10 Q. Did you receive or ever apply for a
11 private investigator license?
12 A. We -- I like to call it
13 certification. I received my certification
14 through the state. And every two years I have
15 to go -- in order to get a renewal, I have to
16 go for a continuing education course.
17 Q. So are you a licensed private
18 investigator?
19 A. In the State of Virginia. It is a
20 licensing course, but what we receive is a
21 registration or a certification.
22 Q. So you have a certification and not
23 a license?
24 A. Right. It is strange. It is a
25 licensing course; but as a private investigator,
0081
1 you receive a certification or a registration.
2 And I am not practicing as a private
3 investigator.
4 Q. And you have no registration as a
5 private investigator?
6 A. Yes, I do. I am registered as a
7 private investigator, but I am not practicing as
8 one.
9 Q. We then move in sequence on your
10 resume to Specialized Course on Document
11 Examination in Bend, Oregon; and you describe a
12 handwriting analysis course instructed by John W.
13 Hargett, the Chief Document Examiner for the
14 U.S. Secret Service, and you go onto describe
15 Mr. Hargett.
16 Would you please tell us when it is
17 that you completed that course?
18 A. Well, I have here that it was in
19 1998. And what --
20 Q. How many classes did you attend?
21 A. He -- what he was -- the reason why
22 I was interested in taking his course, it was
23 promoted by the Northwest Fraud Investigator's
24 Association out on the West Coast, and this was
25 in the State of Washington. And what he was
0082
1 going to be teaching there, what I was told,
2 was exactly what he was teaching in the Secret
3 Service school that is usually taught over a
4 two-week period. And he was teaching a
5 condensed course for this group in document
6 examination.
7 Mr. Hargett is highly regarded, and
8 I knew that was a course that I definitely
9 would want to take.
10 Q. And I believe I asked you how long
11 you --
12 A. It was over a three- to four-day
13 period, I believe.
14 Q. A three- to four-day period?
15 A. That is correct.
16 Q. And how many hours per day?
17 A. It was a full day each day.
18 Q. Is there a course syllabus for that
19 condensed course?
20 A. I can't remember. I just know that
21 what he was teaching he said this is what I
22 teach at the Secret Service school.
23 Q. And --
24 A. And he took us through different
25 exercises, and we worked out certain problems,
0083
1 and he taught us certain basics and some
2 advanced techniques in document examination.
3 Q. You refer to this course as, quote,
4 Specialized, end quote. What was specialized
5 about it?
6 A. Well, that it was not often do you
7 get to take a course by a well respected person
8 like a John Hargett or a Larry Zigler, and I
9 was very fortunate to be able to get this
10 course. And it's specialized because he taught
11 the Secret Service handwriting school, document
12 examination school, and he was also teaching it
13 here.
14 Q. So it was specialized because he was
15 a special individual?
16 A. Well, no. Usually in order to take
17 the Secret Service handwriting course, you have
18 to be a document examiner in the government or
19 someone that is related to the field, and that
20 is when they allow you into that school.
21 Otherwise, you are not able to attend that
22 school.
23 Q. I notice on page 4 of your resume,
24 which is the very next page --
25 A. Yes.
0084
1 Q. -- that you attended the NWFIA
2 conference in 1998 in Bend, Oregon. Was Mr.
3 Hargett's course in document examination offered
4 as part of that particular NWFIA conference in
5 1998?
6 A. Yes. As I mentioned earlier, NWFIA
7 sponsored that course.
8 Q. What were the requirements to take
9 that course?
10 A. If you had an interest in taking the
11 course, then you could sign up for the
12 conference and attend.
13 Q. Was there a fee?
14 A. Yes, there was.
15 Q. How much was that?
16 A. I can't remember. I am sorry.
17 Q. How many people attended that course?
18 A. Wow. It appeared to be 80 or 100
19 or more people there.
20 Q. Were you graded in that course?
21 A. No, we were not graded.
22 Q. Was it a pass/fail course?
23 A. No, it was not.
24 Q. Did you receive a certificate or a
25 diploma or any indication you had taken that
0085
1 course?
2 A. There may have been a certificate of
3 completion, but I am not sure.
4 Q. Did you submit samples of your work
5 to Mr. Hargett?
6 A. No, I did not.
7 Q. Did you take a test?
8 A. We all were given some work to do,
9 just as in Mr. Zigler's class, to compare
10 handwritings and to see how many writers wrote
11 different signatures and so forth and to match
12 them up. And he also gave us group projects
13 also where a group of us got together, and we
14 decided whether certain documents had one or two
15 writers.
16 Q. Did you receive any individual
17 feedback personally from Mr. Hargett?
18 A. I spoke with him afterwards; that is
19 about it.
