2 Q Have you ever met Chris Wolf?

3 A No, I haven't.

4 Q Have you ever had any conversations or

5 communications with Darnay Hoffman?

6 A I seem to recall that I have, but it's

7 been several years.

8 Q Do you have any recollection of the

9 subject matter of those -- that communication or

10 those communications, if there were more than one?

11 A To the best of my recollection, it was

12 around the issue of that we should file charges

13 against Patsy Ramsey because he believed she was the

14 author of the ransom note.

15 Q Did he submit handwriting experts or

16 people he represented as experts to you or to the

17 Boulder Police Department?

18 A Before we go on, is this beyond Chris Wolf

19 questions?

20 MR. MILLER: No, I think it's a Chris Wolf

21 question.

22 THE DEPONENT: Okay.

23 MR. MILLER: As I understood, you asked he

24 being, who, Darnay?

25 MR. WOOD: Darnay Hoffman.

25

1 A In relation to Chris Wolf?

2 Q (BY MR. WOOD) Well, the reason I'm asking

3 you is that he has presented experts in the Chris

4 Wolf case and I'm trying to find out whether he had

5 earlier presented those experts in terms of it may or

6 may not have related to Chris Wolf at the time. I

7 don't know that until I go into that area with you.

8 But obviously he may be using the same people now in

9 part that he was using back then. So I'm curious as

10 to whether that's true. Whether he gave -- I know he

11 contacted Alex Hunter and sent him information.

12 A Right.

13 Q Do you think that the contact that Hoffman

14 had with you was in that same time frame or do you

15 know?

16 A I believe it was, yes.

17 Q Do you believe it would have been sometime

18 in 1997 or 1998?

19 A I don't think it was '97, probably '98.

20 Q Back to what I was trying to get to. Do

21 you know whether he sent to you one or more reports

22 from individuals that he alleged to be handwriting

23 experts?

24 A Yes, I do recall that. Now, I don't know

25 whether that came directly from him or through the

26

1 DA's office.

2 Q Do you recall the names of any of those

3 individuals?

4 A No, I don't.

5 Q Tom Miller ring a bell?

6 A Yes, but I don't know if that's one that

7 he submitted or not.

8 Q David Liedman?

9 A Rings a bell.

10 Q Cina Wong?

11 A Rings a bell.

12 Q Regardless of who they may have been, were

13 those individuals in terms of what the department did

14 with that information, were they accepted as experts,

15 do you know, or was it basically a situation where

16 the department did not feel that they were qualified

17 or competent in their opinions?

18 A Neither. It's something that we really

19 didn't put a whole lot of consideration into because

20 they were not people that as far as we were aware of

21 had access. We knew they didn't have access to the

22 originals, to all the material that we had. We

23 didn't know who these people were. We didn't know

24 who Darnay Hoffman was. Much like anybody sending us

25 material of what I call, you know, their

27

1 self-appointed investigators, we didn't put much

2 stock into.

3 Q One of the problems and if I hear you, is

4 that I take it from whatever source your

5 understanding of handwriting analysis would have

6 required that there be an analysis of the firsthand

7 documents as opposed to second or third generations?

8 MR. MILLER: I think I will object at this

9 point. I don't know that that has got anything to do

10 with Chris Wolf.

11 MR. WOOD: I'm trying to find out about

12 these particular experts. He indicated one of the

13 reasons that he -- they didn't really consider them

14 was because I thought that they did not have access

15 to the originals. And I just wondered if that was

16 based on his understanding that you needed access to

17 the originals to be able to do an analysis. He may

18 or may not know. If you don't want him to answer,

19 I'll --

20 MR. MILLER: I don't think this has got

21 anything to do with Chris Wolf.

22 THE DEPONENT: Okay.

23 Q (BY MR. WOOD) Did you -- did the Boulder

24 Police Department ever have Chris Wolf's handwriting

25 analyzed?

28

1 A Yes.

2 Q Okay. How many different handwriting

3 analysts looked at Chris Wolf's handwriting?

4 A As far as I'm aware of, one.

5 Q Did Leonard Speckin look at Chris Wolf's

6 handwriting?

7 A I'm not sure.

8 Q Did Edwin Alford look at Chris Wolf's

9 handwriting?

10 A I'm not sure.

11 Q Did Richard Dusak analyze Chris Wolf's

12 handwriting?

13 A I'm not sure.

14 Q Did Chet Ubowski analyze Chris Wolf's

15 handwriting?

