#0, Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:03 PM
1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA 2 ATLANTA DIVISION 3 ROBERT CHRISTIAN WOLF, 4 Plaintiff, CIVIL ACTION FILE 5 vs. NO. 00-CIV-1187(JEC) 6 JOHN BENNETT RAMSEY and PATRICIA PAUGH RAMSEY, 7 Defendants. 8 ~~~~~~~~~~~~~~~~~~~~~~~~~~ 9 VIDEOTAPED DEPOSITION OF 10 CINA L. WONG 11 May 13, 2002 9:45 a.m. 12 Sixteenth Floor 13 191 Peachtree Street, N.E. Atlanta, Georgia 14 15 Alexander J. Gallo, CCR-B-1332, CRR 16 17 18 19 20 21 22 23 24 25 0002 1 APPEARANCES OF COUNSEL 2 On behalf of the Plaintiff: 3 (via telephonic means) 4 DARNAY HOFFMAN, Esq. 5 Law Offices of Darnay Hoffman 6 Suite 209 7 210 West 70th Street 8 New York, New York 10023 9 (212) 712-2766 10 . 11 EVAN M. ALTMAN, Esq. 12 Law Offices of Evan M. Altman 13 Suite 300-B 14 6085 Lake Forrest Drive 15 Atlanta, Georgia 30328 16 (404) 845-0695 17 . 18 . 19 . 20 . 21 . 22 . 23 . 24 . 25 // 0003 1 On behalf of the Defendants: 2 JAMES C. RAWLS, Esq. 3 ERIC P. SCHROEDER, Esq. 4 S. DEREK BAUER, Esq. 5 Powell, Goldstein, Frazer & Murphy, L.L.P. 6 Sixteenth Floor 7 191 Peachtree Street, N.E. 8 Atlanta, Georgia 30303 9 (404) 572-6600 10 . 11 L. LIN WOOD, Esq. 12 L. Lin Wood, P.C. 13 2140 The Equitable Building 14 100 Peachtree Street 15 Atlanta, Georgia 30303 16 (404) 522-1713 17 . 18 Also Present: 19 David Stevens, Videographer 20 LaShaunda Cass, In-Training Court Reporter 21 . 22 . 23 . 24 . 25 . 0004 1 Videotaped Deposition of Cina L. Wong 2 May 13, 2002 3 THE VIDEOGRAPHER: On the video 4 record at 9:45, May 13, 2002. 5 MR. RAWLS: Very good. Alex, we 6 are on the written record as well, I assume. 7 If I may just briefly state, this is 8 the deposition of Ms. Cina Wong. 9 THE WITNESS: That is correct. 10 MR. RAWLS: And I hope I've 11 pronounced it correctly. 12 THE WITNESS: That's right. Like 13 Tina, but with a C. So you said it correctly, 14 Cina. 15 MR. RAWLS: Good. Thank you. And 16 the deposition is being taken by the defendants' 17 counsel for John and Patsy Ramsey, in a lawsuit 18 filed here in U.S. District Court in Atlanta on 19 behalf of the plaintiff Robert Christian Wolf. 20 The deposition is scheduled by 21 agreement, and the witness has voluntarily 22 appeared pursuant to that agreement and without 23 a subpoena. 24 Am I correct so far, Evan and 25 Darnay? 0005 1 MR. HOFFMAN: That is correct. 2 MR. ALTMAN: That is correct. 3 MR. RAWLS: Good. And we very much 4 appreciate all counsel having reached that 5 agreement and, Ms. Wong, your having been 6 present pursuant to that agreement. 7 The deposition is taken by the 8 defendants for all proper purposes under the 9 Federal Rules of Evidence and the Federal Rules 10 of Civil Procedure. 11 Those purposes, of course, include 12 but are not limited to discovery potential use 13 in evidence if appropriate under the Rules, 14 potential impeachment, et cetera. 15 Is that an agreeable stipulation up 16 to now? 17 MR. HOFFMAN: Yes. 18 MR. ALTMAN: Yes, it is. 19 MR. RAWLS: And may I further 20 propose that all objections except as to the 21 form of the question and the responsiveness of 22 the answer are reserved until the time of trial, 23 hearing, or other use of this evidence? 24 MR. ALTMAN: That is acceptable. 25 MR. HOFFMAN: Yes. 0006 1 MR. RAWLS: Good. Present, if I 2 may say so for the record, are by telephone 3 Darnay Hoffman and present in person Evan 4 Altman, both of whom represent the plaintiff, 5 Mr. Wolf. 6 Ms. Cina Wong, the witness is 7 present. 8 For defendants, Jim Rawls, Lin Wood, 9 and Eric Schroeder are present; and defendant 10 John Ramsey is present. As an observer, Matt 11 Wood is present. We have two court reporters 12 present, Alex Gallo and LaShaunda Cass. And we 13 have a videographer present, Mr. David Stevens. 14 And I was about to call you Steven, but I 15 would have misplaced your last name had I called 16 you Steven. Good. Thank you. 17 Are there any additional preliminary 18 matters we should raise? 19 MR. HOFFMAN: Just one, and we can 20 do this off the record if you want. We can 21 use your decision as to whether you want this 22 on the record or not. 23 I don't know how many of you are 24 aware of the fact that Cina recently just had 25 an operation, and she may need to stop a little 0007 1 bit more than might be the usual simply because 2 there may be some residual discomfort from any 3 of the sutures or -- not sutures, from the 4 incision and the operation. 5 So just please bear with her if she 6 needs to take an occasional break that, you 7 know, might seem a little bit more often than 8 is normal in a deposition. 9 MR. RAWLS: We fully understand. 10 And, Darnay, yes, Ms. Wong and Mr. Altman 11 brought that to our attention. 12 And, Ms. Wong, if at any time you 13 need a break, please say so. 14 THE WITNESS: Thank you. 15 MR. RAWLS: And we will take one. 16 Very good. Mr. Gallo, if you would 17 please keep time, we would appreciate it. And 18 Mr. Schroeder, if you would also keep a backup 19 time. I am certainly hopeful we will not be 20 at the full seven hours permitted under the 21 Federal Rules, but at the start of a deposition 22 one never knows. 23 Would you please administer the oath? 24 CINA WONG, having been first duly 25 sworn, was examined and testified as follows: 0008 1 EXAMINATION 2 BY-MR.RAWLS: 3 Q. Ms. Wong, for the record, would you 4 please state your full name? 5 A. Yes. My name is Cina, that's 6 spelled C-I-N-A. And the last name is Wong, 7 W-O-N-G. I do have a middle initial L. 8 Q. What does the L stand for? 9 A. That is all I have. 10 Q. Like Harry S. Truman, whose S, as I 11 understand it, did not stand for anything? 12 A. Oh, I didn't know that. Yes. I 13 just have an L. 14 Q. You have an L, and only an initial? 15 A. That is correct. 16 Q. And your date of birth, please, for 17 the record? 18 A. 10/26/62. 19 Q. And place of birth? 20 A. California. Mountain View, 21 California. 22 Q. Ms. Wong, do you have any relatives 23 that live in the Atlanta metro area? 24 A. No, I do not. Oh, hold it. Yes. 25 They just moved here. One. A cousin. 0009 1 Q. Who is that? 2 A. His name is Keith Soo. 3 Q. How is that spelled? 4 A. Oh, I'm sorry. I got him mixed up. 5 S-O-O. I'm sorry. Keith Soo. 6 Q. Keith? 7 A. I have two cousins. One is Keith 8 Koo, I'm sorry. K-O-O. He married into the 9 family. 10 Q. And is there a second cousin in the 11 Atlanta area? 12 A. No. His wife and his child will be 13 joining him shortly in the summer. 14 Q. And the person to whom you are a 15 cousin is who? 16 A. His wife. 17 Q. What is her name? 18 A. Her name is Wai-soo, W-A-I, hyphen, 19 S-O-O. 20 Q. Thank you. Do you know the 21 occupation of both of those individuals? 22 A. I believe he is a doctor in the 23 military, and she is taking care of their 24 daughter at home. 25 Q. Ms. Wong, you are here because it is 0010 1 our understanding that you have agreed to serve 2 as an expert witness on behalf of Mr. Wolf. 3 Am I correct? 4 A. That is correct. 5 Q. Would you tell us, please, when you 6 agreed to serve as such an expert witness? 7 A. Well, I met Darnay Hoffman. He 8 contacted me in '97, I believe. And the Chris 9 Wolf situation arose last year sometime, to the 10 best of my memory. 11 Q. How did you meet Darnay Hoffman? 12 A. He contacted our offices. 13 Q. Let us know, if you will, what you 14 recall as the first things that Mr. Hoffman said 15 to you. 16 A. He said that he had a copy -- 17 excuse me. I am losing -- sorry. 18 But Mr. Hoffman said that he was 19 interested in finding some handwriting experts 20 who would be interested in examining a ransom 21 note and some handwriting exemplars. 22 Q. Did he tell you why he had selected 23 you? 24 A. No, he did not. He just said he 25 had heard of us and that is why he contacted 0011 1 us. 2 Q. And what did you do, if anything, at 3 that time at Mr. Hoffman's request? 4 A. I told him that I would be more 5 than happy to look at the materials to see if 6 we could do anything for him or not. 7 Q. And what did you then do? 8 A. I had him -- I asked him to please 9 send the documents over and that we would look 10 at them when we received them. 11 Q. Did he send documents? 12 A. Yes, he did. 13 Q. What were they? 14 A. He sent a copy of a ransom note and 15 exemplars which consisted of copies of a 16 greeting card. I believe it started off with: 17 Hi, Bob. I am going from memory here. A 18 photograph of some boxes with Ramsey written on 19 it. A poster that had something written on it 20 to the effect of Welcome to the Northwest 21 Territory. A copy of a photo album page with 22 handprinting. And that is all that comes to 23 mind right now. There might have been another 24 one or two. 25 And there was a Polaroid. And I 0012 1 think it said Rainbow Fish Players underneath. 2 Q. And did you study those materials? 3 A. Yes, I did. 4 Q. Did you do that personally or did 5 someone else in your office do that? 6 A. No. At that time I was working 7 with David Liebman. And I did my own 8 independent analysis, and he did his own 9 independent analysis. 10 Q. What was the question that Mr. 11 Hoffman asked you to answer? 12 A. He wanted to know if -- and by the 13 way, the exemplars, we asked him if they had 14 been reviewed and confirmed by any other parties 15 of them being the handwriting exemplars of Patsy 16 Ramsey; and Mr. Hoffman said, yes, they have, 17 and they were confirmed by the housekeeper. And 18 I believe her name is Linda Hoffman-Pugh. And 19 Mr. Hoffman wanted to know if it was a 20 possibility or not that the person who executed 21 the exemplars known as Patsy Ramsey was the one 22 who wrote the ransom note. 23 Q. He asked if there was a possibility; 24 did you say? 25 A. A possibility or not.
#1, 2 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:04 PM
In response to message #0
0013 1 Q. What did you tell him, if anything, 2 in answer to that question? 3 A. I told him I would look at it and I 4 would not be able to give him an opinion in 5 any way until I looked at the materials and 6 rendered a systematic analysis. 7 Q. Did you quote him a fee for that 8 analysis? 9 A. I told him that we had a retainer 10 fee at that -- I can't remember what our fees 11 were at that time. And then he mentioned to 12 us that right now he wouldn't be able to pay. 13 He would be able to send us some money to 14 cover expenses, but he would ask us if we would 15 be interested in doing this pro bono. 16 Q. What was your reply? 17 A. I was very interested in seeing the 18 exemplars since this is a case that was widely 19 talked about in the media, so I told him that 20 I would be glad to. 21 Q. So did you agree to handle the 22 matter on a pro bono basis before you had 23 reached any conclusions about the authorship of 24 the ransom note? 25 A. That is correct. 0014 1 Q. And your reason for doing so had to 2 do with publicity surrounding the death of 3 JonBenet Ramsey? 4 A. It was a curiosity since I am a 5 document examiner to be able to see some of the 6 materials involved and to be able to come to my 7 own opinion. 8 Q. But your curiosity was aroused 9 because of the publicity attending the death of 10 JonBenet Ramsey; am I correct? 11 A. I take other cases on a pro bono, 12 but in this case I was curious and I was 13 interested. I don't know of any document 14 examiner in the country who wouldn't want to 15 look at that. 16 Q. And did you, in 1997, reach a 17 conclusion at the request of Mr. Hoffman? 18 A. According to the information that was 19 available to us, there was a good probability 20 that the writer -- that there were quite a few 21 similarities with the exemplars written by Patsy 22 Ramsey linking her to the ransom note. And I 23 told Mr. Hoffman that I would like additional 24 materials if he could obtain those for me to 25 see, additional exemplars. And that is where we 0015 1 left off there for a while. 2 Q. Do you continue to serve pro bono 3 today? 4 A. Yes, that is correct. 5 Q. And would it be correct, then, that 6 the only moneys you have received on behalf of 7 Mr. Chris Wolf, the plaintiff in this case, have 8 been sums to reimburse expenses? 9 A. Since Mr. Wolf came on the scene, I 10 haven't even received those. I have taken this 11 on pro bono, and whatever time or materials I 12 have put in is on my behalf. 13 Q. Is your travel expense to Atlanta 14 being reimbursed by Mr. Wolf? 15 A. That is being reimbursed. Thank 16 you. 17 Q. Ms. Wong, would you please tell us 18 about your educational background? 19 A. I received a Bachelor's degree from 20 San Jose State University. And upon my 21 graduation I wanted to learn -- I've wanted to 22 get in the field of document examination. I've 23 wanted to do that since I was 15. But I had 24 trouble finding information as where to start. 25 But after I graduated someone told me to speak 0016 1 to a Mr. Ted Widmer in San Francisco. He said 2 that he teaches -- he is a document examiner, 3 and he is a graphologist. And I said, well, I 4 am not interested in learning about graphology, 5 and I said I am only interested in learning 6 about document examination. 7 And he said that there are some 8 similarities between the both, but graphology, 9 you tell personality, and with document 10 examination, you identify. And I said, well, I 11 am only interested in identifying. 12 And he said, well, I am giving a 13 course if you want to sit in on the course. 14 It covers some of the similarities between what 15 you need to know in handwriting sciences, which 16 would be proportion, slant, how letters and 17 sentences are in relationship to the baseline, 18 alignment, certain letter formations, pressure 19 patterns, and so forth. So in the end I ended 20 up taking additional courses from Mr. Ted Widmer 21 that were document examination related. 22 And from there I joined the National 23 Association of Document Examiners, which I am 24 also board certified through. 25 There are some groups out there 0017 1 where you are able to receive your certification 2 by paying a fee, and that is not how I 3 received my certification. In this case I had 4 to first qualify to even fill out an 5 application. In order to qualify, you had to 6 have had at least five court testimonies or 7 three court testimonies and two depositions. 8 And then you were able to fill out an 9 application for a certification. 10 From there you have to take a 11 written test, an extensive written test. You 12 have to pass that. After you pass the written 13 test, then you have to go on to, they have 14 like a mock trial; and you have to pass that 15 oral exam where you were sent a case and you 16 present the case in front of a judge and two 17 attorneys, and you are graded on how well you 18 do. If you pass that, then you are certified 19 through the National Association of Document 20 Examiners. 21 And from -- after I joined the 22 National Association of Document Examiners, they 23 offered some mentorship programs with some of 24 their more experienced members. And I was 25 considering one in Philadelphia, and the other 0018 1 one was in Norfolk, Virginia. I decided to 2 take the one in Norfolk, Virginia, and I studied 3 with Mr. David Liebman. And I did a three-year 4 internship with him strictly on document 5 examination, where he taught me how to 6 systematically approach a case, how to analyze 7 it, what to look for, and so forth. 8 And I also took a college course 9 through Larry Zigler, who used to work as a 10 document examiner for the FBI. And that was at 11 Annadale College in Virginia. And I also took 12 a special course through John Hargett, who at 13 that time was the chief document examiner for 14 the Secret Service. 15 So I've trained with a lot of other 16 people. And then I have training from Larry 17 Zigler and John Hargett who teach other 18 government document examiners in the FBI and the 19 Secret Service. 20 Q. Thank you, Ms. Wong. Would you 21 please tell us what was the nature of the B.A. 22 degree that you obtained at San Jose State? 23 A. It is in mass communications, and it 24 was concentrating in advertising. And how that 25 actually helps me in the field of document 0019 1 examination is that when I got into advertising, 2 it was right at the brink of when computers 3 were being put into advertising offices and 4 using it for graphics. I worked in a small 5 firm where a lot of the layout work, when you 6 -- for magazines and ads were still done by 7 hand. 8 My boss was very strict, and I thank 9 her for it now, because she taught me to be 10 sensitive to when certain things are out of 11 alignment. So my specialty is in pasted 12 forgeries and to identifying if something was 13 done as a paste-up job and then photocopied. 14 And people try to pass documents like that off 15 as originals when, in fact, they are not. 16 Q. What was the date of your degree at 17 San Jose State? 18 A. Oh, when I graduated? 19 Q. Yes. 20 A. 1990, I believe. 21 Q. Where had you attended high school? 22 A. Notre Dame Preparatory. 23 Q. And where is that, please? 24 A. In Belmont, California. 25 Q. What year did you complete high 0020 1 school? 2 A. In 1981. 3 Q. What career did you have, if any, 4 between 1981 and your entry into San Jose State? 5 A. I didn't have a career. I am 6 fortunate enough that my parents have worked 7 very hard; and if I wanted to travel, they 8 would allow me to travel. And so I went to 9 school and I traveled. That explains the great 10 time span in between. 11 Q. So when did you begin at San Jose 12 State, approximately? 13 A. Oh, that is a good question. I 14 can't remember. I started up and I stopped, 15 went traveling, came back again, so. I am 16 sorry. I can't give you an exact date on 17 that. But I went part-time through college. 18 Q. And if I am not mistaken, when you 19 were summarizing your degree at San Jose State, 20 you shared with us that as a document examiner 21 your specialty is in pasted up forgeries; am I 22 correct? 23 A. I do all aspects of document 24 examination; but in that area, I am very strong. 25 Q. Is there any element of a paste-up 0021 1 forgery involved in the ransom note, in your 2 opinion, that you reviewed with reference to the 3 death of JonBenet Ramsey? 4 A. As I understand that there were 5 originals available, which I did request and I 6 was told that they weren't available. There 7 were some destructive tests made on them through 8 fingerprinting which would obliterate the writing 9 involved. So in order to have a paste-up 10 forgery, you, for instance, I would have needed 11 an original of your signature. I would cut it 12 out and paste it on another document and make a 13 photocopy of it and try to pass it off as a 14 legitimate document by saying that I am not sure 15 where the original is, but here is a copy. 16 That is not the only indicator. 17 There are times where copies are 18 authentic, but there are some things that people 19 miss when they just cut out a signature and 20 paste it on a document. And not only a 21 signature, but certain paragraphs, if they want 22 to change the text of the document. 23 Q. Let me rephrase my question. What I 24 am interested in -- 25 A. Yes. 0022 1 Q. -- is your opinion or conclusion 2 about whether there is any element of a paste-up 3 forgery present in the ransom note that you 4 reviewed in connection with the death of 5 JonBenet Ramsey? 6 A. There is no evidence of that 7 pointing to that fact. 8 Q. You certainly reached no conclusion 9 that anything was pasted up and forged on that 10 ransom note; have you? 11 A. On the copies that I have, is that 12 what you mean? 13 Q. Yes. 14 A. That is correct. 15 Q. And you've reached no conclusion that 16 there was any paste-up forgery on the original 17 ransom note as well; haven't you? 18 A. That is correct. 19 If there is an original, then there 20 would not be any -- you can't have a paste-up 21 forgery with an original handwritten document. 22 I am not sure if I made that clear. 23 Q. Are you, Ms. Wong, a full-time 24 document examiner? 25 A. Yes, I am. 0023 1 Q. How long have you been a full-time 2 document examiner? 3 A. Since, it has been almost 12 years. 4 Q. During that time, have you had any 5 other career or business or professional activity 6 at all? 7 A. Just a short stint. There is a 8 place called the Colorado Pen Company that came 9 to town, and I read about them in the 10 newspaper, and I thought what a better way to 11 learn about different types of pens and ink than 12 being in a pen store. And what a lot of 13 document examiners these days don't do is 14 actually go out in the field and actually 15 experience and observe the certain situations 16 that have to do with our jobs. 17 So at the pen company, I spoke to 18 them. And I said I am interested in learning 19 about the different types of pens, the different 20 types of ink composition and so forth. And 21 they said, well, there are a multitude of 22 different pen companies. They all have their own 23 ink formulas, and you would have to ask the 24 representatives for that information. And 25 normally, as a document examiner, that type of 0024 1 information you would have to learn by going to 2 a conference and, hopefully, that they would 3 have someone there with that knowledge that 4 would be speaking about it. 5 In this case, I decided to go 6 directly to the source. And I said, do you 7 mind if I just, you know, work here on the 8 weekends and I would be able to do study with 9 the pens and speak with the representatives and 10 find out about the pens. So in this case, 11 instead of having me pay for the education, I 12 was actually getting paid to get the education 13 myself. So that was a bit of a benefit. 14 The store wasn't open for very long. 15 They weren't in the right target market in our 16 area in Norfolk, Virginia; and they closed up 17 soon after. 18 Q. When was it that you worked with the 19 Colorado Pen Company in Norfolk? 20 A. Oh, good question. I think they 21 went bankrupt in 2000, in 2000, late 2000. So 22 I was there for probably a year, a little bit 23 over a year. So 1999 is probably when I 24 started. 25 Q. And did you work with them only on 0025 1 weekends? 2 A. Yes, that is correct. 3 Q. When you worked with the Colorado 4 Pen Company, were you paid by the hour or were 5 you paid an annual salary? 6 A. I was paid by the hour. And 7 actually where we worked, we have to pay for 8 parking in the mall. So actually parking per 9 day was about $11, and I was only paid $8 an 10 hour. So I would have to work there over an 11 hour just to pay for the parking. So I was 12 there not for the money but, in fact, for the 13 research and the study of the different inks and 14 pens. 15 Q. During the time, approximately a 16 year, when you were working with the Colorado 17 Pen Company, about what percentage of your total 18 income came from the Colorado Pen Company and 19 what percentage from your work as a document 20 examiner? 21 A. I wouldn't even say 1 percent came 22 from the Colorado Pen Company, and everything 23 else was from strictly document examination. 24 Q. You have told us, Ms. Wong, that at 25 one point you worked with David Liebman? 0026 1 A. That is correct. 2 Q. Do you now work together with Mr. 3 Liebman? 4 A. No, we do not. I have gone off on 5 my own. 6 Q. When did you do that? 7 A. It was approximately three, three and 8 a half years ago. 9 Q. Where is your office now as a 10 document examiner? 11 A. It is in Norfolk, Virginia. It's 12 close to downtown. 13 Q. What's the address, please? 14 A. It's 1131 Granby Street. That's 15 spelled G-R-A-N-B-Y, Street. That is in 16 Norfolk. 17 Q. And what is your home address, 18 please? 19 A. I have an office in my home, and 20 the office is separate from my living space. 21 Q. So your home is at the 1131 Granby 22 Street address in Norfolk? 23 A. That is correct. 24 MR. RAWLS: Mr. Gallo, would you 25 please mark this Exhibit Number 1 for the 0027 1 defendant. 2 And here's a copy, Darnay. For your 3 information, this is a copy of the CV that was 4 furnished to us. 5 (Defendant's Exhibit-1 was marked for 6 identification.) 7 Q. (By Mr. Rawls) Ms. Wong, would you 8 take a moment, please, and look over Defendant's 9 Exhibit 1 and let us know if that is a true 10 copy of your curriculum vitae and general 11 resume? 12 A. Looking over it briefly, it appears 13 to be a correct representation of my CV. 14 Q. And I will say for the record this 15 is what we received from the attorneys for Mr. 16 Wolf, Ms. Wong, as your CV. 17 In your work as a document examiner, 18 do you charge based on hours, for the most 19 part, when you don't take a case pro bono? 20 A. Yes, that is correct. 21 Q. So it is much like many lawyers, you 22 are a professional who charges by the hour? 23 A. Yes. 24 Q. And when you do charge by the hour, 25 what is your hourly rate? 0028 1 A. It is $150 an hour. I have a 2 three-hour retainer. And any court testimony or 3 depositions, it is the day rate, and that is 4 $1200. And that does not include traveling 5 portal to portal and so forth. 