8 Q. So you did not, to the best of your
9 knowledge, inquire who won the case?
10 A. That is correct.
11 Q. In this case, the April 5, 1994,
12 case, was David Liebman involved?
13 A. I can't remember.
14 Q. In the previous case, the GMAC
15 versus Otis Green, was Mr. Liebman involved?
16 A. He may have been involved in that
17 one.
18 Q. And let's turn to June 1994. Was
19 this also in court?
20 A. It says that it's here in Yorktown,
21 in Virginia Circuit Court.
22 Q. And the matter is Commonwealth versus
23 James W. Malone. What was that about?
24 A. I don't remember anything about that
25 one, sorry.
0123
1 Q. It appears possible that that was a
2 criminal prosecution.
3 A. Yes. I believe that was one of the
4 cases where the Commonwealth Attorney retained
5 us. Let me think.
6 Q. But you're just not sure?
7 A. But I believe the -- I think the
8 judge had to give permission for our fee.
9 Q. And do you know whether your side
10 won?
11 A. I don't know.
12 Q. Was David Liebman involved in that?
13 A. He may have been involved in that
14 one.
15 Q. Do you know if the question in that
16 case involved a signature authentication?
17 A. I can't remember if it was a
18 signature or a body of writing. I am not
19 sure.
20 Q. Was it a forgery case?
21 A. I can't remember. I am sorry.
22 Q. And let's turn to September 14,
23 1994. This was testimony in court?
24 A. Yes.
25 Q. And do you recall the case of
0124
1 Worrell versus Worrell?
2 A. Uh-huh (affirmative).
3 Q. What was that about?
4 A. It was a disputed will.
5 Q. Was your role to authenticate a
6 signature --
7 A. Yes.
8 Q. -- or not?
9 A. To authenticate it or not, that is
10 correct.
11 Q. Do you recall whose side you were
12 on?
13 A. One of the Worrells.
14 Q. Were you opposing the genuineness of
15 the signature on the will or in favor of it?
16 A. I was in favor of it.
17 Q. Who won?
18 A. On technicality, the other side
19 because someone took forever to take the will to
20 the courthouse to submit there -- to probate the
21 will.
22 Q. So the delay cost one side the case?
23 A. That is correct.
24 Q. And was David Liebman involved in
25 the September 14, 1994, estate matter?
0125
1 A. Yes.
2 Q. Did he testify?
3 A. Yes.
4 Q. Were you there as a testifier or as
5 a --
6 A. I was there as a -- everything I
7 write here is only if I had testified.
8 Q. So you were not simply an assistant
9 to Mr. Liebman in that matter; you gave
10 testimony?
11 A. That is correct.
12 Q. Did Mr. Liebman represent the same
13 client that you represented?
14 A. Yes, that is correct.
15 Q. Let's move to November 7, 1994. The
16 Juvenile and Domestic Relations Court in
17 Fredericksburg, Virginia, Hicks versus Hicks.
18 What was that about?
19 A. I can't remember. It's J&DR Court.
20 I guess it was a husband and wife fighting over
21 something.
22 Q. So you don't recall what your
23 assignment was or your testimony in that case
24 was?
25 A. That is correct. I know it was
0126
1 handwriting related, document examination related.
2 Q. Was David Liebman involved?
3 A. I believe he was. I am trying to
4 think. He may have been.
5 Q. You gave testimony November 16, 1995?
6 A. Yes. That was a deposition. It is
7 stated right after the date. It says
8 deposition.
9 Q. A deposition. And that was in the
10 case of Gee, or Ghee, versus Elizabeth Nelson,
11 and you gave testimony in Norfolk?
12 A. That is correct.
13 Q. What was that matter about?
14 A. It was a disputed will case.
15 Q. And were you testifying about the
16 genuineness of a signature?
17 A. That is correct. It was a signature
18 and I think it was a will also. It was, like,
19 a two- or three-page will.
20 Q. Was it a handwritten will?
21 A. That is correct, a holographic will.
22 Q. And which side were you on?
23 A. Elizabeth Nelson.
24 Q. Was she contesting the will or was
25 she in favor of the will?
0127
1 A. She was in favor of the will.
2 Q. And who won?
3 A. Well, after I did a deposition, they
4 saw my exhibits, they settled the case.
5 Q. Was David Liebman involved?
6 A. Yes, he was involved in that one.
7 Q. Did he give a deposition also?
8 A. Yes, I believe he did.
9 Q. How much was paid in that
10 settlement?
11 A. Oh, I don't know.
12 Q. You gave testimony in court October
13 30, 1995, according to the next entry on page
14 3. You were hired by Neil Dilloff with Piper
15 and Marbury, and this was in U.S. District Court
16 in Baltimore.
