22 Q. And in those that you have told us
23 about, with reference again to the same 30 cases
24 listed on Defendants' Exhibit 5 and the two
25 other recent cases in which you have testified
0162
1 that you told us about, have you given testimony
2 about similarities in an extended document to
3 other exemplars of a person's handwriting?
4 A. I am sorry. You said extended
5 documents?
6 Q. Yes.
7 A. I am not quite sure -- can you ask
8 me that again?
9 Q. Do you know what I mean by extended
10 document?
11 A. No, I am not quite sure how you are
12 using that.
13 Q. Then that is the problem, and let me
14 do without that.
15 A. Okay.
16 Q. How many times have you given
17 testimony about the authorship of a particular
18 document based upon similarities between that
19 document and other handwriting exemplars?
20 A. In saying that the writer is -- with
21 regards to similarities?
22 Q. Yes.
23 A. Out of these cases here?
24 Q. Yes.
25 A. Oh, good question.
0163
1 Q. One was the defamatory note, correct?
2 A. That is correct.
3 Q. You did testify that because of
4 similarities which you found comparing the
5 defamatory note to other exemplars --
6 A. Right.
7 Q. -- you testified about a conclusion
8 of authorship of --
9 A. Right.
10 Q. -- the defamatory note?
11 A. Right. I am trying to go through
12 all of the cases trying to figure out which
13 one.
14 Q. Exactly.
15 A. And some of these I don't even
16 remember what happened in the case.
17 Q. Tell me any other such examples of
18 testimony that you know of, please.
19 A. With just anonymous notes or it's
20 similar because it is an authentic signature and
21 that's why it would have similarities?
22 Q. Good question. Let's go with
23 anonymous notes.
24 A. Okay. So we were just down to
25 those two.
0164
1 Q. Well, I only know of one so far,
2 apart from the ransom note in JonBenet Ramsey.
3 A. I'm sorry. You are referring to the
4 Norfolk Southern case. And then you are saying
5 just with anonymous notes; is that what you are
6 saying?
7 Q. Yes.
8 A. Oh, okay. The Norfolk Southern
9 case.
10 Q. That one is the only one you can
11 recall today that involved your comparison of an
12 anonymous notes' handwriting with exemplars of
13 other handwriting; is that correct?
14 A. Oh, with many exemplars from many
15 people.
16 Q. And then the only other time you
17 have compared an anonymous note with handwriting
18 exemplars to reach a conclusion about the
19 authorship of the anonymous note was involving
20 the JonBenet Ramsey ransom note?
21 A. Well, you asked me just about the
22 cases in Exhibit 5. I have worked on other
23 cases also, but I did not testify about those.
24 Q. And I am limiting this to your
25 testimony.
0165
1 A. Okay. So, yes, that one.
2 Q. And apart from the ransom note in
3 connection with the death of JonBenet Ramsey,
4 have you ever been hired to attempt to determine
5 the identity of the author of a ransom note?
6 A. There are very few cases where there
7 are ransom notes, so I have not looked at one
8 that was specifically about a ransom note.
9 Q. So the only ransom note you have
10 ever been hired to attempt to determine the
11 authorship of is the ransom note found in
12 connection with the death of JonBenet Ramsey; is
13 that correct?
14 A. Right. And a ransom note is
15 anonymous writing.
16 Q. Yes. You agree with me that the
17 ransom note left at the Ramsey home in
18 connection with the death of JonBenet was
19 anonymous; do you not?
20 A. That is correct. As with any
21 writing that you send to someone, if someone
22 leaves a note on your door saying something not
23 very nice, of course, you don't know those,
24 those are all considered anonymous notes, too.
25 Q. Now, of the cases that are listed in
0166
1 Defendants' Exhibit 5, would you take a look
2 through there and tell me if any of those were
3 done by you pro bono?
4 A. Yeah, on page 2, I know I did one.
5 I believe this one was it. It was in
6 Fredericksburg. It is Hicks versus Hicks.
7 Q. Okay.
8 A. And the case below it, the attorney
9 never paid us; so I guess that is pro bono,
10 but not of my choosing.
11 Q. Well, pro bono is one --
12 A. I agree with that.
13 Q. -- in which you agree to testify for
14 free. So we won't call that pro bono by that
15 definition.
