22 Q. Apart from the one or two cases with
23 the Commonwealth Attorney and the one case with
24 the U.S. Probation Office, have you ever been
25 retained by any government agency at the federal
0037
1 level, at the state level, or the county or
2 city level?
3 A. No. Usually they have their own
4 document examiners. Like I say, it is only
5 when they can't have anybody within their system
6 do it do they go outside.
7 Q. Have you ever been employed as a
8 document examiner by any government agency?
9 A. No, I have not.
10 Q. Ms. Wong, can you give us a
11 definition of graphology, please?
12 A. Yes. Graphology is when -- where
13 people study handwriting specifically for the
14 purpose of learning how to determine someone's
15 personality from their handwriting.
16 Q. And on your resume, if you would
17 turn with me to page 2, under Training, the
18 first thing you list is the, quote,
19 International School of Handwriting Sciences, end
20 quote; is it not?
21 A. Yes, that is correct. There are two
22 portions to that school. There is a portion to
23 the school where Mr. Widmer teaches document
24 examination, and there is a second portion of
25 his school where he does teach graphology.

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jameson
Member since 5-8-02
08-15-02, 04:19 PM (EST)

2. "3 Cina Wong depo"
In response to message #1


0038
1 Q. And Mr. Widmer is a graphologist; is
2 he not?
3 A. He is a document examiner and a
4 graphologist.
5 Q. And by whom is he certified as a
6 document examiner?
7 A. He is not certified. He doesn't
8 belong to any of the document examination
9 groups. He's read all the texts in the field,
10 the leading texts that all document examiners
11 read.
12 Q. And are you a graphologist?
13 A. No. Certainly not.
14 Q. Why do you say certainly not?
15 A. I have looked into it because, as
16 anybody who deals in the field of handwriting
17 sciences, you should look into all aspects of
18 handwriting and study all of it in order to
19 give a comprehensive analysis or speak about it.
20 There are lots of document examiners, I should
21 say, out there who say things about graphology
22 when they don't even know anything about it.
23 How can you speak about something fluently
24 without knowing? So I looked into it. I
25 don't see that there is any validity to it. A
0039
1 lot of people disagree with me. But my area
2 is strictly in document examination.
3 Q. You refer in your CV, this again is
4 Defendant's Exhibit 1 on page 2, and this is
5 immediately under the International School of
6 Handwriting Sciences, you refer to, quote, a
7 six-month program --
8 A. Yes.
9 Q. -- in Handwriting Sciences, end
10 quote.
11 Did you get a diploma?
12 A. I don't think he issued a diploma,
13 no.
14 Q. Did you get a degree?
15 A. Not a degree, no.
16 Q. Did you get a grade?
17 A. No. Probably I have a certificate
18 of completion, but that would be about what we
19 received.
20 Q. So in those six months, was this a
21 full-time educational curriculum?
22 A. It was once a week.
23 Q. Once a week. Which day of the
24 week?
25 A. You are asking me to think back 12
0040
1 years. I can't remember. I am sorry. I know
2 it was a weekday.
3 Q. And in that once-a-week program, how
4 long were you there the day you were there each
5 week?
6 A. Anywhere from four to five hours.
7 Q. What did you pay for that course?
8 A. I can't remember. It was a while
9 ago.
10 Q. Did you do a term paper in that
11 program?
12 A. No, we did not.
13 Q. Did you submit handwriting analyses
14 for feedback?
15 A. I am sorry. I don't understand your
16 question.
17 Q. Well, in the course of this
18 six-month program, which we've learned was a
19 once-a-week program, four to five hours on that
20 one day a week, were you asked to complete a
21 document analysis and to submit it for review
22 and feedback?
23 A. I am not quite sure what you are
24 saying. But we were asked to bring in
25 handwriting samples; and we would look at them
0041
1 and study them for slant, proportion, placement,
2 letter forms; and that is what we did.
3 Q. Did you demonstrate to Mr. Widmer or
4 anyone else your analysis so that you could
5 obtain feedback and his judgment on whether you
6 were right or wrong?