17 A. That is correct. That was federal
18 court, yes.
19 Q. Yes, U.S. federal court. The case
20 was Baltimore Life Insurance versus Alex
21 Knopfler. Do you remember the matter?
22 A. Yes.
23 Q. What was that about?
24 A. Mr. Knopfler was an insurance agent,
25 and there were a lot of spurious signatures on
0128
1 -- there were a lot of applicants that were
2 questionable whether they existed or not. And
3 in each file there were many signatures to
4 examine from signatures on documents to
5 signatures on beneficiary forms and so forth.
6 And Baltimore Life obtained me and David Liebman
7 to go through all the files to determine if any
8 were or were not authentic.
9 Q. How many did you determine were not?
10 A. Wow. We had a case file somewhere
11 between 100 to 200 something files. I remember
12 there were some that were genuine, but the
13 majority were not.
14 Q. And did you so testify?
15 A. Yes, I did.
16 Q. Who won the case?
17 A. Actually, it ended up being settled
18 before it was over.
19 Q. And as you testified, David Liebman
20 was also involved in that?
21 A. That is correct.
22 Q. Did he give testimony in court too?
23 A. No, he did not.
24 Q. Then you testified in the office of
25 Thomas Wood in Baltimore on November 1. Was
0129
1 that a deposition?
2 A. That is correct.
3 Q. So you had given court testimony on
4 October 30 before a judge?
5 A. They were hearing some sort of
6 motion. I can't remember what it was. And
7 then they took our depositions, as you see
8 later, and then the case was settled.
9 Q. Okay. So you gave a deposition on
10 November 1, and you gave another deposition
11 November 7 and 8?
12 A. That is correct.
13 Q. All in the Baltimore Life versus
14 Alex Knopfler case; is that correct?
15 A. That is correct.
16 Q. Then we move to January 1996. You
17 testified in court?
18 A. Yes, that is correct. Circuit
19 court.
20 Q. In the matter of Joseph Antich
21 versus Bruno Antich?
22 A. Uh-huh (affirmative).
23 Q. Was that a will matter?
24 A. I can't remember a darn thing about
25 this case. I am sorry.
0130
1 Q. Did Mr. Liebman testify also?
2 A. I don't remember. Actually, by that
3 time probably, I don't think so.
4 Q. Probably not because of the timing?
5 A. Yes.
6 Q. Do you know which side was your
7 side?
8 A. No, I don't remember.
9 Q. Whichever side Carl Schmidt was on
10 was the side you were on?
11 A. That is correct.
12 Q. And you don't know who won?
13 A. That is correct. I don't remember.
14 Q. Then in June of 1996, you testified
15 in Virginia Circuit Court in Virginia Beach in a
16 criminal matter, Commonwealth versus Kenneth
17 Leigh Montgomery; is that correct?
18 A. That is correct.
19 Q. The attorney you have named here was
20 Philip Liebman. Is he related to David?
21 A. Yes, he is.
22 Q. Brother?
23 A. That is correct.
24 Q. Was David Liebman hired in that
25 case?
0131
1 A. No, he was not.
2 Q. And what was that case about?
3 A. It was a disputed signature on some
4 sort of document. I remember Mr. Montgomery
5 worked in the construction business. That is
6 all I remember.
7 Q. So you testified that it was his
8 signature?
9 A. I can't remember whether it was or
10 it wasn't. I can't remember.
11 Q. But the whole question was whether
12 it was his signature?
13 A. That is correct.
14 Q. Do you know who won?
15 A. I know our side did.
16 Q. Your side won. And it was David
17 Liebman's brother who hired you, correct?
18 A. Well, it was -- Mr. Montgomery had a
19 different attorney before, and he asked me if I
20 knew of any other attorneys, and I knew Mr.
21 Philip Liebman. And so he called Mr. Liebman
22 and told him I was already on the case. So in
23 that sense, I was hired.
24 Q. You were hired first by Mr.
25 Montgomery?
0132
1 A. That is correct. Or probably Mr.
2 Montgomery's previous attorney. I can't remember
3 who that was.
4 Q. You gave testimony then, June 4,
5 1996, the very next day, in a commissioner's
6 hearing in Norfolk, Virginia --
7 A. That is correct.
8 Q. -- in the case of Susanne P. Jones
9 versus Estate of Charles J. Waterfield, Jr., et
10 al.
11 A. Uh-huh (affirmative).
12 Q. What was that about?
13 A. I can't remember. It might have
14 been a will case.
15 Q. Do you recall what the issue was
16 that you testified about?