6 Q. Do you keep records of the number of 7 billable hours that you are engaged for in a 8 given year? 9 A. Oh, in a given year? 10 Q. Yes. 11 A. Oh, I don't add everything up within 12 in the year. No, I don't do that. I just 13 add them up per case. 14 Q. So as we sit here today in May of 15 2002, you cannot tell me how many hours you 16 billed professionally for in the year 2001; is 17 that correct? 18 A. That is correct. 19 Q. Can you give me an approximation? 20 A. Oh, I don't even know where to 21 start. Some cases take much longer, that I've 22 had to travel to Buffalo, New York for. Other 23 cases are just very simple. I don't even want 24 to begin to pull a number out of the hat. But 25 -- I don't know where to start. I am sorry. 0029 1 Q. Does all of your income come from 2 document examination? 3 A. That is correct. 4 Q. 100 percent of it after the Colorado 5 Pen Company went bankrupt? 6 A. Yes, that is correct. Before and 7 after. 8 Q. So one way you could start, and I 9 don't mean or intend to ask you your annual 10 income, but I expect you know your annual income 11 for the year 2001. And I would think from 12 that, with simple arithmetic, you could give me 13 the approximate number of hours that you billed? 14 A. Okay. Usually I just take 15 everything and send it off to my accountant. I 16 really don't know what to tell you. I am 17 sorry, Mr. Rawls. If I could answer you, I 18 would. 19 Q. Would you please take Defendant's 20 Exhibit 1 and let's start, if we may, on page 21 2. At the top it says Board Certification. 22 What is the board that certified 23 you? 24 A. As I mentioned earlier, it is part 25 of the National Association of Document 0030 1 Examiners. And it consisted first of two 2 founders. They were grandfathered into the 3 organization as being certified. Then the rest 4 of the other people had to go through the 5 written and oral exam to pass their 6 certification. And the board consists, at that 7 time when I was involved, it consisted of five 8 to seven people. 9 Q. And when did you receive your board 10 certification? 11 A. That is a good question. Oh, right 12 there. 1995. 13 Q. Who were the five to seven people on 14 the board that gave you your certification? 15 A. Okay. They are different than the 16 people now. Let me see if I can remember. 17 I believe one was Kathy Koppenhaver, 18 Phyllis Cook, Paul Wease, who is now deceased. 19 And I can't remember the other people that were 20 in the room, but those are the three that I 21 remember. Renee Martin may have been there. 22 Q. Was Mr. Liebman there? 23 A. I believe he was in the room, yes. 24 Q. Who were the two founders of the 25 National Association of Document Examiners? 0031 1 A. First one is Phyllis Cook, and the 2 second one is Renee Martin. 3 Q. Ms. Wong, the resume at the top of 4 the first page has a name Cina L. Wong 5 Associates Limited; does it not? 6 A. Uh-huh (affirmative). 7 Q. And does the title tell us that this 8 is a partnership organization? 9 A. No, it is not. I spoke to my 10 attorney when I incorporated this, and I was 11 just going to put it as Cina Wong Limited, and 12 he recommended it Cina Wong & Associates. He 13 is an attorney, so I didn't argue with him. 14 Q. Who are the associates? 15 A. Every once in a while if I have 16 some additional cases that I am not able to do 17 due to time constraint situations, then I have 18 Mr. Liebman step in. 19 Q. For the most part, there is not an 20 associate; but sometimes you recruit Mr. Liebman 21 to assist? 22 A. That is correct. 23 Q. Does Mr. Liebman also, from time to 24 time, recruit you to assist him with a matter? 25 A. Yes. If there are cases that he 0032 1 has to be out of town, then I take over. 2 Q. Ms. Wong, am I correct that you have 3 received no college degree in forensic science? 4 A. That is correct. 5 Q. Am I correct also that you have 6 received no college degree in document 7 examination? 8 A. I have taken a college course with 9 Mr. Zigler. And when I started there was no, 10 at that time, there weren't any college degrees 11 available in document examination. And this is 12 a field where there is no standard that says 13 that your training or your education has to come 14 from a certain college or have a certain degree. 15 Q. Let me ask Mr. Gallo to re-read my 16 question, please, if you can give me a yes or 17 a no. 18 A. Okay. I am sorry. 19 Q. If you don't mind. 20 (The record was read by the 21 reporter.) 22 THE WITNESS: That is correct. It 23 was not available. 24 Q. (By Mr. Rawls) Thank you. At 25 present what colleges do offer degrees in 0033 1 document examination? 2 A. At this time a new forensic college 3 just opened in Richmond, Virginia. There is an 4 author, her name is Patricia Cornwell, and she 5 put up a large sum of money which is state 6 matched, and they opened up a forensic college. 7 And I believe that you can get a degree in 8 document examination from that college. And 9 there may be a few other ones now, but that 10 was not available at that time to me when I 11 started document examination. 12 Q. When was the forensic college first 13 opened for business in Richmond? 14 A. I believe it was two years ago. 15 That is according to what I have read in the 16 paper. 17 Q. Have you made application to attend? 18 A. I have made an inquiry to the 19 college. And from what I understand is after you 20 graduate from the college, they would like you 21 to work for the government for a certain amount 22 of years. And I asked them, so is this kind 23 of like the military, you sign up and they help 24 you with the education and then you go work for 25 them for a while? And basically the person 0034 1 said to me, something like that. So I wasn't 2 interested in going to the college in that sense 3 and going to work for the government for a 4 certain amount of years. But that was my 5 understanding, that was what was told to me. 6 Q. How many years would a graduate be 7 expected to work with the government? 8 A. I can't remember. 9 Q. Was it the federal government or the 10 state government or just any government? 11 A. That wasn't made clear to me, and I 12 didn't ask. 13 Q. So service for a county or city 14 might have been sufficient? 15 A. I am sorry? 16 Q. Service for a county or a city might 17 have been sufficient to serve as the government 18 work component? 19 A. It may have, but I am not clear on 20 that. 21 Q. Have you ever worked for any 22 government organization? 23 A. No, I haven't. I am private 24 practice. 25 Q. Have you ever been retained by any 0035 1 government organization? 2 A. I have been retained by the 3 Commonwealth Attorney's office. 4 Q. So -- 5 A. And by the U.S. Probation Office. 6 That case was a while ago, but it was the U.S. 7 Probation Office. 8 Q. When were you first retained by the 9 Commonwealth Attorney's office? 10 A. This is probably in -- this is a 11 guesstimate -- somewhere between '93 and '95. 12 Q. And how many times? 13 A. I did one or two. 14 Q. And since then have you been 15 retained again by the Commonwealth Attorney? 16 A. No. Usually they have document 17 examiners in the police office, part of their 18 check squad. And when they are overloaded or 19 when they are not able to do the case, that is 20 when the Commonwealth Attorney will go outside 21 and hire someone from the private field. 22 Q. Let me remind you, I had asked you, 23 were you retained since by the Commonwealth 24 Attorney. 25 A. No, I have not. 0036 1 Q. So since approximately 1995, you have 2 not been retained by the Commonwealth Attorney; 3 am I correct? 4 A. That is correct. 5 Q. When were you first hired by the 6 United States Probation Office? 7 A. The best of my memory, it was 8 somewhere around -- anywhere from '96 to '99. 9 That is something I would have to look up. 10 Q. How many times were you retained by 11 the U.S. Probation Office? 12 A. Once. 13 Q. The one or two cases that you 14 assisted the Commonwealth Attorney on, did those 15 involve check forgery? 16 A. I believe they were. 17 Q. What was the matter, the one matter 18 you were engaged by the U.S. Probation Office to 19 assist on? 20 A. That one I can't remember. I am 21 sorry.
#2, 3 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:06 PM
In response to message #1
22 Q. Apart from the one or two cases with 23 the Commonwealth Attorney and the one case with 24 the U.S. Probation Office, have you ever been 25 retained by any government agency at the federal 0037 1 level, at the state level, or the county or 2 city level? 3 A. No. Usually they have their own 4 document examiners. Like I say, it is only 5 when they can't have anybody within their system 6 do it do they go outside. 7 Q. Have you ever been employed as a 8 document examiner by any government agency? 9 A. No, I have not. 10 Q. Ms. Wong, can you give us a 11 definition of graphology, please? 12 A. Yes. Graphology is when -- where 13 people study handwriting specifically for the 14 purpose of learning how to determine someone's 15 personality from their handwriting. 16 Q. And on your resume, if you would 17 turn with me to page 2, under Training, the 18 first thing you list is the, quote, 19 International School of Handwriting Sciences, end 20 quote; is it not? 21 A. Yes, that is correct. There are two 22 portions to that school. There is a portion to 23 the school where Mr. Widmer teaches document 24 examination, and there is a second portion of 25 his school where he does teach graphology. Remove | Alert | IP Printer-friendly page | Edit | Reply | Reply With Quote | Top
jameson Member since 5-8-02 08-15-02, 04:19 PM (EST) 2. "3 Cina Wong depo" In response to message #1 0038 1 Q. And Mr. Widmer is a graphologist; is 2 he not? 3 A. He is a document examiner and a 4 graphologist. 5 Q. And by whom is he certified as a 6 document examiner? 7 A. He is not certified. He doesn't 8 belong to any of the document examination 9 groups. He's read all the texts in the field, 10 the leading texts that all document examiners 11 read. 12 Q. And are you a graphologist? 13 A. No. Certainly not. 14 Q. Why do you say certainly not? 15 A. I have looked into it because, as 16 anybody who deals in the field of handwriting 17 sciences, you should look into all aspects of 18 handwriting and study all of it in order to 19 give a comprehensive analysis or speak about it. 20 There are lots of document examiners, I should 21 say, out there who say things about graphology 22 when they don't even know anything about it. 23 How can you speak about something fluently 24 without knowing? So I looked into it. I 25 don't see that there is any validity to it. A 0039 1 lot of people disagree with me. But my area 2 is strictly in document examination. 3 Q. You refer in your CV, this again is 4 Defendant's Exhibit 1 on page 2, and this is 5 immediately under the International School of 6 Handwriting Sciences, you refer to, quote, a 7 six-month program -- 8 A. Yes. 9 Q. -- in Handwriting Sciences, end 10 quote. 11 Did you get a diploma? 12 A. I don't think he issued a diploma, 13 no. 14 Q. Did you get a degree? 15 A. Not a degree, no. 16 Q. Did you get a grade? 17 A. No. Probably I have a certificate 18 of completion, but that would be about what we 19 received. 20 Q. So in those six months, was this a 21 full-time educational curriculum? 22 A. It was once a week. 23 Q. Once a week. Which day of the 24 week? 25 A. You are asking me to think back 12 0040 1 years. I can't remember. I am sorry. I know 2 it was a weekday. 3 Q. And in that once-a-week program, how 4 long were you there the day you were there each 5 week? 6 A. Anywhere from four to five hours. 7 Q. What did you pay for that course? 8 A. I can't remember. It was a while 9 ago. 10 Q. Did you do a term paper in that 11 program? 12 A. No, we did not. 13 Q. Did you submit handwriting analyses 14 for feedback? 15 A. I am sorry. I don't understand your 16 question. 17 Q. Well, in the course of this 18 six-month program, which we've learned was a 19 once-a-week program, four to five hours on that 20 one day a week, were you asked to complete a 21 document analysis and to submit it for review 22 and feedback? 23 A. I am not quite sure what you are 24 saying. But we were asked to bring in 25 handwriting samples; and we would look at them 0041 1 and study them for slant, proportion, placement, 2 letter forms; and that is what we did. 3 Q. Did you demonstrate to Mr. Widmer or 4 anyone else your analysis so that you could 5 obtain feedback and his judgment on whether you 6 were right or wrong? 7 A. Oh, you mean like a personality 8 analysis? I didn't partake in that. I was 9 there for the information with regards to 10 learning the basics, because I was -- there is 11 certain overlap with graphology and document 12 examination strictly with the fact that it has 13 to do with the formations and angles and initial 14 strokes and terminal strokes and letter 15 formations. And otherwise, that is where it 16 stops. 17 Q. Now, the second entry under Training 18 in your resume, and again I am still on page 2 19 of Defendant's Exhibit 1, you list again 20 International School of Handwriting Sciences. 21 And this time your CV tells us of your 22 completion of an advanced course in Questioned 23 Document Examination. 24 A. Uh-huh (affirmative). 25 Q. And according to your resume, this 0042 1 involved forgery detection, case studies, 2 hands-on equipment operation technique, and court 3 qualification procedures. 4 Have I accurately read your CV? 5 A. Yes, that is correct. 6 Q. How long was this advanced course? 7 A. I believe it was over four days, 8 three or four days. It was all day. Or it 9 was eight or ten hours. It was a very intense 10 course. 11 Q. And since Mr. Widmer has no 12 certification as a document examiner, I assume 13 this course was taught by someone else? 14 A. No. There is no standard in this 15 field where you need certification, but Mr. 16 Widmer has studied all the texts in document 17 examination, and he was the one that was 18 teaching the course. 19 Q. So Mr. Widmer taught the six-month 20 program in handwriting sciences as well as the 21 advanced course for three to four days in 22 questioned document examination; am I correct? 23 A. That is correct. 24 Q. Was there anyone that came in to 25 assist Mr. Widmer as a faculty member for those 0043 1 three to four days? 2 A. If my memory serves me right, I 3 think he had assistance from Mr. Marcel Matley. 4 Q. Can you spell that, please? 5 A. Yes, Matley, M-A-T-L-E-Y. 6 Q. Was Mr. Matley a certified document 7 examiner? 8 A. He is certified now through the 9 National Association of Document Examiners. 10 Q. When you say he is certified now, 11 does that mean he was not certified at the time 12 he assisted in teaching this course in 1991? 13 A. That is correct. But he is well 14 read in the field, and he is also well 15 published in the field. 16 Q. What has he published? 17 A. He has published an index that 18 covers all the articles that deal with document 19 examination. He has a book on sequential 20 handwriting. He has a book on forgery 21 detection. Quite a few others that I have in 22 my library that are all document examination 23 related. 24 Q. Now, in 1991, according to the next 25 entry under Training in your CV, you have 0044 1 experience or had a course of study in Signature 2 Identification also in San Francisco; am I 3 correct? 4 A. Yes, that is correct. 5 Q. And according to your resume, this 6 was a study of various techniques used to verify 7 signatures, recognizing different forms of forged 8 signatures, use of equipment to aid in 9 handwriting ID. Am I correct? 10 A. That is correct. 11 Q. How long was this course? 12 A. This course, I believe, it was three 13 days. 14 Q. Who taught that course? 15 A. That was taught by Marcel Matley. 16 Q. Were those full days? 17 A. Yes, definitely. 18 Q. The next course listed is the 19 Effects of Health on Handwriting. This is said 20 to have taken place in Sunnyvale, California. 21 A. That's correct. 22 Q. Is that correct? 23 A. It is near San Jose, Silicon Valley. 24 Q. How long was that course? 25 A. That was a day, full day. 0045 1 Q. And according to your resume, this 2 was taught by Patricia Wellingham-Jones? 3 A. Yes. She is a nurse. 4 Q. And your resume says she is an 5 expert in identifying health related conditions 6 and medications affecting handwriting? 7 A. Yes. She has written a book about 8 that. The course that she taught that day, she 9 had done some research work with regards to how 10 someone with an IV in their arm would affect 11 their signature or not, and different hospital 12 forms when people fill them out where they may 13 look like it is not their signature when, in 14 fact, it is, due to stress conditions or 15 medication. 16 Q. Then, according to your resume, you 17 had advanced training with David Liebman, whose 18 name you have mentioned before as formerly 19 someone with whom you worked? 20 A. That is correct. 21 Q. And according to your resume, this 22 was, this advanced training was in a mentorship 23 program offered by the National Association of 24 Document Examiners. 25 Can you describe, please, how that 0046 1 association offered a mentorship program? 2 A. Yes. There were certain senior 3 members who often -- NADE is an association that 4 is open to all people of all levels of document 5 examination. So whether a person who has been in 6 the field for a long time or if someone is 7 just a student or if someone is just interested 8 in the field of document examination can join 9 NADE. And from there -- there are very few 10 organizations that are open to students where 11 they can receive more information and learn 12 about the field of document examination. And at 13 that time, NADE did offer an advanced mentorship 14 program in document examination where you work 15 hands-on with a document examiner. 16 Q. And how long was this advanced 17 training that you took with Mr. Liebman? 18 A. It was three years, all practically 19 five days a week. 20 Q. Was this more or less on-the-job 21 training? 22 A. Yes, that is correct. 23 Q. Were you paid for that work? 24 A. No, I was not. 25 Q. Did you pay Mr. Liebman for that 0047 1 training? 2 A. No, I did not. 3 Q. Would you receive advanced training 4 by assisting Mr. Liebman in his work as a 5 document examiner? Is that what that program 6 was all about? 7 A. No. I did not assist him with his 8 work. We would -- when cases would come in, I 9 would work on it independently. And then after 10 I finished all my work, I would hand the folder 11 to him with the documents, and he would do his 12 work independently. 13 And then afterwards, he would look 14 at my notes to see how I went through my 15 systematic analysis, and he would critique what 16 I did. 17 And sometimes there were cases that 18 came in that we would need infrared lighting and 19 so forth, and that is something I didn't know 20 at the time, and I learned that through Mr. 21 Liebman. 22 Q. Were you yourself, from 1992 to 1995 23 when you were in this advanced training 24 mentorship, were you taking assignments yourself 25 for a fee from clients? 0048 1 A. I was not working by myself at that 2 time. Towards the end of the program, Mr. 3 Liebman, he was satisfied with my work, and he 4 felt very comfortable with everything that I 5 have learned and how I was proceeding, so I was 6 receiving some money from certain cases. 7 Q. And then you sought and received 8 your board certification from NADE; am I 9 correct? 10 A. That is correct. 11 Q. Is the International School of 12 Handwriting Sciences an accredited university? 13 A. No, it is not. 14 Q. Does it have any accreditation from 15 any organization? 16 A. Not that I am aware of. 17 Q. Is it accredited by the NADE? 18 A. NADE does not accredit any schools 19 or associations, so it wouldn't. 20 Q. What are the entrance requirements 21 for the International School of Handwriting 22 Sciences? 23 A. If you have an inte her -- you know, if someone is interested in 25 the graphology portion, they can pay a fee and 0049 1 learn that portion. And if you are interested 2 in their document examination section, then you 3 take those courses and pay a fee to learn that 4 information. 5 Q. So the entrance requirements are none 6 except payment of a fee? 7 A. I am sorry? 8 Q. The entrance requirements for the 9 international School of Handwriting Sciences -- 10 A. Yes. 11 Q. -- involves simply the payment of a 12 fee? 13 A. If you are interested in it at 14 first, yes. And then you pay a fee to learn; 15 that is correct. 16 Q. No one is going to pay a fee who is 17 not interested? 18 A. I hope not. 19 Q. And there is no application process? 20 A. No, there is not. 21 Q. The payment of a fee is all that is 22 required for entrance into the course? 23 A. That is correct. 24 Q. And to the best of your knowledge, 25 no one is rejected from the course of study who 0050 1 has paid the fee? 2 A. Not that I am aware of. 3 Q. How many people were present with 4 you in this once-a-week program for approximately 5 six months? 6 A. Good question. Probably, I would 7 say, ten to 15. 8 Q. How many of them had a college 9 degree? 10 A. Oh, I am not sure about that. 11 Q. The six-month program which was 12 attended once a week for four to five hours 13 each week, is that the graphology part of your 14 education? 15 A. No. It is part graphology, and it 16 is part that has to do with document 17 examination. 18 Q. Am I correct that the word 19 graphology is not found on your resume? 20 A. That is correct, because I am not a 21 graphologist. I would not be able to tell 22 anyone's personality from their handwriting if my 23 life depended on it, so you would have to just 24 shoot me. 25 Q. Ms. Wong, I am going to try to 0051 1 avoid -- 2 A. Shooting me. 3 Q. -- shooting you, regardless of any 4 reaction we may have to your testimony. 5 A. All right. Thank you. 6 Q. Am I correct that for purposes of 7 your effort to obtain credibility as a document 8 examiner you prefer to disassociate yourself from 9 your graphology studies? 10 A. There are many things -- I am not 11 quite sure how to answer that, what you are 12 asking. But there are many things I have 13 learned in the past. Just because I learned 14 gardening and I don't do it very well or I 15 don't practice it doesn't mean that, oh, well, 16 since I studied it at one time, then I must be 17 a gardener. I don't practice graphology. I 18 don't use it. 19 And I am strictly a document 20 examiner, and I identify and authenticate 21 handwriting. 22 Q. And graphology does not have a lot 23 of credibility among document examiners; does it? 24 A. That is correct. 25 Q. And consequently, to be a or to seek 0052 1 to be a credible document examiner, I am 2 correct, am I not, that you wish to disassociate 3 yourself from your graphology study? 4 A. That is not true. I don't deny it. 5 To be anybody who -- as I mentioned, to be 6 well versed in the field of document 7 examination, you should look at everything that 8 deals with handwriting sciences, because if you 9 don't then you are missing and lacking in a 10 certain area of your studies. 11 In order to be a good scientist, you 12 have to research all areas. And that is what 13 I did in this case. It doesn't mean I believe 14 it, but I researched it. 15 (Defendants' Exhibit-2 was marked for 16 identification.) 17 Q. (By Mr. Rawls) Ms. Wong, Mr. Gallo 18 has just handed you a brochure which has been 19 marked Defendants' Exhibit 2, and I have given 20 Mr. Altman a copy of that and I am looking at 21 a copy. 22 Can you identify that, please, for 23 the record? 24 A. Yes. I haven't seen this before. 25 It is a brochure. I assume it is new. It is 0053 1 titled the International School of Handwriting 2 Sciences. 3 Q. As you look at that, please, would 4 you tell me whether any of these lessons -- and 5 you will see the lessons listed as the ten 6 lessons. 7 A. Okay. 8 Q. Do you see that column? 9 A. Yes. 10 Q. This is essentially, for the record, 11 of course, the video is showing you looking at 12 the brochure. But it is a fold-up paper that 13 contains about eight columns, four on one side 14 and four on the other; am I correct? 15 A. You mean on this side or the back? 16 Q. Four on each side? 17 A. Oh, four on each side. Yes, that 18 is correct. 19 Q. And the ten lessons, do you see that 20 list on the far left side of what I take to be 21 the back page? 22 A. Yes. 23 Q. And tell us if you had any of those 24 ten lessons, please, where you took the courses 25 in 1990 and 1991 out in California. 0054 1 A. Okay. The first one is Use of 2 Space. And that covers how a person uses a 3 piece of paper in regards to margin area, which 4 is something that's used in document examination. 5 How far they start from the top of the paper 6 and how they use this -- how much margin they 7 leave on the side. 8 The Size of the Writing. That is 9 common sense, large and small.
