1 IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
2 ATLANTA DIVISION
3 ROBERT CHRISTIAN WOLF,
4 Plaintiff,
CIVIL ACTION FILE
5 vs. NO. 00-CIV-1187(JEC)
6 JOHN BENNETT RAMSEY and
PATRICIA PAUGH RAMSEY,
7
Defendants.
8 ~~~~~~~~~~~~~~~~~~~~~~~~~~
9 VIDEOTAPED DEPOSITION OF
10 CINA L. WONG
11 May 13, 2002
9:45 a.m.
12
Sixteenth Floor
13 191 Peachtree Street, N.E.
Atlanta, Georgia
14
15
Alexander J. Gallo, CCR-B-1332, CRR
16
17
18
19
20
21
22
23
24
25
0002
1 APPEARANCES OF COUNSEL
2 On behalf of the Plaintiff:
3 (via telephonic means)
4 DARNAY HOFFMAN, Esq.
5 Law Offices of Darnay Hoffman
6 Suite 209
7 210 West 70th Street
8 New York, New York 10023
9 (212) 712-2766
10 .
11 EVAN M. ALTMAN, Esq.
12 Law Offices of Evan M. Altman
13 Suite 300-B
14 6085 Lake Forrest Drive
15 Atlanta, Georgia 30328
16 (404) 845-0695
17 .
18 .
19 .
20 .
21 .
22 .
23 .
24 .
25 //
0003
1 On behalf of the Defendants:
2 JAMES C. RAWLS, Esq.
3 ERIC P. SCHROEDER, Esq.
4 S. DEREK BAUER, Esq.
5 Powell, Goldstein, Frazer & Murphy, L.L.P.
6 Sixteenth Floor
7 191 Peachtree Street, N.E.
8 Atlanta, Georgia 30303
9 (404) 572-6600
10 .
11 L. LIN WOOD, Esq.
12 L. Lin Wood, P.C.
13 2140 The Equitable Building
14 100 Peachtree Street
15 Atlanta, Georgia 30303
16 (404) 522-1713
17 .
18 Also Present:
19 David Stevens, Videographer
20 LaShaunda Cass, In-Training Court Reporter
21 .
22 .
23 .
24 .
25 .
0004
1 Videotaped Deposition of Cina L. Wong
2 May 13, 2002
3 THE VIDEOGRAPHER: On the video
4 record at 9:45, May 13, 2002.
5 MR. RAWLS: Very good. Alex, we
6 are on the written record as well, I assume.
7 If I may just briefly state, this is
8 the deposition of Ms. Cina Wong.
9 THE WITNESS: That is correct.
10 MR. RAWLS: And I hope I've
11 pronounced it correctly.
12 THE WITNESS: That's right. Like
13 Tina, but with a C. So you said it correctly,
14 Cina.
15 MR. RAWLS: Good. Thank you. And
16 the deposition is being taken by the defendants'
17 counsel for John and Patsy Ramsey, in a lawsuit
18 filed here in U.S. District Court in Atlanta on
19 behalf of the plaintiff Robert Christian Wolf.
20 The deposition is scheduled by
21 agreement, and the witness has voluntarily
22 appeared pursuant to that agreement and without
23 a subpoena.
24 Am I correct so far, Evan and
25 Darnay?
0005
1 MR. HOFFMAN: That is correct.
2 MR. ALTMAN: That is correct.
3 MR. RAWLS: Good. And we very much
4 appreciate all counsel having reached that
5 agreement and, Ms. Wong, your having been
6 present pursuant to that agreement.
7 The deposition is taken by the
8 defendants for all proper purposes under the
9 Federal Rules of Evidence and the Federal Rules
10 of Civil Procedure.
11 Those purposes, of course, include
12 but are not limited to discovery potential use
13 in evidence if appropriate under the Rules,
14 potential impeachment, et cetera.
15 Is that an agreeable stipulation up
16 to now?
17 MR. HOFFMAN: Yes.
18 MR. ALTMAN: Yes, it is.
19 MR. RAWLS: And may I further
20 propose that all objections except as to the
21 form of the question and the responsiveness of
22 the answer are reserved until the time of trial,
23 hearing, or other use of this evidence?
24 MR. ALTMAN: That is acceptable.
25 MR. HOFFMAN: Yes.
0006
1 MR. RAWLS: Good. Present, if I
2 may say so for the record, are by telephone
3 Darnay Hoffman and present in person Evan
4 Altman, both of whom represent the plaintiff,
5 Mr. Wolf.
6 Ms. Cina Wong, the witness is
7 present.
8 For defendants, Jim Rawls, Lin Wood,
9 and Eric Schroeder are present; and defendant
10 John Ramsey is present. As an observer, Matt
11 Wood is present. We have two court reporters
12 present, Alex Gallo and LaShaunda Cass. And we
13 have a videographer present, Mr. David Stevens.
14 And I was about to call you Steven, but I
15 would have misplaced your last name had I called
16 you Steven. Good. Thank you.
17 Are there any additional preliminary
18 matters we should raise?
19 MR. HOFFMAN: Just one, and we can
20 do this off the record if you want. We can
21 use your decision as to whether you want this
22 on the record or not.
23 I don't know how many of you are
24 aware of the fact that Cina recently just had
25 an operation, and she may need to stop a little
0007
1 bit more than might be the usual simply because
2 there may be some residual discomfort from any
3 of the sutures or -- not sutures, from the
4 incision and the operation.
5 So just please bear with her if she
6 needs to take an occasional break that, you
7 know, might seem a little bit more often than
8 is normal in a deposition.
9 MR. RAWLS: We fully understand.
10 And, Darnay, yes, Ms. Wong and Mr. Altman
11 brought that to our attention.
12 And, Ms. Wong, if at any time you
13 need a break, please say so.
14 THE WITNESS: Thank you.
15 MR. RAWLS: And we will take one.
16 Very good. Mr. Gallo, if you would
17 please keep time, we would appreciate it. And
18 Mr. Schroeder, if you would also keep a backup
19 time. I am certainly hopeful we will not be
20 at the full seven hours permitted under the
21 Federal Rules, but at the start of a deposition
22 one never knows.
