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.