25 Q. And you did not give an opinion that
0263
1 it was a certainty that Patsy Ramsey wrote the
2 ransom note; did you?
3 A. Let me understand what you are
4 saying. Can you explain yourself?
5 Q. You used the words highly probable.
6 A. That is correct.
7 Q. You did not say it is plain or
8 clear or definite?
9 A. Well, actually, if you look at my
10 opinions, most people will derive that opinion
11 that Mrs. Ramsey is the person who penned the
12 note.
13 Q. Well, do you feel that you have
14 eliminated all reasonable doubt about whether
15 Patsy Ramsey wrote the ransom note?
16 A. In this case, I highly believe she
17 wrote the note.
18 Q. And please answer my question.
19 A. I am sorry.
20 Q. Do you feel that you have eliminated
21 all reasonable doubt?
22 A. With the people, the possibilities of
23 who could be involved in this case with the
24 three handwriting samples that were given to me
25 and enormous -- the enormous similarities that
0264
1 Patsy Ramsey's handwriting and the note, yes, I
2 believe she is the writer.
3 Q. Well, you believe she is most likely
4 of those three to have authored the note?
5 A. Correct.
6 Q. But those are the only three whose
7 exemplars you have studied?
8 A. But I am also familiar with
9 different types of handwriting since I have
10 looked at many, many, many handwritings and yet
11 have I ever seen so many similarities in one
12 handwriting group.
13 Q. So have you eliminated all reasonable
14 doubt? Can you say with definiteness that Patsy
15 Ramsey did write the note?
16 A. She in some way is very involved.
17 Q. You said she in some way is very
18 involved. Well, she was the mother of the
19 deceased. Now, that is involved; is it not?
20 A. In that sense, yes. With penning
21 the note, she wrote the note.
22 Q. You are sure she wrote the note?
23 A. There is too many similarities
24 pointing to that fact that in this world it
25 would be highly unlikely to find anybody who
0265
1 would have all these similarities, who would
2 have the same and in the same combination.
3 Q. And handwriting analysts can only
4 provide their own opinions about authorship; can
5 they not?
6 A. That is correct.
7 Q. And the opinions of qualified
8 handwriting analysts may differ on the authorship
9 of the same document; might they not?
10 A. At times there are document examiners
11 who may give convenient opinions. I do not
12 give convenient opinions.
13 Q. The opinions of qualified handwriting
14 examiners can vary; can they not?
15 A. At times, yes.
16 Q. And if, indeed, different qualified
17 document examiners from yourself reach the
18 conclusion that it was probable that Patsy
19 Ramsey did not author the note, that would not
20 surprise you?
21 A. I am sorry. You are saying
22 different examiners from myself? I am sorry?
23 Q. If they reach the conclusion that
24 Patsy Ramsey probably did not author the ransom
25 note, that would not surprise you; would it?
0266
1 A. That wouldn't surprise me, but there
2 is Gideon Epstein and Larry Zigler who have also
3 come to the same opinion that I have in this
4 case.
5 MR. RAWLS: I do move to strike the
6 portion of the answer that you have just given
7 us that was not responsive.
8 Q. (By Mr. Rawls) And, Ms. Wong, are
9 you aware Mr. Zigler has withdrawn himself from
10 this case?
11 A. I am aware of that, but that doesn't
12 change his opinion.
13 Q. Well, I don't know whether it
14 changes his opinion or not, but I am afraid we
15 are not going to have the benefit of seeing his
16 opinion.
17 A. Okay.
18 Q. Today we have your opinion that is
19 the subject of our testimony; do we not?
20 A. That is correct.
21 Q. Do you base your opinion on that of
22 Gideon Epstein?
23 A. Oh, no, I do not.
24 Q. Do you base it on that of Larry
25 Zigler?
0267
1 A. I do not base my opinion upon Mr.
2 Zigler's opinion, but I did take a course from
3 Mr. Zigler. And what he teaches is the same
4 of everything that I've studied and all the
5 leading textbooks.
6 Q. And do you base your opinion on that
7 of David Liebman?
8 A. On his opinion? I didn't read his
9 opinion, as I told you. I did my own
10 independent examination in this case.
11 Q. So the answer is no, you don't base
12 your opinion on the opinion --
13 A. Anybody but my own.
14 Q. -- of anybody else?
15 A. That's correct.
16 Q. You base yours on yourself alone.
17 A. That is correct.
18 Q. Correct?
19 Which --
20 A. Well, not just -- I'm sorry. I am
21 not quite understanding what you are saying.
22 That my opinion, based on the examination,
23 correct. I just don't look at it and say,
24 hey, well, I assume this. I just want to make
25 that clear.
0268
1 Q. Do you have in front of you a copy
2 of the ransom note itself?
3 A. Yes, I do.
4 (Defendants' Exhibit-17 was marked for
5 identification.)