23 Would you please administer the oath?
24 CINA WONG, having been first duly
25 sworn, was examined and testified as follows:
0008
1 EXAMINATION
2 BY-MR.RAWLS:
3 Q. Ms. Wong, for the record, would you
4 please state your full name?
5 A. Yes. My name is Cina, that's
6 spelled C-I-N-A. And the last name is Wong,
7 W-O-N-G. I do have a middle initial L.
8 Q. What does the L stand for?
9 A. That is all I have.
10 Q. Like Harry S. Truman, whose S, as I
11 understand it, did not stand for anything?
12 A. Oh, I didn't know that. Yes. I
13 just have an L.
14 Q. You have an L, and only an initial?
15 A. That is correct.
16 Q. And your date of birth, please, for
17 the record?
18 A. 10/26/62.
19 Q. And place of birth?
20 A. California. Mountain View,
21 California.
22 Q. Ms. Wong, do you have any relatives
23 that live in the Atlanta metro area?
24 A. No, I do not. Oh, hold it. Yes.
25 They just moved here. One. A cousin.
0009
1 Q. Who is that?
2 A. His name is Keith Soo.
3 Q. How is that spelled?
4 A. Oh, I'm sorry. I got him mixed up.
5 S-O-O. I'm sorry. Keith Soo.
6 Q. Keith?
7 A. I have two cousins. One is Keith
8 Koo, I'm sorry. K-O-O. He married into the
9 family.
10 Q. And is there a second cousin in the
11 Atlanta area?
12 A. No. His wife and his child will be
13 joining him shortly in the summer.
14 Q. And the person to whom you are a
15 cousin is who?
16 A. His wife.
17 Q. What is her name?
18 A. Her name is Wai-soo, W-A-I, hyphen,
19 S-O-O.
20 Q. Thank you. Do you know the
21 occupation of both of those individuals?
22 A. I believe he is a doctor in the
23 military, and she is taking care of their
24 daughter at home.
25 Q. Ms. Wong, you are here because it is
0010
1 our understanding that you have agreed to serve
2 as an expert witness on behalf of Mr. Wolf.
3 Am I correct?
4 A. That is correct.
5 Q. Would you tell us, please, when you
6 agreed to serve as such an expert witness?
7 A. Well, I met Darnay Hoffman. He
8 contacted me in '97, I believe. And the Chris
9 Wolf situation arose last year sometime, to the
10 best of my memory.
11 Q. How did you meet Darnay Hoffman?
12 A. He contacted our offices.
13 Q. Let us know, if you will, what you
14 recall as the first things that Mr. Hoffman said
15 to you.
16 A. He said that he had a copy --
17 excuse me. I am losing -- sorry.
18 But Mr. Hoffman said that he was
19 interested in finding some handwriting experts
20 who would be interested in examining a ransom
21 note and some handwriting exemplars.
22 Q. Did he tell you why he had selected
23 you?
24 A. No, he did not. He just said he
25 had heard of us and that is why he contacted
0011
1 us.
2 Q. And what did you do, if anything, at
3 that time at Mr. Hoffman's request?
4 A. I told him that I would be more
5 than happy to look at the materials to see if
6 we could do anything for him or not.
7 Q. And what did you then do?
8 A. I had him -- I asked him to please
9 send the documents over and that we would look
10 at them when we received them.
11 Q. Did he send documents?
12 A. Yes, he did.
13 Q. What were they?
14 A. He sent a copy of a ransom note and
15 exemplars which consisted of copies of a
16 greeting card. I believe it started off with:
17 Hi, Bob. I am going from memory here. A
18 photograph of some boxes with Ramsey written on
19 it. A poster that had something written on it
20 to the effect of Welcome to the Northwest
21 Territory. A copy of a photo album page with
22 handprinting. And that is all that comes to
23 mind right now. There might have been another
24 one or two.
25 And there was a Polaroid. And I
0012
1 think it said Rainbow Fish Players underneath.
2 Q. And did you study those materials?
3 A. Yes, I did.
4 Q. Did you do that personally or did
5 someone else in your office do that?
6 A. No. At that time I was working
7 with David Liebman. And I did my own
8 independent analysis, and he did his own
9 independent analysis.
10 Q. What was the question that Mr.
11 Hoffman asked you to answer?
12 A. He wanted to know if -- and by the
13 way, the exemplars, we asked him if they had
14 been reviewed and confirmed by any other parties
15 of them being the handwriting exemplars of Patsy
16 Ramsey; and Mr. Hoffman said, yes, they have,
17 and they were confirmed by the housekeeper. And
18 I believe her name is Linda Hoffman-Pugh. And
19 Mr. Hoffman wanted to know if it was a
20 possibility or not that the person who executed
21 the exemplars known as Patsy Ramsey was the one
22 who wrote the ransom note.
23 Q. He asked if there was a possibility;
24 did you say?
25 A. A possibility or not.

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jameson
Member since 5-8-02
08-15-02, 04:19 PM (EST)

2. "3 Cina Wong depo"
In response to message #1


0038
1 Q. And Mr. Widmer is a graphologist; is
2 he not?
3 A. He is a document examiner and a
4 graphologist.
5 Q. And by whom is he certified as a
6 document examiner?
7 A. He is not certified. He doesn't
8 belong to any of the document examination
9 groups. He's read all the texts in the field,
10 the leading texts that all document examiners
11 read.
12 Q. And are you a graphologist?
13 A. No. Certainly not.
14 Q. Why do you say certainly not?
15 A. I have looked into it because, as
16 anybody who deals in the field of handwriting
17 sciences, you should look into all aspects of
18 handwriting and study all of it in order to
19 give a comprehensive analysis or speak about it.
20 There are lots of document examiners, I should
21 say, out there who say things about graphology
22 when they don't even know anything about it.
23 How can you speak about something fluently
24 without knowing? So I looked into it. I
25 don't see that there is any validity to it. A
0039
1 lot of people disagree with me. But my area
2 is strictly in document examination.
3 Q. You refer in your CV, this again is
4 Defendant's Exhibit 1 on page 2, and this is
5 immediately under the International School of
6 Handwriting Sciences, you refer to, quote, a
7 six-month program --
8 A. Yes.
9 Q. -- in Handwriting Sciences, end
10 quote.
