2 A. Actually, my opinion with Patsy
3 Ramsey writing the note back then, after
4 receiving the exemplars, the extensive exemplars
5 that were taken by the CBI more than confirms
6 my opinion with that regard.
7 Q. But you didn't look at the
8 handwriting of Chris Wolf until last year?
9 A. That is the best of my memory.
10 Q. To compare it to the ransom note?
11 A. That is correct. I wanted to make
12 sure and look at -- Mr. Hoffman asked me to
13 compare it to the ransom note.
14 Q. And you knew if you determined that
15 Chris Wolf had done it, you probably would never
16 get on radio or television again?
17 A. That is not what was important to
18 me. What was important to me is that the
19 evidence that I found is quite overwhelming that
20 Patsy Ramsey wrote the note. And it is
21 important for people to know. Someone has to
22 speak up for JonBenet, and that is why I am
23 here doing this pro bono. And if my opinion
24 had changed, well, so be it, then I would
25 rather clear somebody of something. It is quite
0181
1 horrible to think that a mother was involved in
2 some way.
3 Q. You told us about your media
4 appearances earlier?
5 A. That is correct.
6 Q. In print, on radio, and on
7 television?
8 A. That is correct.
9 Q. On all of those occasions, in all of
10 those media, the subject of the article or the
11 broadcast was your conclusion that Patsy Ramsey
12 authored the ransom note; was it not?
13 A. Actually, I will make an addition
14 there. I remember that is another -- I was
15 interviewed recently -- not recently, earlier
16 this year with regards to the anthrax letters.
17 The station had copies of it; they wanted me to
18 look them over, and I did.
19 Q. So you were once in the media on
20 something other than the JonBenet Ramsey death?
21 A. That is correct. And most all of
22 us involved in this case have been mentioned in
23 one way or another in some form in some part
24 of the media.
25 Q. Back to my question about the other
0182
1 media appearances involving you.
2 A. Sure.
3 Q. Those that involve the JonBenet
4 Ramsey matter, did all of those media
5 appearances or quotes involve your assertion that
6 Patsy Ramsey was the author of the ransom note?
7 A. I am not sure if they all included
8 that. Some of these I didn't even see.
9 Sometimes they just interview me and I don't see
10 the interview.
11 Q. But every time you were interviewed,
12 you expressed your opinion that Patsy Ramsey
13 authored the ransom note; did you not?
14 A. Oh, I showed on my exhibits how I
15 came to my opinion; and that was my opinion.
16 Q. And when you came to your opinion
17 the first time that Patsy was probably the
18 author of the note, had you even studied the
19 handwriting of John Ramsey?
20 A. I saw certain portions of Mr.
21 Ramsey's handwriting, but I was not given
22 specific samples.
23 Q. And were you given an assignment to
24 compare John Ramsey's handwriting to that of the
25 ransom note?
0183
1 A. During what time period?
2 Q. The first time you reached the
3 conclusion that Patsy was probably the author?
4 A. They were not given to me. But I
5 was able to obtain some.
6 Q. What is SERAPH, S-E-R-A-P-H?
7 A. S-E-R-I-F. Oh, S-E-R-A-P-H. You
8 are talking about the organization?
9 Q. Yes.
10 A. Yes. That is owned by Mr. Dale
11 Yeager, and he has an organization. And he
12 wanted to know if he could put my name on his
13 website so if any of his clients needed document
14 examination work that he could refer them to me.
15 Q. Have you ever been affiliated with
16 or associated with SERAPH?
17 A. In what way?
18 Q. You tell me.
19 A. Oh, I haven't done any work -- he
20 hasn't had the occasion to call -- oh, yes, he
21 has. He had a client that needed document
22 examination work, and so Mr. Yeager had his
23 client contact me.
24 Q. Is that the only association you
25 have ever had with SERAPH?
0184
1 A. Yes, that is correct.
2 Q. SERAPH, you understand to be most
3 involved in the JonBenet Ramsey matter; do you
4 not?
5 A. To a small degree, but that is all
6 I know.
7 Q. And what do you understand the
8 involvement of SERAPH to be in connection with
9 the JonBenet Ramsey death?