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jameson Member since 5-8-02 08-15-02, 04:19 PM (EST) 3. "4 Cina Wong depo" In response to message #2 10 Q. As you tell us about each of these 11 ten -- 12 A. Yes. 13 Q. -- tell us whether you took that 14 course of study. 15 A. Well, it is interesting, because what 16 he writes underneath is nothing I remember. 17 It says Use of Space, how these 18 principles alone can give you a surprising 19 in-depth analysis. 20 On what I am not sure. 21 The Size of the Writing, how people 22 feel about themselves and others. 23 I don't remember that. I just know 24 size of writing with regards to document 25 examination. 0055 1 The Zonal Principle. How to tell 2 how self actualized someone is. 3 I don't remember that. But I 4 remember zones with regards to upper zones of 5 the handwriting, which would include the upper 6 portions of the lower case H's, top portions of 7 L's and so forth. Lower zones would be the 8 bottom parts of small G's and small Y's. 9 Left and Right Tendencies with Slant. 10 In documentation examination we study different 11 types of slants. His explanation is: Universal 12 concepts that allow you to develop insights in 13 any writing. 14 I don't remember that, and it 15 doesn't make any sense to me. 16 Connective Forms. That is very 17 important in document examination. It shows if 18 something is -- a connection stroke is if it is 19 curved or if it is angular or if it is arcade. 20 Mr. Widmer writes on here: How these show 21 strong indications of personality types and 22 attitudes towards the people and other people. 23 I don't know what to make of that. 24 Pressure. That is something document 25 examiners study. An example is someone who, 0056 1 when they write, when they press very hard into 2 a paper when they write leave deep impressions 3 as opposed to when someone writes with a lighter 4 hand. Mr. Widmer says here: With pressure, a 5 third dimension of handwriting and even what the 6 choice of writing implement can tell about 7 someone. 8 I don't remember covering that, but 9 I remember the heavy and light pressure and 10 medium pressure and varied pressure within 11 writing. 12 Let's see, For Those Who Print, he 13 writes: For those of you that thought you 14 could not analyze printed writing, you better 15 know this because most people today print. 16 All I remember from that course were 17 some unusual printing styles, but I don't 18 remember what the personality aspect that was 19 derived from printing. 20 Specific Letter Formations, he 21 mentions Alphabet from A to I -- A to some -- 22 well, some totally different approach to 23 individual letter formations, the most important 24 letter in the alphabet. 25 I don't know what that is about, but 0057 1 I saw some very unique -- he has an array of 2 samples in his file of interesting letter 3 formations that as a document examiner you need 4 to be exposed to a lot of handwriting in order 5 to figure out what exactly is part of a class 6 characteristic or an individual characteristic of 7 writing. 8 Specific Letter Formations. Doesn't 9 say anything about that. But that also had to 10 do with different letter formations. 11 And Form Level. Form level has to 12 do with the capability in document examination 13 how if they write in the higher form level or 14 a lower, more, I hate to use the word, 15 uneducated form level, someone who is not adept 16 at using the pen or pencil very well. And 17 someone who writes very poorly can't write 18 better than they can write. And not only that 19 was taught in this class, and that is also 20 taught in document examination. 21 And Mr. Widmer has here under Form 22 Level: Taking intuition out of handwriting 23 analysis and putting it all together. 24 So, I don't know. 25 Q. Thank you. We have been going just 0058 1 over an hour. Is this a convenient time for a 2 short recess? 3 A. Yes. I have been trying to hold 4 the best I can. So, yes, this would be great. 5 Q. Good. 6 A. Thank you. 7 THE VIDEOGRAPHER: Going off the 8 video record at 10:56. 9 (A recess was taken.) 10 THE VIDEOGRAPHER: Back on the video 11 record at 11:11. 12 MR. RAWLS: Evan and Darnay, I had, 13 I believe in an exchange of e-mails, advised you 14 all that at the deposition we would have a 15 check in payment of the expense sum of money 16 which you all had told us about for Ms. Wong's 17 expenses. And, Evan, if I may deliver that 18 check to you now. 19 MR. ALTMAN: Thank you. Sure. 20 MR. RAWLS: I had intended to bring 21 it earlier today. 22 MR. HOFFMAN: Thank you. And just 23 while we're on that subject, I just received 24 your costs on that other case involving Linda 25 Hoffman-Pugh, and that is being sent out to you. 0059 1 And I am assuming that should be sent to your 2 office or to Lin's. 3 MR. RAWLS: My office is fine, 4 Darnay. Thank you.
#3, 4 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:07 PM
In response to message #2
5 MR. HOFFMAN: Should it be made to 6 your firm or to an individual? 7 MR. RAWLS: To the firm. 8 MR. HOFFMAN: Thank you. 9 MR. RAWLS: Alex, would you please 10 mark this as Defendants' Exhibit 3? 11 Evan, here is a copy for you. 12 (Defendants' Exhibit-3 was marked for 13 identification.) 14 Q. (By Mr. Rawls) Ms. Wong, Mr. Gallo 15 has just handed you a copy of what we have 16 marked Defendants' Exhibit 3. And I will tell 17 you that we received, we had these printed off 18 of the internet, and they are pages on what we 19 understand to be the website of the 20 International School of Handwriting Sciences. 21 Are you familiar with any of these pages? 22 A. No. I haven't seen these before, 23 but I know Mr. Widmer is no longer teaching 24 document examination. He found that it wasn't 25 lucrative. There weren't many people interested 0060 1 in learning about document examination, and he 2 is strictly teaching graphology now. I haven't 3 seen any of the literature. But I had heard 4 from him that he had put together a course, 5 which is what you presented to me today in the 6 brochure and in the internet, what you printed 7 out from the internet. 8 Q. Would you please turn to the second 9 page of the Defendants' Exhibit 3 which Mr. 10 Gallo just gave you. And this is a page that 11 at the top says it is about ISHS. 12 A. Okay. 13 Q. If you would look with me, please, 14 at a sentence that begins in the second 15 paragraph. And the sixth line of the second 16 paragraph -- 17 A. Starting with? 18 Q. -- there is a sentence beginning, 19 quote, The introductory class emphasizes basic 20 principles of graphology. 21 Did you take such a class? 22 A. He spoke about graphology within the 23 course that I took. 24 Q. Okay. And -- 25 A. But I am not sure if this is the 0061 1 class. 2 Q. You don't know if it is going to be 3 the same class as described here? 4 A. Like, because he has a whole new 5 program, so I am not sure what it is. I am 6 not familiar with this. 7 Q. Then going on in the same sentence, 8 this paper states: The intermediate class 9 stresses the relationship of graphology to 10 psychology. 11 Did you take such a class? 12 A. No, I don't remember -- I took 13 advanced document examination class. I don't 14 remember taking anything like this. 15 Q. And the same sentence goes on to 16 say: And the advanced class introduces the 17 student to a system called the personality 18 flowchart -- 19 A. Okay. 20 Q. -- end quote. Did you take a 21 class, any class at all about the personality 22 flowchart? 23 A. I don't remember that. That must be 24 new. I see the copyright symbol there also. 25 Q. Yes, and the personality flowchart 0062 1 has a small copyright symbol near it which 2 indicates that perhaps ISHS has copyrighted that 3 name or course? 4 A. Probably. 5 Q. But that is new to you; is that 6 correct? 7 A. Oh, yes, it is. 8 Oh, he still offers his questioned 9 document class. Good. 10 Q. Did you take the course of study 11 with the ISHS in person or from home study? 12 A. In person. I lived in the San 13 Francisco Bay area. I heard that this home 14 study is something new within the past year or 15 so. 16 Q. And if you would turn with me for a 17 moment, please, back to Defendant's Exhibit 1, 18 which is, again, your resume? 19 A. Yes. 20 Q. We spoke briefly earlier about the 21 course in Sunnyvale taught by Patricia 22 Wellingham-Jones, who you had told us is a 23 nurse, on effects of health on handwriting? 24 A. Right. And she also is involved in 25 handwriting, and she is a nurse. 0063 1 Q. Was that course on effects of health 2 on handwriting, was that part of the ISHS 3 school? 4 A. No. That is separate. 5 Q. Was this something that you paid 6 for? 7 A. Yes, that is correct. 8 Q. And would you say that Ms. 9 Wellingham-Jones gave a course on graphology to 10 you during that one-day program? 11 A. No. She just spoke about her 12 studies and her research with regards to the 13 effects of health on handwriting and about her 14 IV research. I did find out, actually just 15 recently I was posed a question whether she was 16 a graphologist or not, and I didn't realize 17 that, and someone had informed me that she was. 18 But I did not know that at the time when I 19 took her course. 20 Q. Okay. Let's, and with further 21 reference to your resume, Defendant's Exhibit 1, 22 let's move on down to page 2 to the last group 23 of entries on the page. And this has to do 24 with what your resume states is, quote, 25 Completion of college level course in questioned 0064 1 documents, end quote, at Northern Virginia 2 College? 3 A. That's correct. 4 Q. Did you enroll in Northern Virginia 5 College in order to take this course? 6 A. Yes. 7 Q. And for how long did you enroll? 8 A. Oh, it is just specifically for this 9 course. I filled out papers. I am not sure. 10 I can't remember. You mean enroll and I had 11 to send in my transcripts from my previous 12 college and so forth? 13 Q. Yes. 14 A. Yeah. I can't remember if I had to 15 do that. I just remember signing up for the 16 course. I am not sure what type of application 17 I had to fill out. I may have. 18 Q. So whatever enrollment or application 19 you did with Northern Virginia College, it was a 20 one-course effort only? 21 A. That is correct. 22 Q. And this was the course, that is, 23 Mr. Zigler's course on questioned documents? 24 A. Yes. I was specifically interested 25 in his course. And Mr. Zigler is a well 0065 1 respected document examiner in the whole field. 2 Q. How many days a week did you attend 3 this class with Larry Zigler? 4 A. Actually, in the usual course where 5 it took place actually on the weekends. I 6 think it was Friday, Saturday or Saturday, 7 Sunday. I can't remember. 8 But it went on for two or three 9 weeks. And though graphology was not taught in 10 this class, because it was strictly document 11 examination, Mr. Zigler has taught courses to 12 FBI and Secret Service agents with regard to 13 graphology because he knows it is important for 14 all the agents that are involved in document 15 examination to have a well-rounded information in 16 handwriting sciences. 17 Q. And on the weekends, how long each 18 day did you spend in this course? 19 A. It was a full day. 20 Q. So this was two full days during how 21 many weekends? 22 A. It was either two, three, or four. 23 I can't remember exactly. 24 Q. So this was a total, this class with 25 Larry Zigler took a total of either four, six, 0066 1 or eight days -- 2 A. That is correct. 3 Q. -- to complete? 4 A. Yes. 5 Q. And were you graded in this course? 6 A. I don't believe we were, but we 7 received a certificate of completion. 8 Q. Did you receive college credit for 9 this course? 10 A. Good question. I don't know. I 11 wasn't interested in the college credit. I was 12 just interested in taking the course. 13 Q. Northern Virginia College's exact name 14 is Northern Virginia Community College; am I 15 right? 16 A. That could be correct. I am sorry. 17 You said it was Northern -- 18 Q. Virginia Community College. 19 A. Okay. It could be. I just know 20 they call it Annadale College. 21 Q. Did you receive at any time any 22 degree from that college? 23 A. No, I did not. 24 Q. When you say that Mr. Zigler's 25 course was a college level course, what do you 0067 1 mean by that? 2 A. He taught it at the college to -- 3 there were other college students involved. 4 There were about 25, 25 or 28 college students 5 in there along with some document examiners. 6 Q. And there were some people there 7 such as yourself who were not college students 8 at all? 9 A. That is correct. 10 Q. Were the students that were, in 11 fact, trying to get some form of a degree from 12 Northern Virginia Community College who attended 13 this course, were they given course credit 14 toward their graduation for that course? 15 A. I am not sure. I didn't speak with 16 them about it. But as a college student, I 17 wouldn't want to take anything I wasn't going to 18 getting credit for. 19 Q. Were they graded? 20 A. I can't remember. I am sorry. 21 Q. Was this pass/fail? 22 A. I don't even remember that. 23 Q. Was there any paper involved? 24 A. No, there was no paper involved. 25 Q. Was there a test involved? 0068 1 A. There was some testing involved with 2 regards to form blindness and to -- he handed 3 out a piece of paper with a bunch of signatures 4 on it we were supposed to identify from another 5 -- we were supposed to categorize which writer 6 wrote certain signatures, and we had to combine 7 those signatures. 8 Q. Did Mr. Zigler give you feedback if 9 he didn't give you a grade? 10 A. Yes. Well, we turned in the form 11 blindness test. He made comments. And also -- 12 I believe he made comments about that one test, 13 he should have, with regards to matching up 14 signatures. 15 Q. So you had a few minutes of 16 individualized comments from Mr. Zigler on your 17 own performance? 18 A. In front of the class he made 19 comments. 20 Q. So you did not have any 21 individualized feedback yourself from Mr. Zigler? 22 A. That is correct. 23 Q. He simply commented to the class as 24 a whole on some of what the students turned in? 25 A. That is correct. And, of course, I 0069 1 spoke to him afterwards about certain portions 2 of the class. 3 Q. So it would not be accurate to say 4 that Mr. Zigler trained you, would it; it would 5 be accurate simply to say that you sat through 6 his course? 7 A. It was a course instructed by Mr. 8 Zigler. 9 Q. The class would, if I understand 10 your testimony correctly, have been a basic 11 overview of the field of questioned document 12 examination; am I right? 13 A. Yes. It included that. 14 Q. And do you recall that Mr. Zigler 15 told his students and the non-students attending 16 the class that these few days of study were not 17 designed to teach them to be practicing forensic 18 document examiners; didn't he? 19 A. I don't remember him mentioning that, 20 but that is true about that course. I mean, 21 you can't take that and go out and be a 22 document examiner; that is correct. 23 Q. Did you ever take any other courses 24 with Mr. Zigler? 25 A. No, I have not. 0070 1 Q. I want to direct your attention back 2 to Mr. Dave Liebman whose name has come up in 3 this deposition up to now several times and who 4 is, of course, also named in your resume on 5 page 2 and with whom you have been in practice 6 regarding questioned documents at times during 7 your career. 8 Does Mr. Liebman teach a course at 9 Old Dominion University? 10 A. He used to at one time. 11 Q. What is the subject of that course? 12 A. Good question. I don't know. When 13 I met Mr. Liebman, I think he was no longer 14 teaching that course. 15 Q. And you met Mr. Liebman when? 16 A. At a conference at the National 17 Association of Document Examiners, a NADE 18 conference. And it was a conference they had 19 in California, which would be in 1991. 20 Q. So he had already stopped teaching 21 that course at Old Dominion, to the best of 22 your knowledge, by 1991? 23 A. I am not sure when. Remove | Alert | IP Printer-friendly page | Edit | Reply | Reply With Quote | Top
jameson Member since 5-8-02 08-15-02, 04:25 PM (EST) 4. "5 Cina Wong depo" In response to message #3 24 Q. Did you learn that the subject of 25 that course taught by Mr. Liebman was 0071 1 determining whether an individual had cancer by 2 examining the person's handwriting? 3 A. No, I was not aware of that. It 4 was taught at a college? Old Dominion or -- 5 Q. I am not here to answer. I am 6 trying to obtain what information you have about 7 that. 8 A. Oh, okay. If it was taught at Old 9 Dominion University, that is an accredited 10 college. 11 Q. But you don't know the subject 12 matter and you don't know whether he taught 13 about determining the existence of cancer by 14 looking at a person's handwriting; am I correct? 15 A. No. He could have taught something 16 about bug larva and I wouldn't know. 17 Q. Was Mr. Liebman asked, to your 18 knowledge, to be an expert witness on behalf of 19 Chris Wolf in this case that brings you here 20 today? 21 A. I am sorry. What was that question? 22 Q. Was Mr. Liebman asked to be an 23 expert witness in the Chris Wolf case, the same 24 case that you are assisting Mr. Darnay Hoffman 25 and Mr. Evan Altman in today? 0072 1 A. I am not sure. At that time when I 2 was asked Mr. Liebman and I no longer had a 3 business. We still talked, but that isn't an 4 issue that comes up. 5 Q. So Mr. Liebman has not told you that 6 he was or was not asked to be an expert 7 witness by Mr. Hoffman or Mr. Altman? 8 A. That is correct. 9 Q. Do you keep in touch with Mr. 10 Widmer, Ted Widmer? 11 A. I spoke to him recently because I 12 heard that, through the grapevine, he had 13 recently gotten married, and I wanted to wish 14 him my best. 15 Q. Are you aware of some legal issues 16 that Mr. Widmer encountered in about 1995? 17 A. No, I am not. What type of legal 18 issues are you talking about? 19 Q. Are you aware that Mr. Widmer signed 20 a stipulation with the San Francisco District 21 Attorney's office that he falsified in court his 22 questioned document credentials? 23 A. No, I did not. To what degree? 24 Q. I am sorry? 25 A. To what degree? 0073 1 Q. I, again -- 2 A. I was curious. I didn't know. 3 Q. I am just here to ask you questions 4 and probe your knowledge. 5 A. Okay. 6 Q. And as I understand your testimony, 7 you have no knowledge of that; am I correct? 8 A. No, I do not. 9 Q. It would not be appropriate, of 10 course, ever to falsify one's credentials as a 11 questioned document examiner? 12 A. That is correct. But his actions 13 have no bearing on my actions. 14 (Discussion ensued off the record.) 15 Q. (By Mr. Rawls) Ms. Wong, would you 16 please turn back to Defendants' Exhibit 3 to 17 your deposition. And on the, I guess this is 18 the third page from the back -- 19 A. Third page from the back. Okay. 20 Q. -- there is a section under the bold 21 caption: Other graphologists rave. 22 Do you see that? 23 A. Uh-huh (affirmative). 24 Q. And there is the quoted phrase: 25 Ted, thanks for giving me my start, end quote. 0074 1 And under that is the name C. Wong, Norfolk, 2 Virginia. 3 A. Uh-huh. 4 Q. Did you, in fact, make that 5 statement about Mr. Widmer's course? 6 A. I did not make it with regards to 7 the graphology course. I made that comment with 8 regards to the document examination course. So 9 I am surprised to see it here today underneath 10 graphology, because actually I first learned 11 document examination through Ted. So this is 12 surprising to me. But I did say that to him, 13 but in a different context. 14 Q. So the fact is you do not consider 15 yourself a graphologist? 16 A. Of course not. 17 Q. And the website page that we've just 18 discussed seems to label you a graphologist? 19 A. That is what it appears to be here, 20 but it is incorrect. 21 Q. And would you, therefore, likely 22 intend to ask Mr. Widmer to please remove your 23 name and your quote from this page? 24 A. Yes. I will ask him to remove the 25 quote or I will have to ask him to put it in 0075 1 the correct context, which is with regards to 2 his document examination course. 3 Q. And, Ms. Wong, if you learn that, in 4 fact, Mr. Widmer did, in 1995, enter a 5 stipulation that he had falsified his own 6 credentials on questioned documents, would you 7 ask him to take your name out of his materials 8 altogether? 9 A. Yes, if that is the truth. Are you 10 saying he -- I don't understand your question 11 clearly. He falsified information with regards 12 to documents at hand or with regards to his CV? 13 Q. His credentials. 14 A. Okay. 15 Q. His credentials? 16 A. Thank you for bringing that to my 17 attention. I didn't realize this. 18 Q. Certainly. 19 Let's move to page 3 of your resume, 20 and this is back, of course, to Defendant's 21 Exhibit 1. You state that, under Continuing 22 Education, you attended Andrew Bradley's Forensic 23 Document Examination course. 24 A. Oh, I didn't attend it. That is a 25 course that is through correspondence through 0076 1 mail. And you send the course and you work on 2 the course when you find the appropriate time 3 to. And there is testing at the end of each 4 chapter is how it works. It gives you a test. 5 And after you answer the questions, you send it 6 back into his office, and they send you a 7 critique back. 8 Q. How much did you pay for that 9 correspondence course? 10 A. I don't remember. I am sorry. 11 Q. How much time did you spend on each 12 of the 20 lessons? 13 A. Actually, I haven't finished all the 14 courses, that is why it is under Continuing. 15 But I can't give you a number right off the 16 top of my head. 17 Q. How many of the 20 lessons have you 18 completed? 19 A. I have been through either the first 20 three or four. 21 Q. On your resume, you state that the 22 course entails subjects such as the mechanics of 23 handwriting, proper procedures for obtaining 24 exemplars, identification of handprinting, 25 disguised writing, forgeries, photocopy 0077 1 examination, typewriter identification, anonymous 2 letters, document photography, examination of ink 3 and paper, writing instruments, erased and 4 obliterated writing, and use of ESDA. 5 Have I read correctly? 6 A. That is correct. 7 Q. And which of those subjects have you 8 yet completed? 9 A. I, just to be -- this is right off 10 the table of contents, so it would be, like, 11 the first three or four. And actually, I have 12 knowledge of all the ones that you've mentioned; 13 I have knowledge in all those areas already. 14 Q. So your continuing education has 15 taken you through the first three or four? 16 A. That is correct. 17 Q. And exactly three or exactly four? 18 A. I can't remember. I am sorry. 19 Q. So you don't know if you have gotten 20 to disguised writing yet, which is number four 21 on this list? 22 A. That is correct. As I mentioned, I 23 have knowledge in all these areas. 24 Q. Is Mr. Bradley certified by the 25 American Board of Forensic Document Examiners? 0078 1 A. I am not sure of that. 2 Q. Is Mr. Bradley certified by the 3 American Society of Questioned Document 4 Examiners? 5 A. I am not sure. All I know of Mr. 6 Bradley is he used to be a document examiner 7 with the sheriff's department in, I believe, 8 whatever state he lives in. I forgot. I am 9 sorry. 10 Q. So he worked for the sheriff's 11 office in a county or a city of a state that 12 you don't now recall? 13 A. That is correct. That is my 14 understanding. 15 Q. And back to Mr. Liebman for a 16 moment. Is Mr. Liebman certified by the 17 American Board of Forensic Document Examiners? 18 A. No. But he is certified through 19 NADE, N-A-D-E; and he was also past president of 20 NADE, which I am also a past vice president of. 21 Q. And is Mr. Liebman certified by the 22 American Society of Questioned Document 23 Examiners? 24 A. No. A lot of those organizations 25 that you are mentioning are open to just 0079 1 government or government document examiners who 2 have retired and are now in the private field. 3 So since I have not been in the government 4 field, or anybody that is not in the government 5 field, they are not allowed membership. 6 And certification through some of 7 those associations that you did mention are 8 voluntary. 9 Q. Ms. Wong, back to page 3 of your 10 resume, under Related Education, you state, you 11 list Private Investigator Licensing Course in 12 Virginia Beach, Virginia. And your resume 13 describes this as an in-depth, state-accredited, 14 60-hour course taught by Vince Tortomasi, former 15 Norfolk, Virginia police officer. Am I correct? 16 A. That is correct. 17 Q. Did that private investigator 18 licensing course cover forensic document 19 examination? 20 A. It touched upon it. 21 Q. It touched upon it? 22 A. It touched upon many subjects. 23 Q. About how much time was devoted to 24 document, forensic document examination in that 25 course? 0080 1 A. I wouldn't be able to give you an 2 exact number. I wouldn't remember. But it 3 covered a little bit about fingerprinting; it 4 covered a little bit about ballistics; covered 5 investigation procedures and so forth, including 6 a little bit on document examination. 7 Q. So was it something of an overview 8 of what private investigators need to know? 9 A. That is correct.