17 A. No, but it was document related.
18 Q. And was David Liebman involved?
19 A. No, he was not.
20 Q. Then three days later, you testified
21 in court in the General District Court for
22 criminal matters in Chesapeake, Virginia in the
23 case of Commonwealth and Cheryl Manning versus
24 Marie Estelle Skyles. And this was a
25 prosecution for forgery and, quote, uttering, end
0133
1 quote. Is that correct?
2 A. That is correct.
3 Q. And the uttering was a check?
4 A. I think there were multiple checks.
5 Q. So this person was accused of
6 forging checks and issuing bad checks; is that
7 correct?
8 A. That is correct.
9 Q. And whose side were you on?
10 A. The Commonwealth and Cheryl Manning.
11 Q. Who prevailed?
12 A. Actually, the day I testified, it
13 was a motion for something. I can't remember.
14 And then a year or something, a long time went
15 by, and I think it was settled out of court.
16 Q. The next entry on page 4 skips
17 almost two years to May of '98?
18 A. Uh-huh (affirmative).
19 Q. Did you give any testimony in 1997
20 at all?
21 A. No. Actually, a quiet year. Most
22 cases are settled out of court, and it actually
23 is very rarely that I do go to court and
24 testify.
25 Q. So here June of 1996 had you in
0134
1 court three different times, and you were not in
2 court again until almost two years later, May 28
3 of '98?
4 A. That is right. It is all at once
5 or nothing at all.
6 Q. And this was Pauze versus Pauze in
7 Gloucester, Virginia Circuit Court. What was
8 that one about?
9 A. I don't remember that one.
10 Q. Do you know whether your side won?
11 A. I don't remember. I don't even know
12 if I -- sometimes after I testify, I leave
13 before the decision is rendered.
14 Q. And it is your habit never to
15 inquire?
16 A. Sometimes I do. Sometimes I don't.
17 Q. Then in June, on June 11, 1998, you
18 gave a deposition in a case of Liebman versus
19 Liebman.
20 A. That is correct.
21 Q. In the office of Liebman. Were the
22 parties, Liebman versus Liebman, related to David
23 Liebman?
24 A. That is correct.
25 Q. Was David Liebman one of them?
0135
1 A. Part of them.
2 Q. I am sorry?
3 A. Part. There are, like, three
4 Liebmans.
5 Q. Well, which Liebman was suing which
6 other Liebman?
7 A. David and Michael Liebman were suing
8 Philip Liebman.
9 Q. For what?
10 A. It was over a disputed will.
11 Q. Of a father or mother?
12 A. That is correct.
13 Q. Which?
14 A. Father.
15 Q. And the question was what?
16 A. Whether the signature was authentic
17 or not.
18 Q. And was David the individual that
19 hired you?
20 A. Actually, no. All three of the
21 brothers at one point collectively hired me to
22 look at the case.
23 Q. You were hired by the two plaintiffs
24 along with the one defendant?
25 A. That is correct. They had all
0136
1 signed an agreement that they wanted me to
2 examine the will.
3 Q. And what was your conclusion?
4 A. That the whole document was printed
5 off of an ink jet printer from a computer and
6 that when you looked at the signature through a
7 magnification device you could see that, though
8 the signature looked like it was written from
9 blue ink, it was composed of red and blue dots,
10 so it came from an ink jet printer.
11 After I rendered that opinion,
12 another will mysteriously appeared. There were
13 three wills that appeared in this case.
14 Q. And you, therefore, testified that
15 the signature on the will which you studied was
16 not genuine, at least not a signature made by a
17 human on that document?
18 A. That is correct.
19 Q. And what was the result of the case?
20 A. It was heard at a later date. If
21 you skip down to September 20-- no. I'm sorry.
22 Yes. Okay. September 25th. But you want me
23 to go in order here?
24 Q. Well, let's skip down to Liebman
25 versus Liebman in court.
0137
1 A. All right.
2 Q. Did you give essentially the same
3 testimony?
4 A. Then I gave -- then I was not
5 allowed to testify about the signature on the
6 will that was composed from an ink jet printer.
7 I was only allowed to keep my testimony to the
8 new will, the third will that had popped up.
9 And there were signs of trace marks on that
10 will and a fake notary stamp and other
11 situations in that will.
12 Q. So you testified that there was a
13 fake notary stamp and there were other
14 suspicious matters?
