20 Q. (By Mr. Rawls) And, Ms. Wong, are
21 you able to -- does that refresh your
22 recollection on the time?
23 A. It made me remember that usually
24 during Christmastime or Thanksgiving time, I go
25 home to visit my parents in California. And I
0143
1 remember looking at the documents and then
2 getting on a plane going home. So that helped
3 ring a bell.
4 Q. Good.
5 A. That would make sense.
6 Q. Good. Now, let's turn back, please,
7 to Defendants' Exhibit 5, which is your list of
8 court and deposition testimony. I would like to
9 ask you, please, to stay with us on page 5.
10 And I am turning now to the February 3, 1999,
11 testimony before Judge Leafe in Norfolk, Virginia
12 Circuit Court, in the case of Jettie Menzies
13 versus Jean Derricott. Do you recall that?
14 A. Yes.
15 Q. Whose side were you on?
16 A. It was Jettie Menzies.
17 Q. And what was the nature of the case?
18 A. There was a signature -- there was a
19 signature that was allegedly signed by Ms.
20 Menzies' mother. And, in fact, the signature
21 was a -- the signature was created with a
22 rubber stamp. So it wasn't a signature where
23 you would write out by hand in ink. It was a
24 reproduction with the method of using a rubber
25 stamp.
0144
1 Q. And was the question whether it was
2 a real signature or a rubber stamp?
3 A. It was a question of whether it was
4 a real signature or not.
5 Q. What was your testimony?
6 A. That the signature was created from
7 a rubber stamp. And I pointed out some
8 similarities as to why it was rubber stamped:
9 How the ink sat on top of the paper and
10 absorbed in, not pushed into the paper as
11 opposed to when you are writing with a pen, the
12 ballpoint pen that's pushing the ink into the
13 paper. And sometimes with rubber stamps when
14 they cut your signature from the rubber stamp
15 they don't always do a very good job and they
16 leave trails of loose rubber material that also
17 picks up the ink, and you will see that on the
18 paper when you push down using a rubber stamp.
19 Q. And did your side win?
20 A. I can't remember in that case.
21 Q. Was David Liebman involved?
22 A. No, he was not.
23 Q. Then you testified June 3, 1999,
24 before Judge Byrd in Monterey, Virginia Circuit
25 Court in the case of The Blue Grass Valley Bank
0145
1 versus Robert B. Ralston. Do you recall that?
2 A. Yes, I do.
3 Q. Whose side were you on?
4 A. Mr. Ralston's family.
5 Q. And what was your testimony?
6 A. That the signature of Mr. Ralston, I
7 believe, was authentic on the will.
8 Q. And who won?
9 A. Well, I am sorry. It was not a
10 will. It was something from a -- oh, it was
11 from a bank. That's why. It was a document
12 from a bank. And they said that Mr. Ralston
13 signed the paper. And, in essence, I think he
14 didn't. That was the best of my memory.
15 Q. Did your side win?
16 A. Yes, we did.
17 Q. Was Mr. Liebman involved?
18 A. No, he was not.
19 Q. You then testified in September 1999
20 in two different matters, one a deposition and
21 one in a court case, all involving the case of
22 Tanisa Kawesa and Andrew Kawesa versus Loizou,
23 Inc. Do you recall that?
24 A. Yes.
25 Q. Who hired you?
0146
1 A. Mr. Eason did.
2 Q. Which side did you represent?
3 A. I represented Kawesa.
4 Q. And what was the issue?
5 A. I think Loizou, Incorporated is the
6 -- they own a car dealership. And something
7 happened with an exchange with the Kawesas,
8 about the Kawesas signing a signature, and they
9 owed Loizou some money.
10 Q. Did you testify the signature was
11 genuine?
12 A. Yes, I did.
13 Q. And who won?
14 A. My side did.
15 Q. Was David Liebman involved?
16 A. Yes, he was.
17 Q. Did he testify also?
18 A. Yes, he did.
19 Q. Then in March of 2000, you testified
20 before Judge Glover?
21 A. Uh-huh (affirmative).
22 Q. In a case in Queens, New York
23 Circuit Court?
24 A. Yes.
25 Q. The case of Joy Management versus
0147
1 Imperial Management Corp. And unless I am
2 mistaken, that is the first time you testified
3 outside Virginia; is that right?
4 A. Yes, that is correct.
5 MR. HOFFMAN: Just one point --
6 THE WITNESS: Well, no, Maryland
7 County, a different state.
8 Q. (By Mr. Rawls) I beg your pardon.
9 So you testified out of state one time before
10 this, and that was in Maryland?
