David Liebman
#1
David Liebman, M.A., C.D.E.

Certified Document Examiner/President of NADE

981 South Quail Street o Norfolk, VA o 23513 p (804) 853-4722 622-9606

CURRICULUM VITAE

EDUCATION Master of Science, 1980, Old Dominion University Major Specialty: Biology Education

Minor: Psychology

Bachelor of Science, 1969, Old Dominion University Major Specialty: Earth Science Education


Minor: Psychology

0Additional study toward a Doctorate in Psychology and Biology.

EMPLOYMENT 9Instructor at Old Dominion University.

adjunct Professor at Tidewater Community College.

*Owned a scientific supply company for eleven years.

HANDWRITING T@NING BACKGROTJND:

CERTIFICATION a National Association of Document Examiners.

ADDITIONAL a Forensic document photography at Eastman Kodak Company,

TRAINING Rochester, New York, 1987.

a Statistics and the use of optical, chemical, laboratory, and scientific measuring equipment.

a University science courses requiring technical and specialized knowledge in the use of various types of laboratory equipment and writing lab reports.

ADVANCED t National Association of Document Examiners

TRAINING 1994-1989 Washington D.C.: 1991 Los Angeles, California, 1992 Atlanta, Georgia; 1994 Concord, Massachusetts; 1995 San Antonio, Texas; 1996 Baltimore, Maryland- 1997 Las Vegas, Nevada.

RESEARCH Old Dominion University: Handwriting disturbances.

AND Forensic photography techniques,

DEVELOPMENT Advanced techniques of document examination.

FACILITIES Including a library of over 500 books and articles on hand. writing and forensic document examination; laboratory; and. photo lab.

PROFESSIONAL National Association

ASSOCIATIONS of Document Examiners

Positions held: ]Education Chairman

Election Committee Chairman

Board of Directors

Second Vice President

Currently: President since October 1994

F-Eastman Kodak

Position held: Chairperson for Spring Seminar on @cd and

Ultra-Violet Forensic Document Photography.

LECTURES National Association of Document Examiners.

Photographic techniques and the Document Examiner.

Tidewater Law Board.

Old Dominion University Law Enforcement, Business and

Finance Security Control Departments and Handwriting

used in the business sector.

9 Chamber of Commerce.

& Retail Merchants Association.

o Tidewater Personnel.

& C&P Telephone Company.

COLLEGE 9 Completion of a College Level Course in Questioned Document-

COURSE ments. Northern V' ' 'a College, Annadale, VA. Instructed by

Larry Zieglar, current Questioned Document Examiner for the

FBI. 1995

COURT * Depositions, Hearings and Arbitrations.

EXPERIENCE o, Court qualified as an expert witness in the following courts:

Juvenile and Domestic Relations Court.

General District Court - Civil Division

General District Court - Traffic Division

Circuit Court

U.S. District Courts



PUBLISHED a National Association of Document Examines Journal:

WORKS Articles concerning forensic document photography.

LABORATORY Magnification devices, Microscopes...

EQUIPMENT o Forensic photography equipment.

Infrared and Ultraviolet (longwave and shortwave lamp)

* Calipers and measuring devices.
Reply
#2
DAVID LIEBMAN, M.A., C.D.E.
Certified Document Examiner/President of NADE
981 South Quail Street
Norfolk, VA 23513

September 28, 1998

Alexander M. Hunter, Attorney
Boulder District Attorney
Box 471
Boulder, CO
Fax: (303) 441-4703

Re: JonBenét Ramsey Grand Jury Request

Dear Mr. Hunter:

This letter is a formal request to appear before the JonBenét grand jury in Boulder County.

This request is pursuant to C.R.S. 16-5-204(4)(1). I am court qualified, board certified and president of the National Association of Document Examiners. I have documented evidence that Patsy Ramsey is the author of the ransom note left at the Ramsey residence on December 26, 1996.

Copies of my handwriting report, affidavit and C.V. have been sent to your office by Darnay Hoffman. This was done to enable you to examine them.

Please feel free to contact me concerning my testimony before the grand jury.

Thank you for your consideration.

Sincerely,

David S. Liebman
Reply
#3
THE STATE OF COLORADO
TWENTIETH JUDICIAL DISTRICT
ALEXANDER M. HUNTER
DISTRICT ATTORNEY
JUSTICE CENTER
1777 6th Street
Box 471
Boulder, Colorado 80306

October 2, 1998

Mr. David Liebman, M.A., C.D.E.
981 South Quail Street
Norfolk, VA 23513

Re: Request to Appear Before Grand Jury

Dear Mr. Liebman:

This is to acknowledge receipt of your request to appear before the grand jury, dated September 28, 1998. I would appreciate it if you would provide me with some information to help me consider your request.

