5 MR. HOFFMAN: Should it be made to
6 your firm or to an individual?
7 MR. RAWLS: To the firm.
8 MR. HOFFMAN: Thank you.
9 MR. RAWLS: Alex, would you please
10 mark this as Defendants' Exhibit 3?
11 Evan, here is a copy for you.
12 (Defendants' Exhibit-3 was marked for
13 identification.)
14 Q. (By Mr. Rawls) Ms. Wong, Mr. Gallo
15 has just handed you a copy of what we have
16 marked Defendants' Exhibit 3. And I will tell
17 you that we received, we had these printed off
18 of the internet, and they are pages on what we
19 understand to be the website of the
20 International School of Handwriting Sciences.
21 Are you familiar with any of these pages?
22 A. No. I haven't seen these before,
23 but I know Mr. Widmer is no longer teaching
24 document examination. He found that it wasn't
25 lucrative. There weren't many people interested
0060
1 in learning about document examination, and he
2 is strictly teaching graphology now. I haven't
3 seen any of the literature. But I had heard
4 from him that he had put together a course,
5 which is what you presented to me today in the
6 brochure and in the internet, what you printed
7 out from the internet.
8 Q. Would you please turn to the second
9 page of the Defendants' Exhibit 3 which Mr.
10 Gallo just gave you. And this is a page that
11 at the top says it is about ISHS.
12 A. Okay.
13 Q. If you would look with me, please,
14 at a sentence that begins in the second
15 paragraph. And the sixth line of the second
16 paragraph --
17 A. Starting with?
18 Q. -- there is a sentence beginning,
19 quote, The introductory class emphasizes basic
20 principles of graphology.
21 Did you take such a class?
22 A. He spoke about graphology within the
23 course that I took.
24 Q. Okay. And --
25 A. But I am not sure if this is the
0061
1 class.
2 Q. You don't know if it is going to be
3 the same class as described here?
4 A. Like, because he has a whole new
5 program, so I am not sure what it is. I am
6 not familiar with this.
7 Q. Then going on in the same sentence,
8 this paper states: The intermediate class
9 stresses the relationship of graphology to
10 psychology.
11 Did you take such a class?
12 A. No, I don't remember -- I took
13 advanced document examination class. I don't
14 remember taking anything like this.
15 Q. And the same sentence goes on to
16 say: And the advanced class introduces the
17 student to a system called the personality
18 flowchart --
19 A. Okay.
20 Q. -- end quote. Did you take a
21 class, any class at all about the personality
22 flowchart?
23 A. I don't remember that. That must be
24 new. I see the copyright symbol there also.
25 Q. Yes, and the personality flowchart
0062
1 has a small copyright symbol near it which
2 indicates that perhaps ISHS has copyrighted that
3 name or course?
4 A. Probably.
5 Q. But that is new to you; is that
6 correct?
7 A. Oh, yes, it is.
8 Oh, he still offers his questioned
9 document class. Good.
10 Q. Did you take the course of study
11 with the ISHS in person or from home study?
12 A. In person. I lived in the San
13 Francisco Bay area. I heard that this home
14 study is something new within the past year or
15 so.
16 Q. And if you would turn with me for a
17 moment, please, back to Defendant's Exhibit 1,
18 which is, again, your resume?
19 A. Yes.
20 Q. We spoke briefly earlier about the
21 course in Sunnyvale taught by Patricia
22 Wellingham-Jones, who you had told us is a
23 nurse, on effects of health on handwriting?
24 A. Right. And she also is involved in
25 handwriting, and she is a nurse.
0063
1 Q. Was that course on effects of health
2 on handwriting, was that part of the ISHS
3 school?
4 A. No. That is separate.
5 Q. Was this something that you paid
6 for?
7 A. Yes, that is correct.
8 Q. And would you say that Ms.
9 Wellingham-Jones gave a course on graphology to
10 you during that one-day program?