#4, 5 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:09 PM
In response to message #3
10 Q. Did you receive or ever apply for a 11 private investigator license? 12 A. We -- I like to call it 13 certification. I received my certification 14 through the state. And every two years I have 15 to go -- in order to get a renewal, I have to 16 go for a continuing education course. 17 Q. So are you a licensed private 18 investigator? 19 A. In the State of Virginia. It is a 20 licensing course, but what we receive is a 21 registration or a certification. 22 Q. So you have a certification and not 23 a license? 24 A. Right. It is strange. It is a 25 licensing course; but as a private investigator, 0081 1 you receive a certification or a registration. 2 And I am not practicing as a private 3 investigator. 4 Q. And you have no registration as a 5 private investigator? 6 A. Yes, I do. I am registered as a 7 private investigator, but I am not practicing as 8 one. 9 Q. We then move in sequence on your 10 resume to Specialized Course on Document 11 Examination in Bend, Oregon; and you describe a 12 handwriting analysis course instructed by John W. 13 Hargett, the Chief Document Examiner for the 14 U.S. Secret Service, and you go onto describe 15 Mr. Hargett. 16 Would you please tell us when it is 17 that you completed that course? 18 A. Well, I have here that it was in 19 1998. And what -- 20 Q. How many classes did you attend? 21 A. He -- what he was -- the reason why 22 I was interested in taking his course, it was 23 promoted by the Northwest Fraud Investigator's 24 Association out on the West Coast, and this was 25 in the State of Washington. And what he was 0082 1 going to be teaching there, what I was told, 2 was exactly what he was teaching in the Secret 3 Service school that is usually taught over a 4 two-week period. And he was teaching a 5 condensed course for this group in document 6 examination. 7 Mr. Hargett is highly regarded, and 8 I knew that was a course that I definitely 9 would want to take. 10 Q. And I believe I asked you how long 11 you -- 12 A. It was over a three- to four-day 13 period, I believe. 14 Q. A three- to four-day period? 15 A. That is correct. 16 Q. And how many hours per day? 17 A. It was a full day each day. 18 Q. Is there a course syllabus for that 19 condensed course? 20 A. I can't remember. I just know that 21 what he was teaching he said this is what I 22 teach at the Secret Service school. 23 Q. And -- 24 A. And he took us through different 25 exercises, and we worked out certain problems, 0083 1 and he taught us certain basics and some 2 advanced techniques in document examination. 3 Q. You refer to this course as, quote, 4 Specialized, end quote. What was specialized 5 about it? 6 A. Well, that it was not often do you 7 get to take a course by a well respected person 8 like a John Hargett or a Larry Zigler, and I 9 was very fortunate to be able to get this 10 course. And it's specialized because he taught 11 the Secret Service handwriting school, document 12 examination school, and he was also teaching it 13 here. 14 Q. So it was specialized because he was 15 a special individual? 16 A. Well, no. Usually in order to take 17 the Secret Service handwriting course, you have 18 to be a document examiner in the government or 19 someone that is related to the field, and that 20 is when they allow you into that school. 21 Otherwise, you are not able to attend that 22 school. 23 Q. I notice on page 4 of your resume, 24 which is the very next page -- 25 A. Yes. 0084 1 Q. -- that you attended the NWFIA 2 conference in 1998 in Bend, Oregon. Was Mr. 3 Hargett's course in document examination offered 4 as part of that particular NWFIA conference in 5 1998? 6 A. Yes. As I mentioned earlier, NWFIA 7 sponsored that course. 8 Q. What were the requirements to take 9 that course? 10 A. If you had an interest in taking the 11 course, then you could sign up for the 12 conference and attend. 13 Q. Was there a fee? 14 A. Yes, there was. 15 Q. How much was that? 16 A. I can't remember. I am sorry. 17 Q. How many people attended that course? 18 A. Wow. It appeared to be 80 or 100 19 or more people there. 20 Q. Were you graded in that course? 21 A. No, we were not graded. 22 Q. Was it a pass/fail course? 23 A. No, it was not. 24 Q. Did you receive a certificate or a 25 diploma or any indication you had taken that 0085 1 course? 2 A. There may have been a certificate of 3 completion, but I am not sure. 4 Q. Did you submit samples of your work 5 to Mr. Hargett? 6 A. No, I did not. 7 Q. Did you take a test? 8 A. We all were given some work to do, 9 just as in Mr. Zigler's class, to compare 10 handwritings and to see how many writers wrote 11 different signatures and so forth and to match 12 them up. And he also gave us group projects 13 also where a group of us got together, and we 14 decided whether certain documents had one or two 15 writers. 16 Q. Did you receive any individual 17 feedback personally from Mr. Hargett? 18 A. I spoke with him afterwards; that is 19 about it. 20 Q. So he did not comment on your work 21 or your conclusions? 22 A. That is correct. 23 Q. And, Ms. Wong, may I ask you to 24 move backwards and to the top again of page 3 25 of your resume briefly -- 0086 1 A. Sure. 2 Q. -- back to Mr. Andrew Bradley's 3 forensic document examination course. 4 A. Yes. 5 Q. Mr. Bradley is the person you 6 understood to be a former sheriff from 7 somewhere? 8 A. That is correct. 9 Q. When did you take that 20 -- excuse 10 me. I beg your pardon. 11 When did you begin to take Andrew 12 Bradley's course? 13 A. I think I started, I purchased the 14 course in '92 or something, and I was still in 15 California and then moved over here to -- moved 16 over to Norfolk, Virginia. And as I was 17 unpacking, it just kept getting moved around, so 18 I haven't had a chance to finish it. 19 Q. And down to the private investigator 20 licensing course you took in Virginia Beach -- 21 A. Yes. 22 Q. -- when did you take that course? 23 A. Good question. I've had it for a 24 while. I have taken that at least four -- four, 25 five, or six years ago. It has been a while. 0087 1 Q. Was that a correspondence course? 2 A. No, it was not. 3 Q. Did you pay a fee to take that 4 course? 5 A. Yes, that is correct. 6 Q. Was there any degree offered or any 7 grade offered in that course? 8 A. We had to pass a test. And if we 9 didn't pass, we didn't get our registration. 10 Q. Your resume states that the course 11 was an in-depth course. What was in-depth about 12 it? 13 A. He went through all the specifics on 14 investigation, how to handle an investigation and 15 so forth, went into a lot of that. 16 Q. I want to now ask you to tell me 17 some more about the NADE, the National 18 Association of Document Examiners. Earlier you 19 gave us the names of the two founders, Phyllis 20 Cook and Renee Martin. 21 A. That is correct. 22 Q. Does Ms. Cook have an accreditation, 23 please, with the American Board of Forensic 24 Document Examiners? 25 A. I am not familiar with what her 0088 1 background is in that field. 2 Q. Does she have a certification with 3 the American Society of Questioned Document 4 Examiners? 5 A. I don't have any knowledge of her 6 being associated with them or not. 7 Q. And do you know about whether Ms. 8 Renee Martin is certified by the American Board 9 of Forensic Document Examiners? 10 A. I don't have any knowledge on her 11 background with that regard either. 12 Q. Or the American Society of Questioned 13 Document Examiners? 14 A. I don't have any information. 15 Q. The fact is, is it not, that they 16 are graphologists? 17 A. I know that they do have a 18 graphology background, but the National 19 Association of Document Examiners, it is a 20 strict organization of just purely document 21 examination and no graphology. 22 Q. Would I be correct to characterize 23 the National Association of Document Examiners as 24 an organization that is principally comprised of 25 individuals with graphology backgrounds who would 0089 1 like to be document examiners? 2 A. Well, that is not true. We have 3 people there in the police force who are part 4 of our group. We have an ex -- I think he's 5 FBI, an ex-FBI person that is with us. 6 Actually two, or one may be Secret Service. We 7 have some government people, and we have lots of 8 students also. 9 But, no, the large graphology 10 background and then wanting to be is not true. 11 They've -- a lot of the people that attend our 12 conferences are strictly interested in the field 13 of document examination; and we do not teach 14 graphology there. 15 Q. Aren't most members of the NADE 16 individuals who have graphology backgrounds? 17 A. I know there are individuals there 18 with graphology background. To what degree and 19 how many, I am not sure what that number is. 20 Q. And people tend to come to the NADE 21 for accreditation when they cannot get 22 accreditation as a document examiner through some 23 other organization; am I not correct? 24 A. That is not true. There are other 25 organizations that are open to document examiners 0090 1 also. And even Mr. Zigler has a graphology 2 background. Like I said, he taught it to other 3 agents. 4 Q. Who accredits the NADE? 5 A. What do you mean by that? 6 Q. Does it have any accreditation, the 7 organization itself? 8 A. We are an organization. I don't 9 know -- 10 Q. The NADE, that organization -- 11 A. Yes. 12 Q. -- does it have any accreditation 13 from any place at all? 14 A. We are our own group, and we are 15 not a branch from another group where we need 16 to be accredited or separately. We are not 17 with a large group where we have a document 18 examination section and a fingerprint section. 19 No. We are just strictly document examination. 20 MR. RAWLS: Okay. We need a short 21 pause, I am told, for the benefit of changing 22 the videotape, so let's go off the record. 23 THE WITNESS: Sure. 24 THE VIDEOGRAPHER: Going off the 25 video record at 11:54. 0091 1 (A recess was taken.) 2 THE VIDEOGRAPHER: Back on the video 3 record at 11:57. 4 Q. (By Mr. Rawls) Ms. Wong, is the 5 NADE accredited by any forensic science 6 organization? 7 A. No, not that I am aware of. 8 Q. By any law enforcement group? 9 A. No. I didn't realize law 10 enforcement groups accredited other organizations 11 like document examination. 12 Q. Is there any state or federal 13 government certification or an accreditation of 14 the NADE? 15 A. No, not that I am aware of. 16 Q. There are a -- there are more than 17 just a few organizations that claim to be 18 questioned document examiner organizations; are 19 there not? 20 A. Not claim to be. They say they are 21 document examination organizations. 22 Q. And apart from the NADE, what other 23 ones have you applied to? 24 A. I haven't applied to any other ones. 25 I am happy with the National Association of 0092 1 Document Examiners. But I have heard some good 2 things about AFDE lately, AFDE; and I am 3 interested in finding out more about that group. 4 Q. What is AFDE? 5 A. American Forensic Document Examination 6 group. 7 Q. And, Ms. Wong, with respect to your 8 own board certification you told us about, of 9 the five to seven people in the room when you 10 took the oral portion of the accreditation test, 11 how many of those individuals were, to your 12 knowledge, accredited by some organization other 13 than the NADE? 14 A. I am not aware of what their 15 backgrounds are except for Mr. Liebman. I 16 should say when I mean people in the room, 17 those were the people in the room in charge of 18 making comments and notes with regard to my 19 certification. 20 Q. You joined NADE in 1991, if I am 21 correctly reading your resume; did you not? 22 A. Yes, that is correct. 23 Q. What was required in order for you 24 to be accepted into the NADE as a member? 25 A. As I mentioned, NADE is open to 0093 1 people who are practicing document examiners. 2 They are open to students, and they are open to 3 people who have been interested in the field. 4 So I filled out an application, and I joined 5 NADE. 6 Q. So essentially an application and a 7 fee were all that was required? 8 A. As so it is with most groups. 9 Q. Is the answer yes? 10 A. I am sorry? 11 Q. Is the answer yes to my question? 12 A. Which is, I am sorry? 13 Q. An application and a fee -- 14 A. For NADE, yes. 15 Q. -- were all that NADE required? 16 A. Oh, I am sorry. Application and 17 three letters of reference or recommendation. 18 Q. And who wrote yours? 19 A. One was from Victoria Mertes, who is 20 also past vice president of NADE. And I can't 21 remember who the other two came from. It has 22 been a while. 23 Q. To join NADE, did you have to take 24 any form of test? 25 A. No, I did not. 0094 1 Q. Did you have to get a certain score 2 on anything? 3 A. No, I did not. 4 Q. And what is required for you to 5 continue to be a member of NADE? 6 A. To be a member or a certified 7 member? 8 Q. Well, first a member. 9 A. First a member, you pay your dues. 10 And what the dues include is a newsletter every 11 month, and you receive a professional journal 12 with articles with regard to document examination 13 and notifications of coming conferences, which 14 are reported. 15 Q. And what needs to happen for you to 16 continue to be a certified member of NADE? 17 A. You must attend so many conferences 18 to show that you have continuing education, 19 participate with writing articles for the 20 journal, or a combination of both. 21 Q. Are you a diplomate of the NADE? 22 A. A diplomate, no, I am not. 23 Q. What is a diplomate? 24 A. That -- usually that is held for 25 people who are held in high regard in the 0095 1 association. I haven't applied for it, but 2 there are certain requirements that you have to 3 meet in order to become a diplomate. 4 Q. So you are a past vice president of 5 NADE -- 6 A. That is correct. 7 Q. -- but you have not applied? 8 A. No, I have not. 9 Q. What is required for you to be a 10 diplomate? 11 A. As I mentioned, I am not quite sure 12 what the details are with that. 13 Q. Where is the home office of NADE? 14 A. It is incorporated, I believe, in 15 Delaware or New Jersey, but usually it follows 16 around where the current president is. And the 17 current president at this time is Kathy 18 Koppenhaver, and she is in Maryland. 19 Q. Well, I am sure it has a 20 headquarters office; does it not? 21 A. Oh, I see what you are saying. 22 Usually it is with one of the founders, and I 23 believe it is with Renee Martin. 24 Q. I don't understand your use of the 25 word usually. Is there a headquarters or not? 0096 1 A. I guess I am not sure what you mean 2 by headquarters. But it is with Renee Martin, 3 and I believe she lives in Princeton, New 4 Jersey. Because when you look up the 5 association for NADE, the contact person is 6 Renee Martin, who is past founder. 7 Q. Let me put it this way. Is there a 8 physical office that is the national headquarters 9 of NADE that I could go visit and see people 10 and talk to people and get their brochures, 11 obtain their literature, talk to their 12 receptionist, be escorted to the employees' 13 offices? Is there such a place? 14 A. Oh, we don't have a main office just 15 for that. But Ms. Martin handles all that. 16 Q. Well, do you have any office? 17 A. Yes. Ms. Martin has an office, and 18 also the headquarters of NADE is from that. If 19 anybody needs a brochure on NADE, she would 20 recommend them to contact the membership 21 chairman, or if they would like to speak to the 22 president, then she will direct the call to the 23 president. 24 Q. And is this office in Ms. Martin's 25 professional office? 0097 1 A. Yes, that is correct. 2 Q. And is that in her home? 3 A. I am assuming. I am not sure. 4 Q. You have not visited this office of 5 NADE? 6 A. No, I have not. 7 Q. So are you assuming there is one, 8 but you couldn't tell me for sure? 9 A. I just know from what I am told. 10 Q. Have any of the NADE conferences 11 that you have attended been held in a home 12 office or headquarters office of NADE? 13 A. No, it has not. It is usually held 14 in a location at a hotel with enough conference 15 area to hold all of the members that do attend. 16 Q. How many members does NADE have? 17 A. Last time I checked, which has been 18 a while, it was somewhere between 85 and 89. 19 I believe it is higher now. I believe it is 20 over 100, probably. 21 Q. Once a person is certified by NADE, 22 is there a peer review mechanism within the 23 organization? 24 A. For instance, before the person 25 applies or -- 0098 1 Q. No. After the person is certified. 2 A. Yes. 3 Q. What kind of peer review organization 4 is there or mechanism? 5 A. Well, we have an ethics committee. 6 For instance, if anybody, if it is reported to 7 the ethics committee, they will do an 8 investigation if they find that a member is not 9 behaving within the ethical guidelines. This is 10 for within the organization if we have any 11 complaints. 12 Q. Has anyone ever been expelled from 13 NADE for violating the ethical requirements? 14 A. I believe it was done in a very 15 polite way where the person did not come back. 16 Q. Was the person stripped of his or 17 her board certification? 18 A. This is to the best of my knowledge; 19 I am not sure if these are actual facts of the 20 event. 21 From what I understand, someone 22 claimed to have certification with NADE when, in 23 fact, they did not. So they were not welcome 24 back into the association, and they never had 25 certification to begin with. 0099 1 Q. And that is the only expulsion of a 2 member you are familiar with? 3 A. That I am familiar with. There may 4 be others, but I am not familiar with those. 5 Q. Are there any of the 85 to 89, or 6 possibly more now, members of NADE employed by 7 the FBI? 8 A. Not currently. Some are -- they are 9 retired FBI. We still have some people who 10 work for the state government. 11 Q. Are any of the 85 to 89 or perhaps 12 more members of the NADE employed by the United 13 States Secret Service? 14 A. No, not currently. 15 Q. If I correctly understand your 16 testimony, you yourself have not applied for 17 membership in the American Academy of Forensic 18 service -- excuse me, Forensic Sciences? 19 A. As I mentioned, a lot of those 20 organizations are open to people who work for 21 the government or have come from government 22 jobs. And in that sense, it is a little 23 discriminatory; and I am not able to apply. 24 Q. And have you not applied for the 25 American Board of Forensic Document Examiners? 0100 1 A. I am sorry, which one? 2 Q. The American Board of Forensic 3 Document Examiners. 4 A. That is another group that 5 discriminates against people who are not 6 government employed. 7 Q. Let me ask my question again. 8 A. Sure. 9 Q. It is a yes or no question. 10 A. I am sorry. 11 Q. You have never applied for 12 certification by the American Board of Forensic 13 Document Examiners; have you? 14 A. No. They discriminate. 15 Q. And you also have never applied for 16 certification from the American Society of 17 Questioned Document Examiners; am I correct? 18 A. That is correct. I believe they 19 have the same rules. 20 Q. Have you looked at the requirements 21 for certification by the American Board of 22 Forensic Document Examiners? 23 A. Let's see. I believe so, and I 24 believe it says that is voluntary. A lot of 25 people were grandfathered in early on in the 0101 1 beginning. And I am not sure if it is their 2 group or a different group that their board 3 certification test is sent to them. So it is 4 not taken in a public area where it is 5 proctored. 6 Q. Are you aware that for certification 7 by the American Board of Forensic Document 8 Examiners there are a number of qualifications? 9 Do you know that? 10 A. No. Go ahead.
