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.