15 A. There were trace lines surrounding
16 the signatures of the father, which is Walter
17 Liebman, on every single page of the document.
18 Q. What did those marks mean?
19 A. Trace marks show that someone traced
20 a signature either -- there are certain ways you
21 can do it. A simple way is that you can take
22 a piece of paper and put it over someone's
23 signature or hold it up to the window so you
24 get a transmitted light, and you can transmit
25 the signature onto the document. Some people do
0138
1 it in pen, but other people do it in pencil to
2 give them a guideline. Or other people just
3 use a stylus. Something like, the best thing I
4 can think of a stylus would be a sharp knitting
5 needle where you would make indentation marks
6 onto the signature line or onto the document
7 where you want the signature to appear. And
8 after you place your guidelines onto the
9 document, then you can go over that with an ink
10 pen. But the problem is we can't write the
11 same way twice. We have lots of variation
12 within our own handwritings. So when you go
13 over the tracing lines, you can't get the ink
14 line into the groove exactly and you will see
15 trace marks coming outside of the signature.
16 Q. And who prevailed in that case?
17 A. Actually Philip Liebman did. It was
18 on a technical matter, but he prevailed.
19 Q. Were you on his side in the trial?
20 A. I was hired by all three, so I just
21 went up there and gave my testimony, so.
22 Q. Now, we temporarily skipped over the
23 August 5, 1998, court appearance in the case of
24 Martin Man versus Karl Kaufman.
25 A. Oh, yes, okay.
0139
1 Q. Whose side were you on?
2 A. Karl Kaufman's.
3 Q. And what was that about?
4 A. It was a signature. And it was in
5 sort of a document where Mr. Kaufman sold a
6 plane or something, some signature that had --
7 on a document.
8 Q. And what was your testimony?
9 A. My testimony was that the signature
10 -- I believe Mr. Kaufman said that was not his
11 signature on the form.
12 Q. And --
13 A. And there were -- my -- according to
14 what my testimony was, Mr. Kaufman did not sign
15 that signature.
16 Q. And did he win the case?
17 A. It was strange. It was split. He,
18 Mr. Kaufman, went on the fact that that was not
19 his signature. Both sides were suing each other
20 at the same time, so each one won something.
21 I can't remember what it was about. It was
22 complicated.
23 Q. Was David Liebman involved in that
24 matter?
25 A. No, he was not.
0140
1 MR. RAWLS: Let me suggest since it
2 is now about 10 or 12 minutes after 1:00 that
3 we break here for lunch if that is okay with
4 everybody. I am getting hungry.
5 MR. ALTMAN: I think everybody is.
6 MR. RAWLS: May we go off the
7 record?
8 THE VIDEOGRAPHER: Going off the
9 video record at 1:13.
10 (A recess was taken.)
11 THE VIDEOGRAPHER: Back on the video
12 record at 2:22.
13 Q. (By Mr. Rawls) Ms. Wong, in just a
14 moment I will go back to your list of
15 testimony, of court and deposition testimony, but
16 for now may I ask you a question I forgot to
17 ask you earlier. And that is, have you ever
18 met Chris Wolf?
19 A. No, I have not.
20 Q. Have you ever spoken to Chris Wolf?
21 A. No, I have not.
22 Q. At the time you first spoke with
23 Darnay Hoffman, had you ever heard of Chris
24 Wolf?
25 A. I may have. Mr. and Mrs. Ramsey
0141
1 wrote a book, and in there they -- not only do
2 they mention me, but I think they mention Chris
3 -- I believe they mention Chris Wolf; that's
4 correct.
5 Q. But you had spoken with Mr. Hoffman
6 long before the Ramseys wrote a book; had you
7 not?
8 A. That is correct.
9 Q. And before you spoke first with Mr.
10 Darnay Hoffman, had you ever heard of Chris
11 Wolf?
12 A. I might have come across his name in
13 an article or something, but that is the best
14 of my memory.
15 Q. Have you ever seen Mr. Wolf in any
16 of his performances?
17 A. I don't know -- is he an actor?
18 Q. You would have remembered, I am
19 sure.
20 A. Oh. No, I've never met him. And
21 if he were sitting there across the table from
22 me and no one introduced me to him, I wouldn't
23 know who he was.
24 Q. And let me also, having called your
25 attention again to the first time you spoke with
0142
1 Darnay Hoffman, let me ask you to be as exact
2 as possible in telling us when that was in
3 1997?
4 A. I can't remember the month or the
5 date of when it was in '97.
6 Do you know, Darnay?
7 Q. Can you tell us if it was spring,
8 summer, fall?
9 A. No.
10 MR. RAWLS: Darnay, can you help?
11 MR. HOFFMAN: Yeah. It was either
12 late October or early November of 1997. It was
13 certainly after the ransom note had actually
14 been released to the media, which was -- that
15 was in September. So it was very late October,
16 early November.
17 MR. RAWLS: Darnay, thanks. I
18 appreciate that.
19 THE WITNESS: Thank you.