10 A. I just know that Mr. Yeager was
11 involved and it had to do with the note, but
12 it had nothing to do with document examination.
13 (Defendants' Exhibit-6 was marked for
14 identification.)
15 Q. (By Mr. Rawls) Ms. Wrong, this is
16 Defendant's Exhibit 6. This consists of pages
17 we have taken from the website of SERAPH.
18 Would you please turn to page 8, Ms. Wong. It
19 is the last page of that exhibit.
20 There is on the website of SERAPH a
21 page which at the top says Handwriting and
22 Document Analysis, and on that page is your
23 name --
24 A. That is correct.
25 Q. -- and some of your training. Did
0185
1 you furnish this information to SERAPH?
2 A. Some of the information, and then he
3 retyped it in his form and put it on here.
4 Q. Did you provide your client list to
5 Dale Yeager?
6 A. Yes. That is something that is
7 listed in some of my papers.
8 Q. Okay. Did you provide the client
9 list that included Fortune 500 companies such as
10 Norfolk Southern, IBM, and John Grisham, Junior?
11 A. Yes. To Mr. Yeager?
12 Q. Yes.
13 A. Yes, that is correct.
14 Q. What have you done for IBM?
15 A. IBM, I taught a document examination
16 course to their investigators in Raleigh, North
17 Carolina.
18 Q. How long was that course?
19 A. That was a day, and it was in the
20 fall sometime. And in the fall, that is all I
21 can remember.
22 Q. What were you paid for that?
23 A. Good question. I can't remember.
24 It was through the Certified Fraud Examiners.
25 They asked me to teach a course on document
0186
1 examination to the IBM investigators.
2 Q. When were you hired by John Grisham?
3 A. That would be 19 -- it is my memory
4 1996 or 1997.
5 Q. Did you give any testimony with
6 respect to that --
7 A. No, I did not.
8 Q. -- engagement?
9 Is this the author, John Grisham?
10 A. That is correct.
11 Q. What was your engagement by John
12 Grisham?
13 A. I am sorry. What?
14 Q. What was the nature of your
15 engagement by John Grisham?
16 A. With regards to what the case was?
17 Q. Yes.
18 A. I am limited to what I can say, but
19 it had to do with anonymous writing. And the
20 date, I am sorry. The date I said was -- what
21 did I say? '96, '97. It could be anywhere
22 from'96 to '98. I just can't remember exactly
23 when.
24 Q. You just told me you were limited to
25 what you can say. Why is that?
0187
1 A. Mr. Grisham asked us not to discuss
2 that case.
3 Q. What was the anonymous writing that
4 you were hired by John Grisham to study?
5 A. What do you mean?
6 Q. I --
7 A. I guess I --
8 Q. I can't be more specific than that.
9 My question is what was --
10 A. What did it say or--
11 Q. -- the anonymous document that you
12 were hired to study?
13 A. Oh. A multitude of anonymous
14 letters.
15 Q. Was it your purpose to determine who
16 wrote the letters?
17 A. That is correct.
18 Q. Did you reach such a decision?
19 A. I reached a probability.
20 Q. And you decided that -- well, were
21 you given a number of suspects by Mr. Grisham?
22 A. We asked how many people he
23 suspected. And we received, I am trying to
24 think, handwriting exemplars of one or two
25 people.
0188
1 Q. So he gave you handwriting exemplars
2 on one or two suspects?
3 A. Yes. I am trying to think. Yes.
4 That is the best of my memory right now.
5 Q. Did you ask him for more suspects?
6 A. I asked him, you know, as many as
7 he thought; and he narrowed it down to one or
8 two.
9 Q. And did you decide that one or two
10 -- that one of the one or two had probably
11 authored the multitude of anonymous letters?
12 A. That probably that one person was
13 involved.
14 Q. And what is the -- what was the
15 outcome of all of that?
16 A. I told him that I would need to
17 obtain additional handwriting exemplars, and I
18 haven't received any additional handwriting
19 exemplars from him, so.
20 Q. The fact is you got sued about that
21 case; did you not?
22 A. That woman is suing everybody,
23 everybody that --
24 (Telephone busy signal.)
25 MR. RAWLS: Let's go off the record.
0189
1 THE VIDEOGRAPHER: Going off the
2 record at 3:39.