7 A. Oh, you mean like a personality
8 analysis? I didn't partake in that. I was
9 there for the information with regards to
10 learning the basics, because I was -- there is
11 certain overlap with graphology and document
12 examination strictly with the fact that it has
13 to do with the formations and angles and initial
14 strokes and terminal strokes and letter
15 formations. And otherwise, that is where it
16 stops.
17 Q. Now, the second entry under Training
18 in your resume, and again I am still on page 2
19 of Defendant's Exhibit 1, you list again
20 International School of Handwriting Sciences.
21 And this time your CV tells us of your
22 completion of an advanced course in Questioned
23 Document Examination.
24 A. Uh-huh (affirmative).
25 Q. And according to your resume, this
0042
1 involved forgery detection, case studies,
2 hands-on equipment operation technique, and court
3 qualification procedures.
4 Have I accurately read your CV?
5 A. Yes, that is correct.
6 Q. How long was this advanced course?
7 A. I believe it was over four days,
8 three or four days. It was all day. Or it
9 was eight or ten hours. It was a very intense
10 course.
11 Q. And since Mr. Widmer has no
12 certification as a document examiner, I assume
13 this course was taught by someone else?
14 A. No. There is no standard in this
15 field where you need certification, but Mr.
16 Widmer has studied all the texts in document
17 examination, and he was the one that was
18 teaching the course.
19 Q. So Mr. Widmer taught the six-month
20 program in handwriting sciences as well as the
21 advanced course for three to four days in
22 questioned document examination; am I correct?
23 A. That is correct.
24 Q. Was there anyone that came in to
25 assist Mr. Widmer as a faculty member for those
0043
1 three to four days?
2 A. If my memory serves me right, I
3 think he had assistance from Mr. Marcel Matley.
4 Q. Can you spell that, please?
5 A. Yes, Matley, M-A-T-L-E-Y.
6 Q. Was Mr. Matley a certified document
7 examiner?
8 A. He is certified now through the
9 National Association of Document Examiners.
10 Q. When you say he is certified now,
11 does that mean he was not certified at the time
12 he assisted in teaching this course in 1991?
13 A. That is correct. But he is well
14 read in the field, and he is also well
15 published in the field.
16 Q. What has he published?
17 A. He has published an index that
18 covers all the articles that deal with document
19 examination. He has a book on sequential
20 handwriting. He has a book on forgery
21 detection. Quite a few others that I have in
22 my library that are all document examination
23 related.
24 Q. Now, in 1991, according to the next
25 entry under Training in your CV, you have
0044
1 experience or had a course of study in Signature
2 Identification also in San Francisco; am I
3 correct?
4 A. Yes, that is correct.
5 Q. And according to your resume, this
6 was a study of various techniques used to verify
7 signatures, recognizing different forms of forged
8 signatures, use of equipment to aid in
9 handwriting ID. Am I correct?
10 A. That is correct.
11 Q. How long was this course?
12 A. This course, I believe, it was three
13 days.
14 Q. Who taught that course?
15 A. That was taught by Marcel Matley.
16 Q. Were those full days?
17 A. Yes, definitely.
18 Q. The next course listed is the
19 Effects of Health on Handwriting. This is said
20 to have taken place in Sunnyvale, California.
21 A. That's correct.
22 Q. Is that correct?
23 A. It is near San Jose, Silicon Valley.
24 Q. How long was that course?
25 A. That was a day, full day.
0045
1 Q. And according to your resume, this
2 was taught by Patricia Wellingham-Jones?
3 A. Yes. She is a nurse.
4 Q. And your resume says she is an
5 expert in identifying health related conditions
6 and medications affecting handwriting?
7 A. Yes. She has written a book about
8 that. The course that she taught that day, she
9 had done some research work with regards to how
10 someone with an IV in their arm would affect
11 their signature or not, and different hospital
12 forms when people fill them out where they may
13 look like it is not their signature when, in
14 fact, it is, due to stress conditions or
15 medication.
16 Q. Then, according to your resume, you
17 had advanced training with David Liebman, whose
18 name you have mentioned before as formerly
19 someone with whom you worked?