6 Q. (By Mr. Rawls) Is Defendants'
7 Exhibit 17 a copy of the ransom note, Ms. Wong?
8 A. Yes, it is.
9 Q. When you first studied this note,
10 did you ever at any point make a study of this
11 note when you had no exemplars at all to
12 compare with it?
13 A. You mean, did I look at -- when I
14 received the note and the exemplars, was there a
15 time when I just looked at the ransom note
16 without the exemplars?
17 Q. Well, that is not exactly my
18 question. Did you have this note, a copy of
19 Defendants' Exhibit 17, before you received any
20 exemplars?
21 A. No. I don't think I had seen this.
22 I knew it was released, but I had not received
23 a copy of it.
24 Q. So at the same time you got this
25 note, a copy of this note, you already had
0269
1 received some exemplars that were said to you to
2 be exemplars of Patsy Ramsey's handwriting; am I
3 correct?
4 A. Yes. They were sent in conjunction
5 with a copy of the ransom note.
6 Q. And did you ever analyze the ransom
7 note independently of any other exemplars?
8 A. Analyze the ransom note for what,
9 because I have nothing to compare it to?
10 Q. Did you analyze it based on all of
11 its contents alone and without regard to whether
12 there might be similarities to some other
13 exemplar?
14 A. Are you asking for content
15 analysis --
16 Q. Yes, exactly.
17 A. -- with regard to linguistics?
18 Q. No. With regard to handwriting?
19 A. Regard to handwriting?
20 Q. Yes.
21 A. No, I didn't look at the note and
22 study it that way.
23 Q. Did you develop a, what I would call
24 a master plan confined to a handwriting analysis
25 of this ransom note alone at any time?
0270
1 A. Oh, you are asking me if there were
2 -- if I was looking for certain similarities
3 which are consistent in the ransom note, what
4 they were?
5 Q. Yes.
6 A. Yes, that is correct. And those
7 same -- that same pattern that you're asking me
8 about the master plan, those same similarities I
9 found in Patsy Ramsey's handwriting.
10 Q. That is not my question.
11 Did you prepare a master plan based
12 solely on the ransom note?
13 A. Not solely on the ransom note.
14 Q. Did you ever prepare a master plan
15 of dissimilarities based solely on the ransom
16 note?
17 A. Well, what you consider in here as
18 -- see, I am not sure what you are getting to
19 because -- okay. I am building a master plan,
20 but I also need to have it compared to
21 something. But within the structure of the
22 ransom note itself, I look for consistencies
23 within there, and anything in here that may
24 vary, you notice that the handwriting is slowly
25 written and is awkward. And according to
0271
1 leading textbooks, that this is a form of
2 disguise, where it is slowed down and it is
3 shaky writing.
4 So some of those items in here that
5 I only see repeated once is only repeated once.
6 So if that is what you want to call a
7 difference. But some things in here only show
8 up once, even though it is written by the same
9 writer.
10 Q. Did you ever make a list confined to
11 the ransom note alone of internal similarities
12 in the handwriting in the ransom note?
13 A. I have a sheet at home where I've
14 circled some things, where certain letter
15 connections keep repeating themselves; but that
16 is about it.
17 Q. And you could show us that list;
18 could you not?
19 A. It is not a list drawn out. It's
20 letters that are circled.
21 Q. It is a copy of the ransom note
22 with letters circled?
23 A. That is correct.
24 Q. And you could show us that; could
25 you not?
0272
1 A. That is correct.
2 Q. We would ask you to do that as well
3 when are you looking back at your file, Ms.
4 Wong.
5 A. Let me make note of that.
6 Q. Good. Please take a moment and feel
7 free to do that, and we appreciate that.
8 A. I'm just not -- you call it the
9 master plan. I use the form of pattern
10 recognition within the system. That is why I
11 was having trouble understanding.
12 Q. I see.
13 A. Sorry. Okay.
14 Q. Are you finished making that note?
15 A. Yes. I just made it under quotes
16 what you called it so I know what you are
17 referring to so when I send it back to you I
18 can use your term.
19 Q. Did you ever make a list of internal
20 differences in the ransom note alone?
21 A. At that moment I was just looking
22 for what was consistent throughout the ransom
23 note. Anything else that I didn't make a mark
24 to, could be an accidental or one-time
25 occurrence.
0273
1 Q. So am I correct that at no time you
2 listed dissimilarities found internally in the
3 ransom note itself?
4 A. I didn't make a physical note of it,
5 but it was a notation I made while I was
6 looking through the note, mental notation.
7 Q. You made mental note of
8 dissimilarities found solely in the ransom note?
9 A. At that time when I was looking at
10 the note; that's correct.
11 Q. But you never committed that mental
12 note or those --
13 A. Notation.
14 Q. -- mental notes to paper?
15 A. That's correct.
16 Q. So there is no way you could show
17 us those?
18 A. It would be really hard.
19 Q. And what is the basic copybook form
20 employed by the author of the ransom note?
21 A. It looks like it is based on the
22 Palmer method.
23 Q. Tell us how you reach that
24 conclusion.