11 Did you get a diploma?
12 A. I don't think he issued a diploma,
13 no.
14 Q. Did you get a degree?
15 A. Not a degree, no.
16 Q. Did you get a grade?
17 A. No. Probably I have a certificate
18 of completion, but that would be about what we
19 received.
20 Q. So in those six months, was this a
21 full-time educational curriculum?
22 A. It was once a week.
23 Q. Once a week. Which day of the
24 week?
25 A. You are asking me to think back 12
0040
1 years. I can't remember. I am sorry. I know
2 it was a weekday.
3 Q. And in that once-a-week program, how
4 long were you there the day you were there each
5 week?
6 A. Anywhere from four to five hours.
7 Q. What did you pay for that course?
8 A. I can't remember. It was a while
9 ago.
10 Q. Did you do a term paper in that
11 program?
12 A. No, we did not.
13 Q. Did you submit handwriting analyses
14 for feedback?
15 A. I am sorry. I don't understand your
16 question.
17 Q. Well, in the course of this
18 six-month program, which we've learned was a
19 once-a-week program, four to five hours on that
20 one day a week, were you asked to complete a
21 document analysis and to submit it for review
22 and feedback?
23 A. I am not quite sure what you are
24 saying. But we were asked to bring in
25 handwriting samples; and we would look at them
0041
1 and study them for slant, proportion, placement,
2 letter forms; and that is what we did.
3 Q. Did you demonstrate to Mr. Widmer or
4 anyone else your analysis so that you could
5 obtain feedback and his judgment on whether you
6 were right or wrong?
7 A. Oh, you mean like a personality
8 analysis? I didn't partake in that. I was
9 there for the information with regards to
10 learning the basics, because I was -- there is
11 certain overlap with graphology and document
12 examination strictly with the fact that it has
13 to do with the formations and angles and initial
14 strokes and terminal strokes and letter
15 formations. And otherwise, that is where it
16 stops.
17 Q. Now, the second entry under Training
18 in your resume, and again I am still on page 2
19 of Defendant's Exhibit 1, you list again
20 International School of Handwriting Sciences.
21 And this time your CV tells us of your
22 completion of an advanced course in Questioned
23 Document Examination.
24 A. Uh-huh (affirmative).
25 Q. And according to your resume, this
0042
1 involved forgery detection, case studies,
2 hands-on equipment operation technique, and court
3 qualification procedures.
4 Have I accurately read your CV?
5 A. Yes, that is correct.
6 Q. How long was this advanced course?
7 A. I believe it was over four days,
8 three or four days. It was all day. Or it
9 was eight or ten hours. It was a very intense
10 course.
11 Q. And since Mr. Widmer has no
12 certification as a document examiner, I assume
13 this course was taught by someone else?
14 A. No. There is no standard in this
15 field where you need certification, but Mr.
16 Widmer has studied all the texts in document
17 examination, and he was the one that was
18 teaching the course.
19 Q. So Mr. Widmer taught the six-month
20 program in handwriting sciences as well as the
21 advanced course for three to four days in
22 questioned document examination; am I correct?
23 A. That is correct.
24 Q. Was there anyone that came in to
25 assist Mr. Widmer as a faculty member for those
0043
1 three to four days?
2 A. If my memory serves me right, I
3 think he had assistance from Mr. Marcel Matley.
4 Q. Can you spell that, please?
5 A. Yes, Matley, M-A-T-L-E-Y.
6 Q. Was Mr. Matley a certified document
7 examiner?
8 A. He is certified now through the
9 National Association of Document Examiners.
10 Q. When you say he is certified now,
11 does that mean he was not certified at the time
12 he assisted in teaching this course in 1991?
13 A. That is correct. But he is well
14 read in the field, and he is also well
15 published in the field.
16 Q. What has he published?
17 A. He has published an index that
18 covers all the articles that deal with document
19 examination. He has a book on sequential
20 handwriting. He has a book on forgery
21 detection. Quite a few others that I have in
22 my library that are all document examination
23 related.
24 Q. Now, in 1991, according to the next
25 entry under Training in your CV, you have
0044
1 experience or had a course of study in Signature
2 Identification also in San Francisco; am I
3 correct?
4 A. Yes, that is correct.
5 Q. And according to your resume, this
6 was a study of various techniques used to verify
7 signatures, recognizing different forms of forged
8 signatures, use of equipment to aid in
9 handwriting ID. Am I correct?
10 A. That is correct.
11 Q. How long was this course?
12 A. This course, I believe, it was three
13 days.
14 Q. Who taught that course?
15 A. That was taught by Marcel Matley.
16 Q. Were those full days?
17 A. Yes, definitely.
18 Q. The next course listed is the
19 Effects of Health on Handwriting. This is said
20 to have taken place in Sunnyvale, California.
21 A. That's correct.
22 Q. Is that correct?
23 A. It is near San Jose, Silicon Valley.
24 Q. How long was that course?
25 A. That was a day, full day.
0045
1 Q. And according to your resume, this
2 was taught by Patricia Wellingham-Jones?
3 A. Yes. She is a nurse.
4 Q. And your resume says she is an
5 expert in identifying health related conditions
6 and medications affecting handwriting?
7 A. Yes. She has written a book about
8 that. The course that she taught that day, she
9 had done some research work with regards to how
10 someone with an IV in their arm would affect
11 their signature or not, and different hospital
12 forms when people fill them out where they may
13 look like it is not their signature when, in
14 fact, it is, due to stress conditions or
15 medication.
16 Q. Then, according to your resume, you
17 had advanced training with David Liebman, whose
18 name you have mentioned before as formerly
19 someone with whom you worked?
20 A. That is correct.
21 Q. And according to your resume, this
22 was, this advanced training was in a mentorship
23 program offered by the National Association of
24 Document Examiners.
25 Can you describe, please, how that
0046
1 association offered a mentorship program?