3 (A recess was taken.)
4 (Discussion ensued off the record.)
5 THE VIDEOGRAPHER: Back on the
6 record at 3:41.
7 Q. (By Mr. Rawls) Ms. Wong, did we,
8 when we went off the record, did we interrupt
9 your answer or have you finished?
10 A. If you want to ask the last
11 question, then that will help refresh my memory.
12 Q. The fact is that you were sued in
13 connection with the work you did for John
14 Grisham; were you not?
15 A. That woman sued everybody, anybody's
16 name who was involved in that case.
17 Q. So the answer is yes --
18 A. Yes.
19 Q. -- you were sued?
20 A. Uh-huh (affirmative). Not just
21 me --
22 Q. And In addition --
23 A. -- though.
24 Q. In addition, your client, John
25 Grisham, was sued also, correct?
0190
1 A. That is correct.
2 Q. Several other defendants were also
3 sued?
4 A. Yes, that's correct.
5 Q. The person who sued is the woman
6 that you concluded had probably written the
7 anonymous letters; am I correct?
8 A. That is correct.
9 Q. Her name is Katherine Almy?
10 A. I believe that is correct.
11 Q. A-L-M-Y?
12 A. Uh-huh (affirmative).
13 Q. And Ms. Almy took a polygraph test
14 at her own insistence; did she not?
15 A. As far as I understand, yes.
16 Q. And according to Ms. Almy, the
17 polygraph test indicated that she was truthful
18 and had not written the anonymous notes,
19 correct?
20 A. From what I understand; but I am not
21 a polygraph expert, so I don't know what
22 happened in that test. And there was also a
23 document examination report done by a state
24 document examiner, and he could not eliminate
25 her as a writer either.
0191
1 Q. Do you have counsel assisting you in
2 that lawsuit?
3 A. Yes, I do.
4 Q. Is that the same counsel that is
5 assisting John Grisham?
6 A. No, it is not.
7 Q. Who is your attorney?
8 A. Mr. Morin.
9 Q. Would you spell that, please?
10 A. M-O-R-I-N.
11 Q. And what is his full name and
12 location?
13 A. Donald Morin in Charlottesville,
14 Virginia.
15 Q. Is he defending anybody else in that
16 case?
17 A. No.
18 Q. Do you have, Ms. Wong, any liability
19 insurance that is providing you coverage for
20 your opinion in that case?
21 A. No, I do not.
22 Q. When you were hired by Mr. Grisham,
23 did you handle that matter pro bono?
24 A. No, I did not.
25 Q. So you charged him a fee for your
0192
1 work?
2 A. That is correct.
3 Q. Did you provide John Grisham a
4 written report about your conclusion regarding
5 Ms. Almy?
6 A. Yes.
7 Q. Do you have a copy of that?
8 A. No, I do not.
9 Q. I don't mean with you here today.
10 Do you have a copy anywhere?
11 A. Oh, yes, I do.
12 Q. And I asked you earlier, Ms. Wong,
13 about your look at the handwriting exemplars of
14 Mr. Chris Wolf's handwriting which were furnished
15 to you by Mr. Darnay Hoffman.
16 A. That is correct.
17 Q. And you told me that you made
18 notations. You would underline some letters.
19 Where are those notations that show your
20 conclusions about Mr. Wolf?
21 A. Those are back in Norfolk, Virginia.
22 Q. How many similarities did you find?
23 A. Off the top of my head, I can't
24 remember exactly how many; but I did see some
25 similarities, but way more dissimilarities.
0193
1 Q. So you looked at dissimilarities in
2 connection with Mr. Wolf?
3 A. Not just dissimilarities. I looked
4 at both, and I found some similarities, but I
5 found a greater amount of dissimilarities.
6 Q. How many dissimilarities did you find
7 of Patsy Ramsey?
8 A. What I found in her handwriting were
9 variations. And we all have a certain range of
10 variations. And actually, in one of your --
11 the reports of Mr. Cunningham, what he shows is
12 certain variations notated as the person who
13 wrote the ransom note actually are in Patsy
14 Ramsey's handwriting.
15 Q. Ms. Wong, do you remember the
16 question that I asked you?