11 A. No. She just spoke about her
12 studies and her research with regards to the
13 effects of health on handwriting and about her
14 IV research. I did find out, actually just
15 recently I was posed a question whether she was
16 a graphologist or not, and I didn't realize
17 that, and someone had informed me that she was.
18 But I did not know that at the time when I
19 took her course.
20 Q. Okay. Let's, and with further
21 reference to your resume, Defendant's Exhibit 1,
22 let's move on down to page 2 to the last group
23 of entries on the page. And this has to do
24 with what your resume states is, quote,
25 Completion of college level course in questioned
0064
1 documents, end quote, at Northern Virginia
2 College?
3 A. That's correct.
4 Q. Did you enroll in Northern Virginia
5 College in order to take this course?
6 A. Yes.
7 Q. And for how long did you enroll?
8 A. Oh, it is just specifically for this
9 course. I filled out papers. I am not sure.
10 I can't remember. You mean enroll and I had
11 to send in my transcripts from my previous
12 college and so forth?
13 Q. Yes.
14 A. Yeah. I can't remember if I had to
15 do that. I just remember signing up for the
16 course. I am not sure what type of application
17 I had to fill out. I may have.
18 Q. So whatever enrollment or application
19 you did with Northern Virginia College, it was a
20 one-course effort only?
21 A. That is correct.
22 Q. And this was the course, that is,
23 Mr. Zigler's course on questioned documents?
24 A. Yes. I was specifically interested
25 in his course. And Mr. Zigler is a well
0065
1 respected document examiner in the whole field.
2 Q. How many days a week did you attend
3 this class with Larry Zigler?
4 A. Actually, in the usual course where
5 it took place actually on the weekends. I
6 think it was Friday, Saturday or Saturday,
7 Sunday. I can't remember.
8 But it went on for two or three
9 weeks. And though graphology was not taught in
10 this class, because it was strictly document
11 examination, Mr. Zigler has taught courses to
12 FBI and Secret Service agents with regard to
13 graphology because he knows it is important for
14 all the agents that are involved in document
15 examination to have a well-rounded information in
16 handwriting sciences.
17 Q. And on the weekends, how long each
18 day did you spend in this course?
19 A. It was a full day.
20 Q. So this was two full days during how
21 many weekends?
22 A. It was either two, three, or four.
23 I can't remember exactly.
24 Q. So this was a total, this class with
25 Larry Zigler took a total of either four, six,
0066
1 or eight days --
2 A. That is correct.
3 Q. -- to complete?
4 A. Yes.
5 Q. And were you graded in this course?
6 A. I don't believe we were, but we
7 received a certificate of completion.
8 Q. Did you receive college credit for
9 this course?
10 A. Good question. I don't know. I
11 wasn't interested in the college credit. I was
12 just interested in taking the course.
13 Q. Northern Virginia College's exact name
14 is Northern Virginia Community College; am I
15 right?
16 A. That could be correct. I am sorry.
17 You said it was Northern --
18 Q. Virginia Community College.
19 A. Okay. It could be. I just know
20 they call it Annadale College.
21 Q. Did you receive at any time any
22 degree from that college?
23 A. No, I did not.
24 Q. When you say that Mr. Zigler's
25 course was a college level course, what do you
0067
1 mean by that?
2 A. He taught it at the college to --
3 there were other college students involved.
4 There were about 25, 25 or 28 college students
5 in there along with some document examiners.
6 Q. And there were some people there
7 such as yourself who were not college students
8 at all?
9 A. That is correct.
10 Q. Were the students that were, in
11 fact, trying to get some form of a degree from
12 Northern Virginia Community College who attended
13 this course, were they given course credit
14 toward their graduation for that course?
15 A. I am not sure. I didn't speak with
16 them about it. But as a college student, I
17 wouldn't want to take anything I wasn't going to
18 getting credit for.
