11 Q. Do you know that one of those
12 qualifications is training at a forensic
13 laboratory?
14 A. For that group, that is a
15 requirement.
16 Q. So you do know of that requirement.
17 And have you yourself ever trained
18 at a forensic laboratory?
19 A. There is no standard in this field
20 that dictates where or when --
21 Q. Excuse me. Do you recall the
22 question: Have you yourself ever --
23 A. Oh, okay.
24 Q. -- trained at a forensic laboratory?
25 A. No, I haven't.
0102
1 Q. Thank you. So the American Board of
2 Forensic Document Examiners discriminates against
3 people like yourself who do not have forensic
4 laboratory training; am I correct?
5 A. No, that is different. That is not
6 discriminatory. That is a requirement in, as
7 they put it, for their group.
8 Q. And it is a requirement that you
9 have not met?
10 A. I have had an internship or a
11 mentorship program. But they believe in for
12 three years. But, as I mentioned, where my
13 work is corrected and it's been supervised. But
14 I have also received additional training from
15 Larry Zigler and also from John Hargett.
16 Q. Mr. Liebman did not run a forensic
17 laboratory; did he, Ms. Wong?
18 A. No, he did not.
19 And even the FBI didn't pass their
20 standards for their FBI laboratory at one time
21 either. And so there are difficulties in this
22 field and in the laboratory field with regards
23 to standards.
24 Q. Have you ever applied for training
25 at a forensic laboratory?
0103
1 A. You don't apply for training at a
2 forensic laboratory. How that works is if you
3 are in the field of document examination with
4 the government, then you are able to work within
5 that type of laboratory.
6 Q. Do you know that for certification
7 by the American Board of Forensic Document
8 Examiners a person needs to supply three
9 references from recognized forensic document
10 examiners recognized by the American Board of
11 Forensic Document Examiners? Are you aware of
12 that requirement?
13 A. Yes, I am. That is -- so you
14 actually have to know people to get in. Kind
15 of like nepotism.
16 Q. Actually, you have to obtain
17 references.
18 A. That's right, but from three people
19 you know that are members. So you kind of
20 have to know people in order to get in.
21 Q. Have you --
22 A. You can't -- sorry.
23 Q. Have you any references from American
24 Board of Forensic Document Examiners, recognized
25 forensic document examiners?
0104
1 A. I am sorry.
2 Q. Are there any such individuals who
3 would supply you with a reference if you were
4 to seek certification from the American Board of
5 Forensic Document Examiners?
6 A. I can't answer for them. But if I
7 -- I wouldn't know until I asked.
8 Q. Who are you closest to?
9 A. With regards to?
10 Q. Of recognized ABFDE forensic document
11 examiners?
12 A. Oh, I am not sure. I think Mr.
13 Zigler is a member of it, but I have never
14 asked him for a recommendation. I would only
15 need to ask him for a recommendation if I were
16 to apply to ABF -- American Board of Forensic
17 Document Examiners.
18 Q. Ms. Wong, your resume mentions from
19 time to time the NWFIA, which is said to be
20 the Northwest Fraud Investigators Association; am
21 I correct?
22 A. That is correct.
23 Q. And that is said to be out in
24 Tukwila, Washington?
25 A. Okay. I am not sure how to
0105
1 pronounce it, but, yeah.
2 Q. I am not either, so.
3 A. Sounds good to me.
4 Q. Is that group a forensic document
5 examination group?
6 A. Not strictly a forensic document
7 examination group, but they did sponsor that one
8 course with John Hargett.
9 Q. And that group is principally
10 concerned about check fraud; is it not?
11 A. That is correct. Well, fraud that
12 affects retail. It involves checks. It
13 includes credit cards. All types of areas
14 of --
15 Q. Does that group, the NWFIA, does it
16 certify questioned document examiners?
17 A. No, not that I am aware of.
18 MR. RAWLS: I will show you a
19 document we will mark as Defendants' Exhibit 4.
20 (Defendants' Exhibit-4 was marked for
21 identification.)
22 Q. (By Mr. Rawls) Do you recognize
23 this as a collection of two pages from the
24 NWFIA website?
25 A. I haven't been on their website
0106
1 personally, so this is the first time I am
2 looking at this.
3 Q. So it either -- it may or may not
4 be accurate?
5 A. I am not sure.
6 Q. Do you know that the organization
7 was formerly known as the Northwest Check
8 Investigators Association?
9 A. I am sure I read it at one time,
10 but it wasn't something I remembered.
11 Q. Why do you belong to the Northwest
12 Fraud Investigators Association?
13 A. Oh, I belong to them to receive
14 updates about their upcoming conferences, and to
15 see if there is anything that relates to my
16 field which I would want to attend. Check
17 fraud does involve handwriting and so does
18 credit card fraud. A lot of documents in
19 business involve handwriting and money. So I am
20 always interested in keeping abreast of what is
21 happening in the field, and so I stay a member
22 of the NWFIA.