20 Q. So he did not comment on your work
21 or your conclusions?
22 A. That is correct.
23 Q. And, Ms. Wong, may I ask you to
24 move backwards and to the top again of page 3
25 of your resume briefly --
0086
1 A. Sure.
2 Q. -- back to Mr. Andrew Bradley's
3 forensic document examination course.
4 A. Yes.
5 Q. Mr. Bradley is the person you
6 understood to be a former sheriff from
7 somewhere?
8 A. That is correct.
9 Q. When did you take that 20 -- excuse
10 me. I beg your pardon.
11 When did you begin to take Andrew
12 Bradley's course?
13 A. I think I started, I purchased the
14 course in '92 or something, and I was still in
15 California and then moved over here to -- moved
16 over to Norfolk, Virginia. And as I was
17 unpacking, it just kept getting moved around, so
18 I haven't had a chance to finish it.
19 Q. And down to the private investigator
20 licensing course you took in Virginia Beach --
21 A. Yes.
22 Q. -- when did you take that course?
23 A. Good question. I've had it for a
24 while. I have taken that at least four -- four,
25 five, or six years ago. It has been a while.
0087
1 Q. Was that a correspondence course?
2 A. No, it was not.
3 Q. Did you pay a fee to take that
4 course?
5 A. Yes, that is correct.
6 Q. Was there any degree offered or any
7 grade offered in that course?
8 A. We had to pass a test. And if we
9 didn't pass, we didn't get our registration.
10 Q. Your resume states that the course
11 was an in-depth course. What was in-depth about
12 it?
13 A. He went through all the specifics on
14 investigation, how to handle an investigation and
15 so forth, went into a lot of that.
16 Q. I want to now ask you to tell me
17 some more about the NADE, the National
18 Association of Document Examiners. Earlier you
19 gave us the names of the two founders, Phyllis
20 Cook and Renee Martin.
21 A. That is correct.
22 Q. Does Ms. Cook have an accreditation,
23 please, with the American Board of Forensic
24 Document Examiners?
25 A. I am not familiar with what her
0088
1 background is in that field.
2 Q. Does she have a certification with
3 the American Society of Questioned Document
4 Examiners?
5 A. I don't have any knowledge of her
6 being associated with them or not.
7 Q. And do you know about whether Ms.
8 Renee Martin is certified by the American Board
9 of Forensic Document Examiners?
10 A. I don't have any knowledge on her
11 background with that regard either.
12 Q. Or the American Society of Questioned
13 Document Examiners?
14 A. I don't have any information.
15 Q. The fact is, is it not, that they
16 are graphologists?
17 A. I know that they do have a
18 graphology background, but the National
19 Association of Document Examiners, it is a
20 strict organization of just purely document
21 examination and no graphology.
22 Q. Would I be correct to characterize
23 the National Association of Document Examiners as
24 an organization that is principally comprised of
25 individuals with graphology backgrounds who would
0089
1 like to be document examiners?
2 A. Well, that is not true. We have
3 people there in the police force who are part
4 of our group. We have an ex -- I think he's
5 FBI, an ex-FBI person that is with us.
6 Actually two, or one may be Secret Service. We
7 have some government people, and we have lots of
8 students also.
9 But, no, the large graphology
10 background and then wanting to be is not true.
11 They've -- a lot of the people that attend our
12 conferences are strictly interested in the field
13 of document examination; and we do not teach
14 graphology there.
15 Q. Aren't most members of the NADE
16 individuals who have graphology backgrounds?
17 A. I know there are individuals there
18 with graphology background. To what degree and
19 how many, I am not sure what that number is.
20 Q. And people tend to come to the NADE
21 for accreditation when they cannot get
22 accreditation as a document examiner through some
23 other organization; am I not correct?
24 A. That is not true. There are other
25 organizations that are open to document examiners
0090
1 also. And even Mr. Zigler has a graphology
2 background. Like I said, he taught it to other
3 agents.
4 Q. Who accredits the NADE?
5 A. What do you mean by that?
6 Q. Does it have any accreditation, the
7 organization itself?
8 A. We are an organization. I don't
9 know --
10 Q. The NADE, that organization --
11 A. Yes.
12 Q. -- does it have any accreditation
13 from any place at all?
14 A. We are our own group, and we are
15 not a branch from another group where we need
16 to be accredited or separately. We are not
17 with a large group where we have a document
18 examination section and a fingerprint section.
19 No. We are just strictly document examination.
20 MR. RAWLS: Okay. We need a short
21 pause, I am told, for the benefit of changing
22 the videotape, so let's go off the record.
23 THE WITNESS: Sure.
24 THE VIDEOGRAPHER: Going off the
25 video record at 11:54.
