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.