16 A. That's right.
17 Q. Are you finished?
18 A. Oh, yes. I was waiting for you.
19 Were you waiting for me?
20 Q. I am waiting for you to tell me if
21 there were any other pro bono --
22 A. No. That was it. I knew there was
23 one.
24 Q. That was the only one?
25 A. Yes, that's correct.
0167
1 Q. Thank you.
2 A. I am sorry.
3 Q. I am sorry. I did not understand you
4 were finished.
5 That one that was pro bono that
6 you've just told us about, the matter of Hicks
7 versus Hicks, did David Liebman charge in that
8 case?
9 A. Not that I am aware of.
10 Q. So you had earlier told us that Mr.
11 Liebman may have been involved in that case.
12 If he was involved, is it your understanding
13 that was also pro bono?
14 A. Well, it must have been. I remember
15 that gentleman didn't have any money, but he was
16 correct in the situation.
17 Q. And, Ms. Wong, how many times has a
18 judge heard your credentials, a judge or an
19 arbitrator or a hearing officer or a
20 commissioner, because I know you testified before
21 all of those kinds of people? How many times
22 has the judge or the hearing officer or the
23 arbitrator or the commissioner said I refuse to
24 permit you, Ms. Wong, to testify as an expert
25 in these proceedings?
0168
1 A. I always have been allowed to
2 testify. I have always qualified in court.
3 Q. So no one as of yet has said that,
4 thank you for being here, but I will not permit
5 you to testify about your expert conclusions?
6 A. That is correct.
7 Q. No one has yet done that?
8 A. Not yet, that is correct.
9 Q. Do you know what a Daubert challenge
10 is?
11 A. Yes. That is before you go into
12 federal court.
13 Q. Yes. And has anyone ever made a
14 Daubert challenge to your own credentials?
15 A. No, they have not.
16 Q. And how many times have you
17 testified in the U.S. District Court, which is
18 commonly referred to, and I think referred on
19 your paper to as federal court?
20 A. Once in Maryland.
21 Q. Once in Maryland, and that was the
22 Baltimore Life Insurance case?
23 A. That is correct.
24 Q. And if you do testify as a witness
25 in court in this case, are you aware that would
0169
1 be in the federal court here in Atlanta?
2 A. Yes, I understand.
3 Q. Ms. Wong, what was -- let me start
4 by saying, what is the nature of your
5 relationship today with Mr. David Liebman?
6 A. We no longer are working together,
7 but we are on friendly terms. And as I said,
8 every once in a while if I have to go out of
9 town and there is no one to handle a case, I
10 will refer the case to David Liebman.
11 Q. Have you discussed your testimony or
12 your expert opinion with respect to the ransom
13 note involving the death of JonBenet Ramsey with
14 Mr. Liebman?
15 A. During which time period?
16 Q. At any time.
17 A. Early on in the beginning when we
18 both received the case.
19 Q. In 1997?
20 A. Yes. I did my own analysis. He
21 did his own analysis.
22 Q. Did you compare notes with him then?
23 A. After we were through with our own
24 independent analysis, that's correct.
25 Q. And thereafter did you discuss the
0170
1 ransom note with Mr. Liebman?
2 A. With regards to specifics or --
3 Q. At any time.
4 A. We've -- generalizations about the
5 ransom note; but after we did our analysis, we
6 didn't do any more work with that, that aspect
7 of it.
8 Q. Did Mr. Liebman review your expert
9 witness report that Mr. Hoffman and Mr. Altman
10 have shared with us in this case?
11 A. I haven't shared that report with
12 anybody. I've only sent that off to Mr.
13 Hoffman. And where it has gone from there, I am
14 not sure.
15 Q. So you yourself have not given David
16 Liebman an opportunity to review it or to
17 comment upon it; is that true?
18 A. That is correct.
19 Q. And if he has seen it, it would
20 have been because someone else furnished it to
21 him?
22 A. That is correct.
23 Q. From 1992 through 1995, what was
24 your relationship with David Liebman?
25 A. Oh, I was still going through the
0171
1 mentorship program; and towards the end I was
2 finishing up and we were working as partners.