You referred to your report, affidavit, and C.V. sent to my office by Darnay Hoffman. To be sure that I consider all appropriate information, please confirm that you mean your six page report dated November 26, 1997, your two page affidavit signed 13, 1997, and your two page C.V.

I would also appreciate information on the NADE, particularly its standards for certification as well its standards and operating procedures for document examination. I would also appreciate copies of your published works and any information, such as the syllabus, describing the college course you completed.

Finally I would appreciate a list of the court cases in which you have actually testified, including case name and number, the names and phone numbers of the lawyers who retained you and the opposing counsel, the outcome of the case, and the citation to any published decisions which may have resulted from the cases.

Feel free to send me anything else which you would like to have considered. Thank you for your interest and cooperation.

Sincerely,

Michael J. Kane
Deputy District Attorney
Reply
#4
DAVID LIEBMAN, M.A., C.D.E.
Certified Document Examiner / President of NADE
981 South Quail Street
Norfolk, VA 23513

October 18, 1998

Michael Kane, Esq.
Deputy District Attorney
District Attorney's Office
Boulder County
Box 471
Boulder CO 80306

Re: JonBenet Ramsey Grand Jury

Dear Mr. Kane:

I am responding to your October 2nd letter in which you asked me to provide your office with more information concerning my request to appear before the Boulder grand jury investigating the death of JonBenet Ramsey.

The report, affidavit and CV sent to your office by New York attorney Darnay Hoffman represents much of the material I would like to present to the grand jury.

As the president of NADE I'm also including our bylaws and qualifications for membership certificate. Let me point out that many document examiners who work for law enforcement don't meet our requirements and could not join without additional training and experience.

As per your request, I'm enclosoing a list of representative cases that I have appeared in as an expert witness over the past few years.

Please feel free to contact my office with any questions.

Sincerely,

David S. Liebman, B.C.D.E.
Reply
#5
THE STATE OF COLORADO
TWENTIETH JUDICIAL DISTRICT
ALEXANDER M. HUNTER
DISTRICT ATTORNEY
JUSTICE CENTER
1777 6th Street
Box 471
Boulder, CO 80306

January 20, 1999

Mr. David Liebman
981 South Quail Street
Norfolk, VA 23513

Re: Request to appear before the Boulder County Statutory Grand Jury

Dear Mr. Liebman:

After due consideration of your request to appear and testify before the Boulder County Grand Jury in the JonBenet Ramsey murder investigation, I wish to inform you that your request is denied. We have determined that your proposed testimony would not serve the interests of justice which is the controlling standard by which to judge your request.

The primary reson that we have reached this decision is that we believe that the methodology which you have used in reaching your conclusions does not meet the standards employed by the vast majority of forensic questioned document examiners in this country.

Most significant is your complete failure to account for or even reference any unexplained dissimilarities between the questioned and known samples. You are willing to conclude with 100% certainty that a writing was authored by a particular person based on some threshold level of similarities without any mention that there may be 10, 100 or 10,000 unexplainable dissimilarities between the known and unknown writings. I know of no reputable forensic document examiner who will not agree that unexplainable dissimilarities between a person's natural writing and questioned handwriting will preclude a positive identification. In fact, where the degree of unexplained dissimilarity is high, it may result in a elimination in spite of the existence of a number of points of similarity.

Because of this, it is not clear that your analytic methods would pass the test for admissibility in the courts of Colorado. We recognize that the rules of evidence do not apply to a grand jury investigation, but it would be rather pointless to allow the grand jury to indict based in part on opinion evidence that a petit jury might never be permitted to hear in a trial.

In addition to your technical deficiences, there are other reasons for our decision. I would note that you have engaged in a campaign of promoting your opinion in a manner that would surely open your credibility to doubt on cross examination in a judicial proceeding. As an experienced trial attorney, I believe that an expert witness who has attempted to insinuate himself into a particular criminal investigation through a public media campaign would appear less than objective and professional to a jury. It would be pointless to utilize the services of an expert who is vulnerable in this regard, given that there are hundreds of other qualified document examniners who are not tainted in this way.

You, of course, may appeal this decision. If your (sic) choose to do so, you should be aware of an order entered by Judge Daniel Hale and Judge Roxanne Bailin when the grand jury began its work. the order requires that all pleadings filed in this case be filed under seal. Thus, if you plan to appeal, you should be aware that any public dissemination or discussion of your pleadings may be seen by the court as a violation of the order and could result in a (sic) the issuance of a citation for contempt of court. I would suggest that you make your attorney aware of the existence of the order which is on file with the district court clerk. He can advise you in this regard.