#5, 5 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:11 PM
In response to message #4
11 Q. Do you know that one of those 12 qualifications is training at a forensic 13 laboratory? 14 A. For that group, that is a 15 requirement. 16 Q. So you do know of that requirement. 17 And have you yourself ever trained 18 at a forensic laboratory? 19 A. There is no standard in this field 20 that dictates where or when -- 21 Q. Excuse me. Do you recall the 22 question: Have you yourself ever -- 23 A. Oh, okay. 24 Q. -- trained at a forensic laboratory? 25 A. No, I haven't. 0102 1 Q. Thank you. So the American Board of 2 Forensic Document Examiners discriminates against 3 people like yourself who do not have forensic 4 laboratory training; am I correct? 5 A. No, that is different. That is not 6 discriminatory. That is a requirement in, as 7 they put it, for their group. 8 Q. And it is a requirement that you 9 have not met? 10 A. I have had an internship or a 11 mentorship program. But they believe in for 12 three years. But, as I mentioned, where my 13 work is corrected and it's been supervised. But 14 I have also received additional training from 15 Larry Zigler and also from John Hargett. 16 Q. Mr. Liebman did not run a forensic 17 laboratory; did he, Ms. Wong? 18 A. No, he did not. 19 And even the FBI didn't pass their 20 standards for their FBI laboratory at one time 21 either. And so there are difficulties in this 22 field and in the laboratory field with regards 23 to standards. 24 Q. Have you ever applied for training 25 at a forensic laboratory? 0103 1 A. You don't apply for training at a 2 forensic laboratory. How that works is if you 3 are in the field of document examination with 4 the government, then you are able to work within 5 that type of laboratory. 6 Q. Do you know that for certification 7 by the American Board of Forensic Document 8 Examiners a person needs to supply three 9 references from recognized forensic document 10 examiners recognized by the American Board of 11 Forensic Document Examiners? Are you aware of 12 that requirement? 13 A. Yes, I am. That is -- so you 14 actually have to know people to get in. Kind 15 of like nepotism. 16 Q. Actually, you have to obtain 17 references. 18 A. That's right, but from three people 19 you know that are members. So you kind of 20 have to know people in order to get in. 21 Q. Have you -- 22 A. You can't -- sorry. 23 Q. Have you any references from American 24 Board of Forensic Document Examiners, recognized 25 forensic document examiners? 0104 1 A. I am sorry. 2 Q. Are there any such individuals who 3 would supply you with a reference if you were 4 to seek certification from the American Board of 5 Forensic Document Examiners? 6 A. I can't answer for them. But if I 7 -- I wouldn't know until I asked. 8 Q. Who are you closest to? 9 A. With regards to? 10 Q. Of recognized ABFDE forensic document 11 examiners? 12 A. Oh, I am not sure. I think Mr. 13 Zigler is a member of it, but I have never 14 asked him for a recommendation. I would only 15 need to ask him for a recommendation if I were 16 to apply to ABF -- American Board of Forensic 17 Document Examiners. 18 Q. Ms. Wong, your resume mentions from 19 time to time the NWFIA, which is said to be 20 the Northwest Fraud Investigators Association; am 21 I correct? 22 A. That is correct. 23 Q. And that is said to be out in 24 Tukwila, Washington? 25 A. Okay. I am not sure how to 0105 1 pronounce it, but, yeah. 2 Q. I am not either, so. 3 A. Sounds good to me. 4 Q. Is that group a forensic document 5 examination group? 6 A. Not strictly a forensic document 7 examination group, but they did sponsor that one 8 course with John Hargett. 9 Q. And that group is principally 10 concerned about check fraud; is it not? 11 A. That is correct. Well, fraud that 12 affects retail. It involves checks. It 13 includes credit cards. All types of areas 14 of -- 15 Q. Does that group, the NWFIA, does it 16 certify questioned document examiners? 17 A. No, not that I am aware of. 18 MR. RAWLS: I will show you a 19 document we will mark as Defendants' Exhibit 4. 20 (Defendants' Exhibit-4 was marked for 21 identification.) 22 Q. (By Mr. Rawls) Do you recognize 23 this as a collection of two pages from the 24 NWFIA website? 25 A. I haven't been on their website 0106 1 personally, so this is the first time I am 2 looking at this. 3 Q. So it either -- it may or may not 4 be accurate? 5 A. I am not sure. 6 Q. Do you know that the organization 7 was formerly known as the Northwest Check 8 Investigators Association? 9 A. I am sure I read it at one time, 10 but it wasn't something I remembered. 11 Q. Why do you belong to the Northwest 12 Fraud Investigators Association? 13 A. Oh, I belong to them to receive 14 updates about their upcoming conferences, and to 15 see if there is anything that relates to my 16 field which I would want to attend. Check 17 fraud does involve handwriting and so does 18 credit card fraud. A lot of documents in 19 business involve handwriting and money. So I am 20 always interested in keeping abreast of what is 21 happening in the field, and so I stay a member 22 of the NWFIA. 23 Q. Ms. Wong, I would like now to talk 24 a little about your employment. 25 A. Okay. 0107 1 Q. Have you ever worked for a crime 2 lab? 3 A. No, I have not. 4 Q. Apart from the one or two 5 engagements that you received from the 6 Commonwealth Attorney's office and the one 7 engagement you had with the U.S. Probation 8 organization, have you ever been employed in any 9 law enforcement capacity? 10 A. No, I have not. 11 Q. Did you ever apply for a position 12 with the FBI? 13 A. One time a long time ago. 14 Q. When? 15 A. Good question. Many, many, many 16 years ago. I can't remember. I am sorry. 17 Q. What was the result? 18 A. Let's see, I decided not to pursue 19 it. I was contacted by the FBI that they had 20 received my lengthy application. There was a 21 lot to fill out. I can't remember at that time 22 why I decided not to pursue it. 23 Q. Did you apply -- well, for what 24 position in the FBI did you apply? 25 A. It was for a document examination 0108 1 job. 2 Q. Was it after you had received your 3 1991 training from Mr. Ted Widmer, graphologist? 4 A. It would not have been before that. 5 It was way, way after that. It was when I was 6 living at -- at least after '95. 7 Q. So it was after 1995, and you 8 applied for a questioned document examination 9 position -- 10 A. That is correct. 11 Q. -- with the FBI? 12 A. That is correct. 13 Q. And were you advised that you did 14 not have the necessary credentials for the job? 15 A. No, I was not. 16 Q. No one ever told you that? 17 A. That is correct. 18 Q. Am I not correct that your 19 application was rejected by the FBI? 20 A. I was not told that. 21 Q. Did you ever receive an acceptance? 22 A. I neither received an acceptance or 23 a rejection. All I received, I think it was 24 verbally, that they had received my application. 25 Q. You told us that your office is in 0109 1 your home; have you not? 2 A. That is correct. 3 Q. How large is the space in your home 4 that is your office? 5 A. It is approximately 350 or 6 400-something square feet. 7 Q. Do you have your own forensic 8 document examination laboratory? 9 A. It's -- the office and the 10 laboratory are all in that one room, and they 11 are on separate sides of the room. 12 Q. And what equipment is located right 13 there in that office in your home? 14 A. Not including office equipment? You 15 are specifically asking for document examination 16 equipment? 17 Q. Yes. 18 A. Okay. I have a stereoscopic 19 microscope. I have reticles. I have 20 magnification devices. I have your basic 21 rulers. I have your -- I have a light table. 22 I have a gooseneck lamp to examine indented 23 writing. And I out-source if I need anything 24 that needs to be done on ESDA or on a VSC. 25 Q. If we could turn, please, to your 0110 1 resume. And this, again, is back to Defendant's 2 Exhibit 1. On page 5 there is a list of 3 accessible handwriting identification equipment. 4 A. Uh-huh (affirmative). 5 Q. The first of these is the Apollo 6 18-inch by 12.5-inch light table. Is that the 7 one that is the light table in your office? 8 A. That is correct. 9 Q. Then there is Leica 2000 Zoom 10 Stereoscopic Microscope. Is that the one that 11 is in your office? 12 A. That is correct. 13 Q. There is an indication that there is 14 forensic photography equipment including Nikon 15 6006. Is that in your office? 16 A. That is correct. 17 Q. Then the next bullet point says 18 magnification loupes. Are those in your office? 19 A. That is correct. 20 Q. Measuring devices, caliper; are those 21 in your offices? 22 A. Correct. 23 Q. Grids and gauges; are they in your 24 office? 25 A. That is correct. 0111 1 Q. And the next bullet point is UV 2 light for determination of paper substitutions 3 and authentication. Is that in your office? 4 A. Yes. 5 Q. Next it says various oblique lighting 6 apparatuses for identifying indented writing, 7 inks and obliterated writing. Are those 8 apparatuses in your office? 9 A. Yes. 10 Q. And you said you out-sourced certain 11 things. What are those things? 12 A. It would be for an ESDA machine or 13 sometimes it goes underneath the name of 14 Kinderprint or Vaccubox. It is an equipment 15 that is used to bring up indented writing. 16 Q. All right. And was there anything 17 else that you out-sourced? 18 A. That is if I need anything for a 19 VSC, which is a videospector comparator. And 20 some of the items I have do some of the things 21 that VSC does. For instance, it has oblique 22 writing; it has UV lighting and so forth. But 23 you are able to use -- to bring something up 24 on your computer and actually print it out, what 25 that has that-- is usually sent out. 0112 1 What you can tell by different 2 lighting is with different filters and 3 wavelengths you're able to tell the different 4 types of inks that may be on a piece paper, 5 but it is not ink chemistry. 6 Q. Okay. 7 A. And the VSC can run up to $60,000, 8 so that would be quite an expensive piece of 9 equipment. And they have some older versions 10 that are less expensive. 11 Q. Ms. Wong, have you published any 12 papers on forensics document examination? 13 A. No, I have not. I have some in the 14 works, but I have not published yet. 15 Q. Have you published any of your 16 results or your conclusions on document 17 examinations so that they may be reviewed by 18 other document examiners? 19 A. No, I have not. As I said, I have 20 some of those items in the works. 21 Q. Are you tested annually to see if 22 your skills and your methods are reliable? 23 A. No, I am not tested annually; but 24 there are some proficiency tests that you can be 25 a part of. You just have to be aware of when 0113 1 they are happening and so forth. 2 Q. Ms. Wong, does Defendant's Exhibit 1, 3 that is your CV, does this include all of the 4 education that you have received that you 5 consider pertinent to the subject of document 6 examination and your credentials for document 7 examination? 8 A. As far as I know. 9 Q. Are you still on page 5 of your 10 resume? And if you are not, would you mind 11 turning to page 5, please. 12 A. Yeah. The last page? 13 Q. Yes. Do you see an entry for print 14 media, another for radio appearances, and another 15 for broadcast media? 16 A. Yes. And those are just for 17 advertising for business. 18 Q. You say under print media that you 19 were the subject or mentioned in articles in 20 "USA Today," the "Virginian Pilot," the "Boulder 21 Camera," the Boulder Daily, the "Progress Index" 22 and the "New York Post." Am I correct? 23 A. Yes. That is correct. 24 Q. What was the case that brought about 25 the mention of you in "USA Today"? 0114 1 A. It was a case with regards to 2 examining the ransom note for the JonBenet 3 murder. 4 Q. So it was the Ramsey matter, the 5 JonBenet Ramsey murder matter -- 6 A. That is correct. 7 Q. -- that brought you to the attention 8 of those who read "USA Today" the time that you 9 were named? 10 A. That is correct. 11 Q. And what case was it that led to 12 your being mentioned in the "Virginian Pilot"? 13 A. The same case. 14 Q. And the "Boulder Camera"? 15 A. The same case. 16 Just to make it easier for you, it 17 is all the same case. 18 Q. Okay. So the "Boulder Daily," the 19 "Progress Index" and the "New York Post," all of 20 that got you -- got your name in newspapers 21 based on one case, the case of the death of 22 JonBenet Ramsey? 23 A. Yes. 24 Q. Is the same true of the radio, all 25 of the radio appearances listed? 0115 1 A. Yes. That is correct. 2 Q. Is the same true of all of the 3 broadcast media listed? 4 A. Yes, that is correct. 5 Q. So nothing that you, Cina Wong, have 6 ever done has obtained you any newspaper or 7 radio or television publicity other than the 8 connection that you have with the JonBenet 9 Ramsey murder matter? 10 A. That is correct. I am not as 11 popular as Mr. Wood. 12 Q. May I say, Ms. Wong -- 13 A. Yes. 14 Q. -- you certainly are as glamorous. 15 A. Oh, thank you. Well, I think -- 16 Q. If Mr. Wood will not strangle me. 17 MR. WOOD: We will take that up off 18 the record. 19 MR. RAWLS: Let's go off the record 20 just a moment, if we could. 21 THE VIDEOGRAPHER: Going off the 22 video record at 12:30. 23 (A recess was taken.) 24 THE VIDEOGRAPHER: Back on the video 25 record at 12:43. 0116 1 (Defendants' Exhibit-5 was marked for 2 identification.) 3 Q. (By Mr. Rawls) Ms. Wong, let me 4 show you, please, a document Mr. Gallo has 5 marked as Defendants' Exhibit 5. Do you 6 recognize that? 7 MR. ALTMAN: Jim, do you have a 8 copy? 9 MR. RAWLS: Yes, I do. 10 MR. ALTMAN: Thank you. 11 THE WITNESS: Yes. 12 Q. (By Mr. Rawls) What is that, 13 please? 14 A. This is a compilation of my expert 15 witness testimony in court and in depositions. 16 It includes hearings also. 17 Q. Is it accurate? 18 A. There are two that I just -- two 19 cases that I've just testified on that aren't in 20 here. 21 Q. So this is a full and correct list 22 of all of your expert witness testimony, except 23 for two matters that are recent; and because 24 they are recent they have not yet been listed 25 on this document? 0117 1 A. That is correct. 2 Q. Would you first, please, tell us of 3 the two recent matters? 4 A. Let's see. It was -- the date was 5 January, and I can't remember what date. 6 Actually, let me check something. January, and 7 it was a case Considine versus Considine. The 8 attorney on my side was Robert Kantas, 9 K-A-N-T-A-S, I believe it was. And there was no 10 opposing attorney. Mr. Considine represented 11 himself, and it was in Sandston, Virginia. And 12 it was a hearing, a commissioner's hearing. 13 Q. And the other one? 14 A. And the other one is -- it was a 15 disputed will of Henry Hazelwood. It was in 16 May, just passed. And the judge's name is 17 Judge Powell. The attorney on my side was 18 Chuck Lollar, L-O-L-L-A-R. And the attorney on 19 the other side was Tommy Normant; and that was 20 in Williamsburg, Virginia, the circuit court. 21 Q. All right. Thank you. I want to 22 go through Defendants' Exhibit 5 and ask several 23 questions about these matters. Let's start with 24 page 1 and the first item, the testimony June 25 15 through 17, 1993. Were you testifying in 0118 1 court or in a deposition? 2 A. In court. 3 Q. In court. Was Mr. Liebman with you? 4 A. Yes. I believe he testified in that 5 also. 6 Q. What was the nature of the case? 7 A. It says it was a disputed will of 8 Mr. Painter. 9 Q. Which side were you on? 10 A. I can't remember. 11 Q. Which side was Mr. Liebman on? 12 A. The same side. 13 Q. And did the matter come out in favor 14 of the side you and Mr. Liebman were on? 15 A. I can't remember. I am sorry. 16 Some of these I remember, and some of them I 17 don't. And some of them I don't even know 18 what the outcome was. 19 Q. Was your testimony in that case 20 about the verification or authentication of the 21 genuineness of a signature? 22 A. Yes, that is correct. 23 Q. Was that the sole matter you gave an 24 opinion about in that case? 25 A. Yes, that is correct. All the cases 0119 1 I listed here has to do with document 2 examination, my testimony concerning document 3 examination. 4 Q. And let's go to the second entry, 5 testimony, August 8, 1993. And this was a 6 matter called WSB of Norfolk, Inc., Radio 7 Station Z104 versus Plaka, P-L-A-K-A, 8 Enterprises, Inc. What was the nature of that 9 case? 10 A. I believe it had to do with an 11 advertising contract that the radio station had 12 that was signed by whoever the gentleman was who 13 owned Plaka Enterprises. And the gentleman at 14 Plaka Enterprises said that he did not sign the 15 document. And there was an opposing document 16 examiner in that case. 17 Q. So, again, the question in that case 18 that you gave an opinion about was the 19 authenticity or genuineness of the signature by 20 someone with Plaka Enterprises; am I correct? 21 A. That is correct. 22 Q. And whose side were you on? 23 A. I was on the side for the radio 24 station. 25 Q. And who won? 0120 1 A. My side did. 2 Q. Was Mr. Liebman also involved? 3 A. Yes, but I am not sure if he 4 testified or not. 5 Q. Let's go to the next testimony, 6 March 29, 1994. Was this in court? 7 A. Yes, it was. 8 Q. I mean to ask whether your testimony 9 in the radio matter for WSB in the Norfolk 10 matter, was that in court or just in a 11 deposition? 12 A. Oh, right above it you will see I 13 mention in court. It was in Virginia Beach, 14 Virginia Circuit Court. And if it is a 15 deposition, then I will write that it is a 16 deposition. 17 Q. So on March 29, 1994, this was in 18 court? 19 A. Yes, that is correct, circuit court 20 in Norfolk. 21 Q. And GMAC was going after one Mr. 22 Otis Green for a sum of money of just over 23 $4,000? 24 A. That is correct. 25 Q. And you gave testimony in that case 0121 1 about what? 2 A. It was a disputed signature on 3 something. I can't remember what it was. I 4 guess it was some money that Mr. Green owed 5 GMAC. 6 Q. Whose side were you on? 7 A. I think I was for GMAC. 8 Q. And Otis Green said a certain 9 document did not contain his signature? 10 A. I believe that was the case. 11 Q. And you concluded it did? 12 A. I believe that was the case. 13 Q. Who won? 14 A. Our side did. 15 Q. And we will go to April 5, 1994. 16 Was this in court? 17 A. No, that was a commissioner's 18 hearing. It is written on the next page. 19 Q. Okay. And what was that about? 20 Was that a will signature authentication? 21 A. I can't remember. It just says 22 Estate of Virginia Burton versus Athalia 23 Robinson. So it may have been. 24 Q. Might have been a signature. Whose 25 side were you on? 0122 1 A. I was doing Mr. -- Mr. Walton hired 2 me. I can't remember. 3 Q. Do you know if your side won? 4 A. Usually with commissioner hearings, 5 they don't render an opinion until weeks, 6 sometimes months down the road, so we never even 7 hear.
#6, 6 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:12 PM
In response to message #5
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.
#7, 7 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:13 PM
In response to message #6
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.
#8, 8 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:15 PM
In response to message #7
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?
#9, 9 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:16 PM
In response to message #8
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.
#10, 10 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:18 PM
In response to message #9
6 Q. Was that sentence that I have just 7 read about anonymous letters often written in a 8 disguised manner, was that sentence written in 9 order to account for the fact that there were 10 many differences between the exemplars that you 11 were given from Ms. Almy and the anonymous 12 letters that you were comparing the exemplars 13 to? 14 A. Was that the specific reason? No. 15 Q. What was the specific reason? 16 A. I just remember that -- 17 That doesn't sound very good. 18 MR. ALTMAN: Just a four o'clock 19 rain. 20 THE WITNESS: Oh, that is thunder? 21 MR. RAWLS: That is thunder. We 22 will stipulate that that is thunder. 23 Q. (By Mr. Rawls) Could we proceed 24 with your answer? 25 A. Yes. Sorry. Sorry. That threw me 0199 1 off guard there. 2 I am sorry. Your question again? 3 MR. RAWLS: Mr. Gallo, would you 4 read that back, please. 5 (The record was read by the 6 reporter.) 7 THE WITNESS: Mr. Grisham said he 8 wanted an explanation about anonymous letters. 9 He told Mr. Liebman that, and Mr. Liebman wrote 10 -- he told me to include that in the letter, 11 and I agreed with it. 12 Q. (By Mr. Rawls) But you don't 13 mention any differences in your letter to John 14 Grisham at all; do you? 15 A. This is a basic letter of opinion. 16 And if they want to know more information, that 17 is usually when they depose us. This is just 18 a basic opinion letter. 19 Q. Was it your opinion that all of the 20 differences between the handwriting exemplars of 21 Ms. Almy and the handwriting in the anonymous 22 notes were the product of disguise? 23 A. Yes, that is correct. 24 Q. And that is your conclusion in the 25 case of JonBenet Ramsey and the ransom note in 0200 1 this case as well; is it not? 2 A. In this case, it could be disguised, 3 but it could normally have been -- well, I 4 guess I am not sure exactly what you are asking 5 me. 6 Could it be disguised or is it or 7 is it not? Is that what you are asking? 8 Q. You reached the same conclusion in 9 connection with Patsy Ramsey that you reached in 10 connection with Katherine Almy; did you not? 11 A. No. My opinion is stronger in the 12 Ramsey case. 13 Q. I see. But again, in the Ramsey 14 case, just like the case of Katherine Almy, you 15 conclude that any differences are accounted for 16 by disguise; do you not? 17 A. I am not quite sure what differences 18 you are talking about in the ransom note. If 19 you can point one out. 20 Q. Did you find any differences in the 21 ransom note and Patsy Ramsey's exemplars? 22 A. I found some variations within the 23 ransom note and Patsy Ramsey's handwriting that 24 are in her handwriting. 25 Q. Did you find any differences? 0201 1 A. There might be one or two areas 2 where I couldn't find anything to match it 3 exactly; but I could -- comparing it to Patsy 4 Ramsey's exemplars, it was within the realm of 5 her handwriting. 6 Q. You are telling me there were no 7 differences and there were just a small number 8 of variations; is that your testimony? 9 A. Not a small number of variations. 10 It was an incredible number of similarities. 11 There were some variations. And what you want 12 to call differences could be coined as 13 accidentals that happen, as I mentioned, once in 14 every hundred, 200 or 300 writings, were there. 15 But that is only if we have an additional 16 sample of handwriting taken over time will we 17 see that. 18 Q. And you account for the variations 19 by saying they were either accidental or the 20 product of disguise in the case of the ransom 21 note in this case? 22 A. Let me clarify myself. Variations 23 aren't differences. They are just different 24 ways of writing something within someone's 25 handwriting. May I show you? 0202 1 In your own expert's report, for 2 instance, let me just get the page. I believe 3 this is Mr. Cunningham's report. And he shows 4 the different types of P's. He shows that it 5 has a tendency to flatten on the face of the 6 bulge. Now, as you can see, there are five 7 examples here. And, you know, these all came 8 from the ransom note and came from one person. 9 But when you compare this to a page of my 10 writing, you will see -- let me see if I can 11 juggle here. Can you hold this? I'm sorry. 12 MR. ALTMAN: Sure. 13 THE WITNESS: Thank you. 14 And on my exhibit here, as you can 15 see, the letter P that starts out on this side, 16 the range where it gets extremely square, this 17 is within the range of her handwriting. That 18 is what I mean by range. It shows a range. 19 And this shows it is right within the range. 20 And so Mr. Cunningham shows it over 21 and over again that -- I will just take this 22 one. He talks about the lower case n-g 23 combination. Thank you. And he says that the 24 back leg of the N enters into the bottom 25 portion of the G. And that is also located in 0203 1 Patsy Ramsey's handwriting in page 12. 2 On this side, it is her handwriting. 3 And if you look at the N, it comes underneath 4 the G. It also appears on 13. 5 You notice on this one, the n-g 6 combination, how the G comes out, just outward 7 towards the right and goes in. And you see 8 that example down here in the lower portion, 9 excuse me, of this right here. 10 So there is, like, a certain range 11 that you go by because we can't write the same 12 way twice. We are not computers and we're not 13 typewriters, and we don't produce the same 14 written letter or combination exactly the same 15 every time. So that is why we have variations 16 because it is variable for people. 17 Q. (By Mr. Rawls) Ms. Wong, I am at a 18 loss to understand how what you just told us 19 had any relationship to the question that I 20 asked you. 21 A. I am sorry. I was trying to 22 explain variation to you. 23 Q. And what you have said, however, is 24 that you found no differences between the Patsy 25 Ramsey exemplars and the authorship of the 0204 1 ransom note; but you did find some things you 2 consider variations. 3 A. That is correct. 4 Q. Am I correct? 5 A. That is correct. 6 So what your expert, Mr. Cunningham, 7 he had some exhibits showing what he thought 8 were consistencies within the ransom note which 9 were not found in Mrs. Ramsey's handwriting, 10 which, in fact, they were found in her 11 handwriting. 12 Q. And, Ms. Wong, I had not even asked 13 you a question when you gave me that lecture 14 just now, which I will move to strike. 15 A. Okay. I am sorry. 16 Q. Because it is your job to answer 17 questions only after they are asked. 18 A. Okay. I thought I was trying to 19 explain variations to you, so I was trying to 20 help you understand. My apologies if I 21 misunderstood the question. 22 Q. Do you examine both handprinting and 23 cursive writing, Ms. Wong? 24 A. Yes, I do. 25 Q. What is the difference between 0205 1 examining handprinting and examining cursive 2 writing? 3 A. Cursive writing is the script, and 4 printing can usually be the letters which aren't 5 connected. And then sometimes you are dealing 6 with handwritten, with writing that is a 7 combination of both. 8 Q. Do you compare one to the another, 9 handprinting with cursive writing? 10 A. It is difficult. It is hard to 11 find the same letter formations in cursive as in 12 print. But what you can use sometimes if there 13 are numbers involved, punctuation marks, or usage 14 of the paper if you want to look at the 15 marginalia, how the usage is. 16 Q. How does a document examiner make a 17 decision between a true difference in handwriting 18 which disqualifies a person as an author of a 19 questioned document on the one hand and a 20 disguise by the author on the other hand? 21 A. Okay. The first question is how do 22 you differentiate what is a difference in a 23 handwriting? 24 Q. What is a true difference that is a 25 disqualifying difference? 0206 1 A. If something is written that is 2 structurally and how the letter is constructed 3 is very different than the way it is done. 4 For instance, if you are comparing two 5 handwritings, if, for instance -- may I 6 demonstrate just with the letter D? 7 Q. Sure. Do you need a piece of 8 paper? 9 A. Yes, please. That would be nice. 10 MR. ALTMAN: I will give her one. 11 THE WITNESS: Thank you. 12 So, for instance, what I mean by 13 construction and structure of a letter D, come 14 forward with the stem first, and the lower part, 15 portion of it, which, for the sake of 16 explanation looks like a lower case C. For 17 other people, the construction will be this 18 first and the stem second. That would be 19 something that is a major difference since the 20 construction of the two letters are composed 21 differently even though they may appear to be 22 the same, because this is something that is 23 subconscious where you just write and you don't 24 think about what stroke to make next and so 25 forth. 0207 1 Q. (By Mr. Rawls) And go on. 2 A. Oh, okay. Sorry. 3 Q. With how you determine what is a 4 true difference -- 5 A. Okay. 6 Q. -- that is disqualified? 7 A. I didn't want to go on. You 8 scolded me earlier. I didn't want to over step 9 my bounds. 10 Other differences you may find is 11 that the letter forms are very different from 12 the questioned writing to the known handwriting 13 samples. If line placement, you look at how 14 certain letter combinations are formed, how 15 certain letters are formed, dots of the I's, the 16 placement of that, the placement of the T bars, 17 if those are varied. 18 You look for usage of space on the 19 paper. And when originals are available, you 20 look at the pressure. And you look at slant. 21 You look at angles. There are many items 22 involved. So it is all the document examination 23 going down the list and looking for what it is 24 you are comparing. 25 Q. And how do you differentiate finding 0208 1 differences that are disqualifying from finding 2 differences that you consider a disguise? 3 A. Oh, disguised handwriting is usually 4 written very slow and arduous and carefully. 5 Sometimes there are shakes involved. Sometimes 6 there are touch-up marks and patches and so 7 forth. And so when someone is disguising their 8 handwriting, they usually either, some of the 9 ways, of course, changing letter forms. But 10 other ways would be changing the speed of the 11 writing where the writer believes that they are 12 actually disguising their handwriting. But the 13 problem is with disguised writing, your natural 14 habits come out sooner or later if you write 15 too much. 16 Q. Have you found in the literature any 17 test results showing the known rates of error 18 for determining the authority of unknown 19 writings? 20 A. Specifically with unknown writings? 21 No, I have not. 22 Q. Are you aware of tests showing how 23 good a job forensic document examiners do when 24 compared to lay persons at determining the 25 authorship of unknown writings? 0209 1 A. What do you mean unknown? You are 2 talking anonymous writings or are you talking -- 3 Q. Yes, anonymous writings. 4 A. Just specifically anonymous writings? 5 Because I read studies, but I am not sure if 6 they dealt with anonymous writings. I know they 7 were asked to match up certain writings to see 8 if they were written by certain people. 9 Q. How good a job did the forensic 10 document examiners do relative to lay persons in 11 those study results you have looked at? 12 A. To the best of my memory, that the 13 document examiners did better than the lay 14 persons. And there was actually a Mr. Bryan 15 Found, who is actually Dr. Bryan Found. He has 16 a Ph.D., out of Australia. Mr. Found with 17 another professor released a proficiency test, 18 and I think it encompassed about 50 document 19 examiners. Some of those were government and 20 some of those were private. And the eight high 21 scores actually belonged to private document 22 examiners. 23 Q. How many of those were NADE 24 certified? 25 A. I am not sure how many of them 0210 1 were, but I know definitely one, and that is 2 our current president. She had the highest 3 score, I believe. 4 Q. You mentioned earlier that the NADE 5 had 85 to 89 members last time you checked and 6 that the membership, of course, might have 7 changed after that. 8 A. That's correct. 9 Q. How many NADE certified document 10 examiners are there? 11 A. That is a good question. I don't 12 have the answer to that. 13 Q. Have you kept a track record of 14 whether your opinions have proven to be accurate 15 or in error? 16 A. My test -- how I was tested was 17 that my work was supervised through Mr. Liebman 18 when I worked with him through the mentorship 19 program. And from there I also took the 20 certification test with NADE. So I had the 21 mentorship program where I was supervised, and I 22 had to take the written and oral exam through 23 NADE to receive that certification. 24 Q. What is your own known rate of error 25 in your own conclusions? 0211 1 A. I am not sure what that would be. 2 Q. Did you make an error in the case 3 of Katherine Almy? 4 A. No. What I did is I submitted an 5 opinion there that it appears to be which is 6 probable, and it was up to -- what I write 7 after that is up to Mr. Grisham, and he handed 8 it to an investigator. And after he read it, he 9 seemed to believe that there was enough 10 information to pursue an investigation. 11 Q. And you don't know yet whether Ms. 12 Almy is correct or not when she says she did 13 not author the anonymous notes in that case? 14 A. You said I don't know whether she is 15 correct or not? 16 Q. Yes. 17 A. Well, after I look at the evidence 18 and the state document examiner that she hired, 19 they were not able to eliminate her. I asked 20 for additional handwriting samples, and the state 21 document examiner asked the same. But she has 22 not supplied either of us with any additional 23 samples. 24 Q. So you don't know yet whether she is 25 right in her case or not? 0212 1 A. That is right. She hasn't been very 2 cooperative in giving us information we need. 3 Q. Ms. Wong, when did you first become 4 aware of the case involving the death of 5 JonBenet Ramsey? 6 A. When did I become aware of it? 7 Q. Yes. 8 A. When it was broadcasted in the 9 media. 10 Q. And as best you recall, when was 11 that? 12 A. I am guessing. I will say December 13 1996. 14 Q. When did you first come to any 15 conclusions, however tentative, about who 16 committed the murder? 17 A. Well, I don't have any opinion as to 18 who committed the murder back then or today. 19 Q. Have you ever had any tentative 20 conclusions? 21 A. About who committed the murder? 22 Q. Yes. 23 A. No, I do not. 24 Q. When did you first view the ransom 25 note? 0213 1 A. Mr. Liebman received a call from a 2 newspaper person, and then Mr. Liebman told me 3 that someone was sending a copy of the note and 4 some handwriting samples of Patsy Ramsey. 5 Q. When was that? 6 A. That's a good question. I can't 7 remember. The note had already been released in 8 the media, and it was way after that. That is 9 all I can remember. 10 Q. Who was the newspaper person? 11 A. I can't remember his name, but he 12 was actually with the Enquirer. 13 Q. Have you ever seen the original 14 ransom note? 15 A. No, I have not. I did ask to see 16 it, but I hear it is not available. 17 Q. When did you ask to see it? 18 A. When the newspaper reporter called, I 19 asked him. And then at a later date when Mr. 20 Hoffman called, I also asked. And then again 21 when this case arose, I asked again if it was 22 available. 23 Q. And approximately when did you first 24 see a copy? 25 A. As I said, it was way after the 0214 1 date that the ransom note was released to the 2 media, whenever that may have been. 3 Q. What type of copy did you see? 4 A. A copy was sent to us in the mail. 5 Q. What generation copy was it? 6 A. That is what we asked, and we 7 weren't sure. So we are assuming it is a 8 later generation. 9 Q. When you first saw it, did you take 10 any action? Did you make a study of it? 11 A. Of the ransom note? 12 Q. Yes. 13 A. When we received it, of course I 14 looked at it.