11 A. That is correct.
12 Q. In Baltimore.
13 MR. ALTMAN: It was federal court.
14 Q. (By Mr. Rawls) So this was your
15 second testimony out of state?
16 A. That's correct.
17 Q. And what was this case about?
18 A. It was a dispute between the two
19 companies whether someone had signed a stock
20 certificate or not, I believe.
21 Q. And which company did you represent?
22 A. Joy Management.
23 Q. Did you testify it was a genuine or
24 not signature?
25 A. That it was genuine.
0148
1 Q. Who won?
2 A. Don't know. The last time I spoke
3 to the attorney, the judge had still not
4 rendered an opinion.
5 Q. And was David Liebman involved?
6 A. No, he was not.
7 Q. Then in March of 2000, you testified
8 in the circuit court in Fairfax, Virginia in the
9 matter of Quantum Communications, Inc., versus
10 Brian Bird versus Michael Hardy; is that
11 correct?
12 A. Mr. Hardy actually belongs to Quantum
13 Communications. I am trying to think. Yes, it
14 was Quantum Communications who is owned by
15 Michael Hardy against Brian Bird.
16 Q. Which was your side?
17 A. Quantum Communications.
18 Q. What was that question?
19 A. It was a document that Mr. Bird said
20 that Mr. Hardy allegedly signed. Mr. Hardy had
21 caught Mr. Bird on videotape stealing from his
22 office and stealing certain documents. So Mr.
23 Hardy had to let Mr. Bird go. And on the day
24 Mr. Hardy let Mr. Bird go -- well, I mean, he
25 let Mr. Bird go and the months went by. And
0149
1 then Mr. Bird said that on the day Mr. Hardy
2 let him go, he signed over a third of his
3 multi-million dollar company over to him.
4 Q. And it was Mr. Hardy's position he
5 had not done so?
6 A. That is correct.
7 Q. Was it your testimony Mr. Hardy's
8 signature was forged?
9 A. In all appearances, it appeared that
10 Mr. Hardy had signed the signature; but upon a
11 closer examination, it was a cut and paste job.
12 The original was missing. And I could tell
13 from the signature of Michael Hardy and from the
14 line underneath it, it said something like
15 Quantum Communications, Inc., that that was of
16 probably something like a further generation. I
17 am not sure if you are familiar with it.
18 You make a copy from an original, it
19 is a first generation; and a copy from that is
20 second generation. So the document we were
21 dealing with was a second or third generation.
22 But then the signature of Mr. Hardy's was of,
23 like, an eighth generation.
24 Q. And am I correct that you testified
25 the signature of Mr. Hardy was forged?
0150
1 A. It was cut and paste. It was his
2 signature, but it was not intended for that
3 purpose.
4 Q. Who won the case?
5 A. I am trying to think. I believe we
6 did, but then it was going -- oh. We did, and
7 then it went for appeal and then they settled
8 out of court.
9 Q. Was David Liebman involved?
10 A. No, he was not.
11 Q. Then in June of 2000, you testified
12 before a hearing officer, Mark Hamilton, in the
13 matter of Norfolk Southern versus Sutherland, and
14 this testimony was in Chicago; is that correct?
15 A. That is correct.
16 Q. So that was your third trip out of
17 state to testify, true?
18 A. Yes.
19 Q. What was that about?
20 A. Usually it has to do with a
21 signature on some sort of form they have to
22 fill out when they go from -- when they go
23 from one railroad station to another. I am
24 trying to think. He was supposed to have
25 signed something, but they believe it was signed
0151
1 by someone else. It was a little more detailed
2 than that, but that is all I remember.
3 Q. But your testimony was about a
4 particular signature?
5 A. I think it was a couple of
6 signatures.
7 Q. And did your side win?
8 A. Yes, we prevailed.
9 Q. Was David Liebman involved?
10 A. No, he was not.
11 Q. You gave testimony, then, in
12 September 2000 before Judge Burgess in the
13 Chesterfield, Virginia Juvenile and Domestic
14 Relations Court in the case of Commonwealth
15 versus Karen Hoover; is that right?
16 A. That is correct.
17 Q. What was that about?
18 A. I don't remember that case, but I
19 remember that's a court area I don't want to be
20 in. There are too many people having arguments
21 about their children, so. I don't remember
22 anything about that case.
23 Q. Do you remember if the question was
24 about a signature?
25 A. It was either a signature or a
0152
1 document.