Very truly yours,

Alexander M. Hunter
District Attorney

By:____________
Michale J. Kane
Deputy District Attorney
Reply
#6
Jul-07-01, 03:20 PM (GMT)
 
"Liebman analysis"
 
  
David Liebman, M.A., C D.E,
Certified Document Examiner/President of NADE
981 South Quail Street
Norfolk, VA 23513
757-853-4722 / 622-9606

November 26, 1997
Mr. Darnay Hoffman
210 West 70th Street
Suite 209
New York, N.Y. 10023

Re:Ramsey Handwriting Report
Dear Mr. Hoffman:
Please find enclosed the results of my examination of the following handwritten documents:
SYNOPSIS
Careful examination revealed the writer of the "ransom" note to be very probably the same writer as
the author of the "known" of samples of the handwriting listed below.
I found fifty one (51) points of comparison and similarity, which is a very high number.
Ransom notes are often written in a disguised handwriting. Not surprisingly, the writer will attempt to
hide his/her true identity.
It is usually safe to assume that every effort will be made on the part of the writer to hide his/her
normal style of handwriting. As result, the true writing habits and style of the writer will only
occasionally appear.
However, the greater the sample length of handwriting, the greater the likelihood the writer will not
be conscious of the fact that he/she have slipped back into their normal writing style.
It is my conclusion, which can be stated with a probability of 90-95%,that Patsy Ramsey is the
ransom note writer.
The following documents were examined as requested.
Questioned Document (copy):
Ql: A three page anonymous "ransom" letter beginning with the words "Mr. Ramsey" and ending with
"S.B.T.C.". This document consists of 67 lines.
Known Samples used for comparison (copies):
Kl: A letter addressed to "Miss Kit" dated "Wednesday, June 4".
K2: A greeting card beginning with "Wishing you a bright - season" and ending with "Love, Patsy,
John & Family".
K3: A color copy of a photograph of a sign "Welcome to the Northwest Territory." The sign is on a
brown background.
K4: A color copy of a photograph of a yellowish box. In the lower right is the word "Ramsey."
K5: A color copy of a photograph of four young children, their heads are just above center. Under the
photo is "Rainbow Fish Players" written in a red-brown color.
K6: A color copy of three photographs with the following print: "This me when I was first born. That's
my Mom and the doctor."
"I was 1/2. I'm having a picture taken."
"I was 1/2. I was going bike riding with my Mom and my Dad."
K7: Printing: "Hello. I'm Marilyn Monroe " on a circular background.
K8: Printing on a box "RAMSEY XMAS."
Consistencies between the "Ransom" note and the known exemplars.
The designation Q = ransom note, K = known exemplars, P = page, and W = word number will be
used.
The dot is placed below the base line.
QP3L 66; KlP2. The center strokes of the capital "W" are retraced.
Q2 "W"e; KlLl. The distance between the first two parallel strokes is greater that the 2nd and 3rd of
the W. QL2 We; KlP2L5 "w"ould. Capital W final upstroke is higher than the first stroke and is curved
to the right.
QL 12; K3. The 2nd downstroke of the "X" is higher than the lst. QL66; KlLl3. The spacing between
words in the Q and the other documents is great. The left margin decreases downward.
QP2; Sl&S2. The lower case "d" has a bow to the left down stroke.
QL 12,34; K6 "doctor & Dad." In the letter "b" the curve comes to a point in the upper position.
QL19 "bag"; K5 "Rainbow." The M is very similar, having angular tops and a concave final stroke.
QLl "Mr."; K7 "I'm." Sometimes the lower case of Y" first down stroke is at least twice as long as the
circle height.
Q22; KlP2Lll. The reverse curved punctuation dots or commas.
QL22 "will", QL24 The "F" cross stroke begins to the left of the down stroke.
QL4; K6 "first born." Circle letters sometimes have an angle at the 12:00 position.
QL52&44; K3 "to." Lower case "1" with a gentle curve above the baseline.
QL 49&51 ; K3 We"1"come. The upper case "A" crossbar connects with the letter "n."
QL29 "An"y; K4. The final down stroke of the uppercase capital "R" does not touch the baseline.
QL1; K7 & K4. The uppermost right tending movement of the capital "R" overshoots the down stroke
to the left.
Q41; K4. The top of the capital "R: is open to the right.
Ql; K4.The lower case "t" bar is sometimes concave.
QL 12; K3 "t"o. The lower case "t" bar is sometimes to the left of the stem.
QL34 "gentlemen"; KlL6. The lower case "t" bar is sometimes to the right of the stem.
QPlL9,23 "t"o & Q2L35; KlL7 "it" & QlP21. The 'It" bar on the right is more common than the placement
