I respond with Gideon Epstein:
Q. As best you recall, how many times have you been mistaken on the authorship of a document?
A. To the best of my knowledge, if I have made a mistake it's never been brought to my attention.
Q. So is it your view that your success at questioned document examination has been 100 percent throughout your career?
A. As I say, if I have made a mistake in this work, it has never been brought to my attention. So I'm not aware of my mistakes that I've made in the identification of handwriting.
Q. What is your degree of certainty yourself as you sit here today that Patsy Ramsey wrote the note?
A. I am absolutely certain that she wrote the note.
Q. Is that 60 percent certain?
A. No, that's 100 percent certain.
Q. You are 100 percent certain that Patsy Ramsey wrote the ransom note in this case; is that your testimony?
Q. You will acknowledge that as a human being the possibility of error is a part of your genetic makeup.
A. Absolutely.
Q. But you will not testify that there's any possibility of a mistake on your part with respect to Patsy Ramsey; am I correct?
A. No, that's -- in regards to Patsy Ramsey I feel that the conclusion that I reached is the correct one, and that is that she is the author of that note.
Q. And again, that is with not just a little bit certainty, that is with 100 percent positive conviction.
A. Yes, sir.
DEPOSITION OF GIDEON EPSTEIN
May 17, 2002
His qualifications:
ASSIGNMENTS
Served with the Army Crime Laboratory System as a Forensic Document Examiner from 1967 to retirement as Chief, Forensic Document Examiner in February 1978. Then served as a Senior Forensic Document Examiner with the National Laboratory Center, Bureau of Alcohol, Tobacco and Firearms, Rockville, Maryland from 1978-1980. Established the Immigration and Naturalization Service Forensic Document Laboratory in 1980 and served as the Chief Forensic Document Examiner until retirement in December of 2000. Opened his private practice in January 2001
CERTIFICATION
Certified by the Department of Defense (Army); Department of the Treasury (ATF) and Department of Justice (INS), U.S. Department of State, Federal Prison System as well as the Department of Homeland Security (FDL), to perform forensic document examinations for them.