3 Q. And was your relationship with Mr.
4 Liebman professional only?
5 A. Oh, it's professional, yes.
6 Q. Only professional?
7 A. Yes. I mean, I might have gone out
8 with him for dinner or lunch a few times the
9 first few months, but that was about it.
10 Q. Of the eight to ten other cases that
11 you are working on now, how many of them
12 involve something other than the question of the
13 authenticity of one or more signatures?
14 A. They all do.
15 Q. They all involve more than
16 signatures?
17 A. There might be one case that might
18 be an obliteration case, but I haven't received
19 that yet.
20 Q. So what do these eight to ten cases
21 involve that you are working now?
22 A. Identify if someone has written on a
23 certain document or if they wrote a certain
24 phrase, and other ones are to authenticate the
25 signature or the writing.
0172
1 Q. Now, referring back, please, to your
2 Norfolk Southern case that involved the question
3 of who wrote a particular defamatory letter, how
4 many exemplars were you given that you compared
5 with the defamatory note?
6 A. Of the suspect, I am trying to think
7 back. I can give you an estimate. Somewhere
8 around 30 to 40 or 50 documents. And then we
9 also looked at the handwriting of anywhere from
10 23 to 30 other people.
11 Q. Why did you do that?
12 A. I wanted to be sure that, in --
13 they suspected a certain person, but I wanted to
14 know if there were any people around that were
15 involved in that area at that time frame, if
16 there was a possibility they could have been
17 involved also.
18 Q. And was it your conclusion that the
19 particular suspect of whose handwriting you were
20 given 30 to 50 exemplary documents was, in fact,
21 the author of the defamatory note in question?
22 A. Yes. It was highly probable that he
23 was the writer of the note.
24 Q. But to make sure of that, it was
25 your request to have lots of other documents
0173
1 authored by lots of other people around the
2 circumstances of the event?
3 A. That is correct.
4 Q. So you looked at not only samples of
5 the handwriting of the suspect but also of some
6 23 to 30 other people in that case?
7 A. That is correct.
8 Q. In connection with analyzing the
9 ransom note that was found at the Ramsey home
10 in connection with the death of JonBenet Ramsey,
11 you looked at the handwriting exemplars of how
12 many people?
13 A. Three people.
14 Q. Who were those three?
15 A. Mr. Ramsey, Mrs. Ramsey, and Mr.
16 Wolf.
17 Q. Did you ask to have other exemplars
18 of the handwriting of other people presented to
19 you so that you could analyze similarities
20 between those other persons' handwriting and the
21 ransom note?
22 A. Yes. I asked Mr. Hoffman that if
23 there were any other people available that were
24 connected with the event if he were able to get
25 their handwriting samples; and he told me that
0174
1 those samples had already been gone through by
2 the document examiners at the CBI and that they
3 had been ruled out. So, for the moment what I
4 had available to me were those three people that
5 I named there.
6 Q. Do I understand correctly that Mr.
7 Hoffman told you that every other potential
8 author had been eliminated by the CBI?
9 A. By the document examiners involved
10 over there, that's correct; that's what I was
11 told.
12 Q. And eliminated based on comparing
13 their handwriting?
14 A. That they weren't suspects for
15 writing the ransom note.
16 Q. Have you written a report concerning
17 your comparison of the handwriting of Chris Wolf
18 to the handwriting of the ransom note?
19 A. Have I written a report?
20 Q. Yes.
21 A. No, I have not.
22 Q. Why was that?
23 A. I wasn't asked to write a report.
24 Q. Sorry?
25 A. I wasn't asked to write a report.
0175
1 Q. What was your conclusion about Mr.
2 Wolf?
3 A. I found a few similarities, but they
4 weren't anything like I found between Patsy
5 Ramsey's handwriting and the ransom note writer.
6 I found a multitude of similarities between her
7 handwriting and the ransom note writer, and
8 they're quite glaring.
9 Q. Did you put on paper a list of
10 similarities between Mr. Wolf's handwriting and
11 that in the ransom note?
12 A. Not on paper like in that form, no.
13 Q. Well, in any form did you put
14 similarities on paper between Mr. Wolf's
15 handwriting and that you found in the ransom
16 note?
17 A. I made notations.
18 Q. Where are those notations?
19 A. I don't have them here with me
20 today, but I may have circled certain letters or
21 underlined certain letters that corresponded with
22 certain items that I saw in the ransom note.