20 A. That is correct.
21 Q. And according to your resume, this
22 was, this advanced training was in a mentorship
23 program offered by the National Association of
24 Document Examiners.
25 Can you describe, please, how that
0046
1 association offered a mentorship program?
2 A. Yes. There were certain senior
3 members who often -- NADE is an association that
4 is open to all people of all levels of document
5 examination. So whether a person who has been in
6 the field for a long time or if someone is
7 just a student or if someone is just interested
8 in the field of document examination can join
9 NADE. And from there -- there are very few
10 organizations that are open to students where
11 they can receive more information and learn
12 about the field of document examination. And at
13 that time, NADE did offer an advanced mentorship
14 program in document examination where you work
15 hands-on with a document examiner.
16 Q. And how long was this advanced
17 training that you took with Mr. Liebman?
18 A. It was three years, all practically
19 five days a week.
20 Q. Was this more or less on-the-job
21 training?
22 A. Yes, that is correct.
23 Q. Were you paid for that work?
24 A. No, I was not.
25 Q. Did you pay Mr. Liebman for that
0047
1 training?
2 A. No, I did not.
3 Q. Would you receive advanced training
4 by assisting Mr. Liebman in his work as a
5 document examiner? Is that what that program
6 was all about?
7 A. No. I did not assist him with his
8 work. We would -- when cases would come in, I
9 would work on it independently. And then after
10 I finished all my work, I would hand the folder
11 to him with the documents, and he would do his
12 work independently.
13 And then afterwards, he would look
14 at my notes to see how I went through my
15 systematic analysis, and he would critique what
16 I did.
17 And sometimes there were cases that
18 came in that we would need infrared lighting and
19 so forth, and that is something I didn't know
20 at the time, and I learned that through Mr.
21 Liebman.
22 Q. Were you yourself, from 1992 to 1995
23 when you were in this advanced training
24 mentorship, were you taking assignments yourself
25 for a fee from clients?
0048
1 A. I was not working by myself at that
2 time. Towards the end of the program, Mr.
3 Liebman, he was satisfied with my work, and he
4 felt very comfortable with everything that I
5 have learned and how I was proceeding, so I was
6 receiving some money from certain cases.
7 Q. And then you sought and received
8 your board certification from NADE; am I
9 correct?
10 A. That is correct.
11 Q. Is the International School of
12 Handwriting Sciences an accredited university?
13 A. No, it is not.
14 Q. Does it have any accreditation from
15 any organization?
16 A. Not that I am aware of.
17 Q. Is it accredited by the NADE?
18 A. NADE does not accredit any schools
19 or associations, so it wouldn't.
20 Q. What are the entrance requirements
21 for the International School of Handwriting
22 Sciences?
23 A. If you have an inteher -- you know, if someone is interested in
25 the graphology portion, they can pay a fee and
0049
1 learn that portion. And if you are interested
2 in their document examination section, then you
3 take those courses and pay a fee to learn that
4 information.
5 Q. So the entrance requirements are none
6 except payment of a fee?
7 A. I am sorry?
8 Q. The entrance requirements for the
9 international School of Handwriting Sciences --
10 A. Yes.
11 Q. -- involves simply the payment of a
12 fee?
13 A. If you are interested in it at
14 first, yes. And then you pay a fee to learn;
15 that is correct.
16 Q. No one is going to pay a fee who is
17 not interested?
18 A. I hope not.
19 Q. And there is no application process?
20 A. No, there is not.
21 Q. The payment of a fee is all that is
22 required for entrance into the course?
23 A. That is correct.
24 Q. And to the best of your knowledge,
25 no one is rejected from the course of study who
0050
1 has paid the fee?
2 A. Not that I am aware of.
3 Q. How many people were present with
4 you in this once-a-week program for approximately
5 six months?
6 A. Good question. Probably, I would
7 say, ten to 15.
8 Q. How many of them had a college
9 degree?