19 Q. Were they graded?
20 A. I can't remember. I am sorry.
21 Q. Was this pass/fail?
22 A. I don't even remember that.
23 Q. Was there any paper involved?
24 A. No, there was no paper involved.
25 Q. Was there a test involved?
0068
1 A. There was some testing involved with
2 regards to form blindness and to -- he handed
3 out a piece of paper with a bunch of signatures
4 on it we were supposed to identify from another
5 -- we were supposed to categorize which writer
6 wrote certain signatures, and we had to combine
7 those signatures.
8 Q. Did Mr. Zigler give you feedback if
9 he didn't give you a grade?
10 A. Yes. Well, we turned in the form
11 blindness test. He made comments. And also --
12 I believe he made comments about that one test,
13 he should have, with regards to matching up
14 signatures.
15 Q. So you had a few minutes of
16 individualized comments from Mr. Zigler on your
17 own performance?
18 A. In front of the class he made
19 comments.
20 Q. So you did not have any
21 individualized feedback yourself from Mr. Zigler?
22 A. That is correct.
23 Q. He simply commented to the class as
24 a whole on some of what the students turned in?
25 A. That is correct. And, of course, I
0069
1 spoke to him afterwards about certain portions
2 of the class.
3 Q. So it would not be accurate to say
4 that Mr. Zigler trained you, would it; it would
5 be accurate simply to say that you sat through
6 his course?
7 A. It was a course instructed by Mr.
8 Zigler.
9 Q. The class would, if I understand
10 your testimony correctly, have been a basic
11 overview of the field of questioned document
12 examination; am I right?
13 A. Yes. It included that.
14 Q. And do you recall that Mr. Zigler
15 told his students and the non-students attending
16 the class that these few days of study were not
17 designed to teach them to be practicing forensic
18 document examiners; didn't he?
19 A. I don't remember him mentioning that,
20 but that is true about that course. I mean,
21 you can't take that and go out and be a
22 document examiner; that is correct.
23 Q. Did you ever take any other courses
24 with Mr. Zigler?
25 A. No, I have not.
0070
1 Q. I want to direct your attention back
2 to Mr. Dave Liebman whose name has come up in
3 this deposition up to now several times and who
4 is, of course, also named in your resume on
5 page 2 and with whom you have been in practice
6 regarding questioned documents at times during
7 your career.
8 Does Mr. Liebman teach a course at
9 Old Dominion University?
10 A. He used to at one time.
11 Q. What is the subject of that course?
12 A. Good question. I don't know. When
13 I met Mr. Liebman, I think he was no longer
14 teaching that course.
15 Q. And you met Mr. Liebman when?
16 A. At a conference at the National
17 Association of Document Examiners, a NADE
18 conference. And it was a conference they had
19 in California, which would be in 1991.
20 Q. So he had already stopped teaching
21 that course at Old Dominion, to the best of
22 your knowledge, by 1991?
23 A. I am not sure when.

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jameson
Member since 5-8-02
08-15-02, 04:25 PM (EST)

4. "5 Cina Wong depo"
In response to message #3


24 Q. Did you learn that the subject of
25 that course taught by Mr. Liebman was
0071
1 determining whether an individual had cancer by
2 examining the person's handwriting?
3 A. No, I was not aware of that. It
4 was taught at a college? Old Dominion or --
5 Q. I am not here to answer. I am
6 trying to obtain what information you have about
7 that.
8 A. Oh, okay. If it was taught at Old
9 Dominion University, that is an accredited
10 college.
11 Q. But you don't know the subject
12 matter and you don't know whether he taught
13 about determining the existence of cancer by
14 looking at a person's handwriting; am I correct?
15 A. No. He could have taught something
16 about bug larva and I wouldn't know.
17 Q. Was Mr. Liebman asked, to your
18 knowledge, to be an expert witness on behalf of
19 Chris Wolf in this case that brings you here
20 today?
21 A. I am sorry. What was that question?
22 Q. Was Mr. Liebman asked to be an
23 expert witness in the Chris Wolf case, the same
24 case that you are assisting Mr. Darnay Hoffman
25 and Mr. Evan Altman in today?
