what sense?
17 Q. In a professional document
18 examination?
19 A. Yeah. In a systematic way, yes, I
20 looked at the ransom note and then I looked at
21 exemplars that were available. And I went
22 through the steps of, I guess, this time we
23 were working with copies. But it is amazing that
24 even though we were working with a copy of the
25 note that there were so many -- in normally
0215
1 what a copy would hide, there are so many
2 similarities and distinct features that did pop
3 out.
4 And we looked -- when I looked at
5 the note, I looked at certain letter formations
6 in the note. I did a -- I studied the note
7 to understand the handwriting in there, the way
8 it is formed, the way it is written, how
9 certain items and certain letters fit on -- how
10 they are to the baseline, if they are above or
11 below, certain spacings between words, alignment,
12 a lot of the other things I've mentioned before.
13 And then I looked at the samples
14 that were sent to us of Mrs. Ramsey's
15 handwriting. And from there I studied her
16 handwriting to see what was in the range of her
17 handwriting to see how she wrote.
18 Q. Did you make that systematic
19 examination of the ransom note and exemplars
20 even before you had heard from Darnay Hoffman?
21 A. In that case, yes, that is correct.
22 Q. What conclusion had you reached
23 before you heard from Darnay Hoffman?
24 A. That it was probable. There were
25 just striking similarities between the ransom
0216
1 note and the handwriting of Patsy Ramsey. But
2 the reason why it was probable is because I
3 told the newspaper reporter that we would need
4 additional samples.
5 Q. Did the "National Enquirer" pay you
6 or Mr. Liebman?
7 A. No, they did not.
8 Q. Did they --
9 A. Well, I can only speak for myself.
10 No, they did not pay me. And I don't believe
11 that they paid Mr. Liebman.
12 Q. Did the "National Enquirer" ask you
13 to study the note and exemplars and reach a
14 conclusion?
15 A. They didn't ask me personally. They
16 asked Mr. Liebman.
17 Q. And so you and Mr. Liebman did this
18 analysis in 1997 at the request of the "National
19 Enquirer," a tabloid publication; and that was
20 your first official, professional involvement in
21 the case of the JonBenet Ramsey ransom note?
22 A. If that is what you want to call
23 it.
24 Q. Yes is your answer?
25 A. Oh, okay, yes. I don't know what
0217
1 you mean as professional or what since we were
2 not retained with any money.
3 MR. WOOD: I am sorry. What did
4 she say?
5 MR. HOFFMAN: Would you read the
6 answer back?
7 (The record was read by the
8 reporter.)
9 THE WITNESS: We weren't paid to do
10 the work. There weren't any --
11 Q. (By Mr. Rawls) You got just as
12 much money from the "National Enquirer" as you
13 did from Chris Wolf; am I correct?
14 A. Oh, you mean zero?
15 Q. That is what I mean.
16 A. I haven't received any money from
17 Mr. Wolf.
18 Q. So one may or may not consider that
19 professional; is that your testimony?
20 A. No, no, no. I just wasn't sure
21 what you were trying to imply.
22 Q. So is it fair to assume that Mr.
23 Darnay Hoffman had learned of your existence and
24 your credentials from the tabloid?
25 A. That is how he heard our names.
0218
1 Q. I see. In your resume when you
2 listed your news media appearances, did you list
3 the "National Enquirer"?
4 A. No, I did not.
5 Q. Why is that?
6 A. Oh, there were many other ones I did
7 not put on there, so.
8 MR. RAWLS: I see. Let's take a
9 five-minute break, if that is agreeable.
10 THE VIDEOGRAPHER: Going off the
11 video record at 4:19.
12 (A recess was taken.)
13 THE VIDEOGRAPHER: Back on the
14 record at 4:33.
15 Q. (By Mr. Rawls) Ms. Wong, did you
16 yourself ever receive any money from any tabloid
17 in connection with the JonBenet Ramsey death or
18 murder?
19 A. Any tabloid, no. You mean like
20 "Globe" and those other papers?
21 Q. Yes.
22 A. No, I have not.
23 Q. Or anybody affiliated with a tabloid?
24 A. I -- is "Hard Copy," I think they
25 paid us something one time. They wanted an
0219
1 exclusive or something.
2 Q. In connection with the ransom note?
3 A. That is correct.
4 Q. How much did "Hard Copy" pay you?
5 A. I can't remember. I think David
6 Liebman and I split, like, $500.
7 Q. Did, to your knowledge, any tabloid
8 pay David Liebman anything?
9 A. Not to my knowledge.
10 Q. The "National Enquirer"?
11 A. I am not aware if they paid him or
12 not.
13 Q. "American Media"?
14 A. Who are they?
15 Q. I believe they are the owner of the
16 "National Enquirer."
17 A. Oh, okay. No. Sorry.
18 Q. The "Globe"?
19 A. No.
20 Q. Any other publication pay David
21 Liebman any money?
22 A. No, not that I know of.
23 Q. Any other broadcaster apart from
24 "Hard Copy" pay David Liebman any money?
25 A. No, not that I know of.
0220
1 Q. And apart from your having split
2 yourself $500 with David Liebman that was
3 received from "Hard Copy," have you ever been
4 paid anything by anybody in connection with the
5 ransom note?
6 A. No, I have not.
7 Q. And I mean the ransom note that was
8 found in the Ramsey home in connection with the
9 death of JonBenet Ramsey?
10 A. That is correct.
11 Q. Is your answer the same, no money to
12 you apart from the $500 that you split?
13 A. That is correct. From what I
14 remember, that is all.
15 Q. And the "National Enquirer," when it
16 asked you and Mr. Liebman to look at the ransom
17 note --
18 A. Well, they asked Mr. Liebman, and I
19 was just working at that time for --
20 Q. You just what?
21 A. I was working for Mr. Liebman at
22 that time, so I wasn't specifically asked by
23 them.
24 Q. What exemplars did the "National
25 Enquirer" give to you and Mr. Liebman?
0221
1 A. Oh, you asked me that earlier. See
2 if I remember again.
3 It was a picture of the box with
4 Ramsey written on it. A picture of a poster
5 that said Welcome to the Northwest Territory.
6 Q. What else?
7 A. I am trying to think. I am not
8 sure if that one in front of you came from Mr.
9 Hoffman or the Enquirer, but it was all around
10 the same time period. There was a Rainbow Fish
11 Player picture. There was also a Hi, Bob,
12 letter.
13 Q. So the fact is you don't know
14 whether the Rainbow Fish Player's exemplar came
15 from the "National Enquirer" or Darnay Hoffman?
16 A. That is correct.
17 Q. And you don't know whether the Hi,
18 Bob, note came from the "National Enquirer" or
19 from Darnay Hoffman?
20 A. I am trying to remember. Yes, that
21 is correct. I can't remember exactly where it
22 came from.
23 Q. Now, did you or Mr. Liebman ask the
24 "National Enquirer" to authenticate that the
25 exemplars you have described came from Patsy
0222
1 Ramsey?
2 A. Yes. We asked them where the
3 exemplars came from and if there was anybody to
4 verify that those signatures -- or I am sorry,
5 that those writings were created by her; and
6 they told us that the photo of the boxes were
7 taken through the window of their house. And I
8 said, well, how do we know that was written by
9 Patsy. And also there was the poster. And I
10 think they said that they also had them maybe
11 verified. I can't remember clearly. But that
12 is a question that we always ask.
13 Q. You just don't remember what the
14 "National Enquirer" said?
15 A. That is correct.
16 Q. The photo of the boxes you were told
17 was taken through the window, and you asked the
18 very good question how did the "National
19 Enquirer" know whose hand had written the name
20 on the boxes?
21 A. Correct.
22 Q. And did you get an answer to that?
23 A. I am trying to remember. It kind
24 of blurs during the time period with the
25 "National Enquirer" and Mr. Hoffman what was
0223
1 received and so forth, because that came -- they
2 came pretty close in time.
3 Q. Do you remember getting an answer
4 that definitely tied Patsy Ramsey or anybody
5 else to the name on the box?
6 A. I am trying to think. At that time
7 I wouldn't have used it if they said they
8 didn't confirm it. But I cannot remember if I
9 really even utilized that box as part of an
10 exemplar, at the moment.
11 Q. And what verification did the
12 "National Enquirer" give you concerning the
13 Welcome to the Northwest Territories poster?
14 A. I can't remember at the moment.
15 But, I mean, I remember the way they told me
16 how they acquired the picture.
17 Q. How was that?
18 A. It was just they took a photo of it
19 in front of -- somebody was in her garage, and
20 they took a picture of it. And that was it.
