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
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17
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20
21
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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 .
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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.