7 MR. RAWLS: And we would like the
8 actual letter so we will not have to be using
9 reproductions, Ms. Wong, if that can be found,
10 and if Mr. Hoffman and Mr. Altman will agree
11 that it should be produced.
12 MR. HOFFMAN: Yes, if the original
13 can be produced, absolutely. But there's
14 certainly not going to be any prohibition from
15 you introducing it in the event there is a
16 trial because there is a copy. Of course, we
17 will try and give you the original, naturally.
18 MR. RAWLS: Or a Xerox of the
19 original. I am not standing on formality. I
20 don't need to see the original. We are not
21 going to try to hire someone to try to
22 authenticate Michael Kane's handwriting.
23 Q. (By Mr. Rawls) Do you also, Ms.
24 Wong, have a copy of your letter to Alex Hunter
25 of September 28, 1998, which I believe is
0249
1 Exhibit 12?
2 A. I may not have a signed copy. I
3 may just have a printed version in my computer
4 somewhere.
5 Q. But you probably do have a record of
6 that letter?
7 A. Somewhere.
8 Q. And we would like a copy of that as
9 well.
10 Do you have in your files also a
11 copy of the letter which --
12 A. One moment. I am trying to make
13 note of this.
14 Q. Sure. Take your time. I don't
15 mean to rush.
16 A. Okay. Sorry. Go ahead.
17 Q. That's okay. Do you also likely
18 have in your office a copy of Defendants'
19 Exhibit 14, that being the October 16, 1998,
20 letter in which you replied to Michael Kane to
21 Defendants' Exhibit 13, which was his letter of
22 October 2, 1998, to you?
23 A. I may have a copy in my computer.
24 Q. And we would like that as well if
25 that can be found and if Mr. Hoffman and Mr.
0250
1 Altman agree that we can see that copy.
2 And, finally, do you have a copy of
3 your letter which is Defendants' Exhibit 15 to
4 Judge Bailin in your office?
5 A. Probably be in my computer.
6 Q. Good. Do you need to make a note
7 of that?
8 A. I am making a note of that now.
9 MR. HOFFMAN: Again, Jim, I am
10 making notes too.
11 MR. RAWLS: Good. Thank you all.
12 MR. WOOD: Darnay, do you want to
13 take five minutes, maybe, and let Jim organize
14 his --
15 MR. HOFFMAN: Yes, please.
16 MR. RAWLS: I would like about a
17 five-minute break to get organized and try to
18 prioritize what I need to do in the time
19 remaining.
20 MR. ALTMAN: Jim, what I would ask,
21 you said there may be a possibility of a way
22 to get her bags over here if we are going to
23 get close to that 6:30. I think it is going
24 to be a little bit pressed maybe if --
25 THE WITNESS: And I have a question.
0251
1 MR. RAWLS: Let's go off the record.
2 THE VIDEOGRAPHER: Off the video
3 record at 5:33.
4 (A recess was taken.)
5 THE VIDEOGRAPHER: Back on the video
6 record at 5:46.
7 Q. (By Mr. Rawls) Ms. Wong, can you
8 tell us, please, the date of the interview that
9 you did with Hard Copy?
10 Let me just repeat that question
11 after I locate my mike because it seems to have
12 -- let me start that over, please.
13 Ms. Wong, can you give us the date
14 of the interview that you did with Hard Copy?
15 A. No, I don't remember what that date
16 is.
17 Q. Can you give it to us approximately?
18 A. Late '77. I am sorry. Late '97 to
19 '98 or something like that.
20 Q. Thank you. And for now is that the
21 best you can do for us?
22 A. Yes, it is.
23 Q. Do you have anything in your office
24 that would let you pin down the date with more
25 precision?
0252
1 A. I may.
2 Q. Do you have a videotape of your
3 appearance?
4 A. I think I recorded it, and my VCR
5 went on the blitz, so I actually don't have a
6 copy of it.
7 Q. Do you have a calendar entry or a
8 date book or diary entry that might help us
9 learn that date?
10 A. I may.
11 Q. Can you check that when you are
12 looking for some of the other things we've
13 discussed today?
14 A. That is a lot of work. Actually,
15 this is easier, but I will take a look.
16 Q. Thank you.
17 You have, Ms. Wong, have you not,
18 authored an expert report at the request of Mr.
19 Darnay Hoffman and Mr. Evan Altman for this
20 case?
21 A. Yes, that is correct.
22 Q. And in that report, you said that
23 your opinion was given based on well
24 established, I am quoting now, well established
25 and recognized principles of questioned document
0253
1 examination as discussed and defined in the
2 following recognized texts, close quote.
3 Do you recall that language in your
4 report?