2 Q. Was David Liebman involved in that?
3 A. No, he was not. Oh, it might have
4 had to do with a check, I think. That is the
5 best of my memory.
6 Q. Then in January 2001 you testified
7 in a deposition in Alexandria, Virginia in the
8 case of Pafels versus Tugado. Do you recall
9 that?
10 A. Faintly.
11 Q. What was that about?
12 A. I don't remember. Sorry.
13 Q. Do you know if that was about a
14 signature?
15 A. It was either about a signature or
16 handwriting. All the work I do is related to
17 document examination.
18 Q. Did that case go to trial?
19 A. I believe it did.
20 Q. It looks like --
21 A. Yes.
22 Q. -- you were in court five days
23 later --
24 A. Okay.
25 Q. -- in Fairfax, Virginia Circuit Court
0153
1 in that case. Does that help you recall what
2 it was about?
3 A. No, it doesn't. Sorry.
4 Q. Do you recall which side you were
5 on?
6 A. Well, Mr. Steinmetz retained me. I
7 can't remember which side. Sorry.
8 Q. Was David Liebman involved in that?
9 A. No, he was not.
10 Q. And you still can't recall the
11 issue?
12 A. No. I am trying. If I remember
13 later, I will let you know.
14 Q. Then in the following month you
15 testified in an arbitration. The court was in
16 Buffalo, New York. Where was the testimony?
17 A. Oh, I am sorry. It shouldn't say
18 court. It should say where the hearing was held.
19 Excuse me. And it was held in --
20 Q. It says arbitration.
21 A. Yeah, arbitration, so. It should --
22 it was held up, excuse me, the arbitration in a
23 hotel somewhere in a conference room.
24 Q. And in what state?
25 A. In New York.
0154
1 Q. So this was your fourth trip out of
2 state to testify?
3 A. Is that what the count is?
4 Q. Last one I had was Chicago, and this
5 seems to be --
6 A. Chicago, New York, Maryland. Okay.
7 So this would be the fourth time, yes.
8 Q. And it seems to be another Norfolk
9 Southern case. Is that a repeat client of
10 yours?
11 A. Yes. That is correct.
12 Q. What was this Norfolk Southern versus
13 Penfield matter about?
14 A. Allegedly someone had written a
15 defamatory note, and I can't remember if it was
16 posted somewhere or what. Oh, it was a
17 defamatory note sent to one of their other
18 workers.
19 Q. Did you give testimony about the
20 author of the note?
21 A. Yes, I did.
22 Q. Who did you testify was the author?
23 A. A high probability that was Mr.
24 Penfield.
25 Q. Was there an opposing handwriting
0155
1 witness on the other side?
2 A. Yes. He came in last minute. He
3 had not looked at any of the other documents;
4 and he rendered an opinion, which was strange.
5 Q. And who won that case?
6 A. We did, and they filed for appeal,
7 but it stayed the same.
8 Q. Then in August 2001 you appeared in
9 Stafford, Virginia in the offices of Locklear &
10 Saller in the case of Dona Hall versus John
11 Hall. Was that a deposition?
12 A. No. That was a testimony.
13 Q. Testimony before the --
14 A. Before a commissioner.
15 Q. -- commissioner?
16 A. Yes. That is correct.
17 Q. What was that about?
18 A. Mrs. Hall allegedly wrote on some
19 documents. She said she didn't write those
20 phrases. She said Mr. Hall did. And Mr. Hall
21 said that he didn't and that it was actually in
22 Mrs. Hall's handwriting.
23 Q. Who was your client?
24 A. My client was Mr. Hall.
25 Q. And you testified that she had
0156
1 written the phrases?
2 A. That it was in her own natural
3 handwriting.
4 Q. Whose side won?
5 A. My side won. And there was an
6 opposing expert that was from the Secret
7 Service. He wasn't from the Secret Service at
8 that time. He was ex Secret Service, I should
9 clarify.
10 Q. Was David Liebman involved in that?
11 A. No, he was not.
12 Q. Was David Liebman involved in the
13 Norfolk Southern matter in New York?
14 A. No, he was not.
15 Q. And off of this list are two more
16 recent items that you had told us about. One
17 Considine versus Considine, and that was a
18 hearing before the commissioner. What was the
19 question in Considine versus Considine?
20 A. Well, Mr. Considine was a
21 stockbroker. He invested some money for his wife
22 at that time, April Considine. And in the
23 midst of their divorce, some papers popped up
24 because Mr. Considine had lost, from what I
25 understand, quite a few dollars from Ms.
