#15, 15 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:24 PM
In response to message #14
1 Q. And by the year 2000, you had only 2 one more exemplar, and that was S4-A? 3 A. That is correct. 4 Q. And where had you obtained S4-A? 5 A. Good question. Maybe Mr. Hoffman 6 can help me with this. 7 MR. RAWLS: Darnay, do you -- 8 MR. HOFFMAN: You know, actually, 9 unless I see it, I am a little confused as to 10 the time sequencing there or whatever. It is 11 possible that it was an exemplar that we had 12 that she has included in her first preliminary 13 report. I know that over this period of a 14 year or two, she had more of an opportunity to 15 look at the exemplars and do more work in that 16 area. But I don't know exactly why that is 17 popping up listed as an exemplar then as against 18 before. I really don't. 19 MR. RAWLS: Thank you. That is all 20 we have. 21 And, Ms. Wong, thank you for your 22 presence here today, your coming here voluntarily 23 despite your surgery and the fact that you are 24 experiencing some pain. We appreciate it. 25 THE WITNESS: Thank you. 0280 1 MR. HOFFMAN: Thank you. And, Jim, 2 if there are questions that you want to address 3 either in letter form or whatever way, we will 4 do our best to answer. 5 MR. RAWLS: And we will look forward 6 to getting those written documents in due 7 course. Do you all have an approximate time 8 frame? 9 MR. HOFFMAN: We will get them to 10 you within the next two-week period at the 11 latest. We will try to do it within a week of 12 today. 13 THE WITNESS: Darnay, I haven't had 14 much time after the surgery. 15 MR. HOFFMAN: No, no. I understand. 16 But that is what we would like to do. 17 THE WITNESS: Okay. I will do my 18 best to get it within that time frame. But if 19 not, please give me some leeway. 20 MR. RAWLS: Thank you. Would the 21 witness like to read and sign this deposition? 22 THE WITNESS: Yes, please, I would 23 like to. 24 MR. RAWLS: And we will certainly be 25 glad to stipulate that that signature can be 0281 1 made before any notary. 2 MR. HOFFMAN: And if you want to 3 stipulate that a facsimile copy of the signature 4 in a separate part will be different than an 5 original attached to an original. Okay? 6 MR. RAWLS: Okay. I am ready to go 7 off the record if everyone else is. 8 MR. ALTMAN: Fine. 9 MR. HOFFMAN: Thank you. It has 10 been a pleasure, as always. 11 THE VIDEOGRAPHER: That concludes the 12 deposition at 6:25 p.m. 13 (Whereupon, the deposition was 14 concluded at 6:25 p.m.) 15 . 16 . 17 . 18 . 19 . 20 . 21 . 22 . 23 . 24 . 25 . 0282 1 DESCRIPTION OF EXHIBITS 2 EXHIBIT IDENTIFICATION 3 1 Curriculum Vitae and General 4 Resume of Cina L. Wong 5 2 "The Expert's Course in 6 Handwriting Analysis" brochure 7 3 Printout from The International 8 School of Handwriting Sciences 9 website, www.handwriting.org 10 4 "The History of NWFIA" brochure 11 5 Listing for Cina Wong of 12 appearances as expert witness 13 for depositions and court cases 14 6 Printout from Seraph website, 15 www.seraph.net 16 7 Letter - June 2, 1998 From Mr. 17 Liebman and Ms. Wong to Mr. 18 Grisham 19 8 Letter - November 14, 1997 20 From Ms. Wong to Mr. Hoffman 21 9 Letter - October 31, 1997 22 From Mr. Hoffman to Mr. Miller 23 10 Facsimile - July 30, 1997 24 From Mr. Liebman and Ms. Wong 25 to Jai 0283 1 DESCRIPTION OF EXHIBITS (continued) 2 EXHIBIT IDENTIFICATION 3 11 Affidavit of Cina L. Wong 4 12 Letter - September 28, 1998 5 From Ms. Wong to Mr. Hunter 6 13 Letter - October 2, 1998 7 From Mr. Kane to Ms. Wong 8 14 Letter - October 16, 1998 9 From Ms. Wong to Mr. Kane 10 15 Letter - November 14, 1998 11 From Ms. Wong to The Honorable 12 Bailin 13 16 Letter - January 20, 1999 14 From Mr. Kane to Ms. Wong 15 17 Photocopy of ransom note 16 18 Letter/Report - April 20, 2000 17 From Ms. Wong to Mr. Hoffman 18 (Original exhibits attached to the 19 original transcript.) 