23 Q. Ms. Wong, I would like now to talk
24 a little about your employment.
25 A. Okay.
0107
1 Q. Have you ever worked for a crime
2 lab?
3 A. No, I have not.
4 Q. Apart from the one or two
5 engagements that you received from the
6 Commonwealth Attorney's office and the one
7 engagement you had with the U.S. Probation
8 organization, have you ever been employed in any
9 law enforcement capacity?
10 A. No, I have not.
11 Q. Did you ever apply for a position
12 with the FBI?
13 A. One time a long time ago.
14 Q. When?
15 A. Good question. Many, many, many
16 years ago. I can't remember. I am sorry.
17 Q. What was the result?
18 A. Let's see, I decided not to pursue
19 it. I was contacted by the FBI that they had
20 received my lengthy application. There was a
21 lot to fill out. I can't remember at that time
22 why I decided not to pursue it.
23 Q. Did you apply -- well, for what
24 position in the FBI did you apply?
25 A. It was for a document examination
0108
1 job.
2 Q. Was it after you had received your
3 1991 training from Mr. Ted Widmer, graphologist?
4 A. It would not have been before that.
5 It was way, way after that. It was when I was
6 living at -- at least after '95.
7 Q. So it was after 1995, and you
8 applied for a questioned document examination
9 position --
10 A. That is correct.
11 Q. -- with the FBI?
12 A. That is correct.
13 Q. And were you advised that you did
14 not have the necessary credentials for the job?
15 A. No, I was not.
16 Q. No one ever told you that?
17 A. That is correct.
18 Q. Am I not correct that your
19 application was rejected by the FBI?
20 A. I was not told that.
21 Q. Did you ever receive an acceptance?
22 A. I neither received an acceptance or
23 a rejection. All I received, I think it was
24 verbally, that they had received my application.
25 Q. You told us that your office is in
0109
1 your home; have you not?
2 A. That is correct.
3 Q. How large is the space in your home
4 that is your office?
5 A. It is approximately 350 or
6 400-something square feet.
7 Q. Do you have your own forensic
8 document examination laboratory?
9 A. It's -- the office and the
10 laboratory are all in that one room, and they
11 are on separate sides of the room.
12 Q. And what equipment is located right
13 there in that office in your home?
14 A. Not including office equipment? You
15 are specifically asking for document examination
16 equipment?
17 Q. Yes.
18 A. Okay. I have a stereoscopic
19 microscope. I have reticles. I have
20 magnification devices. I have your basic
21 rulers. I have your -- I have a light table.
22 I have a gooseneck lamp to examine indented
23 writing. And I out-source if I need anything
24 that needs to be done on ESDA or on a VSC.
25 Q. If we could turn, please, to your
0110
1 resume. And this, again, is back to Defendant's
2 Exhibit 1. On page 5 there is a list of
3 accessible handwriting identification equipment.
4 A. Uh-huh (affirmative).
5 Q. The first of these is the Apollo
6 18-inch by 12.5-inch light table. Is that the
7 one that is the light table in your office?
8 A. That is correct.
9 Q. Then there is Leica 2000 Zoom
10 Stereoscopic Microscope. Is that the one that
11 is in your office?
12 A. That is correct.
13 Q. There is an indication that there is
14 forensic photography equipment including Nikon
15 6006. Is that in your office?
16 A. That is correct.
17 Q. Then the next bullet point says
18 magnification loupes. Are those in your office?
19 A. That is correct.
20 Q. Measuring devices, caliper; are those
21 in your offices?
22 A. Correct.
23 Q. Grids and gauges; are they in your
24 office?
25 A. That is correct.
0111
1 Q. And the next bullet point is UV
2 light for determination of paper substitutions
3 and authentication. Is that in your office?
4 A. Yes.
5 Q. Next it says various oblique lighting
6 apparatuses for identifying indented writing,
7 inks and obliterated writing. Are those
8 apparatuses in your office?
9 A. Yes.
10 Q. And you said you out-sourced certain
11 things. What are those things?
12 A. It would be for an ESDA machine or
13 sometimes it goes underneath the name of
14 Kinderprint or Vaccubox. It is an equipment
15 that is used to bring up indented writing.
16 Q. All right. And was there anything
17 else that you out-sourced?
18 A. That is if I need anything for a
19 VSC, which is a videospector comparator. And
20 some of the items I have do some of the things
21 that VSC does. For instance, it has oblique
22 writing; it has UV lighting and so forth. But
23 you are able to use -- to bring something up
24 on your computer and actually print it out, what
25 that has that-- is usually sent out.