21 Q. In whose garage?
22 A. I am sorry. Mr. and Mrs. Ramsey's
23 garage.
24 Q. Who took a picture of it?
25 A. I don't know.
0224
1 Q. Someone from the "National Enquirer"?
2 A. Could be.
3 Q. But you don't recall at this time?
4 A. That is correct. I mean, they could
5 have sent out an independent photographer. I am
6 not sure.
7 (Defendants' Exhibit-8 was marked for
8 identification.)
9 Q. (By Mr. Rawls) Ms. Wong, can you
10 tell us if you recognize Defendant's Exhibit 8?
11 A. Yes, I do. It is a report issued
12 to Mr. Hoffman on November 14, 1997.
13 Q. From whom?
14 A. From me.
15 Q. And are you the sole author of this
16 report?
17 A. Yes. I wrote a -- there are some
18 typos in here.
19 Yes, I wrote this.
20 Q. Did you list all of the exemplars
21 that you used for comparison with the ransom
22 note in this letter?
23 A. What was available to me at that
24 time, yes.
25 Q. And there were seven items; were
0225
1 there not?
2 A. Yes, that is correct.
3 Q. And let me ask you, using this
4 letter and pages one and two of this letter as
5 your guide, to tell me which of S1 through S7
6 was furnished to you by Mr. Ramsey -- excuse
7 me, by Mr. Hoffman and which of those items, S1
8 through S7, had previously been furnished to you
9 by the "National Enquirer."
10 A. The two-page letter addressed to Miss
11 Kit. I am not sure if that came from the
12 "National Enquirer" or Darnay.
13 A greeting card with the --
14 preprinted with Wishing you a bright and
15 beautiful holiday season; and it begins with Hi,
16 Bob. I am not sure if that came from Darnay
17 or the "National Enquirer."
18 The color photocopy of the photograph
19 of Welcome to the Northwest Territory. That
20 came from the "National Enquirer."
21 The color photocopy of the picture
22 of the box that says Ramsey in the lower
23 right-hand corner that came from the Enquirer.
24 The color photocopy of the photo
25 with four children, which is Rainbow Fish
0226
1 Players. I can't remember if that came from
2 the "National Enquirer" or Darnay.
3 The photocopy of the color scrapbook
4 with the handprinting, This is me when I was
5 first born. That came from Darnay Hoffman.
6 And there was a copy of a round
7 metal button with the handprinting, Hello, I am
8 Marilyn Monroe. That came from Mr. Hoffman.
9 Q. Did you keep records of the analysis
10 that you made which you provided to the
11 "National Enquirer"?
12 A. I would have to look at my files.
13 I am not sure.
14 Q. Would you do that for us, because
15 the answer --
16 A. I would be more than happy to.
17 Q. -- would be very useful to us?
18 A. Okay. If I can find it, I will be
19 more than happy to show it to you.
20 Q. Because I can only assume that you
21 did a detailed and careful study before you or
22 Mr. Liebman gave any conclusions to the
23 "National Enquirer"; am I correct?
24 A. Correct. My case file on this,
25 though, is filling up boxes. So, hopefully, I
0227
1 will be able to find it.
2 Q. Did you submit anything in writing
3 to the "National Enquirer"?
4 A. Not that I am aware of.
5 Q. But you did do a written analysis
6 for your own purposes before commenting to the
7 "National Enquirer"; did you not?
8 A. No. I would just have my notes,
9 and they would ask what my opinion was. I
10 only do a written letter of opinion or report
11 when I am asked to.
12 Q. And your conclusion to the "National
13 Enquirer," then, was made based on S3 as listed
14 in Defendants' Exhibit 8 and was made based on
15 S4 as listed in Exhibit 8 and might have been
16 made based on no additional exemplar whatsoever?
17 A. That is not true. I would have to
18 look at my notes in order to give you a more
19 concise answer.
20 Q. Well, for today's purposes, the only
21 things that you know for sure you had even seen
22 before you spoke with Darnay Hoffman are S3 and
23 S4; are they not?
24 A. That is what I remember.
25 Q. So those are the things you know you
0228
1 got from the "National Enquirer" --
2 A. That is correct.
3 Q. -- and not later from Mr. Hoffman,
4 correct?
5 A. That is correct.
6 Q. There is nothing else you can tell
7 me about today that you know you had received
8 from the "National Enquirer"?
9 A. Not that I can remember.
10 Q. Okay. So to the best of your
11 knowledge today, you base the opinion you gave
12 to the "National Enquirer" solely on S3 and S4?
13 A. I am not sure. I can't give you a
14 correct answer on that until I look at my notes
15 or find them.
16 MR. HOFFMAN: Jim, I am confused.
17 Can I just ask one question --
18 MR. RAWLS: Yes.
19 MR. HOFFMAN: -- because I may have
20 missed this?
21 What opinion is it that you are
22 referring to? Was there actually an opinion
23 that was quoted somewhere with respect to Cina
24 or David, because you are talking about her
25 opinion? What opinion is that?
0229
1 MR. RAWLS: She's testified that she
2 and Mr. Liebman gave an opinion to the "National
3 Enquirer," and that is the opinion I am
4 discussing.
5 MR. HOFFMAN: Okay. So you are not
6 talking about an opinion that appeared in print
7 in the Enquirer or anything like that? You are
8 basing this opinion -- and we are not even sure
9 of the language of the opinion in this case?
10 MR. WOOD: Other than what she's
11 testified to.
12 MR. HOFFMAN: Other than what she's
13 testified to. Okay. So there is no external
14 document that you are referring to with respect
15 to an opinion to the Enquirer? Because you
16 keep asking her about her opinion. I don't
17 even know what this opinion is except that maybe
18 there was some sort of conclusion drawn. But
19 in what sort of language?
20 MR. RAWLS: I don't know what was
21 published in the "National Enquirer."
22 MR. WOOD: But, Darnay, that is not
23 to say that I may know.
24 MR. HOFFMAN: Okay. I just thought
25 maybe I had missed it in this, because I was
0230
1 just wondering if there was a reference to an
2 actual quote as against what she's just stated
3 her memory to be with respect to this opinion
4 in the Enquirer.
5 MR. WOOD: Can you help us as to
6 maybe clarify in which of these documents you
7 got from her, because she had them from the
8 "National Enquirer" and which ones you had?
9 MR. HOFFMAN: Well, let me just try
10 and clarify. Do you want to do this initially
11 off the record and then make a record? How do
12 you want to do this?
13 MR. RAWLS: Sure.
14 MR. HOFFMAN: Okay. So why don't
15 we just go off the record for a minute; and if
16 you need to make a record, we will do it, so I
17 don't do this on your own time.
18 MR. RAWLS: We are off the record.
19 THE VIDEOGRAPHER: We are off the
20 record at 4:47.
21 (Discussion ensued off the record.)
22 THE VIDEOGRAPHER: Going back on the
23 record at 4:57.
24 Q. (By Mr. Rawls) Ms. Wong, you have
25 been here listening to the colloquy we've just
0231
1 had off the record, have you not, with Mr.
2 Darnay Hoffman?
3 A. Yes, that is correct.
4 Q. Has that refreshed your recollection
5 about several of the events that happened in
6 1997?
7 A. It might explain why my memory of
8 everything is kind of intermingling.
9 Q. Sure.
10 A. But I really won't know until I get
11 back and look through the files and see.
12 Q. And from your files, let me tell you
13 a few things we would like to obtain from you
14 if you have them.
15 A. If I have them.

16 Q. And Mr. Hoffman and Mr. Altman can
17 tell us if it is agreeable for those to be
18 furnished to us if you do, indeed, have them.
19 First is your notes that were made
20 about the handwriting on the ransom note and any
21 exemplars furnished to you or to Mr. Liebman by
22 the "National Enquirer."
23 And, Darnay, and, Evan, is it
24 agreeable that those be produced if, indeed, Ms.
25 Wong possesses them?
0232
1 MR. HOFFMAN: Yeah. It is fine
2 with us so long as there isn't some sort of
3 privilege that she can establish. But I have
4 no problem with it. I don't know about you,
5 Evan.
6 MR. ALTMAN: Yeah, I have no
7 problem.
8 Q. (By Mr. Rawls) Are you sure this
9 was the "National Enquirer," Ms. Wong, as
10 opposed to some other tabloid?
11 A. As far as I remember, that is who I
12 think it was.
13 Q. And if it is some other tabloid and
14 you can find the notes but it turns out to be
15 a different tabloid, we would like those notes
16 as well.