2 A. Yes. There were certain senior
3 members who often -- NADE is an association that
4 is open to all people of all levels of document
5 examination. So whether a person who has been in
6 the field for a long time or if someone is
7 just a student or if someone is just interested
8 in the field of document examination can join
9 NADE. And from there -- there are very few
10 organizations that are open to students where
11 they can receive more information and learn
12 about the field of document examination. And at
13 that time, NADE did offer an advanced mentorship
14 program in document examination where you work
15 hands-on with a document examiner.
16 Q. And how long was this advanced
17 training that you took with Mr. Liebman?
18 A. It was three years, all practically
19 five days a week.
20 Q. Was this more or less on-the-job
21 training?
22 A. Yes, that is correct.
23 Q. Were you paid for that work?
24 A. No, I was not.
25 Q. Did you pay Mr. Liebman for that
0047
1 training?
2 A. No, I did not.
3 Q. Would you receive advanced training
4 by assisting Mr. Liebman in his work as a
5 document examiner? Is that what that program
6 was all about?
7 A. No. I did not assist him with his
8 work. We would -- when cases would come in, I
9 would work on it independently. And then after
10 I finished all my work, I would hand the folder
11 to him with the documents, and he would do his
12 work independently.
13 And then afterwards, he would look
14 at my notes to see how I went through my
15 systematic analysis, and he would critique what
16 I did.
17 And sometimes there were cases that
18 came in that we would need infrared lighting and
19 so forth, and that is something I didn't know
20 at the time, and I learned that through Mr.
21 Liebman.
22 Q. Were you yourself, from 1992 to 1995
23 when you were in this advanced training
24 mentorship, were you taking assignments yourself
25 for a fee from clients?
0048
1 A. I was not working by myself at that
2 time. Towards the end of the program, Mr.
3 Liebman, he was satisfied with my work, and he
4 felt very comfortable with everything that I
5 have learned and how I was proceeding, so I was
6 receiving some money from certain cases.
7 Q. And then you sought and received
8 your board certification from NADE; am I
9 correct?
10 A. That is correct.
11 Q. Is the International School of
12 Handwriting Sciences an accredited university?
13 A. No, it is not.
14 Q. Does it have any accreditation from
15 any organization?
16 A. Not that I am aware of.
17 Q. Is it accredited by the NADE?
18 A. NADE does not accredit any schools
19 or associations, so it wouldn't.
20 Q. What are the entrance requirements
21 for the International School of Handwriting
22 Sciences?
23 A. If you have an interest in learning,
24 whether -- you know, if someone is interested in
25 the graphology portion, they can pay a fee and
0049
1 learn that portion. And if you are interested
2 in their document examination section, then you
3 take those courses and pay a fee to learn that
4 information.
5 Q. So the entrance requirements are none
6 except payment of a fee?
7 A. I am sorry?
8 Q. The entrance requirements for the
9 international School of Handwriting Sciences --
10 A. Yes.
11 Q. -- involves simply the payment of a
12 fee?
13 A. If you are interested in it at
14 first, yes. And then you pay a fee to learn;
15 that is correct.
16 Q. No one is going to pay a fee who is
17 not interested?
18 A. I hope not.
19 Q. And there is no application process?
20 A. No, there is not.
21 Q. The payment of a fee is all that is
22 required for entrance into the course?
23 A. That is correct.
24 Q. And to the best of your knowledge,
25 no one is rejected from the course of study who
0050
1 has paid the fee?
2 A. Not that I am aware of.
3 Q. How many people were present with
4 you in this once-a-week program for approximately
5 six months?
6 A. Good question. Probably, I would
7 say, ten to 15.
8 Q. How many of them had a college
9 degree?
10 A. Oh, I am not sure about that.
11 Q. The six-month program which was
12 attended once a week for four to five hours
13 each week, is that the graphology part of your
14 education?
15 A. No. It is part graphology, and it
16 is part that has to do with document
17 examination.
18 Q. Am I correct that the word
19 graphology is not found on your resume?
20 A. That is correct, because I am not a
21 graphologist. I would not be able to tell
22 anyone's personality from their handwriting if my
23 life depended on it, so you would have to just
24 shoot me.
25 Q. Ms. Wong, I am going to try to
0051
1 avoid --
2 A. Shooting me.
3 Q. -- shooting you, regardless of any
4 reaction we may have to your testimony.
5 A. All right. Thank you.
6 Q. Am I correct that for purposes of
7 your effort to obtain credibility as a document
8 examiner you prefer to disassociate yourself from
9 your graphology studies?
10 A. There are many things -- I am not
11 quite sure how to answer that, what you are
12 asking. But there are many things I have
13 learned in the past. Just because I learned
14 gardening and I don't do it very well or I
15 don't practice it doesn't mean that, oh, well,
16 since I studied it at one time, then I must be
17 a gardener. I don't practice graphology. I
18 don't use it.
19 And I am strictly a document
20 examiner, and I identify and authenticate
21 handwriting.
22 Q. And graphology does not have a lot
23 of credibility among document examiners; does it?
24 A. That is correct.
25 Q. And consequently, to be a or to seek
0052
1 to be a credible document examiner, I am
2 correct, am I not, that you wish to disassociate
3 yourself from your graphology study?
4 A. That is not true. I don't deny it.
5 To be anybody who -- as I mentioned, to be
6 well versed in the field of document
7 examination, you should look at everything that
8 deals with handwriting sciences, because if you
9 don't then you are missing and lacking in a
10 certain area of your studies.
11 In order to be a good scientist, you
12 have to research all areas. And that is what
13 I did in this case. It doesn't mean I believe
14 it, but I researched it.
15 (Defendants' Exhibit-2 was marked for
16 identification.)
17 Q. (By Mr. Rawls) Ms. Wong, Mr. Gallo
18 has just handed you a brochure which has been
19 marked Defendants' Exhibit 2, and I have given
20 Mr. Altman a copy of that and I am looking at
21 a copy.
22 Can you identify that, please, for
23 the record?
24 A. Yes. I haven't seen this before.
25 It is a brochure. I assume it is new. It is
0053
1 titled the International School of Handwriting
2 Sciences.
3 Q. As you look at that, please, would
4 you tell me whether any of these lessons -- and
5 you will see the lessons listed as the ten
6 lessons.
