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.