17 A. I am sorry.
18 Q. How many dissimilarities did you find
19 between Patsy Ramsey's handwriting exemplars and
20 the ransom note?
21 A. Any of what I found were variations.
22 And every once in a while you will find an
23 accidental, which can be considered -- some
24 people see it as a difference, but sometimes it
25 just happens once in every two to 300 samples
0194
1 when you write.
2 Q. Ms. Wong, again, do you remember the
3 question that I asked you?
4 A. I keep thinking I am answering it
5 the best I can. I am sorry if I am not
6 answering it correctly. I don't know how many
7 exactly, but --
8 Q. So the answer is you don't know how
9 many dissimilarities between Patsy Ramsey's
10 handwriting and those in the ransom note?
11 A. Very, very, very few, and they are
12 considered variations in her handwriting.
13 Q. By you?
14 A. That is my opinion.
15 Q. You don't know how many
16 dissimilarities, and you didn't count them
17 because you decided you would treat them all as
18 variations, not as dissimilarities?
19 A. Oh, that's not true. Because they
20 are all within the realm of her handwriting and
21 skill. Now, if she were not capable of it, then
22 there would be significant dissimilarities.
23 Q. How many pages of notations do you
24 have back in your office about the similarities
25 or dissimilarities between Chris Wolf's
0195
1 handwriting exemplars and the ransom note?
2 A. How many pages?
3 Q. Yes.
4 A. I am not sure. It is just in a
5 file.
6 Q. Will you agree to furnish those to
7 us if you are so advised by Mr. Hoffman and
8 Mr. Altman?
9 MR. ALTMAN: No objections. Darnay?
10 MR. HOFFMAN: I have no objections.
11 THE WITNESS: I would be happy to.
12 MR. ALTMAN: We will get that to
13 you.
14 (Defendants' Exhibit-7 was marked for
15 identification.)
16 Q. (By Mr. Rawls) This is Defendant's
17 Exhibit 7, Ms. Wong. Do you recognize that?
18 A. Uh-huh (affirmative).
19 Q. Is that, in fact, a true copy of a
20 document which you authored and presented to
21 John Grisham?
22 A. That appears to be.
23 Q. And this appears to have been signed
24 by yourself as well as by David Liebman --
25 A. That's correct.
0196
1 Q. -- is that correct?
2 A. That is correct.
3 Q. Did he make his examination separate
4 from yours?
5 A. Yes. Always.
6 Q. So as you go through this letter,
7 which of those opinions were yours and which
8 ones were his?
9 A. I don't understand what you are
10 saying.
11 Q. Well, I assume since you made
12 separate and independent analyses, you and Mr.
13 Liebman, some of these findings were yours and
14 some of these findings were his?
15 A. Actually, both came to the same
16 conclusions.
17 Q. I see. And that conclusion is
18 worded in the paragraph on page 2 that begins
19 with the language, quote, Based upon thorough
20 analysis of these items?
21 A. Uh-huh (affirmative).
22 Q. And is this the opinion that
23 resulted in your being sued by Ms. Almy?
24 A. Mr. Grisham took this opinion to a
25 detective, and the detective wanted -- which
0197
1 warranted a further investigation. And Ms. Almy
2 was not pleased with the investigation, which is
3 my understanding is how this whole lawsuit came
4 up.
5 Q. Now, that document that is in front
6 of you, Defendant's Exhibit 7, and on page 2 in
7 the paragraph beginning: Based upon thorough
8 analysis, you describe the fact that there are
9 similarities, but you do not mention differences.
10 Is that correct?
11 A. There appears to be some
12 similarities.
13 Q. And you base --
14 A. So, obviously, there are some things
15 that are different but are within the realm of
16 her handwriting skill.
17 Q. So you based your opinion on the
18 number of similarities; did you not?
19 A. In this case, the similarities
20 outweighed the differences in variations.
21 Q. This case being the matter of John
22 Grisham and Katherine Almy?
23 A. That is correct.
24 Q. And you went on in your conclusion
25 to say: Anonymous letters by their very nature
0198
1 are often written in a disguised manner to hide
2 the identity of the writer.
3 Did I correctly read that sentence
4 in your conclusion?
5 A. Yes.