17 MR. ALTMAN: I think subject to the
18 same potential, if there is some privilege, then
19 I don't think we will have any privilege
20 otherwise.
21 Q. (By Mr. Rawls) In addition, Ms.
22 Wong, did you keep a copy of the resulting
23 article published by the "National Enquirer" or
24 whatever tabloid it was as a result of the work
25 that you and Mr. Liebman did and reported to
0233
1 the tabloid?
2 A. I may and I may not have. I won't
3 know until I look in the file.
4 Q. And we would like a copy of that
5 article if it, indeed, exists in your file, Ms.
6 Wong.
7 And, Darnay, and, Evan, we hope that
8 will be something you all will agree to produce
9 if found.
10 A. Right.
11 Q. We would also like a copy of the
12 Tom Miller, the Attorney Tom Miller report that
13 we understand based on Mr. Hoffman's remarks
14 just now off the record was furnished by Mr.
15 Darnay Hoffman to you, Ms. Wong, during 1997,
16 which we understand attached were included S1
17 through S7 or some or all of those exemplars as
18 listed on your letter which is Defendant's
19 Exhibit 8.
20 A. Okay.
21 Q. So do you feel that you likely have
22 that Tom Miller report?
23 A. I am not sure. I would have to go
24 look, but I remember Darnay sending it. And I
25 was thinking to myself why do attorneys even
0234
1 bother doing that because I don't even read it
2 until after I do my analysis first.
3 Q. So is it your testimony you do or
4 you do not remember the Tom Miller report?
5 A. I remember receiving it, and I
6 remember reading it way later on after the fact.
7 Q. So it is your positive testimony
8 that you did not read the Tom Miller report
9 until you had reached your own conclusions?
10 A. That is correct.
11 Q. And that report, of course, may or
12 may not continue to be in your files; am I
13 correct?
14 A. That is correct.
15 Q. And if it is in there, we ask you
16 for that.
17 And, Mr. Hoffman, and, Mr. Altman,
18 we hope that is agreeable to produce.
19 MR. ALTMAN: That is agreeable.
20 (Defendants' Exhibit-9 was marked for
21 identification.)
22 Q. (By Mr. Rawls) Ms. Wong,
23 Defendants' Exhibit 9 is a copy of a letter
24 from Darnay Hoffman to Thomas C. Miller,
25 Esquire, in Denver, Colorado, dated October 31,
0235
1 1997. And my question for you is simply were
2 you ever furnished a copy of this letter by Mr.
3 Hoffman?
4 A. I don't recognize this letter.
5 Q. Would you take a moment to read
6 through it, please?
7 A. Sure.
8 MR. HOFFMAN: Jim?
9 MR. RAWLS: Yes.
10 MR. HOFFMAN: Can I comment just on
11 the circumstances of that letter while she is
12 reading it? And I can do it briefly.
13 MR. RAWLS: Darnay, I would prefer
14 that you not do that.
15 MR. HOFFMAN: Oh, okay.
16 Q. (By Mr. Rawls) Have you had a
17 chance to take a look at that letter and its
18 contents?
19 A. Yes, I've briefly read it.
20 Q. And did Mr. Hoffman -- having read
21 this letter, does it refresh your recollection
22 as to whether you had ever seen it before
23 today?
24 A. No, I haven't seen it.
25 Q. Did Mr. Hoffman tell you in
0236
1 substance any of the information that is found
2 in this letter to Mr. Miller?
3 A. No, he has not.
4 Q. You will note in the second
5 paragraph of this letter that Mr. Hoffman states
6 he had spoken with handwriting expert Paul A.
7 Osborn, who is referred to as the grandson of
8 Albert S. and son of Albert D. Osborn. Did
9 Mr. Hoffman tell you about his conversation with
10 Paul Osborn?
11 A. Not that I can remember.
12 Q. Did he tell you that Mr. Paul Osborn
13 knew the handwriting experts who gave reports to
14 the defense team and to the Colorado Bureau of
15 Investigation?
16 A. Not that I can remember.
17 Q. Did Mr. Hoffman tell you that
18 according to Paul Osborn those experts were at
19 the top of their field?
20 A. Did Mr. Hoffman tell me that?
21 Q. Yes.
22 A. No.
23 Q. Did he tell you those experts had
24 impeccable ethical credentials?
25 A. No.
0237
1 Q. Did he tell that you their verdict
2 was that the similarities between Patsy's
3 handwriting and the ransom note handwriting were
4 at the lowest end of the spectrum?
5 A. No.
6 Q. That there was little or no basis
7 for a match?
8 A. I wasn't told that.
9 MR. RAWLS: And, Darnay, I wanted to
10 ask those few questions before you made your
11 explanation; but if you've got an explanation
12 you want to make now off the record, we can go
13 off the record.
14 MR. HOFFMAN: Sure.
15 MR. RAWLS: Okay. We will go off
16 the record.
17 THE VIDEOGRAPHER: Going off the
18 record at 5:05.
19 (A recess was taken.)
20 (Defendants' Exhibit-10 was marked for
21 identification.)

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jameson
Member since 5-8-02
08-15-02, 04:32 PM (EST)

11. "12 Cina Wong depo"
In response to message #10


22 THE VIDEOGRAPHER: Back on the video
23 record at 5:11.
24 Q. (By Mr. Rawls) Ms. Wong, let me
25 show you Defendants' Exhibit 10, please.
0238
1 Here is a copy for you, a copy for
2 you.
3 Do you recognize this document?
4 A. Yes, I sure do.
5 Q. Is it a true copy of a document
6 that was signed by yourself and David Liebman in
7 1997?
8 A. That is correct.
9 Q. And was submitted to the law offices
10 of Mr. Hadden?
11 A. That is correct.
12 Q. In Colorado?
13 A. That is correct.
14 Q. Was this before or after you all had
15 spoken with the "National Enquirer"?
16 A. Way before.
17 Q. Way before. So the "National
18 Enquirer" people would have talked with you some
19 weeks or months after July 30, 1997?
20 A. Right. I had not even seen a copy
21 of the ransom note at this time, I believe.
22 This came about because I saw Mrs. Ramsey on TV
23 making a plea for anybody who might be able to
24 help her in this situation. My heart went out
25 to her. It was -- I can't imagine being in
0239
1 such a situation that she was involved in. And
2 I wanted to be able to help assist Mrs. Ramsey
3 in any way.
4 So I heard that Mr. Hadden was their
5 attorney, and I sent them a fax letting them
6 know we were available if they needed our
7 assistance.
8 Q. And this letter, then, also is dated
9 before you had ever spoken with Darnay Hoffman;
10 is that true?
11 A. That is correct.
12 (Defendants' Exhibit-11 was marked for
13 identification.)
14 Q. (By Mr. Rawls) Ms. Wong, you just
15 have been handed Defendants' Exhibit 11 by Mr.
16 Gallo. Do you recognize this document?
17 A. Yes, that is correct.
18 Q. Is that an authentic signature of
19 yours on the second page of this document?
20 A. Yes, that is my signature.
21 Q. And is that an authentic notary
22 public signature --
23 A. Yes, it is.
24 Q. -- below your signature?
25 A. Uh-huh (affirmative).
0240
1 Q. And it is an area of your own
2 expertise to know that, is it not, whether those
3 are authentic signatures or not?
4 A. Well, I signed it, and I saw the
5 lady notarize it, so.
6 Q. Who is Yolanda Feggans or Feggans?
7 A. I don't know her personally, but she
8 was a notary at a law firm.
9 Q. To whom did you provide this
10 affidavit?
11 A. To Mr. Hoffman.
12 Q. Did you provide it to Mr. Hoffman on
13 or about the date you signed it, November 13,
14 1997?
15 A. I assume so. It would not be
16 before.
17 (Defendants' Exhibit-12, Exhibit-13
18 and Exhibit-14 were marked for identification.)
19 Q. (By Mr. Rawls) Ms. Wong, this is a
20 reproduction of an alleged letter, and I want to
21 ask you if this is a reproduction of a true
22 letter authored by you?
23 A. Okay. I don't recognize it in this
24 form, since it is a reproduction. Or is it in
25 the form that it came in?
0241
1 Q. The reproduction is the only form
2 that we have it in.
3 A. Okay. Yeah, I --
4 Q. But did you send such a letter to
5 Alex Hunter in or about September 28, 1998?
6 A. Yes. I remember speaking to Mr.
7 Hoffman about the situation, and he told me what
8 was going on and asked me if I wanted to
9 assist in this. And I told him that, yes, I
10 would like to. And I asked him how I could go
11 about this.