#11, 11 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:20 PM
In response to message #10
15 Q. Did you make a study of it? 16 A. In what sense? 17 Q. In a professional document 18 examination? 19 A. Yeah. In a systematic way, yes, I 20 looked at the ransom note and then I looked at 21 exemplars that were available. And I went 22 through the steps of, I guess, this time we 23 were working with copies. But it is amazing that 24 even though we were working with a copy of the 25 note that there were so many -- in normally 0215 1 what a copy would hide, there are so many 2 similarities and distinct features that did pop 3 out. 4 And we looked -- when I looked at 5 the note, I looked at certain letter formations 6 in the note. I did a -- I studied the note 7 to understand the handwriting in there, the way 8 it is formed, the way it is written, how 9 certain items and certain letters fit on -- how 10 they are to the baseline, if they are above or 11 below, certain spacings between words, alignment, 12 a lot of the other things I've mentioned before. 13 And then I looked at the samples 14 that were sent to us of Mrs. Ramsey's 15 handwriting. And from there I studied her 16 handwriting to see what was in the range of her 17 handwriting to see how she wrote. 18 Q. Did you make that systematic 19 examination of the ransom note and exemplars 20 even before you had heard from Darnay Hoffman? 21 A. In that case, yes, that is correct. 22 Q. What conclusion had you reached 23 before you heard from Darnay Hoffman? 24 A. That it was probable. There were 25 just striking similarities between the ransom 0216 1 note and the handwriting of Patsy Ramsey. But 2 the reason why it was probable is because I 3 told the newspaper reporter that we would need 4 additional samples. 5 Q. Did the "National Enquirer" pay you 6 or Mr. Liebman? 7 A. No, they did not. 8 Q. Did they -- 9 A. Well, I can only speak for myself. 10 No, they did not pay me. And I don't believe 11 that they paid Mr. Liebman. 12 Q. Did the "National Enquirer" ask you 13 to study the note and exemplars and reach a 14 conclusion? 15 A. They didn't ask me personally. They 16 asked Mr. Liebman. 17 Q. And so you and Mr. Liebman did this 18 analysis in 1997 at the request of the "National 19 Enquirer," a tabloid publication; and that was 20 your first official, professional involvement in 21 the case of the JonBenet Ramsey ransom note? 22 A. If that is what you want to call 23 it. 24 Q. Yes is your answer? 25 A. Oh, okay, yes. I don't know what 0217 1 you mean as professional or what since we were 2 not retained with any money. 3 MR. WOOD: I am sorry. What did 4 she say? 5 MR. HOFFMAN: Would you read the 6 answer back? 7 (The record was read by the 8 reporter.) 9 THE WITNESS: We weren't paid to do 10 the work. There weren't any -- 11 Q. (By Mr. Rawls) You got just as 12 much money from the "National Enquirer" as you 13 did from Chris Wolf; am I correct? 14 A. Oh, you mean zero? 15 Q. That is what I mean. 16 A. I haven't received any money from 17 Mr. Wolf. 18 Q. So one may or may not consider that 19 professional; is that your testimony? 20 A. No, no, no. I just wasn't sure 21 what you were trying to imply. 22 Q. So is it fair to assume that Mr. 23 Darnay Hoffman had learned of your existence and 24 your credentials from the tabloid? 25 A. That is how he heard our names. 0218 1 Q. I see. In your resume when you 2 listed your news media appearances, did you list 3 the "National Enquirer"? 4 A. No, I did not. 5 Q. Why is that? 6 A. Oh, there were many other ones I did 7 not put on there, so. 8 MR. RAWLS: I see. Let's take a 9 five-minute break, if that is agreeable. 10 THE VIDEOGRAPHER: Going off the 11 video record at 4:19. 12 (A recess was taken.) 13 THE VIDEOGRAPHER: Back on the 14 record at 4:33. 15 Q. (By Mr. Rawls) Ms. Wong, did you 16 yourself ever receive any money from any tabloid 17 in connection with the JonBenet Ramsey death or 18 murder? 19 A. Any tabloid, no. You mean like 20 "Globe" and those other papers? 21 Q. Yes. 22 A. No, I have not. 23 Q. Or anybody affiliated with a tabloid? 24 A. I -- is "Hard Copy," I think they 25 paid us something one time. They wanted an 0219 1 exclusive or something. 2 Q. In connection with the ransom note? 3 A. That is correct. 4 Q. How much did "Hard Copy" pay you? 5 A. I can't remember. I think David 6 Liebman and I split, like, $500. 7 Q. Did, to your knowledge, any tabloid 8 pay David Liebman anything? 9 A. Not to my knowledge. 10 Q. The "National Enquirer"? 11 A. I am not aware if they paid him or 12 not. 13 Q. "American Media"? 14 A. Who are they? 15 Q. I believe they are the owner of the 16 "National Enquirer." 17 A. Oh, okay. No. Sorry. 18 Q. The "Globe"? 19 A. No. 20 Q. Any other publication pay David 21 Liebman any money? 22 A. No, not that I know of. 23 Q. Any other broadcaster apart from 24 "Hard Copy" pay David Liebman any money? 25 A. No, not that I know of. 0220 1 Q. And apart from your having split 2 yourself $500 with David Liebman that was 3 received from "Hard Copy," have you ever been 4 paid anything by anybody in connection with the 5 ransom note? 6 A. No, I have not. 7 Q. And I mean the ransom note that was 8 found in the Ramsey home in connection with the 9 death of JonBenet Ramsey? 10 A. That is correct. 11 Q. Is your answer the same, no money to 12 you apart from the $500 that you split? 13 A. That is correct. From what I 14 remember, that is all. 15 Q. And the "National Enquirer," when it 16 asked you and Mr. Liebman to look at the ransom 17 note -- 18 A. Well, they asked Mr. Liebman, and I 19 was just working at that time for -- 20 Q. You just what? 21 A. I was working for Mr. Liebman at 22 that time, so I wasn't specifically asked by 23 them. 24 Q. What exemplars did the "National 25 Enquirer" give to you and Mr. Liebman? 0221 1 A. Oh, you asked me that earlier. See 2 if I remember again. 3 It was a picture of the box with 4 Ramsey written on it. A picture of a poster 5 that said Welcome to the Northwest Territory. 6 Q. What else? 7 A. I am trying to think. I am not 8 sure if that one in front of you came from Mr. 9 Hoffman or the Enquirer, but it was all around 10 the same time period. There was a Rainbow Fish 11 Player picture. There was also a Hi, Bob, 12 letter. 13 Q. So the fact is you don't know 14 whether the Rainbow Fish Player's exemplar came 15 from the "National Enquirer" or Darnay Hoffman? 16 A. That is correct. 17 Q. And you don't know whether the Hi, 18 Bob, note came from the "National Enquirer" or 19 from Darnay Hoffman? 20 A. I am trying to remember. Yes, that 21 is correct. I can't remember exactly where it 22 came from. 23 Q. Now, did you or Mr. Liebman ask the 24 "National Enquirer" to authenticate that the 25 exemplars you have described came from Patsy 0222 1 Ramsey? 2 A. Yes. We asked them where the 3 exemplars came from and if there was anybody to 4 verify that those signatures -- or I am sorry, 5 that those writings were created by her; and 6 they told us that the photo of the boxes were 7 taken through the window of their house. And I 8 said, well, how do we know that was written by 9 Patsy. And also there was the poster. And I 10 think they said that they also had them maybe 11 verified. I can't remember clearly. But that 12 is a question that we always ask. 13 Q. You just don't remember what the 14 "National Enquirer" said? 15 A. That is correct. 16 Q. The photo of the boxes you were told 17 was taken through the window, and you asked the 18 very good question how did the "National 19 Enquirer" know whose hand had written the name 20 on the boxes? 21 A. Correct. 22 Q. And did you get an answer to that? 23 A. I am trying to remember. It kind 24 of blurs during the time period with the 25 "National Enquirer" and Mr. Hoffman what was 0223 1 received and so forth, because that came -- they 2 came pretty close in time. 3 Q. Do you remember getting an answer 4 that definitely tied Patsy Ramsey or anybody 5 else to the name on the box? 6 A. I am trying to think. At that time 7 I wouldn't have used it if they said they 8 didn't confirm it. But I cannot remember if I 9 really even utilized that box as part of an 10 exemplar, at the moment. 11 Q. And what verification did the 12 "National Enquirer" give you concerning the 13 Welcome to the Northwest Territories poster? 14 A. I can't remember at the moment. 15 But, I mean, I remember the way they told me 16 how they acquired the picture. 17 Q. How was that? 18 A. It was just they took a photo of it 19 in front of -- somebody was in her garage, and 20 they took a picture of it. And that was it. 21 Q. In whose garage? 22 A. I am sorry. Mr. and Mrs. Ramsey's 23 garage. 24 Q. Who took a picture of it? 25 A. I don't know. 0224 1 Q. Someone from the "National Enquirer"? 2 A. Could be. 3 Q. But you don't recall at this time? 4 A. That is correct. I mean, they could 5 have sent out an independent photographer. I am 6 not sure. 7 (Defendants' Exhibit-8 was marked for 8 identification.) 9 Q. (By Mr. Rawls) Ms. Wong, can you 10 tell us if you recognize Defendant's Exhibit 8? 11 A. Yes, I do. It is a report issued 12 to Mr. Hoffman on November 14, 1997. 13 Q. From whom? 14 A. From me. 15 Q. And are you the sole author of this 16 report? 17 A. Yes. I wrote a -- there are some 18 typos in here. 19 Yes, I wrote this. 20 Q. Did you list all of the exemplars 21 that you used for comparison with the ransom 22 note in this letter? 23 A. What was available to me at that 24 time, yes. 25 Q. And there were seven items; were 0225 1 there not? 2 A. Yes, that is correct. 3 Q. And let me ask you, using this 4 letter and pages one and two of this letter as 5 your guide, to tell me which of S1 through S7 6 was furnished to you by Mr. Ramsey -- excuse 7 me, by Mr. Hoffman and which of those items, S1 8 through S7, had previously been furnished to you 9 by the "National Enquirer." 10 A. The two-page letter addressed to Miss 11 Kit. I am not sure if that came from the 12 "National Enquirer" or Darnay. 13 A greeting card with the -- 14 preprinted with Wishing you a bright and 15 beautiful holiday season; and it begins with Hi, 16 Bob. I am not sure if that came from Darnay 17 or the "National Enquirer." 18 The color photocopy of the photograph 19 of Welcome to the Northwest Territory. That 20 came from the "National Enquirer." 21 The color photocopy of the picture 22 of the box that says Ramsey in the lower 23 right-hand corner that came from the Enquirer. 24 The color photocopy of the photo 25 with four children, which is Rainbow Fish 0226 1 Players. I can't remember if that came from 2 the "National Enquirer" or Darnay. 3 The photocopy of the color scrapbook 4 with the handprinting, This is me when I was 5 first born. That came from Darnay Hoffman. 6 And there was a copy of a round 7 metal button with the handprinting, Hello, I am 8 Marilyn Monroe. That came from Mr. Hoffman. 9 Q. Did you keep records of the analysis 10 that you made which you provided to the 11 "National Enquirer"? 12 A. I would have to look at my files. 13 I am not sure. 14 Q. Would you do that for us, because 15 the answer -- 16 A. I would be more than happy to. 17 Q. -- would be very useful to us? 18 A. Okay. If I can find it, I will be 19 more than happy to show it to you. 20 Q. Because I can only assume that you 21 did a detailed and careful study before you or 22 Mr. Liebman gave any conclusions to the 23 "National Enquirer"; am I correct? 24 A. Correct. My case file on this, 25 though, is filling up boxes. So, hopefully, I 0227 1 will be able to find it. 2 Q. Did you submit anything in writing 3 to the "National Enquirer"? 4 A. Not that I am aware of. 5 Q. But you did do a written analysis 6 for your own purposes before commenting to the 7 "National Enquirer"; did you not? 8 A. No. I would just have my notes, 9 and they would ask what my opinion was. I 10 only do a written letter of opinion or report 11 when I am asked to. 12 Q. And your conclusion to the "National 13 Enquirer," then, was made based on S3 as listed 14 in Defendants' Exhibit 8 and was made based on 15 S4 as listed in Exhibit 8 and might have been 16 made based on no additional exemplar whatsoever? 17 A. That is not true. I would have to 18 look at my notes in order to give you a more 19 concise answer. 20 Q. Well, for today's purposes, the only 21 things that you know for sure you had even seen 22 before you spoke with Darnay Hoffman are S3 and 23 S4; are they not? 24 A. That is what I remember. 25 Q. So those are the things you know you 0228 1 got from the "National Enquirer" -- 2 A. That is correct. 3 Q. -- and not later from Mr. Hoffman, 4 correct? 5 A. That is correct. 6 Q. There is nothing else you can tell 7 me about today that you know you had received 8 from the "National Enquirer"? 9 A. Not that I can remember. 10 Q. Okay. So to the best of your 11 knowledge today, you base the opinion you gave 12 to the "National Enquirer" solely on S3 and S4? 13 A. I am not sure. I can't give you a 14 correct answer on that until I look at my notes 15 or find them. 16 MR. HOFFMAN: Jim, I am confused. 17 Can I just ask one question -- 18 MR. RAWLS: Yes. 19 MR. HOFFMAN: -- because I may have 20 missed this? 21 What opinion is it that you are 22 referring to? Was there actually an opinion 23 that was quoted somewhere with respect to Cina 24 or David, because you are talking about her 25 opinion? What opinion is that? 0229 1 MR. RAWLS: She's testified that she 2 and Mr. Liebman gave an opinion to the "National 3 Enquirer," and that is the opinion I am 4 discussing. 5 MR. HOFFMAN: Okay. So you are not 6 talking about an opinion that appeared in print 7 in the Enquirer or anything like that? You are 8 basing this opinion -- and we are not even sure 9 of the language of the opinion in this case? 10 MR. WOOD: Other than what she's 11 testified to. 12 MR. HOFFMAN: Other than what she's 13 testified to. Okay. So there is no external 14 document that you are referring to with respect 15 to an opinion to the Enquirer? Because you 16 keep asking her about her opinion. I don't 17 even know what this opinion is except that maybe 18 there was some sort of conclusion drawn. But 19 in what sort of language? 20 MR. RAWLS: I don't know what was 21 published in the "National Enquirer." 22 MR. WOOD: But, Darnay, that is not 23 to say that I may know. 24 MR. HOFFMAN: Okay. I just thought 25 maybe I had missed it in this, because I was 0230 1 just wondering if there was a reference to an 2 actual quote as against what she's just stated 3 her memory to be with respect to this opinion 4 in the Enquirer. 5 MR. WOOD: Can you help us as to 6 maybe clarify in which of these documents you 7 got from her, because she had them from the 8 "National Enquirer" and which ones you had? 9 MR. HOFFMAN: Well, let me just try 10 and clarify. Do you want to do this initially 11 off the record and then make a record? How do 12 you want to do this? 13 MR. RAWLS: Sure. 14 MR. HOFFMAN: Okay. So why don't 15 we just go off the record for a minute; and if 16 you need to make a record, we will do it, so I 17 don't do this on your own time. 18 MR. RAWLS: We are off the record. 19 THE VIDEOGRAPHER: We are off the 20 record at 4:47. 21 (Discussion ensued off the record.) 22 THE VIDEOGRAPHER: Going back on the 23 record at 4:57. 24 Q. (By Mr. Rawls) Ms. Wong, you have 25 been here listening to the colloquy we've just 0231 1 had off the record, have you not, with Mr. 2 Darnay Hoffman? 3 A. Yes, that is correct. 4 Q. Has that refreshed your recollection 5 about several of the events that happened in 6 1997? 7 A. It might explain why my memory of 8 everything is kind of intermingling. 9 Q. Sure. 10 A. But I really won't know until I get 11 back and look through the files and see. 12 Q. And from your files, let me tell you 13 a few things we would like to obtain from you 14 if you have them. 15 A. If I have them.
