03-29-2017, 09:44 PM
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.
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.
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.
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.