0112
1 What you can tell by different
2 lighting is with different filters and
3 wavelengths you're able to tell the different
4 types of inks that may be on a piece paper,
5 but it is not ink chemistry.
6 Q. Okay.
7 A. And the VSC can run up to $60,000,
8 so that would be quite an expensive piece of
9 equipment. And they have some older versions
10 that are less expensive.
11 Q. Ms. Wong, have you published any
12 papers on forensics document examination?
13 A. No, I have not. I have some in the
14 works, but I have not published yet.
15 Q. Have you published any of your
16 results or your conclusions on document
17 examinations so that they may be reviewed by
18 other document examiners?
19 A. No, I have not. As I said, I have
20 some of those items in the works.
21 Q. Are you tested annually to see if
22 your skills and your methods are reliable?
23 A. No, I am not tested annually; but
24 there are some proficiency tests that you can be
25 a part of. You just have to be aware of when
0113
1 they are happening and so forth.
2 Q. Ms. Wong, does Defendant's Exhibit 1,
3 that is your CV, does this include all of the
4 education that you have received that you
5 consider pertinent to the subject of document
6 examination and your credentials for document
7 examination?
8 A. As far as I know.
9 Q. Are you still on page 5 of your
10 resume? And if you are not, would you mind
11 turning to page 5, please.
12 A. Yeah. The last page?
13 Q. Yes. Do you see an entry for print
14 media, another for radio appearances, and another
15 for broadcast media?
16 A. Yes. And those are just for
17 advertising for business.
18 Q. You say under print media that you
19 were the subject or mentioned in articles in
20 "USA Today," the "Virginian Pilot," the "Boulder
21 Camera," the Boulder Daily, the "Progress Index"
22 and the "New York Post." Am I correct?
23 A. Yes. That is correct.
24 Q. What was the case that brought about
25 the mention of you in "USA Today"?
0114
1 A. It was a case with regards to
2 examining the ransom note for the JonBenet
3 murder.
4 Q. So it was the Ramsey matter, the
5 JonBenet Ramsey murder matter --
6 A. That is correct.
7 Q. -- that brought you to the attention
8 of those who read "USA Today" the time that you
9 were named?
10 A. That is correct.
11 Q. And what case was it that led to
12 your being mentioned in the "Virginian Pilot"?
13 A. The same case.
14 Q. And the "Boulder Camera"?
15 A. The same case.
16 Just to make it easier for you, it
17 is all the same case.
18 Q. Okay. So the "Boulder Daily," the
19 "Progress Index" and the "New York Post," all of
20 that got you -- got your name in newspapers
21 based on one case, the case of the death of
22 JonBenet Ramsey?
23 A. Yes.
24 Q. Is the same true of the radio, all
25 of the radio appearances listed?
0115
1 A. Yes. That is correct.
2 Q. Is the same true of all of the
3 broadcast media listed?
4 A. Yes, that is correct.
5 Q. So nothing that you, Cina Wong, have
6 ever done has obtained you any newspaper or
7 radio or television publicity other than the
8 connection that you have with the JonBenet
9 Ramsey murder matter?
10 A. That is correct. I am not as
11 popular as Mr. Wood.
12 Q. May I say, Ms. Wong --
13 A. Yes.
14 Q. -- you certainly are as glamorous.
15 A. Oh, thank you. Well, I think --
16 Q. If Mr. Wood will not strangle me.
17 MR. WOOD: We will take that up off
18 the record.
19 MR. RAWLS: Let's go off the record
20 just a moment, if we could.
21 THE VIDEOGRAPHER: Going off the
22 video record at 12:30.
23 (A recess was taken.)
24 THE VIDEOGRAPHER: Back on the video
25 record at 12:43.
0116
1 (Defendants' Exhibit-5 was marked for
2 identification.)
3 Q. (By Mr. Rawls) Ms. Wong, let me
4 show you, please, a document Mr. Gallo has
5 marked as Defendants' Exhibit 5. Do you
6 recognize that?
7 MR. ALTMAN: Jim, do you have a
8 copy?
9 MR. RAWLS: Yes, I do.
10 MR. ALTMAN: Thank you.
11 THE WITNESS: Yes.
12 Q. (By Mr. Rawls) What is that,
13 please?
14 A. This is a compilation of my expert
15 witness testimony in court and in depositions.
16 It includes hearings also.
17 Q. Is it accurate?
18 A. There are two that I just -- two
19 cases that I've just testified on that aren't in
20 here.
21 Q. So this is a full and correct list
22 of all of your expert witness testimony, except
23 for two matters that are recent; and because
24 they are recent they have not yet been listed
25 on this document?
0117
1 A. That is correct.
2 Q. Would you first, please, tell us of
3 the two recent matters?