#12, 12 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:21 PM
In response to message #11
16 Q. And Mr. Hoffman and Mr. Altman can 17 tell us if it is agreeable for those to be 18 furnished to us if you do, indeed, have them. 19 First is your notes that were made 20 about the handwriting on the ransom note and any 21 exemplars furnished to you or to Mr. Liebman by 22 the "National Enquirer." 23 And, Darnay, and, Evan, is it 24 agreeable that those be produced if, indeed, Ms. 25 Wong possesses them? 0232 1 MR. HOFFMAN: Yeah. It is fine 2 with us so long as there isn't some sort of 3 privilege that she can establish. But I have 4 no problem with it. I don't know about you, 5 Evan. 6 MR. ALTMAN: Yeah, I have no 7 problem. 8 Q. (By Mr. Rawls) Are you sure this 9 was the "National Enquirer," Ms. Wong, as 10 opposed to some other tabloid? 11 A. As far as I remember, that is who I 12 think it was. 13 Q. And if it is some other tabloid and 14 you can find the notes but it turns out to be 15 a different tabloid, we would like those notes 16 as well. 17 MR. ALTMAN: I think subject to the 18 same potential, if there is some privilege, then 19 I don't think we will have any privilege 20 otherwise. 21 Q. (By Mr. Rawls) In addition, Ms. 22 Wong, did you keep a copy of the resulting 23 article published by the "National Enquirer" or 24 whatever tabloid it was as a result of the work 25 that you and Mr. Liebman did and reported to 0233 1 the tabloid? 2 A. I may and I may not have. I won't 3 know until I look in the file. 4 Q. And we would like a copy of that 5 article if it, indeed, exists in your file, Ms. 6 Wong. 7 And, Darnay, and, Evan, we hope that 8 will be something you all will agree to produce 9 if found. 10 A. Right. 11 Q. We would also like a copy of the 12 Tom Miller, the Attorney Tom Miller report that 13 we understand based on Mr. Hoffman's remarks 14 just now off the record was furnished by Mr. 15 Darnay Hoffman to you, Ms. Wong, during 1997, 16 which we understand attached were included S1 17 through S7 or some or all of those exemplars as 18 listed on your letter which is Defendant's 19 Exhibit 8. 20 A. Okay. 21 Q. So do you feel that you likely have 22 that Tom Miller report? 23 A. I am not sure. I would have to go 24 look, but I remember Darnay sending it. And I 25 was thinking to myself why do attorneys even 0234 1 bother doing that because I don't even read it 2 until after I do my analysis first. 3 Q. So is it your testimony you do or 4 you do not remember the Tom Miller report? 5 A. I remember receiving it, and I 6 remember reading it way later on after the fact. 7 Q. So it is your positive testimony 8 that you did not read the Tom Miller report 9 until you had reached your own conclusions? 10 A. That is correct. 11 Q. And that report, of course, may or 12 may not continue to be in your files; am I 13 correct? 14 A. That is correct. 15 Q. And if it is in there, we ask you 16 for that. 17 And, Mr. Hoffman, and, Mr. Altman, 18 we hope that is agreeable to produce. 19 MR. ALTMAN: That is agreeable. 20 (Defendants' Exhibit-9 was marked for 21 identification.) 22 Q. (By Mr. Rawls) Ms. Wong, 23 Defendants' Exhibit 9 is a copy of a letter 24 from Darnay Hoffman to Thomas C. Miller, 25 Esquire, in Denver, Colorado, dated October 31, 0235 1 1997. And my question for you is simply were 2 you ever furnished a copy of this letter by Mr. 3 Hoffman? 4 A. I don't recognize this letter. 5 Q. Would you take a moment to read 6 through it, please? 7 A. Sure. 8 MR. HOFFMAN: Jim? 9 MR. RAWLS: Yes. 10 MR. HOFFMAN: Can I comment just on 11 the circumstances of that letter while she is 12 reading it? And I can do it briefly. 13 MR. RAWLS: Darnay, I would prefer 14 that you not do that. 15 MR. HOFFMAN: Oh, okay. 16 Q. (By Mr. Rawls) Have you had a 17 chance to take a look at that letter and its 18 contents? 19 A. Yes, I've briefly read it. 20 Q. And did Mr. Hoffman -- having read 21 this letter, does it refresh your recollection 22 as to whether you had ever seen it before 23 today? 24 A. No, I haven't seen it. 25 Q. Did Mr. Hoffman tell you in 0236 1 substance any of the information that is found 2 in this letter to Mr. Miller? 3 A. No, he has not. 4 Q. You will note in the second 5 paragraph of this letter that Mr. Hoffman states 6 he had spoken with handwriting expert Paul A. 7 Osborn, who is referred to as the grandson of 8 Albert S. and son of Albert D. Osborn. Did 9 Mr. Hoffman tell you about his conversation with 10 Paul Osborn? 11 A. Not that I can remember. 12 Q. Did he tell you that Mr. Paul Osborn 13 knew the handwriting experts who gave reports to 14 the defense team and to the Colorado Bureau of 15 Investigation? 16 A. Not that I can remember. 17 Q. Did Mr. Hoffman tell you that 18 according to Paul Osborn those experts were at 19 the top of their field? 20 A. Did Mr. Hoffman tell me that? 21 Q. Yes. 22 A. No. 23 Q. Did he tell you those experts had 24 impeccable ethical credentials? 25 A. No. 0237 1 Q. Did he tell that you their verdict 2 was that the similarities between Patsy's 3 handwriting and the ransom note handwriting were 4 at the lowest end of the spectrum? 5 A. No. 6 Q. That there was little or no basis 7 for a match? 8 A. I wasn't told that. 9 MR. RAWLS: And, Darnay, I wanted to 10 ask those few questions before you made your 11 explanation; but if you've got an explanation 12 you want to make now off the record, we can go 13 off the record. 14 MR. HOFFMAN: Sure. 15 MR. RAWLS: Okay. We will go off 16 the record. 17 THE VIDEOGRAPHER: Going off the 18 record at 5:05. 19 (A recess was taken.) 20 (Defendants' Exhibit-10 was marked for 21 identification.) Remove | Alert | IP Printer-friendly page | Edit | Reply | Reply With Quote | Top
jameson Member since 5-8-02 08-15-02, 04:32 PM (EST) 11. "12 Cina Wong depo" In response to message #10 22 THE VIDEOGRAPHER: Back on the video 23 record at 5:11. 24 Q. (By Mr. Rawls) Ms. Wong, let me 25 show you Defendants' Exhibit 10, please. 0238 1 Here is a copy for you, a copy for 2 you. 3 Do you recognize this document? 4 A. Yes, I sure do. 5 Q. Is it a true copy of a document 6 that was signed by yourself and David Liebman in 7 1997? 8 A. That is correct. 9 Q. And was submitted to the law offices 10 of Mr. Hadden? 11 A. That is correct. 12 Q. In Colorado? 13 A. That is correct. 14 Q. Was this before or after you all had 15 spoken with the "National Enquirer"? 16 A. Way before. 17 Q. Way before. So the "National 18 Enquirer" people would have talked with you some 19 weeks or months after July 30, 1997? 20 A. Right. I had not even seen a copy 21 of the ransom note at this time, I believe. 22 This came about because I saw Mrs. Ramsey on TV 23 making a plea for anybody who might be able to 24 help her in this situation. My heart went out 25 to her. It was -- I can't imagine being in 0239 1 such a situation that she was involved in. And 2 I wanted to be able to help assist Mrs. Ramsey 3 in any way. 4 So I heard that Mr. Hadden was their 5 attorney, and I sent them a fax letting them 6 know we were available if they needed our 7 assistance. 8 Q. And this letter, then, also is dated 9 before you had ever spoken with Darnay Hoffman; 10 is that true? 11 A. That is correct. 12 (Defendants' Exhibit-11 was marked for 13 identification.) 14 Q. (By Mr. Rawls) Ms. Wong, you just 15 have been handed Defendants' Exhibit 11 by Mr. 16 Gallo. Do you recognize this document? 17 A. Yes, that is correct. 18 Q. Is that an authentic signature of 19 yours on the second page of this document? 20 A. Yes, that is my signature. 21 Q. And is that an authentic notary 22 public signature -- 23 A. Yes, it is. 24 Q. -- below your signature? 25 A. Uh-huh (affirmative). 0240 1 Q. And it is an area of your own 2 expertise to know that, is it not, whether those 3 are authentic signatures or not? 4 A. Well, I signed it, and I saw the 5 lady notarize it, so. 6 Q. Who is Yolanda Feggans or Feggans? 7 A. I don't know her personally, but she 8 was a notary at a law firm. 9 Q. To whom did you provide this 10 affidavit? 11 A. To Mr. Hoffman. 12 Q. Did you provide it to Mr. Hoffman on 13 or about the date you signed it, November 13, 14 1997? 15 A. I assume so. It would not be 16 before. 17 (Defendants' Exhibit-12, Exhibit-13 18 and Exhibit-14 were marked for identification.) 19 Q. (By Mr. Rawls) Ms. Wong, this is a 20 reproduction of an alleged letter, and I want to 21 ask you if this is a reproduction of a true 22 letter authored by you? 23 A. Okay. I don't recognize it in this 24 form, since it is a reproduction. Or is it in 25 the form that it came in? 0241 1 Q. The reproduction is the only form 2 that we have it in. 3 A. Okay. Yeah, I -- 4 Q. But did you send such a letter to 5 Alex Hunter in or about September 28, 1998? 6 A. Yes. I remember speaking to Mr. 7 Hoffman about the situation, and he told me what 8 was going on and asked me if I wanted to 9 assist in this. And I told him that, yes, I 10 would like to. And I asked him how I could go 11 about this. 12 Q. And is this identical to or very 13 substantially similar to a letter that you 14 actually did send to District Attorney Alex 15 Hunter in 1998? 16 A. I sent one. I would have to see 17 it. I am not sure what you are speaking 18 about. I mean, is it similar to -- 19 Q. Please read Defendants' Exhibit 12 20 and let me know if that is an identical -- 21 A. This is to Mr. Hunter. 22 Q. Yes. 23 A. That's correct. But you say if I 24 wrote another one; is that what you are saying? 25 Q. No, no. 0242 1 A. Oh, okay. I'm sorry. 2 Q. I am asking did you write this? 3 A. Yeah. Well, I spoke to Mr. Hoffman 4 about how to word it, so it was with his help. 5 Q. So to the best of your knowledge, 6 while this is a reproduction and not a 7 photocopy, this appears to be verbatim accurate. 8 A. That is correct. 9 Q. Correct? 10 A. I remember the situation being 11 discussed, and this is what -- this is what I 12 was partaking in. 13 Q. So did you formally ask District 14 Attorney Hunter to permit you to testify to the 15 grand jury in 1998, correct? 16 A. Uh-huh (affirmative). They were on 17 a fact-finding mission. I had some facts that 18 I thought they would like to be aware of. 19 Q. Who is Michael Kane? You see he 20 got a cc. 21 A. Right. He was an assistant to Mr. 22 Hunter. 23 Q. He is an Assistant District Attorney, 24 correct? 25 A. I think that is what he was. It's 0243 1 been a while. 2 Q. Would you take a look, please, at 3 Defendants' Exhibit 13. This, too, is a 4 reproduction. Let us know if it is verbatim 5 accurate or substantially similar to a letter 6 you received in reply. 7 A. Okay. 8 Yes. I recognize this letter. 9 Q. Is that identical to or substantially 10 similar to the actual reply which you received 11 from Mr. Kane on behalf of District Attorney 12 Hunter? 13 A. I am sorry? You are saying? 14 MR. RAWLS: Would you read the 15 question back, please, Alex? 16 (The record was read by the 17 reporter.) 18 THE WITNESS: Yes, I recognize this. 19 Q. (By Mr. Rawls) Did you then reply 20 to Defendants' Exhibit 13? 21 A. Yes. 22 Q. And is Defendants' Exhibit 14 a 23 reproduction of your actual reply? 24 A. Yes. I recognize that letter. 25 Q. And that is, indeed, your reply? 0244 1 A. That is correct. 2 (Defendants' Exhibit-15 was marked for 3 identification.) 4 Q. (By Mr. Rawls) Is Defendants' 5 Exhibit 15 a true reproduction of a letter which 6 thereafter you sent to Judge Roxanne Bailin of 7 the 20th Judicial District of Colorado? 8 A. Yes. I recognize this letter. 9 Q. Did you send that letter? 10 A. I am trying to think. Well, I 11 mean, I don't know if I sent it directly or if 12 I handed it to someone else to send for me. 13 But with the wording, I did ask Mr. Hoffman 14 also; we conferred in how to word this. 15 Q. Did Mr. Hoffman assist you with your 16 side of this entire body of conversation -- of 17 correspondence we are looking at now? 18 A. Entirely? Or what? 19 Q. With all of these letters of yours 20 to Alex Hunter and Mike Kane and Judge Bailin? 21 A. You are saying he wrote them 22 entirely or are you saying assisted? 23 Q. No, no. I am asking, did he -- let 24 me start over, please. 25 Did Darnay Hoffman assist you in 0245 1 wording all of your letters to Alex Hunter and 2 Michael Kane and Judge Bailin? 3 A. Not all of them. Just some of 4 them. 5 Q. The language was worked out by you 6 in consultation with Darnay Hoffman; is that 7 correct? 8 A. That is correct. 9 Q. And all of this effort was made by 10 you with the assistance of Mr. Hoffman in the 11 hope that you could testify to the grand jury 12 in Colorado that Patsy Ramsey, in your opinion, 13 probably authored the ransom note; is that 14 correct? 15 A. That is correct. I had a lot of 16 information to share. 17 Q. Had you ever been told up to the 18 point of this last letter, Defendants' Exhibit 19 15, that Mr. Hoffman represented Chris Wolf? 20 A. No. I didn't know that. 21 Q. As a matter of fact, this letter was 22 authored more than a year before John and Patsy 23 Ramsey published a book, "The Death of 24 Innocence." 25 A. Okay. 0246 1 Q. Was it not? 2 A. I am not sure of the date. 3 (Defendants' Exhibit-16 was marked for 4 identification.) 5 Q. (By Mr. Rawls) Let me ask you to 6 look at Defendants' Exhibit 16, please. Ms. 7 Wong, it purports to be a three-page 8 reproduction of two letters, one from Michael 9 Kane on behalf of Alex Hunter to you, and one 10 from Michael Kane on behalf of Alex Hunter to 11 David Liebman. 12 Would you please look over the 13 reproduction that is -- that purports to be of 14 a letter to you -- 15 A. Do you have the second page? Oh, 16 it runs on. I see what it's done. 17 Q. My question is, is this, pages one 18 and two of Defendants' Exhibit 16, is there on 19 these pages an accurate reproduction of a letter 20 which Michael Kane sent to you in early 1999? 21 A. Okay. I will read it and let you 22 know. 23 (Deponent reviews document.) 24 Okay. I read my letter, and I 25 think the second one is basically the same. 0247 1 Q. Well, I don't need you to address 2 the reproduction of the letter Mr. Kane sent to 3 Mr. Liebman. I am only interested in whether 4 the reproduction of the letter from Mr. Kane on 5 behalf of Alex Hunter to you is accurate -- 6 A. Yes. 7 Q. -- as best you recall? 8 A. From what I remember, yes. 9 Q. Do you have the originals of all 10 these letters in your file? 11 MR. ALTMAN: Jim, let me interrupt. 12 As far as accurate, do you mean accurate as to 13 what is stated in there or accurate that she 14 did receive it? 15 MR. RAWLS: Well, I mean accurate 16 that it is what he sent to Ms. Wong. 17 MR. ALTMAN: Okay. 18 Q. (By Mr. Rawls) I am not asking do 19 you agree with Mr. Kane's conclusions. 20 A. Okay. Yeah, I do not agree with 21 Mr. Kane's conclusions. 22 I am sorry, your question was? 23 Q. My question is, is this the letter 24 that he sent you? 25 A. The printing, the verbiage and 0248 1 everything, yeah. 2 Q. Yes? 3 A. The way it was written, yes. 4 Q. Thank you. Do you have Mr. Kane's 5 actual letter in your file? 6 A. It should be in a file somewhere.
#13, 13 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:23 PM
In response to message #12
7 MR. RAWLS: And we would like the 8 actual letter so we will not have to be using 9 reproductions, Ms. Wong, if that can be found, 10 and if Mr. Hoffman and Mr. Altman will agree 11 that it should be produced. 12 MR. HOFFMAN: Yes, if the original 13 can be produced, absolutely. But there's 14 certainly not going to be any prohibition from 15 you introducing it in the event there is a 16 trial because there is a copy. Of course, we 17 will try and give you the original, naturally. 18 MR. RAWLS: Or a Xerox of the 19 original. I am not standing on formality. I 20 don't need to see the original. We are not 21 going to try to hire someone to try to 22 authenticate Michael Kane's handwriting. 23 Q. (By Mr. Rawls) Do you also, Ms. 24 Wong, have a copy of your letter to Alex Hunter 25 of September 28, 1998, which I believe is 0249 1 Exhibit 12? 2 A. I may not have a signed copy. I 3 may just have a printed version in my computer 4 somewhere. 5 Q. But you probably do have a record of 6 that letter? 7 A. Somewhere. 8 Q. And we would like a copy of that as 9 well. 10 Do you have in your files also a 11 copy of the letter which -- 12 A. One moment. I am trying to make 13 note of this. 14 Q. Sure. Take your time. I don't 15 mean to rush. 16 A. Okay. Sorry. Go ahead. 17 Q. That's okay. Do you also likely 18 have in your office a copy of Defendants' 19 Exhibit 14, that being the October 16, 1998, 20 letter in which you replied to Michael Kane to 21 Defendants' Exhibit 13, which was his letter of 22 October 2, 1998, to you? 23 A. I may have a copy in my computer. 24 Q. And we would like that as well if 25 that can be found and if Mr. Hoffman and Mr. 0250 1 Altman agree that we can see that copy. 2 And, finally, do you have a copy of 3 your letter which is Defendants' Exhibit 15 to 4 Judge Bailin in your office? 5 A. Probably be in my computer. 6 Q. Good. Do you need to make a note 7 of that? 8 A. I am making a note of that now. 9 MR. HOFFMAN: Again, Jim, I am 10 making notes too. 11 MR. RAWLS: Good. Thank you all. 12 MR. WOOD: Darnay, do you want to 13 take five minutes, maybe, and let Jim organize 14 his -- 15 MR. HOFFMAN: Yes, please. 16 MR. RAWLS: I would like about a 17 five-minute break to get organized and try to 18 prioritize what I need to do in the time 19 remaining. 20 MR. ALTMAN: Jim, what I would ask, 21 you said there may be a possibility of a way 22 to get her bags over here if we are going to 23 get close to that 6:30. I think it is going 24 to be a little bit pressed maybe if -- 25 THE WITNESS: And I have a question. 0251 1 MR. RAWLS: Let's go off the record. 2 THE VIDEOGRAPHER: Off the video 3 record at 5:33. 4 (A recess was taken.) 5 THE VIDEOGRAPHER: Back on the video 6 record at 5:46. 7 Q. (By Mr. Rawls) Ms. Wong, can you 8 tell us, please, the date of the interview that 9 you did with Hard Copy? 10 Let me just repeat that question 11 after I locate my mike because it seems to have 12 -- let me start that over, please. 13 Ms. Wong, can you give us the date 14 of the interview that you did with Hard Copy? 15 A. No, I don't remember what that date 16 is. 17 Q. Can you give it to us approximately? 18 A. Late '77. I am sorry. Late '97 to 19 '98 or something like that. 20 Q. Thank you. And for now is that the 21 best you can do for us? 22 A. Yes, it is. 23 Q. Do you have anything in your office 24 that would let you pin down the date with more 25 precision? 0252 1 A. I may. 2 Q. Do you have a videotape of your 3 appearance? 4 A. I think I recorded it, and my VCR 5 went on the blitz, so I actually don't have a 6 copy of it. 7 Q. Do you have a calendar entry or a 8 date book or diary entry that might help us 9 learn that date? 10 A. I may. 11 Q. Can you check that when you are 12 looking for some of the other things we've 13 discussed today? 14 A. That is a lot of work. Actually, 15 this is easier, but I will take a look. 16 Q. Thank you. 17 You have, Ms. Wong, have you not, 18 authored an expert report at the request of Mr. 19 Darnay Hoffman and Mr. Evan Altman for this 20 case? 21 A. Yes, that is correct. 22 Q. And in that report, you said that 23 your opinion was given based on well 24 established, I am quoting now, well established 25 and recognized principles of questioned document 0253 1 examination as discussed and defined in the 2 following recognized texts, close quote. 3 Do you recall that language in your 4 report? 5 A. Yes. 6 Q. And I am going to now read the 7 texts which are described in your report. 8 First, Questioned Documents by Albert Osborn; 9 second, Handwriting Examination -- 10 MR. ALTMAN: Jim, can you tell us 11 where you are so we can follow along? 12 MR. RAWLS: Yes. This is page 2. 13 This is the February 25, 2002, Forensic 14 Handwriting Report, and this is page 2 of that. 15 And it was furnished to us, Evan, and, Darnay, 16 with a pleading entitled Plaintiff's Disclosure 17 of Expert Testimony. 18 MR. HOFFMAN: Was it a pleading? I 19 think it was just a -- wasn't it just sort of 20 like a pro forma cover with a caption, whatever, 21 all over it? 22 MR. WOOD: Yes. It was not filed. 23 MR. RAWLS: Yes. I am not 24 suggesting when I use the word pleading that it 25 was filed. 0254 1 MR. HOFFMAN: Okay. 2 MR. RAWLS: But it otherwise has the 3 form of a pleading. 4 MR. HOFFMAN: Yeah. 5 Q. (By Mr. Rawls) Okay. The first 6 text on page 2 that you mentioned, Ms. Wong, 7 was "Questioned Documents" by Albert Osborn; is 8 that correct? 9 A. That is correct. 10 Q. The second one was "Handwriting 11 Examination - Facts and Fundamentals" by Huber 12 and Headrick; am I correct? 13 A. That is correct. 14 Q. The next was "Disputed Documents" by 15 Hagin, correct? 16 A. Correct. 17 Q. The next was "Evidential Documents" 18 by Conway? 19 A. That is correct. 20 Q. The next was "Scientific Examination 21 of Documents" by Hilton, correct? 22 A. Correct. 23 Q. The next was "Suspect Documents" by 24 Harrison? 25 A. That is correct. 0255 1 Q. And are those texts all of the texts 2 which you have relied upon as furnishing the 3 well established and recognized principles of 4 questioned document examination which you have 5 relied on in authoring your report? 6 A. Yes. There are more of these, but 7 these I thought were most representative. 8 Q. And these are some of the most 9 reliable textbooks in the questioned document 10 examination field; are they not? 11 A. They are the most respected. For 12 instance, the Osborn book is 73 years old. So 13 there are a lot of things missing and a lot of 14 things that need to be amended that I changed 15 over time. And also with Harrison, a lot long 16 past. There are some things in there that are 17 correct, but there are other things that need to 18 be amended. 19 Q. And you have not relied on anybody 20 else's textbook in coming up with the principles 21 that you base this report on; have you? 22 A. As I mentioned earlier, I used other 23 textbooks; but these are the ones that are most 24 representative, and I mentioned these. 25 Q. And do you possess each of these 0256 1 textbooks in your office? 2 A. Yes, I do. 3 Q. And you brought with you some books 4 here today; did you not? 5 A. I just brought one. 6 Q. And what is that book, please? 7 A. It is a new book by Katherine 8 Koppenhaver, and actually it is quite coming to 9 be one of the most respected books very quickly. 10 It is "An Attorney's Guide to Document 11 Examination." 12 Q. Is this the individual who is part 13 of NADE? 14 A. That is correct. She is currently 15 president. She is past president and current 16 president. 17 Q. Okay. She has been elected to two 18 terms as president of NADE; is that correct? 19 A. That is correct. 20 Q. Can you give us the Library of 21 Congress publication data, please, on that book? 22 A. The ISBN number? 23 Q. Yes. 24 A. Is 1-56720-470-8. 25 Q. And inside the front cover, could 0257 1 you turn to the title page, please? 2 A. This one? 3 Q. Yes. On the back of the title 4 page, do you find publication information? 5 A. Yes. 6 Q. And who is the publisher, and what 7 is the copyright date, please? 8 A. Copyright is 2002. And the 9 publisher is Quorum, that's Q-U-O-R-U-M, Books. 10 Q. Thank you. May I take a quick look 11 at it, please? 12 A. Sure. I am borrowing that copy 13 right now. 14 Q. You have an autographed first 15 edition; do you not? 16 A. Actually, it is Mr. Liebman's copy. 17 I ordered mine. I wanted to read on it 18 quickly, so he was kind enough to let me borrow 19 it. 20 Q. And now we are sitting here on May 21 13, 2002; are we not? 22 A. That is correct. 23 Q. And this book says it was first 24 published in 2002? 25 A. That is correct. 0258 1 Q. And you said this is fast becoming 2 one of the most respected textbooks? 3 A. That is correct. It came out 4 earlier this year, and a lot of people are 5 reading it. And it is put together very well. 6 Q. It had to work pretty fast to become 7 so well -- 8 A. Well, I mean -- 9 Q. -- respected; did it not? 10 A. -- a lot of people are reading it. 11 Q. How many copies has it sold? 12 A. That is a good question. I am not 13 sure. You'd have to ask Ms. Koppenhaver. 14 Q. And what are the other items that 15 you have brought with you here today, Ms. Wong? 16 The video camera, I am sure, has picked up the 17 fact that you have a notebook and several papers 18 in front of you. 19 A. Yes. I have my notebook with me 20 with demonstrative evidence. I have copies of 21 your expert's reports. And I also have copies 22 of some of the exemplars that were used in this 23 case. 24 Q. Are you, Ms. Wong, aware that the 25 Colorado Bureau of Investigation did obtain 0259 1 studies and analyses with respect to the ransom 2 note that was left in connection with the 3 JonBenet Ramsey death from a number of document 4 examiner experts? Did you know that? 5 A. No. It was -- you are saying that 6 they did a lot of tests and analyses? 7 Q. I was asking whether you were aware 8 that the Colorado Bureau of Investigation asked 9 several handwriting and document examiner experts 10 to study the JonBenet Ramsey ransom note? 11 A. I know they were having some 12 document examiners examine the note. That was 13 actually published in the media. 14 Q. Do you know who some of those 15 experts were that were hired by the Colorado 16 Bureau of Investigation? 17 A. Personally, no. 18 Q. Can you name any of them here today 19 before I name a few? 20 A. Oh, Mr. Ubowski and Mr. Riles. And 21 those are the only two I am familiar with at 22 this moment. 23 Q. Have you heard of Leonard Speckin, 24 S-P-E-C-K-I-N? 25 A. Is that of Speckin Laboratories up 0260 1 in Michigan? 2 MR. WOOD: Yes. 3 Q. (By Mr. Rawls) Yes, he is. 4 A. Yes. 5 Q. Is he a qualified questioned document 6 examiner, in your opinion? 7 A. I am not familiar with him. I am 8 familiar with -- is it Leonard the owner? Is 9 he the father? I am familiar with the son. 10 Q. Okay. All right. 11 A. The son has come to the NADE 12 conferences, and he has spoken at our 13 conferences, and he will be -- or their firm 14 is, actually -- will be speaking at a NADE 15 conference coming up in the next couple of 16 weeks. But due to my health condition, I am 17 not able to go. 18 Q. Do you have any understanding of 19 Leonard Speckin's conclusion about authorship of 20 the ransom note, and specifically about whether 21 Patsy Ramsey wrote the note? 22 A. No, I do not. 23 Q. Have you heard of Edwin Alford? 24 A. Oh, he is in Baltimore; isn't he? 25 Baltimore, Maryland? 0261 1 Q. I am not sure. 2 A. Oh, okay. Edwin -- well, I know an 3 Alford, but I am not sure if it is the same 4 one, so I won't say. 5 Edwin or Alfred? 6 Q. Edwin Alford, A-L-F-O-R-D. 7 A. I am not sure if it is the same 8 one, so I am not sure if I'm familiar if that 9 is the correct person or not I am thinking of. 10 Q. Do you know Richard Dusick or have 11 you heard of him? 12 A. No. 13 And I am sorry, going back to Mr. 14 Alford, I have seen his name referred to in 15 some articles. That is where I am familiar with 16 his name. 17 Q. Would you be surprised to know that 18 the Colorado Bureau of Investigation obtained 19 several reports from handwriting analysts that 20 the Colorado Bureau of Investigation considered 21 to be well qualified, and several of those 22 experts concluded that Patsy Ramsey probably did 23 not author the ransom note? Would you be 24 surprised if that is accurate? 25 A. I am not surprised of the opinion. 0262 1 I am not sure about what approach they used or 2 so forth to come to their opinion. 3 Q. Different qualified document examiners 4 can reach different conclusions about authorship 5 of a questioned anonymous document; can they 6 not? 7 A. At times. But basically all 8 document examiners study the same texts, and it 9 also depends on their training. A lot of -- 10 from what I am told, a lot of document 11 examiners that go into government document 12 examination jobs, they are trained by other 13 document examiners who have had a few short 14 courses and they are busy working, and so they 15 are learning from people and who may not go out 16 as often and go to certain conferences and 17 certain seminars and so forth. 18 Q. You concluded in your report, quote, 19 and this is page 4 of the February 25, 2002 20 report that you gave Mr. Hoffman and Mr. Altman, 21 you concluded: Quote, it is highly probable that 22 Patsy Ramsey wrote the ransom note, end quote. 23 Am I correct? 24 A. That is correct.