12 Q. And is this identical to or very
13 substantially similar to a letter that you
14 actually did send to District Attorney Alex
15 Hunter in 1998?
16 A. I sent one. I would have to see
17 it. I am not sure what you are speaking
18 about. I mean, is it similar to --
19 Q. Please read Defendants' Exhibit 12
20 and let me know if that is an identical --
21 A. This is to Mr. Hunter.
22 Q. Yes.
23 A. That's correct. But you say if I
24 wrote another one; is that what you are saying?
25 Q. No, no.
0242
1 A. Oh, okay. I'm sorry.
2 Q. I am asking did you write this?
3 A. Yeah. Well, I spoke to Mr. Hoffman
4 about how to word it, so it was with his help.
5 Q. So to the best of your knowledge,
6 while this is a reproduction and not a
7 photocopy, this appears to be verbatim accurate.
8 A. That is correct.
9 Q. Correct?
10 A. I remember the situation being
11 discussed, and this is what -- this is what I
12 was partaking in.
13 Q. So did you formally ask District
14 Attorney Hunter to permit you to testify to the
15 grand jury in 1998, correct?
16 A. Uh-huh (affirmative). They were on
17 a fact-finding mission. I had some facts that
18 I thought they would like to be aware of.
19 Q. Who is Michael Kane? You see he
20 got a cc.
21 A. Right. He was an assistant to Mr.
22 Hunter.
23 Q. He is an Assistant District Attorney,
24 correct?
25 A. I think that is what he was. It's
0243
1 been a while.
2 Q. Would you take a look, please, at
3 Defendants' Exhibit 13. This, too, is a
4 reproduction. Let us know if it is verbatim
5 accurate or substantially similar to a letter
6 you received in reply.
7 A. Okay.
8 Yes. I recognize this letter.
9 Q. Is that identical to or substantially
10 similar to the actual reply which you received
11 from Mr. Kane on behalf of District Attorney
12 Hunter?
13 A. I am sorry? You are saying?
14 MR. RAWLS: Would you read the
15 question back, please, Alex?
16 (The record was read by the
17 reporter.)
18 THE WITNESS: Yes, I recognize this.
19 Q. (By Mr. Rawls) Did you then reply
20 to Defendants' Exhibit 13?
21 A. Yes.
22 Q. And is Defendants' Exhibit 14 a
23 reproduction of your actual reply?
24 A. Yes. I recognize that letter.
25 Q. And that is, indeed, your reply?
0244
1 A. That is correct.
2 (Defendants' Exhibit-15 was marked for
3 identification.)
4 Q. (By Mr. Rawls) Is Defendants'
5 Exhibit 15 a true reproduction of a letter which
6 thereafter you sent to Judge Roxanne Bailin of
7 the 20th Judicial District of Colorado?
8 A. Yes. I recognize this letter.
9 Q. Did you send that letter?
10 A. I am trying to think. Well, I
11 mean, I don't know if I sent it directly or if
12 I handed it to someone else to send for me.
13 But with the wording, I did ask Mr. Hoffman
14 also; we conferred in how to word this.
15 Q. Did Mr. Hoffman assist you with your
16 side of this entire body of conversation -- of
17 correspondence we are looking at now?
18 A. Entirely? Or what?
19 Q. With all of these letters of yours
20 to Alex Hunter and Mike Kane and Judge Bailin?
21 A. You are saying he wrote them
22 entirely or are you saying assisted?
23 Q. No, no. I am asking, did he -- let
24 me start over, please.
25 Did Darnay Hoffman assist you in
0245
1 wording all of your letters to Alex Hunter and
2 Michael Kane and Judge Bailin?
3 A. Not all of them. Just some of
4 them.
5 Q. The language was worked out by you
6 in consultation with Darnay Hoffman; is that
7 correct?
8 A. That is correct.
9 Q. And all of this effort was made by
10 you with the assistance of Mr. Hoffman in the
11 hope that you could testify to the grand jury
12 in Colorado that Patsy Ramsey, in your opinion,
13 probably authored the ransom note; is that
14 correct?
15 A. That is correct. I had a lot of
16 information to share.
17 Q. Had you ever been told up to the
18 point of this last letter, Defendants' Exhibit
19 15, that Mr. Hoffman represented Chris Wolf?
20 A. No. I didn't know that.
21 Q. As a matter of fact, this letter was
22 authored more than a year before John and Patsy
23 Ramsey published a book, "The Death of
24 Innocence."
25 A. Okay.
0246
1 Q. Was it not?
2 A. I am not sure of the date.
3 (Defendants' Exhibit-16 was marked for
4 identification.)
5 Q. (By Mr. Rawls) Let me ask you to
6 look at Defendants' Exhibit 16, please. Ms.
7 Wong, it purports to be a three-page
8 reproduction of two letters, one from Michael
9 Kane on behalf of Alex Hunter to you, and one
10 from Michael Kane on behalf of Alex Hunter to
11 David Liebman.
12 Would you please look over the
13 reproduction that is -- that purports to be of
14 a letter to you --
15 A. Do you have the second page? Oh,
16 it runs on. I see what it's done.
17 Q. My question is, is this, pages one
18 and two of Defendants' Exhibit 16, is there on
19 these pages an accurate reproduction of a letter
20 which Michael Kane sent to you in early 1999?
21 A. Okay. I will read it and let you
22 know.
23 (Deponent reviews document.)
24 Okay. I read my letter, and I
25 think the second one is basically the same.
0247
1 Q. Well, I don't need you to address
2 the reproduction of the letter Mr. Kane sent to
3 Mr. Liebman. I am only interested in whether
4 the reproduction of the letter from Mr. Kane on
5 behalf of Alex Hunter to you is accurate --
6 A. Yes.
7 Q. -- as best you recall?
8 A. From what I remember, yes.
9 Q. Do you have the originals of all
10 these letters in your file?
11 MR. ALTMAN: Jim, let me interrupt.
12 As far as accurate, do you mean accurate as to
13 what is stated in there or accurate that she
14 did receive it?
15 MR. RAWLS: Well, I mean accurate
16 that it is what he sent to Ms. Wong.
17 MR. ALTMAN: Okay.
18 Q. (By Mr. Rawls) I am not asking do
19 you agree with Mr. Kane's conclusions.
20 A. Okay. Yeah, I do not agree with
21 Mr. Kane's conclusions.
22 I am sorry, your question was?
23 Q. My question is, is this the letter
24 that he sent you?
25 A. The printing, the verbiage and
0248
1 everything, yeah.
2 Q. Yes?
3 A. The way it was written, yes.
4 Q. Thank you. Do you have Mr. Kane's
5 actual letter in your file?
6 A. It should be in a file somewhere.

7 MR. RAWLS: And we would like the
8 actual letter so we will not have to be using
9 reproductions, Ms. Wong, if that can be found,
10 and if Mr. Hoffman and Mr. Altman will agree
11 that it should be produced.
12 MR. HOFFMAN: Yes, if the original
13 can be produced, absolutely. But there's
14 certainly not going to be any prohibition from
15 you introducing it in the event there is a
16 trial because there is a copy. Of course, we
17 will try and give you the original, naturally.
18 MR. RAWLS: Or a Xerox of the
19 original. I am not standing on formality. I
20 don't need to see the original. We are not
21 going to try to hire someone to try to
22 authenticate Michael Kane's handwriting.
23 Q. (By Mr. Rawls) Do you also, Ms.
24 Wong, have a copy of your letter to Alex Hunter
25 of September 28, 1998, which I believe is
0249
1 Exhibit 12?
2 A. I may not have a signed copy. I
3 may just have a printed version in my computer
4 somewhere.
5 Q. But you probably do have a record of
6 that letter?
7 A. Somewhere.
8 Q. And we would like a copy of that as
9 well.
10 Do you have in your files also a
11 copy of the letter which --
12 A. One moment. I am trying to make
13 note of this.
14 Q. Sure. Take your time. I don't
15 mean to rush.
16 A. Okay. Sorry. Go ahead.
17 Q. That's okay. Do you also likely
18 have in your office a copy of Defendants'
19 Exhibit 14, that being the October 16, 1998,
20 letter in which you replied to Michael Kane to
21 Defendants' Exhibit 13, which was his letter of
22 October 2, 1998, to you?
23 A. I may have a copy in my computer.
24 Q. And we would like that as well if
25 that can be found and if Mr. Hoffman and Mr.