0157
1 Considine. And she said she never signed, I
2 think it was, three documents.
3 Q. What was your testimony?
4 A. That it definitely was not her
5 signature.
6 Q. And did your side win?
7 A. Yes -- let me think.
8 No. An opinion has not been
9 rendered yet.
10 Q. Then in a will dispute involving the
11 will of Henry Hazelwood, you testified this very
12 month before Judge Powell. That was in the
13 Williamsburg, Virginia Circuit Court. What was
14 the question in that case?
15 A. Whether the signature of Mr.
16 Hazelwood was authentic or not. It appeared on
17 a will. He had Parkinson's.
18 Q. What was your testimony?
19 A. That it was authentic.
20 Q. Who won?
21 A. There were technical difficulties with
22 the case, but the other side won.
23 Q. Was there an opposing expert in the
24 case?
25 A. Yes, there was.
0158
1 Q. Who was that?
2 A. That was Mr. Farmer, and his opinion
3 was -- he did eyeball analysis, and he said it
4 was not his signature.
5 Q. About how many cases are you hired
6 in for every one that you ultimately testify in?
7 A. There is no rule of thumb. As you
8 saw, there was, like, a year I didn't testify.
9 There are a lot of times, as I said, cases are
10 settled out of court, may never even get there.
11 Q. And what you have shown us are,
12 let's see, a total of, (counting), 32 different
13 matters that have involved your testimony.
14 A. Does that include the new ones?
15 Q. That includes the two new ones.
16 A. Okay.
17 Q. And 33 if you include today. Is
18 that about half of your total engagements in the
19 history of your career?
20 A. Oh, I do a lot more case work than
21 what shows up there.
22 Q. Than twice the 33?
23 A. More than twice.
24 Q. Do you?
25 A. Yes.
0159
1 Q. I want to get back briefly to
2 approximately how much of your time in a year
3 is paid for. Do you have 1,000 billable hours
4 in a year?
5 A. I am trying to think. Like, my
6 last case I just had a lot of hours on that.
7 It shouldn't be more than that.
8 Q. I am sorry?
9 A. I am thinking. I am sorry. If you
10 want to go with an approximate, I will just
11 give you -- you know, I really can't give you
12 a good answer. I am sorry.
13 Q. And what approximate answer would you
14 give me?
15 A. No, I said if that is a number you
16 want to pull out of the hat, I really can't
17 help you. If you want to take a break, I can
18 sit here and fiddle and guess.
19 Q. Most weeks, do you bill 20 hours a
20 week, 30, 40, 10?
21 A. It varies. Sometimes I am working
22 seven days a week, and other times I may only
23 work twice a week. So that is why it is so
24 difficult for me to give you an approximate
25 number because my work is varying.
0160
1 Q. What is the largest total income you
2 have had from handwriting analysis in any
3 calendar year?
4 A. Probably in the high -- like, 28.
5 MR. WOOD: You said $28,000.
6 THE WITNESS: Yes. I am giving you
7 a guesstimate.
8 Q. (By Mr. Rawls) And, Ms. Wong, at
9 the present time, we know one matter you are
10 working on, and that is the engagement on behalf
11 of Chris Wolf by Darnay Hoffman and Evan Altman
12 that brings you here today. How many other
13 matters are you engaged in as a questioned
14 document examiner at present?
15 A. I probably have eight or ten cases
16 right now that are pending.
17 Q. Eight or ten others?
18 A. Yeah, eight or ten, 15. They just
19 -- sometimes they sit dormant for a while and
20 then they come back up.
21 Q. Are any of those eight or ten cases
22 that are pending cases we've already spoken
23 about because they were on your list?
24 A. Oh, these are the ones that I have
25 testified that I've finished with.
0161
1 Q. So the answer is no, those eight or
2 ten other cases you are working on now are not
3 matters we've spoken about earlier?
4 A. That is correct.
5 Q. In any of the cases that we've have
6 talked about today, those that, the 30, I
7 believe, that you listed in Defendants' Exhibit
8 5 and the two others we talked about here
9 today, have you given testimony about disguising
10 handwriting?
11 A. Yes, I have.
12 Q. How many?
13 A. The Norfolk Southern one on February
14 3. The April Considine case. And out of just
15 this list here I think it would be about two
16 of them.
17 Q. The two you mentioned?
18 A. Yes.
19 Q. Norfolk Southern and Considine?
20 A. That's correct. I mean, there might
21 be other ones that I don't remember.