0091
1 (A recess was taken.)
2 THE VIDEOGRAPHER: Back on the video
3 record at 11:57.
4 Q. (By Mr. Rawls) Ms. Wong, is the
5 NADE accredited by any forensic science
6 organization?
7 A. No, not that I am aware of.
8 Q. By any law enforcement group?
9 A. No. I didn't realize law
10 enforcement groups accredited other organizations
11 like document examination.
12 Q. Is there any state or federal
13 government certification or an accreditation of
14 the NADE?
15 A. No, not that I am aware of.
16 Q. There are a -- there are more than
17 just a few organizations that claim to be
18 questioned document examiner organizations; are
19 there not?
20 A. Not claim to be. They say they are
21 document examination organizations.
22 Q. And apart from the NADE, what other
23 ones have you applied to?
24 A. I haven't applied to any other ones.
25 I am happy with the National Association of
0092
1 Document Examiners. But I have heard some good
2 things about AFDE lately, AFDE; and I am
3 interested in finding out more about that group.
4 Q. What is AFDE?
5 A. American Forensic Document Examination
6 group.
7 Q. And, Ms. Wong, with respect to your
8 own board certification you told us about, of
9 the five to seven people in the room when you
10 took the oral portion of the accreditation test,
11 how many of those individuals were, to your
12 knowledge, accredited by some organization other
13 than the NADE?
14 A. I am not aware of what their
15 backgrounds are except for Mr. Liebman. I
16 should say when I mean people in the room,
17 those were the people in the room in charge of
18 making comments and notes with regard to my
19 certification.
20 Q. You joined NADE in 1991, if I am
21 correctly reading your resume; did you not?
22 A. Yes, that is correct.
23 Q. What was required in order for you
24 to be accepted into the NADE as a member?
25 A. As I mentioned, NADE is open to
0093
1 people who are practicing document examiners.
2 They are open to students, and they are open to
3 people who have been interested in the field.
4 So I filled out an application, and I joined
5 NADE.
6 Q. So essentially an application and a
7 fee were all that was required?
8 A. As so it is with most groups.
9 Q. Is the answer yes?
10 A. I am sorry?
11 Q. Is the answer yes to my question?
12 A. Which is, I am sorry?
13 Q. An application and a fee --
14 A. For NADE, yes.
15 Q. -- were all that NADE required?
16 A. Oh, I am sorry. Application and
17 three letters of reference or recommendation.
18 Q. And who wrote yours?
19 A. One was from Victoria Mertes, who is
20 also past vice president of NADE. And I can't
21 remember who the other two came from. It has
22 been a while.
23 Q. To join NADE, did you have to take
24 any form of test?
25 A. No, I did not.
0094
1 Q. Did you have to get a certain score
2 on anything?
3 A. No, I did not.
4 Q. And what is required for you to
5 continue to be a member of NADE?
6 A. To be a member or a certified
7 member?
8 Q. Well, first a member.
9 A. First a member, you pay your dues.
10 And what the dues include is a newsletter every
11 month, and you receive a professional journal
12 with articles with regard to document examination
13 and notifications of coming conferences, which
14 are reported.
15 Q. And what needs to happen for you to
16 continue to be a certified member of NADE?
17 A. You must attend so many conferences
18 to show that you have continuing education,
19 participate with writing articles for the
20 journal, or a combination of both.
21 Q. Are you a diplomate of the NADE?
22 A. A diplomate, no, I am not.
23 Q. What is a diplomate?
24 A. That -- usually that is held for
25 people who are held in high regard in the
0095
1 association. I haven't applied for it, but
2 there are certain requirements that you have to
3 meet in order to become a diplomate.
4 Q. So you are a past vice president of
5 NADE --
6 A. That is correct.
7 Q. -- but you have not applied?
8 A. No, I have not.
9 Q. What is required for you to be a
10 diplomate?
11 A. As I mentioned, I am not quite sure
12 what the details are with that.
13 Q. Where is the home office of NADE?
14 A. It is incorporated, I believe, in
15 Delaware or New Jersey, but usually it follows
16 around where the current president is. And the
17 current president at this time is Kathy
18 Koppenhaver, and she is in Maryland.
19 Q. Well, I am sure it has a
20 headquarters office; does it not?
21 A. Oh, I see what you are saying.
22 Usually it is with one of the founders, and I
23 believe it is with Renee Martin.
24 Q. I don't understand your use of the
25 word usually. Is there a headquarters or not?