0250
1 Altman agree that we can see that copy.
2 And, finally, do you have a copy of
3 your letter which is Defendants' Exhibit 15 to
4 Judge Bailin in your office?
5 A. Probably be in my computer.
6 Q. Good. Do you need to make a note
7 of that?
8 A. I am making a note of that now.
9 MR. HOFFMAN: Again, Jim, I am
10 making notes too.
11 MR. RAWLS: Good. Thank you all.
12 MR. WOOD: Darnay, do you want to
13 take five minutes, maybe, and let Jim organize
14 his --
15 MR. HOFFMAN: Yes, please.
16 MR. RAWLS: I would like about a
17 five-minute break to get organized and try to
18 prioritize what I need to do in the time
19 remaining.
20 MR. ALTMAN: Jim, what I would ask,
21 you said there may be a possibility of a way
22 to get her bags over here if we are going to
23 get close to that 6:30. I think it is going
24 to be a little bit pressed maybe if --
25 THE WITNESS: And I have a question.
0251
1 MR. RAWLS: Let's go off the record.
2 THE VIDEOGRAPHER: Off the video
3 record at 5:33.
4 (A recess was taken.)
5 THE VIDEOGRAPHER: Back on the video
6 record at 5:46.
7 Q. (By Mr. Rawls) Ms. Wong, can you
8 tell us, please, the date of the interview that
9 you did with Hard Copy?
10 Let me just repeat that question
11 after I locate my mike because it seems to have
12 -- let me start that over, please.
13 Ms. Wong, can you give us the date
14 of the interview that you did with Hard Copy?
15 A. No, I don't remember what that date
16 is.
17 Q. Can you give it to us approximately?
18 A. Late '77. I am sorry. Late '97 to
19 '98 or something like that.
20 Q. Thank you. And for now is that the
21 best you can do for us?
22 A. Yes, it is.
23 Q. Do you have anything in your office
24 that would let you pin down the date with more
25 precision?
0252
1 A. I may.
2 Q. Do you have a videotape of your
3 appearance?
4 A. I think I recorded it, and my VCR
5 went on the blitz, so I actually don't have a
6 copy of it.
7 Q. Do you have a calendar entry or a
8 date book or diary entry that might help us
9 learn that date?
10 A. I may.
11 Q. Can you check that when you are
12 looking for some of the other things we've
13 discussed today?
14 A. That is a lot of work. Actually,
15 this is easier, but I will take a look.
16 Q. Thank you.
17 You have, Ms. Wong, have you not,
18 authored an expert report at the request of Mr.
19 Darnay Hoffman and Mr. Evan Altman for this
20 case?
21 A. Yes, that is correct.
22 Q. And in that report, you said that
23 your opinion was given based on well
24 established, I am quoting now, well established
25 and recognized principles of questioned document
0253
1 examination as discussed and defined in the
2 following recognized texts, close quote.
3 Do you recall that language in your
4 report?
5 A. Yes.
6 Q. And I am going to now read the
7 texts which are described in your report.
8 First, Questioned Documents by Albert Osborn;
9 second, Handwriting Examination --
10 MR. ALTMAN: Jim, can you tell us
11 where you are so we can follow along?
12 MR. RAWLS: Yes. This is page 2.
13 This is the February 25, 2002, Forensic
14 Handwriting Report, and this is page 2 of that.
15 And it was furnished to us, Evan, and, Darnay,
16 with a pleading entitled Plaintiff's Disclosure
17 of Expert Testimony.
18 MR. HOFFMAN: Was it a pleading? I
19 think it was just a -- wasn't it just sort of
20 like a pro forma cover with a caption, whatever,
21 all over it?
22 MR. WOOD: Yes. It was not filed.
23 MR. RAWLS: Yes. I am not
24 suggesting when I use the word pleading that it
25 was filed.
0254
1 MR. HOFFMAN: Okay.
2 MR. RAWLS: But it otherwise has the
3 form of a pleading.
4 MR. HOFFMAN: Yeah.
5 Q. (By Mr. Rawls) Okay. The first
6 text on page 2 that you mentioned, Ms. Wong,
7 was "Questioned Documents" by Albert Osborn; is
8 that correct?
9 A. That is correct.
10 Q. The second one was "Handwriting
11 Examination - Facts and Fundamentals" by Huber
12 and Headrick; am I correct?
13 A. That is correct.
14 Q. The next was "Disputed Documents" by
15 Hagin, correct?
16 A. Correct.
17 Q. The next was "Evidential Documents"
18 by Conway?
19 A. That is correct.
20 Q. The next was "Scientific Examination
21 of Documents" by Hilton, correct?
22 A. Correct.
23 Q. The next was "Suspect Documents" by
24 Harrison?
25 A. That is correct.
0255
1 Q. And are those texts all of the texts
2 which you have relied upon as furnishing the
3 well established and recognized principles of
4 questioned document examination which you have
5 relied on in authoring your report?
6 A. Yes. There are more of these, but
7 these I thought were most representative.
8 Q. And these are some of the most
9 reliable textbooks in the questioned document
10 examination field; are they not?
11 A. They are the most respected. For
12 instance, the Osborn book is 73 years old. So
13 there are a lot of things missing and a lot of
14 things that need to be amended that I changed
15 over time. And also with Harrison, a lot long
16 past. There are some things in there that are
17 correct, but there are other things that need to
18 be amended.
19 Q. And you have not relied on anybody
20 else's textbook in coming up with the principles
21 that you base this report on; have you?
22 A. As I mentioned earlier, I used other
23 textbooks; but these are the ones that are most
24 representative, and I mentioned these.
25 Q. And do you possess each of these
0256
1 textbooks in your office?
2 A. Yes, I do.
3 Q. And you brought with you some books
4 here today; did you not?
5 A. I just brought one.
6 Q. And what is that book, please?
7 A. It is a new book by Katherine
8 Koppenhaver, and actually it is quite coming to
9 be one of the most respected books very quickly.
10 It is "An Attorney's Guide to Document
11 Examination."
12 Q. Is this the individual who is part
13 of NADE?
14 A. That is correct. She is currently
15 president. She is past president and current
16 president.
17 Q. Okay. She has been elected to two
18 terms as president of NADE; is that correct?
19 A. That is correct.
20 Q. Can you give us the Library of
21 Congress publication data, please, on that book?
22 A. The ISBN number?
23 Q. Yes.
24 A. Is 1-56720-470-8.
25 Q. And inside the front cover, could
0257
1 you turn to the title page, please?
2 A. This one?
3 Q. Yes. On the back of the title
4 page, do you find publication information?
5 A. Yes.
6 Q. And who is the publisher, and what
7 is the copyright date, please?
8 A. Copyright is 2002. And the
9 publisher is Quorum, that's Q-U-O-R-U-M, Books.
10 Q. Thank you. May I take a quick look
11 at it, please?
12 A. Sure. I am borrowing that copy
13 right now.
14 Q. You have an autographed first
15 edition; do you not?
16 A. Actually, it is Mr. Liebman's copy.
17 I ordered mine. I wanted to read on it
18 quickly, so he was kind enough to let me borrow
19 it.
20 Q. And now we are sitting here on May
21 13, 2002; are we not?
22 A. That is correct.
23 Q. And this book says it was first
24 published in 2002?
25 A. That is correct.
0258
1 Q. And you said this is fast becoming
2 one of the most respected textbooks?
3 A. That is correct. It came out
4 earlier this year, and a lot of people are
5 reading it. And it is put together very well.
6 Q. It had to work pretty fast to become
7 so well --
8 A. Well, I mean --
9 Q. -- respected; did it not?
10 A. -- a lot of people are reading it.
11 Q. How many copies has it sold?
12 A. That is a good question. I am not
13 sure. You'd have to ask Ms. Koppenhaver.
14 Q. And what are the other items that
15 you have brought with you here today, Ms. Wong?
16 The video camera, I am sure, has picked up the
17 fact that you have a notebook and several papers
18 in front of you.
19 A. Yes. I have my notebook with me
20 with demonstrative evidence. I have copies of
21 your expert's reports. And I also have copies
22 of some of the exemplars that were used in this
23 case.
24 Q. Are you, Ms. Wong, aware that the
25 Colorado Bureau of Investigation did obtain
0259
1 studies and analyses with respect to the ransom
2 note that was left in connection with the
3 JonBenet Ramsey death from a number of document
4 examiner experts? Did you know that?
5 A. No. It was -- you are saying that
6 they did a lot of tests and analyses?