23 (A telephone rings.).
24 I'm sorry. I thought I turned that
25 off.
0176
1 MR. ALTMAN: Go off the record.
2 THE VIDEOGRAPHER: Going off the
3 record at 3:10.
4 (A recess was taken.)
5 THE VIDEOGRAPHER: Back on the video
6 record at 3:22.
7 Q. (By Mr. Rawls) Ms. Wong, I wanted
8 to make sure I understand correctly exactly what
9 Mr. Darnay Hoffman told you about why you were
10 furnished handwriting exemplars of three people
11 and why you were not given any more when you
12 asked Mr. Hoffman for handwriting exemplars of
13 others who might have been associated with the
14 events of the death of JonBenet.
15 First, in your words, can you tell
16 me exactly what Darnay Hoffman told you?
17 A. Oh, it was just my understanding
18 that they were going to be available and that
19 the CBI document examiners had already ruled out
20 a lot of the suspects. So in this case, he
21 wanted me to look at the three handwriting
22 samples that were sent to me of Mr. Wolf, Mr.
23 Ramsey and Mrs. Ramsey. And actually,
24 basically, I think that is what your experts
25 looked at also, according to their reports.
0177
1 Q. Did Mr. Hoffman tell you that the
2 CBI had eliminated all other suspects based upon
3 their handwriting?
4 A. That is what I am assuming because
5 of the document examiners looking at them.
6 Q. Did you assume that -- excuse me.
7 Let me start over. Did you rely on that
8 assumption when you formulated your own report
9 comparing Patsy Ramsey's handwriting to the
10 ransom note?
11 A. I am sorry? Ask me that again.
12 Q. Sure. Did you rely in formulating
13 your own conclusions about similarities between
14 Patsy Ramsey's writing and the ransom note, did
15 you rely on the understanding that the CBI had
16 eliminated many other suspects based on their
17 handwriting?
18 A. I kept that in my mind, but I
19 realized in this case that I had three different
20 exemplars to look at. And I looked at them.
21 If I felt that I needed more, then I would
22 have said something; but in this case the
23 similarities were just so overwhelming with
24 regard to Patsy Ramsey's handwriting linking her
25 to the ransom note that I can't see that there
0178
1 is any other possibility unless there is someone
2 out there, who, I don't know, in some foreign
3 country with writing like that. But there is
4 so many unique similarities to her handwriting.
5 I have over 130 points, items on my exhibits,
6 and 157 went to similarity.
7 And In order to find that in any
8 other person's handwriting would be quite, quite,
9 quite rare.
10 Q. But you have looked for those
11 similarities only in the handwriting of three
12 different individuals?
13 A. In this case, that is correct.
14 Q. And when you first decided that
15 Patsy's handwriting appeared to you to be very
16 similar to the handwriting in the ransom note,
17 at that time you had only looked at Patsy's
18 handwriting; am I correct?
19 A. That is correct. There were a lot
20 of unique similarities.
21 Q. So Chris Wolf's handwriting exemplars
22 were furnished to you for the first time when?
23 A. It has been a while ago. You might
24 have to ask Darnay for help on this.
25 Q. Can you tell me the year?
0179
1 A. Last year sometime?
2 Q. Are you telling me or asking me?
3 A. Oh, I am thinking. I think it is
4 last year sometime. That is the best of my
5 memory.
6 Q. Well, the case was filed by Chris
7 Wolf in the year 2000.
8 A. Uh-huh (affirmative).
9 Q. And it was only 2001 when you looked
10 at handwriting exemplars furnished by Chris Wolf?
11 A. I believe so. That is the best
12 time frame I can think of. I don't know why
13 last year sticks in my head.
14 Q. When this complaint was filed in the
15 year 2000, it attached, or at least the
16 mandatory disclosures filed with the complaint
17 attached an opinion of yours that it was
18 probable that Patsy was the author of the ransom
19 note. So is it your testimony that it was
20 months after Chris Wolf's suit was filed and
21 months after you committed professionally to
22 having an opinion that Patsy Ramsey wrote the
23 note that you then made an unbiased analysis of
24 Chris Wolf's hand and found only a few
25 similarities, fewer than those of Patsy Ramsey's
0180
1 hand?