25 A. In the Palmer method, there are
0274
1 different types of ways they would print, and
2 there are two different types of R's available
3 and so forth. I usually have a little form in
4 front of me at home of the copybook version of
5 Palmer and Zaner-Bloser. So as you go through
6 that, and I look at it.
7 Q. Did you ever commit to writing your
8 conclusion that the ransom note was based on the
9 Palmer method?
10 A. No, I did not.
11 Q. And of Patsy Ramsey's exemplars that
12 you studied, what copybook form does Patsy
13 Ramsey use?
14 A. Palmer method.
15 Q. Did you ever commit to writing your
16 conclusion that Patsy Ramsey's exemplars follow
17 the Palmer method?
18 A. No, I did not. The majority of the
19 people in the United States learn from the
20 Palmer method. And currently some are learning
21 Zaner-Bloser, and there is additional, D'Nealin
22 and so forth.
23 MR. RAWLS: Let us just take one
24 minute.
25 THE WITNESS: Sure.
0275
1 MR. RAWLS: We may be getting to a
2 conclusion here pretty soon.
3 THE VIDEOGRAPHER: Going off the
4 video record at 6:13.
5 (A recess was taken.)
6 THE VIDEOGRAPHER: Back on the video
7 record at 6:17.
8 Q. (By Mr. Rawls) Ms. Wong, I have
9 got just a few more questions. Are you able
10 to find among the papers in front of you
11 Defendant's Exhibit 8, please?
12 A. 88?
13 Q. Defendant's Exhibit 8.
14 A. Okay. I'll look for it.
15 Yes, I have it right here.
16 Q. You gave in that document an opinion
17 to Mr. Hoffman in April of the year 2000 about
18 Patsy Ramsey's authorship of the ransom note;
19 did you not?
20 I beg your pardon. I beg your
21 pardon. D-8 is actually 1997; is it not?
22 A. Yes, it is.
23 Q. D-8 was 1997; am I correct?
24 A. That is correct.
25 Q. And let me show you also Defendants'
0276
1 Exhibit 17. I beg your pardon, Defendants'
2 Exhibit 18.
3 (Defendants' Exhibit-18 was marked for
4 identification.)
5 Q. (By Mr. Rawls) Did you later, then,
6 after 1997 give Mr. Hoffman a letter of April
7 20, 2000, which also provided an opinion
8 concerning the authorship of the note?
9 A. Yes.
10 Q. And your opinion was very similar in
11 both November 1997 in Defendants' Exhibit 8 and
12 in April of 2000 in Defendants' Exhibit 18; was
13 it not?
14 A. It is similar.
15 Q. And, in fact, in 1997, your opinion
16 was, and I am referring to the next to last
17 page of Defendant's Exhibit 8, your opinion was
18 that the probability that Patsy Ramsey was the
19 author was 8.5 on a scale of 1 to 10; is that
20 correct?
21 A. That is correct.
22 Q. And by April of 2000, I am looking
23 at page 16 of Defendants' Exhibit 18, your
24 opinion of the probability that Patsy Ramsey was
25 the author had moved to 9.2 on the same 1 to
0277
1 10 scale?
2 A. Yes. In 1997, that was a
3 preliminary report.
4 Q. And in 1997, your report was based
5 exclusively on the exemplars listed as S1
6 through S7; was it not?
7 A. That is correct.
8 Q. And in April of 2000, your report
9 was based on S1 through S7, but additionally you
10 had added S4-A, a color photocopy of a
11 photographed box with, quote, Ramsey Xmas, close
12 quote, printed; is that correct?
13 A. That is correct.
14 Q. And am I correct that, based solely
15 on, in 1997, the documents listed in Defendant's
16 Exhibit 8 as S1 through S7, you reached a
17 conclusion that Patsy Ramsey's probability as the
18 author of the ransom note was greater than a 90
19 percent likelihood?
20 A. In '97 or 2000?
21 Q. In '97.
22 A. I am sorry. In '97. Can you
23 repeat that, please?
24 MR. RAWLS: Would you read that
25 question back, please.
0278
1 (The record was read by the
2 reporter.)
3 THE WITNESS: That is correct.
4 MR. ALTMAN: Are you sure you are
5 saying '97, because I am not sure that is what
6 it said, is '97.
7 THE WITNESS: It is 8.5 on a scale
8 from 1 to 10.
9 MR. ALTMAN: I think he said greater
10 than 90 percent.
11 THE WITNESS: Oh. It is around --
12 it's something like the high eighties, like, 88,
13 89.
14 Sorry. Thank you.
15 Q. (By Mr. Rawls) In fact, in 1999
16 didn't you tell Bill O'Reilly that your
17 conclusion was the probability was 90-plus
18 percent range?
19 A. What year was that?
20 Q. 1999.
21 A. 1999. Yes, I had more time to look
22 at the note.
23 Q. But no more exemplars?
24 A. That is correct. As I mentioned,
25 the 1997 report was a preliminary report.