10 A. Oh, I am not sure about that.
11 Q. The six-month program which was
12 attended once a week for four to five hours
13 each week, is that the graphology part of your
14 education?
15 A. No. It is part graphology, and it
16 is part that has to do with document
17 examination.
18 Q. Am I correct that the word
19 graphology is not found on your resume?
20 A. That is correct, because I am not a
21 graphologist. I would not be able to tell
22 anyone's personality from their handwriting if my
23 life depended on it, so you would have to just
24 shoot me.
25 Q. Ms. Wong, I am going to try to
0051
1 avoid --
2 A. Shooting me.
3 Q. -- shooting you, regardless of any
4 reaction we may have to your testimony.
5 A. All right. Thank you.
6 Q. Am I correct that for purposes of
7 your effort to obtain credibility as a document
8 examiner you prefer to disassociate yourself from
9 your graphology studies?
10 A. There are many things -- I am not
11 quite sure how to answer that, what you are
12 asking. But there are many things I have
13 learned in the past. Just because I learned
14 gardening and I don't do it very well or I
15 don't practice it doesn't mean that, oh, well,
16 since I studied it at one time, then I must be
17 a gardener. I don't practice graphology. I
18 don't use it.
19 And I am strictly a document
20 examiner, and I identify and authenticate
21 handwriting.
22 Q. And graphology does not have a lot
23 of credibility among document examiners; does it?
24 A. That is correct.
25 Q. And consequently, to be a or to seek
0052
1 to be a credible document examiner, I am
2 correct, am I not, that you wish to disassociate
3 yourself from your graphology study?
4 A. That is not true. I don't deny it.
5 To be anybody who -- as I mentioned, to be
6 well versed in the field of document
7 examination, you should look at everything that
8 deals with handwriting sciences, because if you
9 don't then you are missing and lacking in a
10 certain area of your studies.
11 In order to be a good scientist, you
12 have to research all areas. And that is what
13 I did in this case. It doesn't mean I believe
14 it, but I researched it.
15 (Defendants' Exhibit-2 was marked for
16 identification.)
17 Q. (By Mr. Rawls) Ms. Wong, Mr. Gallo
18 has just handed you a brochure which has been
19 marked Defendants' Exhibit 2, and I have given
20 Mr. Altman a copy of that and I am looking at
21 a copy.
22 Can you identify that, please, for
23 the record?
24 A. Yes. I haven't seen this before.
25 It is a brochure. I assume it is new. It is
0053
1 titled the International School of Handwriting
2 Sciences.
3 Q. As you look at that, please, would
4 you tell me whether any of these lessons -- and
5 you will see the lessons listed as the ten
6 lessons.
7 A. Okay.
8 Q. Do you see that column?
9 A. Yes.
10 Q. This is essentially, for the record,
11 of course, the video is showing you looking at
12 the brochure. But it is a fold-up paper that
13 contains about eight columns, four on one side
14 and four on the other; am I correct?
15 A. You mean on this side or the back?
16 Q. Four on each side?
17 A. Oh, four on each side. Yes, that
18 is correct.
19 Q. And the ten lessons, do you see that
20 list on the far left side of what I take to be
21 the back page?
22 A. Yes.
23 Q. And tell us if you had any of those
24 ten lessons, please, where you took the courses
25 in 1990 and 1991 out in California.
0054
1 A. Okay. The first one is Use of
2 Space. And that covers how a person uses a
3 piece of paper in regards to margin area, which
4 is something that's used in document examination.
5 How far they start from the top of the paper
6 and how they use this -- how much margin they
7 leave on the side.
8 The Size of the Writing. That is
9 common sense, large and small.

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jameson
Member since 5-8-02
08-15-02, 04:19 PM (EST)

3. "4 Cina Wong depo"
In response to message #2


10 Q. As you tell us about each of these
11 ten --
12 A. Yes.
13 Q. -- tell us whether you took that
14 course of study.
15 A. Well, it is interesting, because what
16 he writes underneath is nothing I remember.
17 It says Use of Space, how these
18 principles alone can give you a surprising
19 in-depth analysis.