0096
1 A. I guess I am not sure what you mean
2 by headquarters. But it is with Renee Martin,
3 and I believe she lives in Princeton, New
4 Jersey. Because when you look up the
5 association for NADE, the contact person is
6 Renee Martin, who is past founder.
7 Q. Let me put it this way. Is there a
8 physical office that is the national headquarters
9 of NADE that I could go visit and see people
10 and talk to people and get their brochures,
11 obtain their literature, talk to their
12 receptionist, be escorted to the employees'
13 offices? Is there such a place?
14 A. Oh, we don't have a main office just
15 for that. But Ms. Martin handles all that.
16 Q. Well, do you have any office?
17 A. Yes. Ms. Martin has an office, and
18 also the headquarters of NADE is from that. If
19 anybody needs a brochure on NADE, she would
20 recommend them to contact the membership
21 chairman, or if they would like to speak to the
22 president, then she will direct the call to the
23 president.
24 Q. And is this office in Ms. Martin's
25 professional office?
0097
1 A. Yes, that is correct.
2 Q. And is that in her home?
3 A. I am assuming. I am not sure.
4 Q. You have not visited this office of
5 NADE?
6 A. No, I have not.
7 Q. So are you assuming there is one,
8 but you couldn't tell me for sure?
9 A. I just know from what I am told.
10 Q. Have any of the NADE conferences
11 that you have attended been held in a home
12 office or headquarters office of NADE?
13 A. No, it has not. It is usually held
14 in a location at a hotel with enough conference
15 area to hold all of the members that do attend.
16 Q. How many members does NADE have?
17 A. Last time I checked, which has been
18 a while, it was somewhere between 85 and 89.
19 I believe it is higher now. I believe it is
20 over 100, probably.
21 Q. Once a person is certified by NADE,
22 is there a peer review mechanism within the
23 organization?
24 A. For instance, before the person
25 applies or --
0098
1 Q. No. After the person is certified.
2 A. Yes.
3 Q. What kind of peer review organization
4 is there or mechanism?
5 A. Well, we have an ethics committee.
6 For instance, if anybody, if it is reported to
7 the ethics committee, they will do an
8 investigation if they find that a member is not
9 behaving within the ethical guidelines. This is
10 for within the organization if we have any
11 complaints.
12 Q. Has anyone ever been expelled from
13 NADE for violating the ethical requirements?
14 A. I believe it was done in a very
15 polite way where the person did not come back.
16 Q. Was the person stripped of his or
17 her board certification?
18 A. This is to the best of my knowledge;
19 I am not sure if these are actual facts of the
20 event.
21 From what I understand, someone
22 claimed to have certification with NADE when, in
23 fact, they did not. So they were not welcome
24 back into the association, and they never had
25 certification to begin with.
0099
1 Q. And that is the only expulsion of a
2 member you are familiar with?
3 A. That I am familiar with. There may
4 be others, but I am not familiar with those.
5 Q. Are there any of the 85 to 89, or
6 possibly more now, members of NADE employed by
7 the FBI?
8 A. Not currently. Some are -- they are
9 retired FBI. We still have some people who
10 work for the state government.
11 Q. Are any of the 85 to 89 or perhaps
12 more members of the NADE employed by the United
13 States Secret Service?
14 A. No, not currently.
15 Q. If I correctly understand your
16 testimony, you yourself have not applied for
17 membership in the American Academy of Forensic
18 service -- excuse me, Forensic Sciences?
19 A. As I mentioned, a lot of those
20 organizations are open to people who work for
21 the government or have come from government
22 jobs. And in that sense, it is a little
23 discriminatory; and I am not able to apply.
24 Q. And have you not applied for the
25 American Board of Forensic Document Examiners?
0100
1 A. I am sorry, which one?
2 Q. The American Board of Forensic
3 Document Examiners.
4 A. That is another group that
5 discriminates against people who are not
6 government employed.
7 Q. Let me ask my question again.
8 A. Sure.
9 Q. It is a yes or no question.
10 A. I am sorry.
11 Q. You have never applied for
12 certification by the American Board of Forensic
13 Document Examiners; have you?
14 A. No. They discriminate.
15 Q. And you also have never applied for
16 certification from the American Society of
17 Questioned Document Examiners; am I correct?
18 A. That is correct. I believe they
19 have the same rules.
20 Q. Have you looked at the requirements
21 for certification by the American Board of
22 Forensic Document Examiners?
23 A. Let's see. I believe so, and I
24 believe it says that is voluntary. A lot of
25 people were grandfathered in early on in the
0101
1 beginning. And I am not sure if it is their
2 group or a different group that their board
3 certification test is sent to them. So it is
4 not taken in a public area where it is
5 proctored.
6 Q. Are you aware that for certification
7 by the American Board of Forensic Document
8 Examiners there are a number of qualifications?
9 Do you know that?
10 A. No. Go ahead.