7 A. Okay.
8 Q. Do you see that column?
9 A. Yes.
10 Q. This is essentially, for the record,
11 of course, the video is showing you looking at
12 the brochure. But it is a fold-up paper that
13 contains about eight columns, four on one side
14 and four on the other; am I correct?
15 A. You mean on this side or the back?
16 Q. Four on each side?
17 A. Oh, four on each side. Yes, that
18 is correct.
19 Q. And the ten lessons, do you see that
20 list on the far left side of what I take to be
21 the back page?
22 A. Yes.
23 Q. And tell us if you had any of those
24 ten lessons, please, where you took the courses
25 in 1990 and 1991 out in California.
0054
1 A. Okay. The first one is Use of
2 Space. And that covers how a person uses a
3 piece of paper in regards to margin area, which
4 is something that's used in document examination.
5 How far they start from the top of the paper
6 and how they use this -- how much margin they
7 leave on the side.
8 The Size of the Writing. That is
9 common sense, large and small.

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jameson
Member since 5-8-02
08-15-02, 04:19 PM (EST)

3. "4 Cina Wong depo"
In response to message #2


10 Q. As you tell us about each of these
11 ten --
12 A. Yes.
13 Q. -- tell us whether you took that
14 course of study.
15 A. Well, it is interesting, because what
16 he writes underneath is nothing I remember.
17 It says Use of Space, how these
18 principles alone can give you a surprising
19 in-depth analysis.
20 On what I am not sure.
21 The Size of the Writing, how people
22 feel about themselves and others.
23 I don't remember that. I just know
24 size of writing with regards to document
25 examination.
0055
1 The Zonal Principle. How to tell
2 how self actualized someone is.
3 I don't remember that. But I
4 remember zones with regards to upper zones of
5 the handwriting, which would include the upper
6 portions of the lower case H's, top portions of
7 L's and so forth. Lower zones would be the
8 bottom parts of small G's and small Y's.
9 Left and Right Tendencies with Slant.
10 In documentation examination we study different
11 types of slants. His explanation is: Universal
12 concepts that allow you to develop insights in
13 any writing.
14 I don't remember that, and it
15 doesn't make any sense to me.
16 Connective Forms. That is very
17 important in document examination. It shows if
18 something is -- a connection stroke is if it is
19 curved or if it is angular or if it is arcade.
20 Mr. Widmer writes on here: How these show
21 strong indications of personality types and
22 attitudes towards the people and other people.
23 I don't know what to make of that.
24 Pressure. That is something document
25 examiners study. An example is someone who,
0056
1 when they write, when they press very hard into
2 a paper when they write leave deep impressions
3 as opposed to when someone writes with a lighter
4 hand. Mr. Widmer says here: With pressure, a
5 third dimension of handwriting and even what the
6 choice of writing implement can tell about
7 someone.
8 I don't remember covering that, but
9 I remember the heavy and light pressure and
10 medium pressure and varied pressure within
11 writing.
12 Let's see, For Those Who Print, he
13 writes: For those of you that thought you
14 could not analyze printed writing, you better
15 know this because most people today print.
16 All I remember from that course were
17 some unusual printing styles, but I don't
18 remember what the personality aspect that was
19 derived from printing.
20 Specific Letter Formations, he
21 mentions Alphabet from A to I -- A to some --
22 well, some totally different approach to
23 individual letter formations, the most important
24 letter in the alphabet.
25 I don't know what that is about, but
0057
1 I saw some very unique -- he has an array of
2 samples in his file of interesting letter
3 formations that as a document examiner you need
4 to be exposed to a lot of handwriting in order
5 to figure out what exactly is part of a class
6 characteristic or an individual characteristic of
7 writing.
8 Specific Letter Formations. Doesn't
9 say anything about that. But that also had to
10 do with different letter formations.
11 And Form Level. Form level has to
12 do with the capability in document examination
13 how if they write in the higher form level or
14 a lower, more, I hate to use the word,
15 uneducated form level, someone who is not adept
16 at using the pen or pencil very well. And
17 someone who writes very poorly can't write
18 better than they can write. And not only that
19 was taught in this class, and that is also
20 taught in document examination.
21 And Mr. Widmer has here under Form
22 Level: Taking intuition out of handwriting
23 analysis and putting it all together.
24 So, I don't know.
25 Q. Thank you. We have been going just
0058
1 over an hour. Is this a convenient time for a
2 short recess?
3 A. Yes. I have been trying to hold
4 the best I can. So, yes, this would be great.
5 Q. Good.
6 A. Thank you.
7 THE VIDEOGRAPHER: Going off the
8 video record at 10:56.
9 (A recess was taken.)
10 THE VIDEOGRAPHER: Back on the video
11 record at 11:11.
12 MR. RAWLS: Evan and Darnay, I had,
13 I believe in an exchange of e-mails, advised you
14 all that at the deposition we would have a
15 check in payment of the expense sum of money
16 which you all had told us about for Ms. Wong's
17 expenses. And, Evan, if I may deliver that
18 check to you now.
19 MR. ALTMAN: Thank you. Sure.
20 MR. RAWLS: I had intended to bring
21 it earlier today.
22 MR. HOFFMAN: Thank you. And just
23 while we're on that subject, I just received
24 your costs on that other case involving Linda
25 Hoffman-Pugh, and that is being sent out to you.
0059
1 And I am assuming that should be sent to your
2 office or to Lin's.
3 MR. RAWLS: My office is fine,
4 Darnay. Thank you.

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jameson
Member since 5-8-02
08-15-02, 04:25 PM (EST)

4. "5 Cina Wong depo"
In response to message #3


24 Q. Did you learn that the subject of
25 that course taught by Mr. Liebman was
0071
1 determining whether an individual had cancer by
2 examining the person's handwriting?
3 A. No, I was not aware of that. It
4 was taught at a college? Old Dominion or --
5 Q. I am not here to answer. I am
6 trying to obtain what information you have about
7 that.
8 A. Oh, okay. If it was taught at Old
9 Dominion University, that is an accredited
10 college.
11 Q. But you don't know the subject
12 matter and you don't know whether he taught
13 about determining the existence of cancer by
14 looking at a person's handwriting; am I correct?
15 A. No. He could have taught something
16 about bug larva and I wouldn't know.