16 A Yes.

17 Q The other individuals Speckin, Alford and

18 Dusak, were employed by the Boulder Police

19 Department --

20 A Yes.

21 Q -- to analyze handwriting?

22 A Yes.

23 Q Is there any reason why you don't know

24 whether they actually analyzed Chris Wolf's?

25 A I just can't recall what was submitted to

29

1 them at this time.

2 Q Was the normal practice to have an

3 individual who you made a decision you wanted a

4 handwriting analysis performed on, was it the

5 practice to have that individual, his handwriting or

6 her handwriting analyzed by four different examiners?

7 A Was that the practice?

8 Q Yeah, was that the way you all did it?

9 A No.

10 Q How did you make the distinction between

11 the numbers of analysis that you would have done on a

12 given handwriting?

13 A I'm not sure this is --

14 MR. MILLER: I don't know. He has

15 answered the question about Chris Wolf.

16 MR. WOOD: He's telling me he knows

17 Ubowski did it and he's not sure whether the others

18 did. He said there were four that were hired that

19 apparently I would like to find out what would put

20 one in the category of having one or two versus three

21 or four if that's the case and that would help answer

22 perhaps Chris Wolf's standing or status and I won't

23 know until I get an answer.

24 MR. MILLER: Let me just suggest that the

25 question you asked almost sounds like a policy

30

1 question or an investigative technique question as

2 opposed to specifically why they did what they did on

3 Chris Wolf. I think if you ask that question it's

4 probably acceptable.

5 MR. WOOD: I'm trying to find out why and

6 I don't think I can really get to Wolf unless I

7 understand the process.

8 Q (BY MR. WOOD) I mean you had four

9 examiners and my question tries to find out the

10 answer to why Wolf would have been only analyzed by

11 one versus more than one. Was it the results of the

12 first? I mean, I don't know.

13 MR. MILLER: I think he can answer that

14 question why he was analyzed by one, if you know.

15 A Yeah, see at this point I don't know

16 whether we submitted his to anybody else or not. I'm

17 not sure on that so I can't answer that.

18 Q (BY MR. WOOD) That's what I'm trying to

19 find out, if you knew, if you know what generally

20 would cause the department to submit the handwriting

21 exemplar or exemplars to more than one?

22 A Well, one of the fact -- there were

23 numerous factors. I think one of the critical

24 factors was to the degree that CBI could eliminate

25 somebody from being the writer of the note.

31

1 Q And I don't want to get deep into the

2 question of handwriting issues, but when you say

3 could eliminate, do you mean as handwriting question

4 document examiners use that term?

5 A Sure.

6 Q Did they actually eliminate and say that

7 we are confident that within our reasonable certainty

8 this person did not author the note, as compared to

9 some people that say elimination might involve no

10 indications? Do you understand the difference?

11 A Yes, and that's somewhat of what we run

12 into is how they classify those documents. So you

13 really have to have conversations with those people.

14 A lot of times you say what do you mean by this? And

15 so it really came down to this person didn't write

16 the note. You know, I can tell you this person

17 didn't write the note kind of thing.

18 Q Without perhaps putting a formal --

19 A Right.

20 Q -- label to it?

21 A Right, correct.

22 Q Do you recall what was concluded with

23 respect to Chris Wolf?

24 A The conclusion was he didn't write the

25 note.

32

1 Q And was there a written report or analysis

2 of Chris Wolf's handwriting?

3 A Yes.

4 Q Done by Mr. Ubowski?

5 A Yes.

6 Q Do you recall when that analysis was done?

7 A Well, there were several, actually,

8 because we had different, as I recall that, we had

9 different pieces of his handwriting that we submitted

10 at different times. And so there were a couple of

11 times that his handwriting actually went through a

12 comparison. So I believe there were a couple reports

13 that actually came back with some of his samples that

14 had been compared on them.

15 Q Were there any similarities found, to your

16 recollection, between Mr. Wolf's handwriting

17 exemplars and the note?

18 A I don't recall what the exact language was

19 on the lab report.

20 Q Can you give me the dates of the reports?

21 A I believe March of '98, I believe.

22 Q Was the first one or both?

23 A Well, I don't know because there was -- I

24 believe there were some submitted in late '97,

25 November of '97. And then I'm not sure whether we

33

1 got it, I think we got a report back prior to March

2 of '98, but I'm not positive about that but I believe

3 we did. And then we submitted some additional or had

4 some additional comparisons done and then there was a

5 report in March of '98 as well.

6 Q Do you know why you all had the additional

7 comparisons done?

8 A Just trying to be thorough when we had

9 additional handwriting that was provided to us.