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.