17 Q. Was Mr. Liebman asked, to your
18 knowledge, to be an expert witness on behalf of
19 Chris Wolf in this case that brings you here
20 today?
21 A. I am sorry. What was that question?
22 Q. Was Mr. Liebman asked to be an
23 expert witness in the Chris Wolf case, the same
24 case that you are assisting Mr. Darnay Hoffman
25 and Mr. Evan Altman in today?
0072
1 A. I am not sure. At that time when I
2 was asked Mr. Liebman and I no longer had a
3 business. We still talked, but that isn't an
4 issue that comes up.
5 Q. So Mr. Liebman has not told you that
6 he was or was not asked to be an expert
7 witness by Mr. Hoffman or Mr. Altman?
8 A. That is correct.
9 Q. Do you keep in touch with Mr.
10 Widmer, Ted Widmer?
11 A. I spoke to him recently because I
12 heard that, through the grapevine, he had
13 recently gotten married, and I wanted to wish
14 him my best.
15 Q. Are you aware of some legal issues
16 that Mr. Widmer encountered in about 1995?
17 A. No, I am not. What type of legal
18 issues are you talking about?
19 Q. Are you aware that Mr. Widmer signed
20 a stipulation with the San Francisco District
21 Attorney's office that he falsified in court his
22 questioned document credentials?
23 A. No, I did not. To what degree?
24 Q. I am sorry?
25 A. To what degree?
0073
1 Q. I, again --
2 A. I was curious. I didn't know.
3 Q. I am just here to ask you questions
4 and probe your knowledge.
5 A. Okay.
6 Q. And as I understand your testimony,
7 you have no knowledge of that; am I correct?
8 A. No, I do not.
9 Q. It would not be appropriate, of
10 course, ever to falsify one's credentials as a
11 questioned document examiner?
12 A. That is correct. But his actions
13 have no bearing on my actions.
14 (Discussion ensued off the record.)
15 Q. (By Mr. Rawls) Ms. Wong, would you
16 please turn back to Defendants' Exhibit 3 to
17 your deposition. And on the, I guess this is
18 the third page from the back --
19 A. Third page from the back. Okay.
20 Q. -- there is a section under the bold
21 caption: Other graphologists rave.
22 Do you see that?
23 A. Uh-huh (affirmative).
24 Q. And there is the quoted phrase:
25 Ted, thanks for giving me my start, end quote.
0074
1 And under that is the name C. Wong, Norfolk,
2 Virginia.
3 A. Uh-huh.
4 Q. Did you, in fact, make that
5 statement about Mr. Widmer's course?
6 A. I did not make it with regards to
7 the graphology course. I made that comment with
8 regards to the document examination course. So
9 I am surprised to see it here today underneath
10 graphology, because actually I first learned
11 document examination through Ted. So this is
12 surprising to me. But I did say that to him,
13 but in a different context.
14 Q. So the fact is you do not consider
15 yourself a graphologist?
16 A. Of course not.
17 Q. And the website page that we've just
18 discussed seems to label you a graphologist?
19 A. That is what it appears to be here,
20 but it is incorrect.
21 Q. And would you, therefore, likely
22 intend to ask Mr. Widmer to please remove your
23 name and your quote from this page?
24 A. Yes. I will ask him to remove the
25 quote or I will have to ask him to put it in
0075
1 the correct context, which is with regards to
2 his document examination course.
3 Q. And, Ms. Wong, if you learn that, in
4 fact, Mr. Widmer did, in 1995, enter a
5 stipulation that he had falsified his own
6 credentials on questioned documents, would you
7 ask him to take your name out of his materials
8 altogether?
9 A. Yes, if that is the truth. Are you
10 saying he -- I don't understand your question
11 clearly. He falsified information with regards
12 to documents at hand or with regards to his CV?
13 Q. His credentials.
14 A. Okay.
15 Q. His credentials?
16 A. Thank you for bringing that to my
17 attention. I didn't realize this.
18 Q. Certainly.
19 Let's move to page 3 of your resume,
20 and this is back, of course, to Defendant's
21 Exhibit 1. You state that, under Continuing
22 Education, you attended Andrew Bradley's Forensic
23 Document Examination course.
24 A. Oh, I didn't attend it. That is a
25 course that is through correspondence through
0076
1 mail. And you send the course and you work on
2 the course when you find the appropriate time
3 to. And there is testing at the end of each
4 chapter is how it works. It gives you a test.
5 And after you answer the questions, you send it
6 back into his office, and they send you a
7 critique back.
8 Q. How much did you pay for that
9 correspondence course?
10 A. I don't remember. I am sorry.
11 Q. How much time did you spend on each
12 of the 20 lessons?
13 A. Actually, I haven't finished all the
14 courses, that is why it is under Continuing.
15 But I can't give you a number right off the
16 top of my head.
17 Q. How many of the 20 lessons have you
18 completed?
19 A. I have been through either the first
20 three or four.
21 Q. On your resume, you state that the
22 course entails subjects such as the mechanics of
23 handwriting, proper procedures for obtaining
24 exemplars, identification of handprinting,
25 disguised writing, forgeries, photocopy
0077
1 examination, typewriter identification, anonymous
2 letters, document photography, examination of ink
3 and paper, writing instruments, erased and
4 obliterated writing, and use of ESDA.
5 Have I read correctly?
6 A. That is correct.
7 Q. And which of those subjects have you
8 yet completed?
9 A. I, just to be -- this is right off
10 the table of contents, so it would be, like,
11 the first three or four. And actually, I have
12 knowledge of all the ones that you've mentioned;
13 I have knowledge in all those areas already.
14 Q. So your continuing education has
15 taken you through the first three or four?
16 A. That is correct.
17 Q. And exactly three or exactly four?
18 A. I can't remember. I am sorry.
19 Q. So you don't know if you have gotten
20 to disguised writing yet, which is number four
21 on this list?
22 A. That is correct. As I mentioned, I
23 have knowledge in all these areas.
24 Q. Is Mr. Bradley certified by the
25 American Board of Forensic Document Examiners?
0078
1 A. I am not sure of that.
2 Q. Is Mr. Bradley certified by the
3 American Society of Questioned Document
4 Examiners?
5 A. I am not sure. All I know of Mr.
6 Bradley is he used to be a document examiner
7 with the sheriff's department in, I believe,
8 whatever state he lives in. I forgot. I am
9 sorry.