20 . 21 . 22 . 23 . 24 . 25 . 0284 1 STATE OF GEORGIA: 2 COUNTY OF FULTON: 3 I hereby certify that the foregoing 4 transcript was reported, as stated in the 5 caption, and the questions and answers 6 thereto were reduced to typewriting under my 7 direction; that the foregoing pages represent 8 a true, complete, and correct transcript of 9 the evidence given upon said hearing, and I 10 further certify that I am not of kin or 11 counsel to the parties in the case; am not 12 in the employ of counsel for any of said 13 parties; nor am I in anywise interested in 14 the result of said case. 15 . 16 . 17 . 18 . 19 . 20 . 21 . 22 . 23 . 24 . 25 . 0285 1 Disclosure Pursuant to Article 2 8(B) of the Rules and Regulations of the 3 Board of Court Reporting of the Judicial 4 Council of Georgia, I make the following 5 disclosure: 6 I am a Georgia Certified Court 7 Reporter, here as a representative of 8 Alexander Gallo & Associates, Inc., to report 9 the foregoing matter. Alexander Gallo & 10 Associates, Inc., is not taking this 11 deposition under any contract that is 12 prohibited by O.C.G.A. 5-14-37 (a) and (b). 13 Alexander Gallo & Associates, 14 Inc., will be charging its usual and 15 customary rates for this transcript. 16 . 17 . 18 19 ALEXANDER J. GALLO, CCR-B-1332 20 . 21 . 22 . 23 . 24 . 25 . 0286 1 CAPTION 2 The Deposition of Cina L. Wong, 3 taken in the matter, on the date, and at the 4 time and place set out on the title page 5 hereof. 6 It was requested that the deposition 7 be taken by the reporter and that same be 8 reduced to typewritten form. 9 It was agreed by and between counsel 10 and the parties that the Deponent will read 11 and sign the transcript of said deposition. 12 . 13 . 14 . 15 . 16 . 17 . 18 . 19 . 20 . 21 . 22 . 23 . 24 . 25 . 0287 1 CERTIFICATE 2 STATE OF : 3 COUNTY/CITY OF : 4 Before me, this day, personally 5 appeared, Cina L. Wong, who, being duly 6 sworn, states that the foregoing transcript 7 of his/her Deposition, taken in the matter, 8 on the date, and at the time and place set 9 out on the title page hereof, constitutes a 10 true and accurate transcript of said 11 deposition. 12 13 Cina L. Wong 14 . 15 SUBSCRIBED and SWORN to before me this 16 day of , 2002 in the 17 jurisdiction aforesaid. 18 19 My Commission Expires Notary Public 20 . 21 . 22 . 23 . 24 . 25 . 0288 1 DEPOSITION ERRATA SHEET 2 . 3 RE: Alexander Gallo & Associates 4 File No. 1637 5 Case Caption: Robert Christian Wolf vs. 6 John and Patsy Ramsey 7 Deponent: Cina L. Wong 8 Deposition Date: May 13, 2002 9 . 10 To the Reporter: 11 I have read the entire transcript of my 12 Deposition taken in the captioned matter or 13 the same has been read to me. I request 14 that the following changes be entered upon 15 the record for the reasons indicated. I 16 have signed my name to the Errata Sheet and 17 the appropriate Certificate and authorize you 18 to attach both to the original transcript. 19 . 20 Page No. Line No. Change to: 21 22 Reason for change: ....... 5 7 SIGNATURE:_______________________DATE:___________ 8 Cina L. Wong 9 .
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