0072
1 A. I am not sure. At that time when I
2 was asked Mr. Liebman and I no longer had a
3 business. We still talked, but that isn't an
4 issue that comes up.
5 Q. So Mr. Liebman has not told you that
6 he was or was not asked to be an expert
7 witness by Mr. Hoffman or Mr. Altman?
8 A. That is correct.
9 Q. Do you keep in touch with Mr.
10 Widmer, Ted Widmer?
11 A. I spoke to him recently because I
12 heard that, through the grapevine, he had
13 recently gotten married, and I wanted to wish
14 him my best.
15 Q. Are you aware of some legal issues
16 that Mr. Widmer encountered in about 1995?
17 A. No, I am not. What type of legal
18 issues are you talking about?
19 Q. Are you aware that Mr. Widmer signed
20 a stipulation with the San Francisco District
21 Attorney's office that he falsified in court his
22 questioned document credentials?
23 A. No, I did not. To what degree?
24 Q. I am sorry?
25 A. To what degree?
0073
1 Q. I, again --
2 A. I was curious. I didn't know.
3 Q. I am just here to ask you questions
4 and probe your knowledge.
5 A. Okay.
6 Q. And as I understand your testimony,
7 you have no knowledge of that; am I correct?
8 A. No, I do not.
9 Q. It would not be appropriate, of
10 course, ever to falsify one's credentials as a
11 questioned document examiner?
12 A. That is correct. But his actions
13 have no bearing on my actions.
14 (Discussion ensued off the record.)
15 Q. (By Mr. Rawls) Ms. Wong, would you
16 please turn back to Defendants' Exhibit 3 to
17 your deposition. And on the, I guess this is
18 the third page from the back --
19 A. Third page from the back. Okay.
20 Q. -- there is a section under the bold
21 caption: Other graphologists rave.
22 Do you see that?
23 A. Uh-huh (affirmative).
24 Q. And there is the quoted phrase:
25 Ted, thanks for giving me my start, end quote.
0074
1 And under that is the name C. Wong, Norfolk,
2 Virginia.
3 A. Uh-huh.
4 Q. Did you, in fact, make that
5 statement about Mr. Widmer's course?
6 A. I did not make it with regards to
7 the graphology course. I made that comment with
8 regards to the document examination course. So
9 I am surprised to see it here today underneath
10 graphology, because actually I first learned
11 document examination through Ted. So this is
12 surprising to me. But I did say that to him,
13 but in a different context.
14 Q. So the fact is you do not consider
15 yourself a graphologist?
16 A. Of course not.
17 Q. And the website page that we've just
18 discussed seems to label you a graphologist?
19 A. That is what it appears to be here,
20 but it is incorrect.
21 Q. And would you, therefore, likely
22 intend to ask Mr. Widmer to please remove your
23 name and your quote from this page?
24 A. Yes. I will ask him to remove the
25 quote or I will have to ask him to put it in
0075
1 the correct context, which is with regards to
2 his document examination course.
3 Q. And, Ms. Wong, if you learn that, in
4 fact, Mr. Widmer did, in 1995, enter a
5 stipulation that he had falsified his own
6 credentials on questioned documents, would you
7 ask him to take your name out of his materials
8 altogether?
9 A. Yes, if that is the truth. Are you
10 saying he -- I don't understand your question
11 clearly. He falsified information with regards
12 to documents at hand or with regards to his CV?
13 Q. His credentials.
14 A. Okay.
15 Q. His credentials?
16 A. Thank you for bringing that to my
17 attention. I didn't realize this.
18 Q. Certainly.
19 Let's move to page 3 of your resume,
20 and this is back, of course, to Defendant's
21 Exhibit 1. You state that, under Continuing
22 Education, you attended Andrew Bradley's Forensic
23 Document Examination course.
24 A. Oh, I didn't attend it. That is a
25 course that is through correspondence through
0076
1 mail. And you send the course and you work on
2 the course when you find the appropriate time
3 to. And there is testing at the end of each
4 chapter is how it works. It gives you a test.