10 Q. So he worked for the sheriff's
11 office in a county or a city of a state that
12 you don't now recall?
13 A. That is correct. That is my
14 understanding.
15 Q. And back to Mr. Liebman for a
16 moment. Is Mr. Liebman certified by the
17 American Board of Forensic Document Examiners?
18 A. No. But he is certified through
19 NADE, N-A-D-E; and he was also past president of
20 NADE, which I am also a past vice president of.
21 Q. And is Mr. Liebman certified by the
22 American Society of Questioned Document
23 Examiners?
24 A. No. A lot of those organizations
25 that you are mentioning are open to just
0079
1 government or government document examiners who
2 have retired and are now in the private field.
3 So since I have not been in the government
4 field, or anybody that is not in the government
5 field, they are not allowed membership.
6 And certification through some of
7 those associations that you did mention are
8 voluntary.
9 Q. Ms. Wong, back to page 3 of your
10 resume, under Related Education, you state, you
11 list Private Investigator Licensing Course in
12 Virginia Beach, Virginia. And your resume
13 describes this as an in-depth, state-accredited,
14 60-hour course taught by Vince Tortomasi, former
15 Norfolk, Virginia police officer. Am I correct?
16 A. That is correct.
17 Q. Did that private investigator
18 licensing course cover forensic document
19 examination?
20 A. It touched upon it.
21 Q. It touched upon it?
22 A. It touched upon many subjects.
23 Q. About how much time was devoted to
24 document, forensic document examination in that
25 course?
0080
1 A. I wouldn't be able to give you an
2 exact number. I wouldn't remember. But it
3 covered a little bit about fingerprinting; it
4 covered a little bit about ballistics; covered
5 investigation procedures and so forth, including
6 a little bit on document examination.
7 Q. So was it something of an overview
8 of what private investigators need to know?
9 A. That is correct.

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jameson
Member since 5-8-02
08-15-02, 04:32 PM (EST)

11. "12 Cina Wong depo"
In response to message #10


22 THE VIDEOGRAPHER: Back on the video
23 record at 5:11.
24 Q. (By Mr. Rawls) Ms. Wong, let me
25 show you Defendants' Exhibit 10, please.
0238
1 Here is a copy for you, a copy for
2 you.
3 Do you recognize this document?
4 A. Yes, I sure do.
5 Q. Is it a true copy of a document
6 that was signed by yourself and David Liebman in
7 1997?
8 A. That is correct.
9 Q. And was submitted to the law offices
10 of Mr. Hadden?
11 A. That is correct.
12 Q. In Colorado?
13 A. That is correct.
14 Q. Was this before or after you all had
15 spoken with the "National Enquirer"?
16 A. Way before.
17 Q. Way before. So the "National
18 Enquirer" people would have talked with you some
19 weeks or months after July 30, 1997?
20 A. Right. I had not even seen a copy
21 of the ransom note at this time, I believe.
22 This came about because I saw Mrs. Ramsey on TV
23 making a plea for anybody who might be able to
24 help her in this situation. My heart went out
25 to her. It was -- I can't imagine being in
0239
1 such a situation that she was involved in. And
2 I wanted to be able to help assist Mrs. Ramsey
3 in any way.
4 So I heard that Mr. Hadden was their
5 attorney, and I sent them a fax letting them
6 know we were available if they needed our
7 assistance.
8 Q. And this letter, then, also is dated
9 before you had ever spoken with Darnay Hoffman;
10 is that true?
11 A. That is correct.
12 (Defendants' Exhibit-11 was marked for
13 identification.)
14 Q. (By Mr. Rawls) Ms. Wong, you just
15 have been handed Defendants' Exhibit 11 by Mr.
16 Gallo. Do you recognize this document?
17 A. Yes, that is correct.
18 Q. Is that an authentic signature of
19 yours on the second page of this document?
20 A. Yes, that is my signature.
21 Q. And is that an authentic notary
22 public signature --
23 A. Yes, it is.
24 Q. -- below your signature?
25 A. Uh-huh (affirmative).
0240
1 Q. And it is an area of your own
2 expertise to know that, is it not, whether those
3 are authentic signatures or not?
4 A. Well, I signed it, and I saw the
5 lady notarize it, so.
6 Q. Who is Yolanda Feggans or Feggans?
7 A. I don't know her personally, but she
8 was a notary at a law firm.
9 Q. To whom did you provide this
10 affidavit?
11 A. To Mr. Hoffman.
12 Q. Did you provide it to Mr. Hoffman on
13 or about the date you signed it, November 13,
14 1997?
15 A. I assume so. It would not be
16 before.
17 (Defendants' Exhibit-12, Exhibit-13
18 and Exhibit-14 were marked for identification.)
19 Q. (By Mr. Rawls) Ms. Wong, this is a
20 reproduction of an alleged letter, and I want to
21 ask you if this is a reproduction of a true
22 letter authored by you?
23 A. Okay. I don't recognize it in this
24 form, since it is a reproduction. Or is it in
25 the form that it came in?
0241
1 Q. The reproduction is the only form
2 that we have it in.
3 A. Okay. Yeah, I --
4 Q. But did you send such a letter to
5 Alex Hunter in or about September 28, 1998?
6 A. Yes. I remember speaking to Mr.
7 Hoffman about the situation, and he told me what
8 was going on and asked me if I wanted to
9 assist in this. And I told him that, yes, I
10 would like to. And I asked him how I could go
11 about this.
12 Q. And is this identical to or very
13 substantially similar to a letter that you
14 actually did send to District Attorney Alex
15 Hunter in 1998?
16 A. I sent one. I would have to see
17 it. I am not sure what you are speaking
18 about. I mean, is it similar to --
19 Q. Please read Defendants' Exhibit 12
20 and let me know if that is an identical --
21 A. This is to Mr. Hunter.
22 Q. Yes.
23 A. That's correct. But you say if I
24 wrote another one; is that what you are saying?