4 A. Let's see. It was -- the date was
5 January, and I can't remember what date.
6 Actually, let me check something. January, and
7 it was a case Considine versus Considine. The
8 attorney on my side was Robert Kantas,
9 K-A-N-T-A-S, I believe it was. And there was no
10 opposing attorney. Mr. Considine represented
11 himself, and it was in Sandston, Virginia. And
12 it was a hearing, a commissioner's hearing.
13 Q. And the other one?
14 A. And the other one is -- it was a
15 disputed will of Henry Hazelwood. It was in
16 May, just passed. And the judge's name is
17 Judge Powell. The attorney on my side was
18 Chuck Lollar, L-O-L-L-A-R. And the attorney on
19 the other side was Tommy Normant; and that was
20 in Williamsburg, Virginia, the circuit court.
21 Q. All right. Thank you. I want to
22 go through Defendants' Exhibit 5 and ask several
23 questions about these matters. Let's start with
24 page 1 and the first item, the testimony June
25 15 through 17, 1993. Were you testifying in
0118
1 court or in a deposition?
2 A. In court.
3 Q. In court. Was Mr. Liebman with you?
4 A. Yes. I believe he testified in that
5 also.
6 Q. What was the nature of the case?
7 A. It says it was a disputed will of
8 Mr. Painter.
9 Q. Which side were you on?
10 A. I can't remember.
11 Q. Which side was Mr. Liebman on?
12 A. The same side.
13 Q. And did the matter come out in favor
14 of the side you and Mr. Liebman were on?
15 A. I can't remember. I am sorry.
16 Some of these I remember, and some of them I
17 don't. And some of them I don't even know
18 what the outcome was.
19 Q. Was your testimony in that case
20 about the verification or authentication of the
21 genuineness of a signature?
22 A. Yes, that is correct.
23 Q. Was that the sole matter you gave an
24 opinion about in that case?
25 A. Yes, that is correct. All the cases
0119
1 I listed here has to do with document
2 examination, my testimony concerning document
3 examination.
4 Q. And let's go to the second entry,
5 testimony, August 8, 1993. And this was a
6 matter called WSB of Norfolk, Inc., Radio
7 Station Z104 versus Plaka, P-L-A-K-A,
8 Enterprises, Inc. What was the nature of that
9 case?
10 A. I believe it had to do with an
11 advertising contract that the radio station had
12 that was signed by whoever the gentleman was who
13 owned Plaka Enterprises. And the gentleman at
14 Plaka Enterprises said that he did not sign the
15 document. And there was an opposing document
16 examiner in that case.
17 Q. So, again, the question in that case
18 that you gave an opinion about was the
19 authenticity or genuineness of the signature by
20 someone with Plaka Enterprises; am I correct?
21 A. That is correct.
22 Q. And whose side were you on?
23 A. I was on the side for the radio
24 station.
25 Q. And who won?
0120
1 A. My side did.
2 Q. Was Mr. Liebman also involved?
3 A. Yes, but I am not sure if he
4 testified or not.
5 Q. Let's go to the next testimony,
6 March 29, 1994. Was this in court?
7 A. Yes, it was.
8 Q. I mean to ask whether your testimony
9 in the radio matter for WSB in the Norfolk
10 matter, was that in court or just in a
11 deposition?
12 A. Oh, right above it you will see I
13 mention in court. It was in Virginia Beach,
14 Virginia Circuit Court. And if it is a
15 deposition, then I will write that it is a
16 deposition.
17 Q. So on March 29, 1994, this was in
18 court?
19 A. Yes, that is correct, circuit court
20 in Norfolk.
21 Q. And GMAC was going after one Mr.
22 Otis Green for a sum of money of just over
23 $4,000?
24 A. That is correct.
25 Q. And you gave testimony in that case
0121
1 about what?
2 A. It was a disputed signature on
3 something. I can't remember what it was. I
4 guess it was some money that Mr. Green owed
5 GMAC.
6 Q. Whose side were you on?
7 A. I think I was for GMAC.
8 Q. And Otis Green said a certain
9 document did not contain his signature?
10 A. I believe that was the case.
11 Q. And you concluded it did?
12 A. I believe that was the case.
13 Q. Who won?
14 A. Our side did.
15 Q. And we will go to April 5, 1994.
16 Was this in court?
17 A. No, that was a commissioner's
18 hearing. It is written on the next page.
19 Q. Okay. And what was that about?
20 Was that a will signature authentication?
21 A. I can't remember. It just says
22 Estate of Virginia Burton versus Athalia
23 Robinson. So it may have been.
24 Q. Might have been a signature. Whose
25 side were you on?
0122
1 A. I was doing Mr. -- Mr. Walton hired
2 me. I can't remember.
3 Q. Do you know if your side won?
4 A. Usually with commissioner hearings,
5 they don't render an opinion until weeks,
6 sometimes months down the road, so we never even
7 hear.