5 And after you answer the questions, you send it
6 back into his office, and they send you a
7 critique back.
8 Q. How much did you pay for that
9 correspondence course?
10 A. I don't remember. I am sorry.
11 Q. How much time did you spend on each
12 of the 20 lessons?
13 A. Actually, I haven't finished all the
14 courses, that is why it is under Continuing.
15 But I can't give you a number right off the
16 top of my head.
17 Q. How many of the 20 lessons have you
18 completed?
19 A. I have been through either the first
20 three or four.
21 Q. On your resume, you state that the
22 course entails subjects such as the mechanics of
23 handwriting, proper procedures for obtaining
24 exemplars, identification of handprinting,
25 disguised writing, forgeries, photocopy
0077
1 examination, typewriter identification, anonymous
2 letters, document photography, examination of ink
3 and paper, writing instruments, erased and
4 obliterated writing, and use of ESDA.
5 Have I read correctly?
6 A. That is correct.
7 Q. And which of those subjects have you
8 yet completed?
9 A. I, just to be -- this is right off
10 the table of contents, so it would be, like,
11 the first three or four. And actually, I have
12 knowledge of all the ones that you've mentioned;
13 I have knowledge in all those areas already.
14 Q. So your continuing education has
15 taken you through the first three or four?
16 A. That is correct.
17 Q. And exactly three or exactly four?
18 A. I can't remember. I am sorry.
19 Q. So you don't know if you have gotten
20 to disguised writing yet, which is number four
21 on this list?
22 A. That is correct. As I mentioned, I
23 have knowledge in all these areas.
24 Q. Is Mr. Bradley certified by the
25 American Board of Forensic Document Examiners?
0078
1 A. I am not sure of that.
2 Q. Is Mr. Bradley certified by the
3 American Society of Questioned Document
4 Examiners?
5 A. I am not sure. All I know of Mr.
6 Bradley is he used to be a document examiner
7 with the sheriff's department in, I believe,
8 whatever state he lives in. I forgot. I am
9 sorry.
10 Q. So he worked for the sheriff's
11 office in a county or a city of a state that
12 you don't now recall?
13 A. That is correct. That is my
14 understanding.
15 Q. And back to Mr. Liebman for a
16 moment. Is Mr. Liebman certified by the
17 American Board of Forensic Document Examiners?
18 A. No. But he is certified through
19 NADE, N-A-D-E; and he was also past president of
20 NADE, which I am also a past vice president of.
21 Q. And is Mr. Liebman certified by the
22 American Society of Questioned Document
23 Examiners?
24 A. No. A lot of those organizations
25 that you are mentioning are open to just
0079
1 government or government document examiners who
2 have retired and are now in the private field.
3 So since I have not been in the government
4 field, or anybody that is not in the government
5 field, they are not allowed membership.
6 And certification through some of
7 those associations that you did mention are
8 voluntary.
9 Q. Ms. Wong, back to page 3 of your
10 resume, under Related Education, you state, you
11 list Private Investigator Licensing Course in
12 Virginia Beach, Virginia. And your resume
13 describes this as an in-depth, state-accredited,
14 60-hour course taught by Vince Tortomasi, former
15 Norfolk, Virginia police officer. Am I correct?
16 A. That is correct.
17 Q. Did that private investigator
18 licensing course cover forensic document
19 examination?
20 A. It touched upon it.
21 Q. It touched upon it?
22 A. It touched upon many subjects.
23 Q. About how much time was devoted to
24 document, forensic document examination in that
25 course?
0080
1 A. I wouldn't be able to give you an
2 exact number. I wouldn't remember. But it
3 covered a little bit about fingerprinting; it
4 covered a little bit about ballistics; covered
5 investigation procedures and so forth, including
6 a little bit on document examination.
7 Q. So was it something of an overview
8 of what private investigators need to know?
9 A. That is correct.