Cina Wong
from Federal Judge Julie Carnes

Plaintiff, however, asserts that his retained experts believe Mrs. Ramsey to be the author of the Ransom Note. Indeed, Gideon Epstein and Cina Wong, the handwriting experts proffered by plaintiff, opine that they are "100 percent certain" Mrs. Ramsey wrote the Ransom Note. (SMF ¶ 256; PSMF ¶ 256; PSDMF ¶¶ 1-2.) In contrast to the experts relied upon by defendants and by the Boulder Police Department, however, neither of these experts have ever seen or examined the original Ransom Note. (SMF ¶ 256; PSMF ¶ 256.) In fact, Mr. Epstein and Ms. Wong do not know what "generation" copy of the Ransom Note they examined. (SMF ¶ 257; PSMF ¶ 257.) Ms. Wong received her copy of the Ransom Note and certain writings alleged to be historical writings of Mrs. Ramsey from the tabloid, The National Enquirer. (SMF ¶ 258; PSMF ¶ 258.)
But first - - from same judge. Goes to show that there is no revenge equal to that of a scorned expert"

Indeed, forensic document examiners were eager to jump into the
high-profile investigation. In July 1997, Ms. Wong, now plaintiff's expert, had originally
contacted defendants' attorneys and offered to analyze the Ransom Note and point out
weaknesses in analysis by "Government handwriting experts." (SMF 342; PSMF 342. )
Defendants declined such an offer.
Her deposition

4 Plaintiff,
5 vs. NO. 00-CIV-1187(JEC)
8 ~~~~~~~~~~~~~~~~~~~~~~~~~~
11 May 13, 2002
9:45 a.m.
Sixteenth Floor
13 191 Peachtree Street, N.E.
Atlanta, Georgia
Alexander J. Gallo, CCR-B-1332, CRR
2 On behalf of the Plaintiff:
3 (via telephonic means)
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 .
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 //
1 On behalf of the Defendants:
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 .
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?
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.
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
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:
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.
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
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
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
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 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.
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
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
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
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
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
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
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
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.
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.
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
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
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?
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
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?
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.
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
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?
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
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
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
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
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.
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.
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
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.
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
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
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
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
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
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
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.
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
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
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?
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 interest in learning,
24 whether -- you know, if someone is interested in
25 the graphology portion, they can pay a fee and
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
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
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
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
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.
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.
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.
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,
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
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
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.
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.
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
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
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
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.
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
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
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,
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
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?
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
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
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.
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.
24 Q. Did you learn that the subject of
25 that course taught by Mr. Liebman was
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?
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?
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.
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
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
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
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?
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
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?
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.
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,
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
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,
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.
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
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 --
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.
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
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
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
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.
24 THE VIDEOGRAPHER: Going off the
25 video record at 11:54.
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
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
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
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.
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
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?
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?
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
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 --
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.
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?
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
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.
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.
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?
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?
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
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
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.
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
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
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
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.
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.
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
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"?
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?
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.
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.
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?
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
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
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?
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
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
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?
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.
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.
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
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?
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
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?
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
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
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.
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?
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?
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
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
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?
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
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.
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
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.
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.
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
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
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
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.
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
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?
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
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.
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
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.

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