5 A. Yes.
6 Q. And I am going to now read the
7 texts which are described in your report.
8 First, Questioned Documents by Albert Osborn;
9 second, Handwriting Examination --
10 MR. ALTMAN: Jim, can you tell us
11 where you are so we can follow along?
12 MR. RAWLS: Yes. This is page 2.
13 This is the February 25, 2002, Forensic
14 Handwriting Report, and this is page 2 of that.
15 And it was furnished to us, Evan, and, Darnay,
16 with a pleading entitled Plaintiff's Disclosure
17 of Expert Testimony.
18 MR. HOFFMAN: Was it a pleading? I
19 think it was just a -- wasn't it just sort of
20 like a pro forma cover with a caption, whatever,
21 all over it?
22 MR. WOOD: Yes. It was not filed.
23 MR. RAWLS: Yes. I am not
24 suggesting when I use the word pleading that it
25 was filed.
0254
1 MR. HOFFMAN: Okay.
2 MR. RAWLS: But it otherwise has the
3 form of a pleading.
4 MR. HOFFMAN: Yeah.
5 Q. (By Mr. Rawls) Okay. The first
6 text on page 2 that you mentioned, Ms. Wong,
7 was "Questioned Documents" by Albert Osborn; is
8 that correct?
9 A. That is correct.
10 Q. The second one was "Handwriting
11 Examination - Facts and Fundamentals" by Huber
12 and Headrick; am I correct?
13 A. That is correct.
14 Q. The next was "Disputed Documents" by
15 Hagin, correct?
16 A. Correct.
17 Q. The next was "Evidential Documents"
18 by Conway?
19 A. That is correct.
20 Q. The next was "Scientific Examination
21 of Documents" by Hilton, correct?
22 A. Correct.
23 Q. The next was "Suspect Documents" by
24 Harrison?
25 A. That is correct.
0255
1 Q. And are those texts all of the texts
2 which you have relied upon as furnishing the
3 well established and recognized principles of
4 questioned document examination which you have
5 relied on in authoring your report?
6 A. Yes. There are more of these, but
7 these I thought were most representative.
8 Q. And these are some of the most
9 reliable textbooks in the questioned document
10 examination field; are they not?
11 A. They are the most respected. For
12 instance, the Osborn book is 73 years old. So
13 there are a lot of things missing and a lot of
14 things that need to be amended that I changed
15 over time. And also with Harrison, a lot long
16 past. There are some things in there that are
17 correct, but there are other things that need to
18 be amended.
19 Q. And you have not relied on anybody
20 else's textbook in coming up with the principles
21 that you base this report on; have you?
22 A. As I mentioned earlier, I used other
23 textbooks; but these are the ones that are most
24 representative, and I mentioned these.
25 Q. And do you possess each of these
0256
1 textbooks in your office?
2 A. Yes, I do.
3 Q. And you brought with you some books
4 here today; did you not?
5 A. I just brought one.
6 Q. And what is that book, please?
7 A. It is a new book by Katherine
8 Koppenhaver, and actually it is quite coming to
9 be one of the most respected books very quickly.
10 It is "An Attorney's Guide to Document
11 Examination."
12 Q. Is this the individual who is part
13 of NADE?
14 A. That is correct. She is currently
15 president. She is past president and current
16 president.
17 Q. Okay. She has been elected to two
18 terms as president of NADE; is that correct?
19 A. That is correct.
20 Q. Can you give us the Library of
21 Congress publication data, please, on that book?
22 A. The ISBN number?
23 Q. Yes.
24 A. Is 1-56720-470-8.
25 Q. And inside the front cover, could
0257
1 you turn to the title page, please?
2 A. This one?
3 Q. Yes. On the back of the title
4 page, do you find publication information?
5 A. Yes.
6 Q. And who is the publisher, and what
7 is the copyright date, please?
8 A. Copyright is 2002. And the
9 publisher is Quorum, that's Q-U-O-R-U-M, Books.
10 Q. Thank you. May I take a quick look
11 at it, please?
12 A. Sure. I am borrowing that copy
13 right now.
14 Q. You have an autographed first
15 edition; do you not?
16 A. Actually, it is Mr. Liebman's copy.
17 I ordered mine. I wanted to read on it
18 quickly, so he was kind enough to let me borrow
19 it.
20 Q. And now we are sitting here on May
21 13, 2002; are we not?
22 A. That is correct.
23 Q. And this book says it was first
24 published in 2002?
25 A. That is correct.
0258
1 Q. And you said this is fast becoming
2 one of the most respected textbooks?
3 A. That is correct. It came out
4 earlier this year, and a lot of people are
5 reading it. And it is put together very well.