25 Q. No, no.
0242
1 A. Oh, okay. I'm sorry.
2 Q. I am asking did you write this?
3 A. Yeah. Well, I spoke to Mr. Hoffman
4 about how to word it, so it was with his help.
5 Q. So to the best of your knowledge,
6 while this is a reproduction and not a
7 photocopy, this appears to be verbatim accurate.
8 A. That is correct.
9 Q. Correct?
10 A. I remember the situation being
11 discussed, and this is what -- this is what I
12 was partaking in.
13 Q. So did you formally ask District
14 Attorney Hunter to permit you to testify to the
15 grand jury in 1998, correct?
16 A. Uh-huh (affirmative). They were on
17 a fact-finding mission. I had some facts that
18 I thought they would like to be aware of.
19 Q. Who is Michael Kane? You see he
20 got a cc.
21 A. Right. He was an assistant to Mr.
22 Hunter.
23 Q. He is an Assistant District Attorney,
24 correct?
25 A. I think that is what he was. It's
0243
1 been a while.
2 Q. Would you take a look, please, at
3 Defendants' Exhibit 13. This, too, is a
4 reproduction. Let us know if it is verbatim
5 accurate or substantially similar to a letter
6 you received in reply.
7 A. Okay.
8 Yes. I recognize this letter.
9 Q. Is that identical to or substantially
10 similar to the actual reply which you received
11 from Mr. Kane on behalf of District Attorney
12 Hunter?
13 A. I am sorry? You are saying?
14 MR. RAWLS: Would you read the
15 question back, please, Alex?
16 (The record was read by the
17 reporter.)
18 THE WITNESS: Yes, I recognize this.
19 Q. (By Mr. Rawls) Did you then reply
20 to Defendants' Exhibit 13?
21 A. Yes.
22 Q. And is Defendants' Exhibit 14 a
23 reproduction of your actual reply?
24 A. Yes. I recognize that letter.
25 Q. And that is, indeed, your reply?
0244
1 A. That is correct.
2 (Defendants' Exhibit-15 was marked for
3 identification.)
4 Q. (By Mr. Rawls) Is Defendants'
5 Exhibit 15 a true reproduction of a letter which
6 thereafter you sent to Judge Roxanne Bailin of
7 the 20th Judicial District of Colorado?
8 A. Yes. I recognize this letter.
9 Q. Did you send that letter?
10 A. I am trying to think. Well, I
11 mean, I don't know if I sent it directly or if
12 I handed it to someone else to send for me.
13 But with the wording, I did ask Mr. Hoffman
14 also; we conferred in how to word this.
15 Q. Did Mr. Hoffman assist you with your
16 side of this entire body of conversation -- of
17 correspondence we are looking at now?
18 A. Entirely? Or what?
19 Q. With all of these letters of yours
20 to Alex Hunter and Mike Kane and Judge Bailin?
21 A. You are saying he wrote them
22 entirely or are you saying assisted?
23 Q. No, no. I am asking, did he -- let
24 me start over, please.
25 Did Darnay Hoffman assist you in
0245
1 wording all of your letters to Alex Hunter and
2 Michael Kane and Judge Bailin?
3 A. Not all of them. Just some of
4 them.
5 Q. The language was worked out by you
6 in consultation with Darnay Hoffman; is that
7 correct?
8 A. That is correct.
9 Q. And all of this effort was made by
10 you with the assistance of Mr. Hoffman in the
11 hope that you could testify to the grand jury
12 in Colorado that Patsy Ramsey, in your opinion,
13 probably authored the ransom note; is that
14 correct?
15 A. That is correct. I had a lot of
16 information to share.
17 Q. Had you ever been told up to the
18 point of this last letter, Defendants' Exhibit
19 15, that Mr. Hoffman represented Chris Wolf?
20 A. No. I didn't know that.
21 Q. As a matter of fact, this letter was
22 authored more than a year before John and Patsy
23 Ramsey published a book, "The Death of
24 Innocence."
25 A. Okay.
0246
1 Q. Was it not?
2 A. I am not sure of the date.
3 (Defendants' Exhibit-16 was marked for
4 identification.)
5 Q. (By Mr. Rawls) Let me ask you to
6 look at Defendants' Exhibit 16, please. Ms.
7 Wong, it purports to be a three-page
8 reproduction of two letters, one from Michael
9 Kane on behalf of Alex Hunter to you, and one
10 from Michael Kane on behalf of Alex Hunter to
11 David Liebman.
12 Would you please look over the
13 reproduction that is -- that purports to be of
14 a letter to you --
15 A. Do you have the second page? Oh,
16 it runs on. I see what it's done.
17 Q. My question is, is this, pages one
18 and two of Defendants' Exhibit 16, is there on
19 these pages an accurate reproduction of a letter
20 which Michael Kane sent to you in early 1999?
21 A. Okay. I will read it and let you
22 know.
23 (Deponent reviews document.)
24 Okay. I read my letter, and I
25 think the second one is basically the same.
0247
1 Q. Well, I don't need you to address
2 the reproduction of the letter Mr. Kane sent to
3 Mr. Liebman. I am only interested in whether
4 the reproduction of the letter from Mr. Kane on
5 behalf of Alex Hunter to you is accurate --
6 A. Yes.
7 Q. -- as best you recall?
8 A. From what I remember, yes.
9 Q. Do you have the originals of all
10 these letters in your file?
11 MR. ALTMAN: Jim, let me interrupt.
12 As far as accurate, do you mean accurate as to
13 what is stated in there or accurate that she
14 did receive it?
15 MR. RAWLS: Well, I mean accurate
16 that it is what he sent to Ms. Wong.
17 MR. ALTMAN: Okay.
18 Q. (By Mr. Rawls) I am not asking do
19 you agree with Mr. Kane's conclusions.
20 A. Okay. Yeah, I do not agree with
21 Mr. Kane's conclusions.
22 I am sorry, your question was?
23 Q. My question is, is this the letter
24 that he sent you?
25 A. The printing, the verbiage and
0248
1 everything, yeah.
2 Q. Yes?
3 A. The way it was written, yes.
4 Q. Thank you. Do you have Mr. Kane's
5 actual letter in your file?
6 A. It should be in a file somewhere.