20 On what I am not sure.
21 The Size of the Writing, how people
22 feel about themselves and others.
23 I don't remember that. I just know
24 size of writing with regards to document
25 examination.
0055
1 The Zonal Principle. How to tell
2 how self actualized someone is.
3 I don't remember that. But I
4 remember zones with regards to upper zones of
5 the handwriting, which would include the upper
6 portions of the lower case H's, top portions of
7 L's and so forth. Lower zones would be the
8 bottom parts of small G's and small Y's.
9 Left and Right Tendencies with Slant.
10 In documentation examination we study different
11 types of slants. His explanation is: Universal
12 concepts that allow you to develop insights in
13 any writing.
14 I don't remember that, and it
15 doesn't make any sense to me.
16 Connective Forms. That is very
17 important in document examination. It shows if
18 something is -- a connection stroke is if it is
19 curved or if it is angular or if it is arcade.
20 Mr. Widmer writes on here: How these show
21 strong indications of personality types and
22 attitudes towards the people and other people.
23 I don't know what to make of that.
24 Pressure. That is something document
25 examiners study. An example is someone who,
0056
1 when they write, when they press very hard into
2 a paper when they write leave deep impressions
3 as opposed to when someone writes with a lighter
4 hand. Mr. Widmer says here: With pressure, a
5 third dimension of handwriting and even what the
6 choice of writing implement can tell about
7 someone.
8 I don't remember covering that, but
9 I remember the heavy and light pressure and
10 medium pressure and varied pressure within
11 writing.
12 Let's see, For Those Who Print, he
13 writes: For those of you that thought you
14 could not analyze printed writing, you better
15 know this because most people today print.
16 All I remember from that course were
17 some unusual printing styles, but I don't
18 remember what the personality aspect that was
19 derived from printing.
20 Specific Letter Formations, he
21 mentions Alphabet from A to I -- A to some --
22 well, some totally different approach to
23 individual letter formations, the most important
24 letter in the alphabet.
25 I don't know what that is about, but
0057
1 I saw some very unique -- he has an array of
2 samples in his file of interesting letter
3 formations that as a document examiner you need
4 to be exposed to a lot of handwriting in order
5 to figure out what exactly is part of a class
6 characteristic or an individual characteristic of
7 writing.
8 Specific Letter Formations. Doesn't
9 say anything about that. But that also had to
10 do with different letter formations.
11 And Form Level. Form level has to
12 do with the capability in document examination
13 how if they write in the higher form level or
14 a lower, more, I hate to use the word,
15 uneducated form level, someone who is not adept
16 at using the pen or pencil very well. And
17 someone who writes very poorly can't write
18 better than they can write. And not only that
19 was taught in this class, and that is also
20 taught in document examination.
21 And Mr. Widmer has here under Form
22 Level: Taking intuition out of handwriting
23 analysis and putting it all together.
24 So, I don't know.
25 Q. Thank you. We have been going just
0058
1 over an hour. Is this a convenient time for a
2 short recess?
3 A. Yes. I have been trying to hold
4 the best I can. So, yes, this would be great.
5 Q. Good.
6 A. Thank you.
7 THE VIDEOGRAPHER: Going off the
8 video record at 10:56.
9 (A recess was taken.)
10 THE VIDEOGRAPHER: Back on the video
11 record at 11:11.
12 MR. RAWLS: Evan and Darnay, I had,
13 I believe in an exchange of e-mails, advised you
14 all that at the deposition we would have a
15 check in payment of the expense sum of money
16 which you all had told us about for Ms. Wong's
17 expenses. And, Evan, if I may deliver that
18 check to you now.
19 MR. ALTMAN: Thank you. Sure.
20 MR. RAWLS: I had intended to bring
21 it earlier today.
22 MR. HOFFMAN: Thank you. And just
23 while we're on that subject, I just received
24 your costs on that other case involving Linda
25 Hoffman-Pugh, and that is being sent out to you.
0059
1 And I am assuming that should be sent to your
2 office or to Lin's.
3 MR. RAWLS: My office is fine,
4 Darnay. Thank you.