6 Q. It had to work pretty fast to become
7 so well --
8 A. Well, I mean --
9 Q. -- respected; did it not?
10 A. -- a lot of people are reading it.
11 Q. How many copies has it sold?
12 A. That is a good question. I am not
13 sure. You'd have to ask Ms. Koppenhaver.
14 Q. And what are the other items that
15 you have brought with you here today, Ms. Wong?
16 The video camera, I am sure, has picked up the
17 fact that you have a notebook and several papers
18 in front of you.
19 A. Yes. I have my notebook with me
20 with demonstrative evidence. I have copies of
21 your expert's reports. And I also have copies
22 of some of the exemplars that were used in this
23 case.
24 Q. Are you, Ms. Wong, aware that the
25 Colorado Bureau of Investigation did obtain
0259
1 studies and analyses with respect to the ransom
2 note that was left in connection with the
3 JonBenet Ramsey death from a number of document
4 examiner experts? Did you know that?
5 A. No. It was -- you are saying that
6 they did a lot of tests and analyses?
7 Q. I was asking whether you were aware
8 that the Colorado Bureau of Investigation asked
9 several handwriting and document examiner experts
10 to study the JonBenet Ramsey ransom note?
11 A. I know they were having some
12 document examiners examine the note. That was
13 actually published in the media.
14 Q. Do you know who some of those
15 experts were that were hired by the Colorado
16 Bureau of Investigation?
17 A. Personally, no.
18 Q. Can you name any of them here today
19 before I name a few?
20 A. Oh, Mr. Ubowski and Mr. Riles. And
21 those are the only two I am familiar with at
22 this moment.
23 Q. Have you heard of Leonard Speckin,
24 S-P-E-C-K-I-N?
25 A. Is that of Speckin Laboratories up
0260
1 in Michigan?
2 MR. WOOD: Yes.
3 Q. (By Mr. Rawls) Yes, he is.
4 A. Yes.
5 Q. Is he a qualified questioned document
6 examiner, in your opinion?
7 A. I am not familiar with him. I am
8 familiar with -- is it Leonard the owner? Is
9 he the father? I am familiar with the son.
10 Q. Okay. All right.
11 A. The son has come to the NADE
12 conferences, and he has spoken at our
13 conferences, and he will be -- or their firm
14 is, actually -- will be speaking at a NADE
15 conference coming up in the next couple of
16 weeks. But due to my health condition, I am
17 not able to go.
18 Q. Do you have any understanding of
19 Leonard Speckin's conclusion about authorship of
20 the ransom note, and specifically about whether
21 Patsy Ramsey wrote the note?
22 A. No, I do not.
23 Q. Have you heard of Edwin Alford?
24 A. Oh, he is in Baltimore; isn't he?
25 Baltimore, Maryland?
0261
1 Q. I am not sure.
2 A. Oh, okay. Edwin -- well, I know an
3 Alford, but I am not sure if it is the same
4 one, so I won't say.
5 Edwin or Alfred?
6 Q. Edwin Alford, A-L-F-O-R-D.
7 A. I am not sure if it is the same
8 one, so I am not sure if I'm familiar if that
9 is the correct person or not I am thinking of.
10 Q. Do you know Richard Dusick or have
11 you heard of him?
12 A. No.
13 And I am sorry, going back to Mr.
14 Alford, I have seen his name referred to in
15 some articles. That is where I am familiar with
16 his name.
17 Q. Would you be surprised to know that
18 the Colorado Bureau of Investigation obtained
19 several reports from handwriting analysts that
20 the Colorado Bureau of Investigation considered
21 to be well qualified, and several of those
22 experts concluded that Patsy Ramsey probably did
23 not author the ransom note? Would you be
24 surprised if that is accurate?
25 A. I am not surprised of the opinion.
0262
1 I am not sure about what approach they used or
2 so forth to come to their opinion.
3 Q. Different qualified document examiners
4 can reach different conclusions about authorship
5 of a questioned anonymous document; can they
6 not?
7 A. At times. But basically all
8 document examiners study the same texts, and it
9 also depends on their training. A lot of --
10 from what I am told, a lot of document
11 examiners that go into government document
12 examination jobs, they are trained by other
13 document examiners who have had a few short
14 courses and they are busy working, and so they
15 are learning from people and who may not go out
16 as often and go to certain conferences and
17 certain seminars and so forth.
18 Q. You concluded in your report, quote,
19 and this is page 4 of the February 25, 2002
20 report that you gave Mr. Hoffman and Mr. Altman,
21 you concluded: Quote, it is highly probable that
22 Patsy Ramsey wrote the ransom note, end quote.
23 Am I correct?
24 A. That is correct.