as in number 22. The "t" bar sometimes starts lower and raises as the stroke continues.
QL7 "t"ime; K3 Terri "t"ory. The "t" horizontal stroke is used to start the next letter "h".
QL33,,60; KlL4. The height of the "t" is lower than the "h" height.
Q6,14; Kl Northwest. The lower case 1'r" and 'lo" are often connected when in succession.
QL19 b"ro"wn; K7 Mon"ro"e. The lower case "n" and "d" have reduced intra-letter space or touch
when in succession.
Q8; K6 a"nd" the doctor. The lower case "n" and "9" touch.
Q40 talki"ng"; K6 ridi"ng". The capital "I" base is much larger than the parallel top Q19 "I" will; K6 "I"m
having. The majority of the slant in the Q and the K print samples is approximately perpendicular to
the baseline. Some of the letters form a slight lean to the right/left.
Q last page;.K3. The upper case "D" begins at the top well to the left of the down stroke.
QL62; KlL2 "D"ear. The letter "s" is composed of two curves. Sometimes it is compressed in the upper
curve.
QL15 and 16; K6 Fi"s"h. Sometimes the upper"s"curve begins with a shorter initial (beginning) stroke.
QL 15 and 16; K6 Player"s". Sometimes the upper curve of the "s" forms an angle in the left most part
of the upper curve.
QL37 "S"peaking, 38 "s"ituation; K6 Player"s". Sometimes the entire letter "s" is out of alignment with
other letters. It appears to slant backwards or to the left.
QLl Ram"s'ley,, QL5; KlL8, K6. The ending of the "ml' is with a curve similar to a hook.
QLl "M"r.; K3 Welco"m"e.1; The indentation of the first paragragh under the salutation appears to be
approximately determined by the beginning of the second word of that salutation.
QL2 the "L" is below the "Rs';
KlL3 "we" is below the "M"iss. The lower case "e" appears compressed horizontally while the "c"
appears filled in or expanded.
QL48 de"ce"ive, QL49 enfor"ce"ment; KlL5 performan"ce". The lower case "t" bar connects to the "o".
QL17 "to", QL23 "to"; KlPlL8 "to"ps,, KlP2Ll. The lower case "o" appears to float.
Q36 and Q37 t"o"; KlP2L5&6 t"o", KlP2L2 t"o"morrow. In the word "to" the lower case "t" touches the
"o" at the top and bottom.
QL64; K2L7. A lower case "g" down stroke bent in a similar way.
QL16 brin"g", QL55 gettin"g"; K2L7 goin"g". The final lower case "e" ends with straight line
perpendicular to the paper edge or parallel the "t" bar cross.
QL57 "the"; K2L8 "the". The final stroke of the lower case "s" connects to the final "e".
QL23 advi"se", QL64 sen"se"; K4 Ram"se"y. The lower case "d" down stroke extends below the
baseline.
QL29 "d"eviation; KlL9 fiel"d". The lower case letter it S" is enlarged.
QL29 in"s"tructiont's" QL47 "s"he, QL48 u"s"; KlP2Lll "s"ee. The treatment of enlarging the "a" can be
observed in QL37 "a"nyone "a"bout; K4 R"a"msey. The middle of the "m" does not always return to the
baseline.
QL24 "m"onitor, QL15 "m"ake; K6L2 "m"e. "Ransom" note as well as Patsy Ramsey's writings have a
tendency toward using exclamations "!". The lower case "C" is enlarged.
QLl "C"arefully; KlL4 "C"rash "C"ourse.
WHAT TO LOOK FOR IN FUTURE EXEMPLARS & SAMPLES
Observe "$" marks to compare with ransom note marks.
Observe closely the printed letter llk".
Obtain and study Patsy Ramsey's cancelled checks to observe number size variations, e.g. the
smaller "ooo's" in the ransom note.
Study the upside down and left handed script and printing to compare with mirror images in ransom
note.
Many printed letters have no intra-word space. Study more printed exemplars for this tendency.
Look for the same letters that "touch" one another.
Some letters in the ransom note are reduced, look for continuing pattern in exemplars.
Observe closely the "pressure patterns" in the letter numerical "o".
OPINION
There are far too many similarities and consistencies revealed in the handwriting of Patsy Ramsey and
the ransom note for it to be coincidence.
Although many writers share some of the same traits found among other authors, as the number of
identifiable traits increases,- the likelihood of two people sharing the same handwriting decreases
dramatically.
In light of the number of comparisons and similarities between Patsy Ramsey and the ransom note
writer (51), the chances of a third party also sharing the same characteristics is astronomical.
Taken individually, the similarities are not nearly as compelling as the sheer numbers and combinations
found in both the writing of Patsy Ramsey and the ransom note.
In my professional opinion Patsy Ramsey is the ransom note writer.
David S. Liebman, C.D.E.
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