#14, 14 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:24 PM
In response to message #13
25 Q. And you did not give an opinion that 0263 1 it was a certainty that Patsy Ramsey wrote the 2 ransom note; did you? 3 A. Let me understand what you are 4 saying. Can you explain yourself? 5 Q. You used the words highly probable. 6 A. That is correct. 7 Q. You did not say it is plain or 8 clear or definite? 9 A. Well, actually, if you look at my 10 opinions, most people will derive that opinion 11 that Mrs. Ramsey is the person who penned the 12 note. 13 Q. Well, do you feel that you have 14 eliminated all reasonable doubt about whether 15 Patsy Ramsey wrote the ransom note? 16 A. In this case, I highly believe she 17 wrote the note. 18 Q. And please answer my question. 19 A. I am sorry. 20 Q. Do you feel that you have eliminated 21 all reasonable doubt? 22 A. With the people, the possibilities of 23 who could be involved in this case with the 24 three handwriting samples that were given to me 25 and enormous -- the enormous similarities that 0264 1 Patsy Ramsey's handwriting and the note, yes, I 2 believe she is the writer. 3 Q. Well, you believe she is most likely 4 of those three to have authored the note? 5 A. Correct. 6 Q. But those are the only three whose 7 exemplars you have studied? 8 A. But I am also familiar with 9 different types of handwriting since I have 10 looked at many, many, many handwritings and yet 11 have I ever seen so many similarities in one 12 handwriting group. 13 Q. So have you eliminated all reasonable 14 doubt? Can you say with definiteness that Patsy 15 Ramsey did write the note? 16 A. She in some way is very involved. 17 Q. You said she in some way is very 18 involved. Well, she was the mother of the 19 deceased. Now, that is involved; is it not? 20 A. In that sense, yes. With penning 21 the note, she wrote the note. 22 Q. You are sure she wrote the note? 23 A. There is too many similarities 24 pointing to that fact that in this world it 25 would be highly unlikely to find anybody who 0265 1 would have all these similarities, who would 2 have the same and in the same combination. 3 Q. And handwriting analysts can only 4 provide their own opinions about authorship; can 5 they not? 6 A. That is correct. 7 Q. And the opinions of qualified 8 handwriting analysts may differ on the authorship 9 of the same document; might they not? 10 A. At times there are document examiners 11 who may give convenient opinions. I do not 12 give convenient opinions. 13 Q. The opinions of qualified handwriting 14 examiners can vary; can they not? 15 A. At times, yes. 16 Q. And if, indeed, different qualified 17 document examiners from yourself reach the 18 conclusion that it was probable that Patsy 19 Ramsey did not author the note, that would not 20 surprise you? 21 A. I am sorry. You are saying 22 different examiners from myself? I am sorry? 23 Q. If they reach the conclusion that 24 Patsy Ramsey probably did not author the ransom 25 note, that would not surprise you; would it? 0266 1 A. That wouldn't surprise me, but there 2 is Gideon Epstein and Larry Zigler who have also 3 come to the same opinion that I have in this 4 case. 5 MR. RAWLS: I do move to strike the 6 portion of the answer that you have just given 7 us that was not responsive. 8 Q. (By Mr. Rawls) And, Ms. Wong, are 9 you aware Mr. Zigler has withdrawn himself from 10 this case? 11 A. I am aware of that, but that doesn't 12 change his opinion. 13 Q. Well, I don't know whether it 14 changes his opinion or not, but I am afraid we 15 are not going to have the benefit of seeing his 16 opinion. 17 A. Okay. 18 Q. Today we have your opinion that is 19 the subject of our testimony; do we not? 20 A. That is correct. 21 Q. Do you base your opinion on that of 22 Gideon Epstein? 23 A. Oh, no, I do not. 24 Q. Do you base it on that of Larry 25 Zigler? 0267 1 A. I do not base my opinion upon Mr. 2 Zigler's opinion, but I did take a course from 3 Mr. Zigler. And what he teaches is the same 4 of everything that I've studied and all the 5 leading textbooks. 6 Q. And do you base your opinion on that 7 of David Liebman? 8 A. On his opinion? I didn't read his 9 opinion, as I told you. I did my own 10 independent examination in this case. 11 Q. So the answer is no, you don't base 12 your opinion on the opinion -- 13 A. Anybody but my own. 14 Q. -- of anybody else? 15 A. That's correct. 16 Q. You base yours on yourself alone. 17 A. That is correct. 18 Q. Correct? 19 Which -- 20 A. Well, not just -- I'm sorry. I am 21 not quite understanding what you are saying. 22 That my opinion, based on the examination, 23 correct. I just don't look at it and say, 24 hey, well, I assume this. I just want to make 25 that clear. 0268 1 Q. Do you have in front of you a copy 2 of the ransom note itself? 3 A. Yes, I do. 4 (Defendants' Exhibit-17 was marked for 5 identification.) 6 Q. (By Mr. Rawls) Is Defendants' 7 Exhibit 17 a copy of the ransom note, Ms. Wong? 8 A. Yes, it is. 9 Q. When you first studied this note, 10 did you ever at any point make a study of this 11 note when you had no exemplars at all to 12 compare with it? 13 A. You mean, did I look at -- when I 14 received the note and the exemplars, was there a 15 time when I just looked at the ransom note 16 without the exemplars? 17 Q. Well, that is not exactly my 18 question. Did you have this note, a copy of 19 Defendants' Exhibit 17, before you received any 20 exemplars? 21 A. No. I don't think I had seen this. 22 I knew it was released, but I had not received 23 a copy of it. 24 Q. So at the same time you got this 25 note, a copy of this note, you already had 0269 1 received some exemplars that were said to you to 2 be exemplars of Patsy Ramsey's handwriting; am I 3 correct? 4 A. Yes. They were sent in conjunction 5 with a copy of the ransom note. 6 Q. And did you ever analyze the ransom 7 note independently of any other exemplars? 8 A. Analyze the ransom note for what, 9 because I have nothing to compare it to? 10 Q. Did you analyze it based on all of 11 its contents alone and without regard to whether 12 there might be similarities to some other 13 exemplar? 14 A. Are you asking for content 15 analysis -- 16 Q. Yes, exactly. 17 A. -- with regard to linguistics? 18 Q. No. With regard to handwriting? 19 A. Regard to handwriting? 20 Q. Yes. 21 A. No, I didn't look at the note and 22 study it that way. 23 Q. Did you develop a, what I would call 24 a master plan confined to a handwriting analysis 25 of this ransom note alone at any time? 0270 1 A. Oh, you are asking me if there were 2 -- if I was looking for certain similarities 3 which are consistent in the ransom note, what 4 they were? 5 Q. Yes. 6 A. Yes, that is correct. And those 7 same -- that same pattern that you're asking me 8 about the master plan, those same similarities I 9 found in Patsy Ramsey's handwriting. 10 Q. That is not my question. 11 Did you prepare a master plan based 12 solely on the ransom note? 13 A. Not solely on the ransom note. 14 Q. Did you ever prepare a master plan 15 of dissimilarities based solely on the ransom 16 note? 17 A. Well, what you consider in here as 18 -- see, I am not sure what you are getting to 19 because -- okay. I am building a master plan, 20 but I also need to have it compared to 21 something. But within the structure of the 22 ransom note itself, I look for consistencies 23 within there, and anything in here that may 24 vary, you notice that the handwriting is slowly 25 written and is awkward. And according to 0271 1 leading textbooks, that this is a form of 2 disguise, where it is slowed down and it is 3 shaky writing. 4 So some of those items in here that 5 I only see repeated once is only repeated once. 6 So if that is what you want to call a 7 difference. But some things in here only show 8 up once, even though it is written by the same 9 writer. 10 Q. Did you ever make a list confined to 11 the ransom note alone of internal similarities 12 in the handwriting in the ransom note? 13 A. I have a sheet at home where I've 14 circled some things, where certain letter 15 connections keep repeating themselves; but that 16 is about it. 17 Q. And you could show us that list; 18 could you not? 19 A. It is not a list drawn out. It's 20 letters that are circled. 21 Q. It is a copy of the ransom note 22 with letters circled? 23 A. That is correct. 24 Q. And you could show us that; could 25 you not? 0272 1 A. That is correct. 2 Q. We would ask you to do that as well 3 when are you looking back at your file, Ms. 4 Wong. 5 A. Let me make note of that. 6 Q. Good. Please take a moment and feel 7 free to do that, and we appreciate that. 8 A. I'm just not -- you call it the 9 master plan. I use the form of pattern 10 recognition within the system. That is why I 11 was having trouble understanding. 12 Q. I see. 13 A. Sorry. Okay. 14 Q. Are you finished making that note? 15 A. Yes. I just made it under quotes 16 what you called it so I know what you are 17 referring to so when I send it back to you I 18 can use your term. 19 Q. Did you ever make a list of internal 20 differences in the ransom note alone? 21 A. At that moment I was just looking 22 for what was consistent throughout the ransom 23 note. Anything else that I didn't make a mark 24 to, could be an accidental or one-time 25 occurrence. 0273 1 Q. So am I correct that at no time you 2 listed dissimilarities found internally in the 3 ransom note itself? 4 A. I didn't make a physical note of it, 5 but it was a notation I made while I was 6 looking through the note, mental notation. 7 Q. You made mental note of 8 dissimilarities found solely in the ransom note? 9 A. At that time when I was looking at 10 the note; that's correct. 11 Q. But you never committed that mental 12 note or those -- 13 A. Notation. 14 Q. -- mental notes to paper? 15 A. That's correct. 16 Q. So there is no way you could show 17 us those? 18 A. It would be really hard. 19 Q. And what is the basic copybook form 20 employed by the author of the ransom note? 21 A. It looks like it is based on the 22 Palmer method. 23 Q. Tell us how you reach that 24 conclusion. 25 A. In the Palmer method, there are 0274 1 different types of ways they would print, and 2 there are two different types of R's available 3 and so forth. I usually have a little form in 4 front of me at home of the copybook version of 5 Palmer and Zaner-Bloser. So as you go through 6 that, and I look at it. 7 Q. Did you ever commit to writing your 8 conclusion that the ransom note was based on the 9 Palmer method? 10 A. No, I did not. 11 Q. And of Patsy Ramsey's exemplars that 12 you studied, what copybook form does Patsy 13 Ramsey use? 14 A. Palmer method. 15 Q. Did you ever commit to writing your 16 conclusion that Patsy Ramsey's exemplars follow 17 the Palmer method? 18 A. No, I did not. The majority of the 19 people in the United States learn from the 20 Palmer method. And currently some are learning 21 Zaner-Bloser, and there is additional, D'Nealin 22 and so forth. 23 MR. RAWLS: Let us just take one 24 minute. 25 THE WITNESS: Sure. 0275 1 MR. RAWLS: We may be getting to a 2 conclusion here pretty soon. 3 THE VIDEOGRAPHER: Going off the 4 video record at 6:13. 5 (A recess was taken.) 6 THE VIDEOGRAPHER: Back on the video 7 record at 6:17. 8 Q. (By Mr. Rawls) Ms. Wong, I have 9 got just a few more questions. Are you able 10 to find among the papers in front of you 11 Defendant's Exhibit 8, please? 12 A. 88? 13 Q. Defendant's Exhibit 8. 14 A. Okay. I'll look for it. 15 Yes, I have it right here. 16 Q. You gave in that document an opinion 17 to Mr. Hoffman in April of the year 2000 about 18 Patsy Ramsey's authorship of the ransom note; 19 did you not? 20 I beg your pardon. I beg your 21 pardon. D-8 is actually 1997; is it not? 22 A. Yes, it is. 23 Q. D-8 was 1997; am I correct? 24 A. That is correct. 25 Q. And let me show you also Defendants' 0276 1 Exhibit 17. I beg your pardon, Defendants' 2 Exhibit 18. 3 (Defendants' Exhibit-18 was marked for 4 identification.) 5 Q. (By Mr. Rawls) Did you later, then, 6 after 1997 give Mr. Hoffman a letter of April 7 20, 2000, which also provided an opinion 8 concerning the authorship of the note? 9 A. Yes. 10 Q. And your opinion was very similar in 11 both November 1997 in Defendants' Exhibit 8 and 12 in April of 2000 in Defendants' Exhibit 18; was 13 it not? 14 A. It is similar. 15 Q. And, in fact, in 1997, your opinion 16 was, and I am referring to the next to last 17 page of Defendant's Exhibit 8, your opinion was 18 that the probability that Patsy Ramsey was the 19 author was 8.5 on a scale of 1 to 10; is that 20 correct? 21 A. That is correct. 22 Q. And by April of 2000, I am looking 23 at page 16 of Defendants' Exhibit 18, your 24 opinion of the probability that Patsy Ramsey was 25 the author had moved to 9.2 on the same 1 to 0277 1 10 scale? 2 A. Yes. In 1997, that was a 3 preliminary report. 4 Q. And in 1997, your report was based 5 exclusively on the exemplars listed as S1 6 through S7; was it not? 7 A. That is correct. 8 Q. And in April of 2000, your report 9 was based on S1 through S7, but additionally you 10 had added S4-A, a color photocopy of a 11 photographed box with, quote, Ramsey Xmas, close 12 quote, printed; is that correct? 13 A. That is correct. 14 Q. And am I correct that, based solely 15 on, in 1997, the documents listed in Defendant's 16 Exhibit 8 as S1 through S7, you reached a 17 conclusion that Patsy Ramsey's probability as the 18 author of the ransom note was greater than a 90 19 percent likelihood? 20 A. In '97 or 2000? 21 Q. In '97. 22 A. I am sorry. In '97. Can you 23 repeat that, please? 24 MR. RAWLS: Would you read that 25 question back, please. 0278 1 (The record was read by the 2 reporter.) 3 THE WITNESS: That is correct. 4 MR. ALTMAN: Are you sure you are 5 saying '97, because I am not sure that is what 6 it said, is '97. 7 THE WITNESS: It is 8.5 on a scale 8 from 1 to 10. 9 MR. ALTMAN: I think he said greater 10 than 90 percent. 11 THE WITNESS: Oh. It is around -- 12 it's something like the high eighties, like, 88, 13 89. 14 Sorry. Thank you. 15 Q. (By Mr. Rawls) In fact, in 1999 16 didn't you tell Bill O'Reilly that your 17 conclusion was the probability was 90-plus 18 percent range? 19 A. What year was that? 20 Q. 1999. 21 A. 1999. Yes, I had more time to look 22 at the note. 23 Q. But no more exemplars? 24 A. That is correct. As I mentioned, 25 the 1997 report was a preliminary report.
#15, 15 Cina Wong Deposition
Posted by jameson on Aug-26-02 at 08:24 PM
In response to message #14
1 Q. And by the year 2000, you had only 2 one more exemplar, and that was S4-A? 3 A. That is correct. 4 Q. And where had you obtained S4-A? 5 A. Good question. Maybe Mr. Hoffman 6 can help me with this. 7 MR. RAWLS: Darnay, do you -- 8 MR. HOFFMAN: You know, actually, 9 unless I see it, I am a little confused as to 10 the time sequencing there or whatever. It is 11 possible that it was an exemplar that we had 12 that she has included in her first preliminary 13 report. I know that over this period of a 14 year or two, she had more of an opportunity to 15 look at the exemplars and do more work in that 16 area. But I don't know exactly why that is 17 popping up listed as an exemplar then as against 18 before. I really don't. 19 MR. RAWLS: Thank you. That is all 20 we have. 21 And, Ms. Wong, thank you for your 22 presence here today, your coming here voluntarily 23 despite your surgery and the fact that you are 24 experiencing some pain. We appreciate it. 25 THE WITNESS: Thank you. 0280 1 MR. HOFFMAN: Thank you. And, Jim, 2 if there are questions that you want to address 3 either in letter form or whatever way, we will 4 do our best to answer. 5 MR. RAWLS: And we will look forward 6 to getting those written documents in due 7 course. Do you all have an approximate time 8 frame? 9 MR. HOFFMAN: We will get them to 10 you within the next two-week period at the 11 latest. We will try to do it within a week of 12 today. 13 THE WITNESS: Darnay, I haven't had 14 much time after the surgery. 15 MR. HOFFMAN: No, no. I understand. 16 But that is what we would like to do. 17 THE WITNESS: Okay. I will do my 18 best to get it within that time frame. But if 19 not, please give me some leeway. 20 MR. RAWLS: Thank you. Would the 21 witness like to read and sign this deposition? 22 THE WITNESS: Yes, please, I would 23 like to. 24 MR. RAWLS: And we will certainly be 25 glad to stipulate that that signature can be 0281 1 made before any notary. 2 MR. HOFFMAN: And if you want to 3 stipulate that a facsimile copy of the signature 4 in a separate part will be different than an 5 original attached to an original. Okay? 6 MR. RAWLS: Okay. I am ready to go 7 off the record if everyone else is. 8 MR. ALTMAN: Fine. 9 MR. HOFFMAN: Thank you. It has 10 been a pleasure, as always. 11 THE VIDEOGRAPHER: That concludes the 12 deposition at 6:25 p.m. 13 (Whereupon, the deposition was 14 concluded at 6:25 p.m.) 15 . 16 . 17 . 18 . 19 . 20 . 21 . 22 . 23 . 24 . 25 . 0282 1 DESCRIPTION OF EXHIBITS 2 EXHIBIT IDENTIFICATION 3 1 Curriculum Vitae and General 4 Resume of Cina L. Wong 5 2 "The Expert's Course in 6 Handwriting Analysis" brochure 7 3 Printout from The International 8 School of Handwriting Sciences 9 website, www.handwriting.org 10 4 "The History of NWFIA" brochure 11 5 Listing for Cina Wong of 12 appearances as expert witness 13 for depositions and court cases 14 6 Printout from Seraph website, 15 www.seraph.net 16 7 Letter - June 2, 1998 From Mr. 17 Liebman and Ms. Wong to Mr. 18 Grisham 19 8 Letter - November 14, 1997 20 From Ms. Wong to Mr. Hoffman 21 9 Letter - October 31, 1997 22 From Mr. Hoffman to Mr. Miller 23 10 Facsimile - July 30, 1997 24 From Mr. Liebman and Ms. Wong 25 to Jai 0283 1 DESCRIPTION OF EXHIBITS (continued) 2 EXHIBIT IDENTIFICATION 3 11 Affidavit of Cina L. Wong 4 12 Letter - September 28, 1998 5 From Ms. Wong to Mr. Hunter 6 13 Letter - October 2, 1998 7 From Mr. Kane to Ms. Wong 8 14 Letter - October 16, 1998 9 From Ms. Wong to Mr. Kane 10 15 Letter - November 14, 1998 11 From Ms. Wong to The Honorable 12 Bailin 13 16 Letter - January 20, 1999 14 From Mr. Kane to Ms. Wong 15 17 Photocopy of ransom note 16 18 Letter/Report - April 20, 2000 17 From Ms. Wong to Mr. Hoffman 18 (Original exhibits attached to the 19 original transcript.) 20 . 21 . 22 . 23 . 24 . 25 . 0284 1 STATE OF GEORGIA: 2 COUNTY OF FULTON: 3 I hereby certify that the foregoing 4 transcript was reported, as stated in the 5 caption, and the questions and answers 6 thereto were reduced to typewriting under my 7 direction; that the foregoing pages represent 8 a true, complete, and correct transcript of 9 the evidence given upon said hearing, and I 10 further certify that I am not of kin or 11 counsel to the parties in the case; am not 12 in the employ of counsel for any of said 13 parties; nor am I in anywise interested in 14 the result of said case. 15 . 16 . 17 . 18 . 19 . 20 . 21 . 22 . 23 . 24 . 25 . 0285 1 Disclosure Pursuant to Article 2 8(B) of the Rules and Regulations of the 3 Board of Court Reporting of the Judicial 4 Council of Georgia, I make the following 5 disclosure: 6 I am a Georgia Certified Court 7 Reporter, here as a representative of 8 Alexander Gallo & Associates, Inc., to report 9 the foregoing matter. Alexander Gallo & 10 Associates, Inc., is not taking this 11 deposition under any contract that is 12 prohibited by O.C.G.A. 5-14-37 (a) and (b). 13 Alexander Gallo & Associates, 14 Inc., will be charging its usual and 15 customary rates for this transcript. 16 . 17 . 18 19 ALEXANDER J. GALLO, CCR-B-1332 20 . 21 . 22 . 23 . 24 . 25 . 0286 1 CAPTION 2 The Deposition of Cina L. Wong, 3 taken in the matter, on the date, and at the 4 time and place set out on the title page 5 hereof. 6 It was requested that the deposition 7 be taken by the reporter and that same be 8 reduced to typewritten form. 9 It was agreed by and between counsel 10 and the parties that the Deponent will read 11 and sign the transcript of said deposition. 12 . 13 . 14 . 15 . 16 . 17 . 18 . 19 . 20 . 21 . 22 . 23 . 24 . 25 . 0287 1 CERTIFICATE 2 STATE OF : 3 COUNTY/CITY OF : 4 Before me, this day, personally 5 appeared, Cina L. Wong, who, being duly 6 sworn, states that the foregoing transcript 7 of his/her Deposition, taken in the matter, 8 on the date, and at the time and place set 9 out on the title page hereof, constitutes a 10 true and accurate transcript of said 11 deposition. 12 13 Cina L. Wong 14 . 15 SUBSCRIBED and SWORN to before me this 16 day of , 2002 in the 17 jurisdiction aforesaid. 18 19 My Commission Expires Notary Public 20 . 21 . 22 . 23 . 24 . 25 . 0288 1 DEPOSITION ERRATA SHEET 2 . 3 RE: Alexander Gallo & Associates 4 File No. 1637 5 Case Caption: Robert Christian Wolf vs. 6 John and Patsy Ramsey 7 Deponent: Cina L. Wong 8 Deposition Date: May 13, 2002 9 . 10 To the Reporter: 11 I have read the entire transcript of my 12 Deposition taken in the captioned matter or 13 the same has been read to me. I request 14 that the following changes be entered upon 15 the record for the reasons indicated. I 16 have signed my name to the Errata Sheet and 17 the appropriate Certificate and authorize you 18 to attach both to the original transcript. 19 . 20 Page No. Line No. Change to: 21 22 Reason for change: ....... 5 7 SIGNATURE:_______________________DATE:___________ 8 Cina L. Wong 9 .
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