7 Q. I was asking whether you were aware
8 that the Colorado Bureau of Investigation asked
9 several handwriting and document examiner experts
10 to study the JonBenet Ramsey ransom note?
11 A. I know they were having some
12 document examiners examine the note. That was
13 actually published in the media.
14 Q. Do you know who some of those
15 experts were that were hired by the Colorado
16 Bureau of Investigation?
17 A. Personally, no.
18 Q. Can you name any of them here today
19 before I name a few?
20 A. Oh, Mr. Ubowski and Mr. Riles. And
21 those are the only two I am familiar with at
22 this moment.
23 Q. Have you heard of Leonard Speckin,
24 S-P-E-C-K-I-N?
25 A. Is that of Speckin Laboratories up
0260
1 in Michigan?
2 MR. WOOD: Yes.
3 Q. (By Mr. Rawls) Yes, he is.
4 A. Yes.
5 Q. Is he a qualified questioned document
6 examiner, in your opinion?
7 A. I am not familiar with him. I am
8 familiar with -- is it Leonard the owner? Is
9 he the father? I am familiar with the son.
10 Q. Okay. All right.
11 A. The son has come to the NADE
12 conferences, and he has spoken at our
13 conferences, and he will be -- or their firm
14 is, actually -- will be speaking at a NADE
15 conference coming up in the next couple of
16 weeks. But due to my health condition, I am
17 not able to go.
18 Q. Do you have any understanding of
19 Leonard Speckin's conclusion about authorship of
20 the ransom note, and specifically about whether
21 Patsy Ramsey wrote the note?
22 A. No, I do not.
23 Q. Have you heard of Edwin Alford?
24 A. Oh, he is in Baltimore; isn't he?
25 Baltimore, Maryland?
0261
1 Q. I am not sure.
2 A. Oh, okay. Edwin -- well, I know an
3 Alford, but I am not sure if it is the same
4 one, so I won't say.
5 Edwin or Alfred?
6 Q. Edwin Alford, A-L-F-O-R-D.
7 A. I am not sure if it is the same
8 one, so I am not sure if I'm familiar if that
9 is the correct person or not I am thinking of.
10 Q. Do you know Richard Dusick or have
11 you heard of him?
12 A. No.
13 And I am sorry, going back to Mr.
14 Alford, I have seen his name referred to in
15 some articles. That is where I am familiar with
16 his name.
17 Q. Would you be surprised to know that
18 the Colorado Bureau of Investigation obtained
19 several reports from handwriting analysts that
20 the Colorado Bureau of Investigation considered
21 to be well qualified, and several of those
22 experts concluded that Patsy Ramsey probably did
23 not author the ransom note? Would you be
24 surprised if that is accurate?
25 A. I am not surprised of the opinion.
0262
1 I am not sure about what approach they used or
2 so forth to come to their opinion.
3 Q. Different qualified document examiners
4 can reach different conclusions about authorship
5 of a questioned anonymous document; can they
6 not?
7 A. At times. But basically all
8 document examiners study the same texts, and it
9 also depends on their training. A lot of --
10 from what I am told, a lot of document
11 examiners that go into government document
12 examination jobs, they are trained by other
13 document examiners who have had a few short
14 courses and they are busy working, and so they
15 are learning from people and who may not go out
16 as often and go to certain conferences and
17 certain seminars and so forth.
18 Q. You concluded in your report, quote,
19 and this is page 4 of the February 25, 2002
20 report that you gave Mr. Hoffman and Mr. Altman,
21 you concluded: Quote, it is highly probable that
22 Patsy Ramsey wrote the ransom note, end quote.
23 Am I correct?
24 A. That is correct.

25 Q. And you did not give an opinion that
0263
1 it was a certainty that Patsy Ramsey wrote the
2 ransom note; did you?
3 A. Let me understand what you are
4 saying. Can you explain yourself?
5 Q. You used the words highly probable.
6 A. That is correct.
7 Q. You did not say it is plain or
8 clear or definite?
9 A. Well, actually, if you look at my
10 opinions, most people will derive that opinion
11 that Mrs. Ramsey is the person who penned the
12 note.
13 Q. Well, do you feel that you have
14 eliminated all reasonable doubt about whether
15 Patsy Ramsey wrote the ransom note?
16 A. In this case, I highly believe she
17 wrote the note.
18 Q. And please answer my question.
19 A. I am sorry.
20 Q. Do you feel that you have eliminated
21 all reasonable doubt?
22 A. With the people, the possibilities of
23 who could be involved in this case with the
24 three handwriting samples that were given to me
25 and enormous -- the enormous similarities that
0264
1 Patsy Ramsey's handwriting and the note, yes, I
2 believe she is the writer.
3 Q. Well, you believe she is most likely
4 of those three to have authored the note?
5 A. Correct.
6 Q. But those are the only three whose
7 exemplars you have studied?
8 A. But I am also familiar with
9 different types of handwriting since I have
10 looked at many, many, many handwritings and yet
11 have I ever seen so many similarities in one
12 handwriting group.
13 Q. So have you eliminated all reasonable
14 doubt? Can you say with definiteness that Patsy
15 Ramsey did write the note?
16 A. She in some way is very involved.
17 Q. You said she in some way is very
18 involved. Well, she was the mother of the
19 deceased. Now, that is involved; is it not?
20 A. In that sense, yes. With penning
21 the note, she wrote the note.
22 Q. You are sure she wrote the note?
23 A. There is too many similarities
24 pointing to that fact that in this world it
25 would be highly unlikely to find anybody who
0265
1 would have all these similarities, who would
2 have the same and in the same combination.
3 Q. And handwriting analysts can only
4 provide their own opinions about authorship; can
5 they not?
6 A. That is correct.
7 Q. And the opinions of qualified
8 handwriting analysts may differ on the authorship
9 of the same document; might they not?
10 A. At times there are document examiners
11 who may give convenient opinions. I do not
12 give convenient opinions.
13 Q. The opinions of qualified handwriting
14 examiners can vary; can they not?
15 A. At times, yes.
16 Q. And if, indeed, different qualified
17 document examiners from yourself reach the
18 conclusion that it was probable that Patsy
19 Ramsey did not author the note, that would not
20 surprise you?
21 A. I am sorry. You are saying
22 different examiners from myself? I am sorry?
23 Q. If they reach the conclusion that
24 Patsy Ramsey probably did not author the ransom
25 note, that would not surprise you; would it?
0266
1 A. That wouldn't surprise me, but there
2 is Gideon Epstein and Larry Zigler who have also
3 come to the same opinion that I have in this
4 case.
5 MR. RAWLS: I do move to strike the
6 portion of the answer that you have just given
7 us that was not responsive.
8 Q. (By Mr. Rawls) And, Ms. Wong, are
9 you aware Mr. Zigler has withdrawn himself from
10 this case?
11 A. I am aware of that, but that doesn't
12 change his opinion.
13 Q. Well, I don't know whether it
14 changes his opinion or not, but I am afraid we
15 are not going to have the benefit of seeing his
16 opinion.
17 A. Okay.
18 Q. Today we have your opinion that is
19 the subject of our testimony; do we not?
20 A. That is correct.
21 Q. Do you base your opinion on that of
22 Gideon Epstein?
23 A. Oh, no, I do not.
24 Q. Do you base it on that of Larry
25 Zigler?
0267
1 A. I do not base my opinion upon Mr.
2 Zigler's opinion, but I did take a course from
3 Mr. Zigler. And what he teaches is the same
4 of everything that I've studied and all the
5 leading textbooks.
6 Q. And do you base your opinion on that
7 of David Liebman?
8 A. On his opinion? I didn't read his
9 opinion, as I told you. I did my own
10 independent examination in this case.
11 Q. So the answer is no, you don't base
12 your opinion on the opinion --
13 A. Anybody but my own.
14 Q. -- of anybody else?
15 A. That's correct.
16 Q. You base yours on yourself alone.
17 A. That is correct.
18 Q. Correct?
19 Which --
20 A. Well, not just -- I'm sorry. I am
21 not quite understanding what you are saying.
22 That my opinion, based on the examination,
23 correct. I just don't look at it and say,
24 hey, well, I assume this. I just want to make
25 that clear.
0268
1 Q. Do you have in front of you a copy
2 of the ransom note itself?
3 A. Yes, I do.
4 (Defendants' Exhibit-17 was marked for
5 identification.)
6 Q. (By Mr. Rawls) Is Defendants'
7 Exhibit 17 a copy of the ransom note, Ms. Wong?
8 A. Yes, it is.
9 Q. When you first studied this note,
10 did you ever at any point make a study of this
11 note when you had no exemplars at all to
12 compare with it?
13 A. You mean, did I look at -- when I
14 received the note and the exemplars, was there a
15 time when I just looked at the ransom note
16 without the exemplars?
17 Q. Well, that is not exactly my
18 question. Did you have this note, a copy of
19 Defendants' Exhibit 17, before you received any
20 exemplars?
21 A. No. I don't think I had seen this.
22 I knew it was released, but I had not received
23 a copy of it.
24 Q. So at the same time you got this
25 note, a copy of this note, you already had
0269
1 received some exemplars that were said to you to
2 be exemplars of Patsy Ramsey's handwriting; am I
3 correct?
4 A. Yes. They were sent in conjunction
5 with a copy of the ransom note.
6 Q. And did you ever analyze the ransom
7 note independently of any other exemplars?
8 A. Analyze the ransom note for what,
9 because I have nothing to compare it to?
10 Q. Did you analyze it based on all of
11 its contents alone and without regard to whether
12 there might be similarities to some other
13 exemplar?
14 A. Are you asking for content
15 analysis --
16 Q. Yes, exactly.
17 A. -- with regard to linguistics?
18 Q. No. With regard to handwriting?
19 A. Regard to handwriting?
20 Q. Yes.
21 A. No, I didn't look at the note and
22 study it that way.
23 Q. Did you develop a, what I would call
24 a master plan confined to a handwriting analysis
25 of this ransom note alone at any time?
0270
1 A. Oh, you are asking me if there were
2 -- if I was looking for certain similarities
3 which are consistent in the ransom note, what
4 they were?
5 Q. Yes.
6 A. Yes, that is correct. And those
7 same -- that same pattern that you're asking me
8 about the master plan, those same similarities I
9 found in Patsy Ramsey's handwriting.
10 Q. That is not my question.
11 Did you prepare a master plan based
12 solely on the ransom note?
13 A. Not solely on the ransom note.
14 Q. Did you ever prepare a master plan
15 of dissimilarities based solely on the ransom
16 note?
17 A. Well, what you consider in here as
18 -- see, I am not sure what you are getting to
19 because -- okay. I am building a master plan,
20 but I also need to have it compared to
21 something. But within the structure of the
22 ransom note itself, I look for consistencies
23 within there, and anything in here that may
24 vary, you notice that the handwriting is slowly
25 written and is awkward. And according to
0271
1 leading textbooks, that this is a form of
2 disguise, where it is slowed down and it is
3 shaky writing.
4 So some of those items in here that
5 I only see repeated once is only repeated once.
6 So if that is what you want to call a
7 difference. But some things in here only show
8 up once, even though it is written by the same
9 writer.
10 Q. Did you ever make a list confined to
11 the ransom note alone of internal similarities
12 in the handwriting in the ransom note?
13 A. I have a sheet at home where I've
14 circled some things, where certain letter
15 connections keep repeating themselves; but that
16 is about it.
17 Q. And you could show us that list;
18 could you not?
19 A. It is not a list drawn out. It's
20 letters that are circled.
21 Q. It is a copy of the ransom note
22 with letters circled?
23 A. That is correct.
24 Q. And you could show us that; could
25 you not?
0272
1 A. That is correct.
2 Q. We would ask you to do that as well
3 when are you looking back at your file, Ms.
4 Wong.
5 A. Let me make note of that.
6 Q. Good. Please take a moment and feel
7 free to do that, and we appreciate that.
8 A. I'm just not -- you call it the
9 master plan. I use the form of pattern
10 recognition within the system. That is why I
11 was having trouble understanding.
12 Q. I see.
13 A. Sorry. Okay.
14 Q. Are you finished making that note?
15 A. Yes. I just made it under quotes
16 what you called it so I know what you are
17 referring to so when I send it back to you I
18 can use your term.
19 Q. Did you ever make a list of internal
20 differences in the ransom note alone?
21 A. At that moment I was just looking
22 for what was consistent throughout the ransom
23 note. Anything else that I didn't make a mark
24 to, could be an accidental or one-time
25 occurrence.
0273
1 Q. So am I correct that at no time you
2 listed dissimilarities found internally in the
3 ransom note itself?
4 A. I didn't make a physical note of it,
5 but it was a notation I made while I was
6 looking through the note, mental notation.
7 Q. You made mental note of
8 dissimilarities found solely in the ransom note?
9 A. At that time when I was looking at
10 the note; that's correct.
11 Q. But you never committed that mental
12 note or those --
13 A. Notation.
14 Q. -- mental notes to paper?
15 A. That's correct.
16 Q. So there is no way you could show
17 us those?
18 A. It would be really hard.
19 Q. And what is the basic copybook form
20 employed by the author of the ransom note?
21 A. It looks like it is based on the
22 Palmer method.
23 Q. Tell us how you reach that
24 conclusion.
25 A. In the Palmer method, there are
0274
1 different types of ways they would print, and
2 there are two different types of R's available
3 and so forth. I usually have a little form in
4 front of me at home of the copybook version of
5 Palmer and Zaner-Bloser. So as you go through
6 that, and I look at it.
7 Q. Did you ever commit to writing your
8 conclusion that the ransom note was based on the
9 Palmer method?
10 A. No, I did not.
11 Q. And of Patsy Ramsey's exemplars that
12 you studied, what copybook form does Patsy
13 Ramsey use?
14 A. Palmer method.
15 Q. Did you ever commit to writing your
16 conclusion that Patsy Ramsey's exemplars follow
17 the Palmer method?
18 A. No, I did not. The majority of the
19 people in the United States learn from the
20 Palmer method. And currently some are learning
21 Zaner-Bloser, and there is additional, D'Nealin
22 and so forth.
23 MR. RAWLS: Let us just take one
24 minute.
25 THE WITNESS: Sure.
0275
1 MR. RAWLS: We may be getting to a
2 conclusion here pretty soon.
3 THE VIDEOGRAPHER: Going off the
4 video record at 6:13.
5 (A recess was taken.)
6 THE VIDEOGRAPHER: Back on the video
7 record at 6:17.
8 Q. (By Mr. Rawls) Ms. Wong, I have
9 got just a few more questions. Are you able
10 to find among the papers in front of you
11 Defendant's Exhibit 8, please?
12 A. 88?
13 Q. Defendant's Exhibit 8.
14 A. Okay. I'll look for it.
15 Yes, I have it right here.
16 Q. You gave in that document an opinion
17 to Mr. Hoffman in April of the year 2000 about
18 Patsy Ramsey's authorship of the ransom note;
19 did you not?
20 I beg your pardon. I beg your
21 pardon. D-8 is actually 1997; is it not?
22 A. Yes, it is.
23 Q. D-8 was 1997; am I correct?
24 A. That is correct.
25 Q. And let me show you also Defendants'
0276
1 Exhibit 17. I beg your pardon, Defendants'
2 Exhibit 18.
3 (Defendants' Exhibit-18 was marked for
4 identification.)
5 Q. (By Mr. Rawls) Did you later, then,
6 after 1997 give Mr. Hoffman a letter of April
7 20, 2000, which also provided an opinion
8 concerning the authorship of the note?
9 A. Yes.
10 Q. And your opinion was very similar in
11 both November 1997 in Defendants' Exhibit 8 and
12 in April of 2000 in Defendants' Exhibit 18; was
13 it not?
14 A. It is similar.
15 Q. And, in fact, in 1997, your opinion
16 was, and I am referring to the next to last
17 page of Defendant's Exhibit 8, your opinion was
18 that the probability that Patsy Ramsey was the
19 author was 8.5 on a scale of 1 to 10; is that
20 correct?
21 A. That is correct.
22 Q. And by April of 2000, I am looking
23 at page 16 of Defendants' Exhibit 18, your
24 opinion of the probability that Patsy Ramsey was
25 the author had moved to 9.2 on the same 1 to
0277
1 10 scale?
2 A. Yes. In 1997, that was a
3 preliminary report.
4 Q. And in 1997, your report was based
5 exclusively on the exemplars listed as S1
6 through S7; was it not?
7 A. That is correct.
8 Q. And in April of 2000, your report
9 was based on S1 through S7, but additionally you
10 had added S4-A, a color photocopy of a
11 photographed box with, quote, Ramsey Xmas, close
12 quote, printed; is that correct?
13 A. That is correct.
14 Q. And am I correct that, based solely
15 on, in 1997, the documents listed in Defendant's
16 Exhibit 8 as S1 through S7, you reached a
17 conclusion that Patsy Ramsey's probability as the
18 author of the ransom note was greater than a 90
19 percent likelihood?
20 A. In '97 or 2000?
21 Q. In '97.
22 A. I am sorry. In '97. Can you
23 repeat that, please?
24 MR. RAWLS: Would you read that
25 question back, please.
0278
1 (The record was read by the
2 reporter.)
3 THE WITNESS: That is correct.
4 MR. ALTMAN: Are you sure you are
5 saying '97, because I am not sure that is what
6 it said, is '97.
7 THE WITNESS: It is 8.5 on a scale
8 from 1 to 10.
9 MR. ALTMAN: I think he said greater
10 than 90 percent.
11 THE WITNESS: Oh. It is around --
12 it's something like the high eighties, like, 88,
13 89.
14 Sorry. Thank you.
15 Q. (By Mr. Rawls) In fact, in 1999
16 didn't you tell Bill O'Reilly that your
17 conclusion was the probability was 90-plus
18 percent range?
19 A. What year was that?
20 Q. 1999.
21 A. 1999. Yes, I had more time to look
22 at the note.
23 Q. But no more exemplars?
24 A. That is correct. As I mentioned,
25 the 1997 report was a preliminary report.

1 Q. And by the year 2000, you had only
2 one more exemplar, and that was S4-A?
3 A. That is correct.
4 Q. And where had you obtained S4-A?
5 A. Good question. Maybe Mr. Hoffman
6 can help me with this.
7 MR. RAWLS: Darnay, do you --
8 MR. HOFFMAN: You know, actually,
9 unless I see it, I am a little confused as to
10 the time sequencing there or whatever. It is
11 possible that it was an exemplar that we had
12 that she has included in her first preliminary
13 report. I know that over this period of a
14 year or two, she had more of an opportunity to
15 look at the exemplars and do more work in that
16 area. But I don't know exactly why that is
17 popping up listed as an exemplar then as against
18 before. I really don't.
19 MR. RAWLS: Thank you. That is all
20 we have.
21 And, Ms. Wong, thank you for your
22 presence here today, your coming here voluntarily
23 despite your surgery and the fact that you are
24 experiencing some pain. We appreciate it.
25 THE WITNESS: Thank you.
0280
1 MR. HOFFMAN: Thank you. And, Jim,
2 if there are questions that you want to address
3 either in letter form or whatever way, we will
4 do our best to answer.
5 MR. RAWLS: And we will look forward
6 to getting those written documents in due
7 course. Do you all have an approximate time
8 frame?
9 MR. HOFFMAN: We will get them to
10 you within the next two-week period at the
11 latest. We will try to do it within a week of
12 today.
13 THE WITNESS: Darnay, I haven't had
14 much time after the surgery.
15 MR. HOFFMAN: No, no. I understand.
16 But that is what we would like to do.
17 THE WITNESS: Okay. I will do my
18 best to get it within that time frame. But if
19 not, please give me some leeway.
20 MR. RAWLS: Thank you. Would the
21 witness like to read and sign this deposition?
22 THE WITNESS: Yes, please, I would
23 like to.
24 MR. RAWLS: And we will certainly be
25 glad to stipulate that that signature can be
0281
1 made before any notary.
2 MR. HOFFMAN: And if you want to
3 stipulate that a facsimile copy of the signature
4 in a separate part will be different than an
5 original attached to an original. Okay?
6 MR. RAWLS: Okay. I am ready to go
7 off the record if everyone else is.
8 MR. ALTMAN: Fine.
9 MR. HOFFMAN: Thank you. It has
10 been a pleasure, as always.
11 THE VIDEOGRAPHER: That concludes the
12 deposition at 6:25 p.m.
13 (Whereupon, the deposition was
14 concluded at 6:25 p.m.)
15 .
16 .
17 .
18 .
19 .
20 .
21 .
22 .
23 .
24 .
25 .
0282
1 DESCRIPTION OF EXHIBITS
2 EXHIBIT IDENTIFICATION
3 1 Curriculum Vitae and General
4 Resume of Cina L. Wong
5 2 "The Expert's Course in
6 Handwriting Analysis" brochure
7 3 Printout from The International
8 School of Handwriting Sciences
9 website, www.handwriting.org
10 4 "The History of NWFIA" brochure
11 5 Listing for Cina Wong of
12 appearances as expert witness
13 for depositions and court cases
14 6 Printout from Seraph website,
15 www.seraph.net
16 7 Letter - June 2, 1998 From Mr.
17 Liebman and Ms. Wong to Mr.
18 Grisham
19 8 Letter - November 14, 1997
20 From Ms. Wong to Mr. Hoffman
21 9 Letter - October 31, 1997
22 From Mr. Hoffman to Mr. Miller
23 10 Facsimile - July 30, 1997
24 From Mr. Liebman and Ms. Wong
25 to Jai
0283
1 DESCRIPTION OF EXHIBITS (continued)
2 EXHIBIT IDENTIFICATION
3 11 Affidavit of Cina L. Wong
4 12 Letter - September 28, 1998
5 From Ms. Wong to Mr. Hunter
6 13 Letter - October 2, 1998
7 From Mr. Kane to Ms. Wong
8 14 Letter - October 16, 1998
9 From Ms. Wong to Mr. Kane
10 15 Letter - November 14, 1998
11 From Ms. Wong to The Honorable
12 Bailin
13 16 Letter - January 20, 1999
14 From Mr. Kane to Ms. Wong
15 17 Photocopy of ransom note
16 18 Letter/Report - April 20, 2000
17 From Ms. Wong to Mr. Hoffman
18 (Original exhibits attached to the
19 original transcript.)
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0284
1 STATE OF GEORGIA:
2 COUNTY OF FULTON:
3 I hereby certify that the foregoing
4 transcript was reported, as stated in the
5 caption, and the questions and answers
6 thereto were reduced to typewriting under my
7 direction; that the foregoing pages represent
8 a true, complete, and correct transcript of
9 the evidence given upon said hearing, and I
10 further certify that I am not of kin or
11 counsel to the parties in the case; am not
12 in the employ of counsel for any of said
13 parties; nor am I in anywise interested in
14 the result of said case.
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0285
1 Disclosure Pursuant to Article
2 8(B) of the Rules and Regulations of the
3 Board of Court Reporting of the Judicial
4 Council of Georgia, I make the following
5 disclosure:
6 I am a Georgia Certified Court
7 Reporter, here as a representative of
8 Alexander Gallo & Associates, Inc., to report
9 the foregoing matter. Alexander Gallo &
10 Associates, Inc., is not taking this
11 deposition under any contract that is
12 prohibited by O.C.G.A. 5-14-37 (a) and (b).
13 Alexander Gallo & Associates,
14 Inc., will be charging its usual and
15 customary rates for this transcript.
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19 ALEXANDER J. GALLO, CCR-B-1332
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0286
1 CAPTION
2 The Deposition of Cina L. Wong,
3 taken in the matter, on the date, and at the
4 time and place set out on the title page
5 hereof.
6 It was requested that the deposition
7 be taken by the reporter and that same be
8 reduced to typewritten form.
9 It was agreed by and between counsel
10 and the parties that the Deponent will read
11 and sign the transcript of said deposition.
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0287
1 CERTIFICATE
2 STATE OF :
3 COUNTY/CITY OF :
4 Before me, this day, personally
5 appeared, Cina L. Wong, who, being duly
6 sworn, states that the foregoing transcript
7 of his/her Deposition, taken in the matter,
8 on the date, and at the time and place set
9 out on the title page hereof, constitutes a
10 true and accurate transcript of said
11 deposition.
12
13 Cina L. Wong
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15 SUBSCRIBED and SWORN to before me this
16 day of , 2002 in the
17 jurisdiction aforesaid.
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19 My Commission Expires Notary Public
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0288
1 DEPOSITION ERRATA SHEET
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3 RE: Alexander Gallo & Associates
4 File No. 1637
5 Case Caption: Robert Christian Wolf vs.
6 John and Patsy Ramsey
7 Deponent: Cina L. Wong
8 Deposition Date: May 13, 2002
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10 To the Reporter:
11 I have read the entire transcript of my
12 Deposition taken in the captioned matter or
13 the same has been read to me. I request
14 that the following changes be entered upon
15 the record for the reasons indicated. I
16 have signed my name to the Errata Sheet and
17 the appropriate Certificate and authorize you
18 to attach both to the original transcript.
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20 Page No. Line No. Change to:
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22 Reason for change:
.......

5
7 SIGNATURE:_______________________DATE:___________
8 Cina L. Wong
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