Motion for Court Reporter or Interpreter in Chuangxia Cai v. Xiao He Liu, Does 1-50| Trellis.Law

On December 17, 2021 a Exhibit,Appendix was filed involving a dispute between Chuangxia Cai, and Does 1-50, Xiao He Liu, for Commercial - Contract in the District Court of Suffolk County.

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FILED: SUFFOLK COUNTY CLERK 04/12/2024 11:02 AM INDEX NO. 623377/2021
NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 04/12/2024

Forensic Handwriting Examination
Chuangxia Cai Matter

1) Forensic Handwriting Examination Report.

2) Terminology for Expressing Conclusions/Standard for
Handwritten Items.

3) Full-Sized Comparison Charts.

4) Questioned and Known Documents Examined.

5) Questioned and Known Signature Collection.

7) Curriculum Vitae of Cina L. Wong, CDE.
FILED: SUFFOLK COUNTY CLERK 04/12/2024 11:02 AM INDEX NO. 623377/2021
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CINA L. WONG & ASSOCIATES, LTD.
COURT QUALIFIED DOCUMENT EXAMINER

Vahe Khojayan, Esq.

YK Law LLP
445 S. Figueroa St. Ste 2280

Los Angeles CA 90071

March 28, 2024

FORENSIC DOCUMENT EXAMINATION REPORT CONCERNING
AUTHENTICITY OF CHUANGXIA ON CAI SIGNATURES
QUESTIONED LIMITED LIABILITY COMPANY AGREEMENT
AND AMENDMENT TO OPERATING AGREEMENT

I. INTRODUCTION

This comparative forensic questioned document handwriting examination

summary has been prepared at the request of Vahe Khojayan, Esquire. I,

Cina L. Wong, a Board Certified Document Examiner, have been retained to

express opinions as to the authorship of the signature of Chuangxia Cai on a

Questioned Limited Liability Company Agreement and an Amendment to

Operating Agreement concerning 130 Real Estate NY LLC which were

allegedly signed on August 30, 2019.

II. PROFESSIONAL QUALIFICATIONS

I am a former vice president of the National Association of Document

Examiners (NADE). In 1994, I received certification through NADE after

successfully passing extensive written and oral exams on document

examination. Throughout the years since I have stayed
my certification,

abreast of new technological advances and research in the field by attending

continuing education courses that qualified me to be re-certified in through

PO Box 1293, Norfolk, VA 23501
Cell: (757) 536-3454 ¼ CinaWong FDE@aol.com
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NADE. In addition, I am an adjunct professor at East Tennessee State
University (ETSU) with the Criminal Justice Department’s Graduate
Certificate program on Questioned Documents. Attached to this report is a
copy of my curriculum vitae, detailing my professional and educational
background.

I have been in practice as a forensic handwriting expert and questioned
document examiner for over 30 years. I speak conversational Cantonese.
When I was younger, I attended Chinese school for 8 years.

I have qualified and have testified in various United States courts concerning
Chinese handwritings and signatures.

III. MATTERS CONSIDERED

I have received and examined the following documents as part of my
examination:

Questioned Document: (Signatures of Chuangxia Cai are disputed.)

QD1a: Limited Liability Company Agreement to 130 Real Estate NY LLC.
Three pages. First questioned signature is located on page 2, under
the heading of “Existing Member.” Dated August 30, 2019. Digital
copy.

QD1b: Limited Liability Company Agreement to 130 Real Estate NY LLC.
Three pages. Second questioned signature is located on page 2, under
the heading of “Transferring Member.” Dated August 30, 2019.
Digital copy.

QD2: Amendment to Operating Agreement to 130 Real Estate NY LLC.
Questioned signature is at the bottom of the page. Dated August 30,
2019. Digital copy.

Known Standards Used for Comparison of Chuangxia Cai:

K1: X-Hong International Group Inc. stock certificate #002 for 100 shares.
Date 2/28/2013. Digital scan.

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K2: Drocnoc USA Corp. stock certificate #002 for 100 shares. Date
5/03/2013. Digital scan.

K3: Sporting good agreement. No date. Digital scan.

K4: Property Sale Agreement. June 20, 2017. Digital scan.

K5: Apartment Reserve Purchase Agreement. December 1, 2017. Digital
scan.

K6: Social Contract (in German) PG1. No date (est. early 2020). Digital
scan.

K7: Social Contract (in German) PG2. No date (est. early 2020). Digital
scan.

K8: Wonderbuggy licensing Agreement. 3/15/2019. Digital scan.

K9: Banking verification document. 3/3/2020. Digital scan.

K10: GTIN Exemption Letter. 6/15/2020. Digital scan.

K11: Office/Property Rent Agreement. 8/28/2020. Digital scan.

K12: W-8BEN, 2/19/2021. Digital scan.

K13: East West Bank. 2/19/2021. Digital scan.

K14: Real Estate Seller potential exclusion document. 6/4/2021. Digital
scan.

K15: Sales Agreement. 6/4/2021. Digital scan.

K16: Property Owner Agreement. 6/4/2021. Digital scan.

K17: Construction Project Agreement. 7/1/2021. Digital scan.

K18: Construction Itemized Listed. 7/1/2021. Digital scan.

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K19: Xiahong Toys Trading Co. 7/31/2021. Digital scan.

K20: Linbo Hong Kong Document. No date. Digital scan.

IV. FACTUAL BACKGROUND

A forensic handwriting examination of the questioned document and review
of known exemplars were conducted by applying well-established and
recognized principles of questioned document examination, as discussed and
defined in this partial list of recognized texts:
Questioned Documents by Albert Osborn, Handwriting Examination – Facts
and Fundamentals by Huber & Hedrick, Disputed Documents by Hagan,
Evidential Documents by Conway, Scientific Examination of Documents by
Hilton, Suspect Documents by Harrison.

V. ANSI/ASB METHODOLOGY AND ACCEPTED
PUBLISHED STANDARDS

I subscribe to the ANSI/ASB Standards for methodology and standards for
the examination of handwritten items https://www.aafs.org/asb-
standard/standard-examination-handwritten-items The ANSI/ASB Standards
supersede the Scientific Working Group for Forensic Document
Examination (SWGDOC) standards.

Still employed and accepted in the field of questioned documents is
SWGDOC’s Standard Terminology for Expressing Conclusions of Forensic
Document Examiners.

VI. MY PROFESSIONAL OPINION

I have conducted an independent examination of the documents listed in this
report. Based upon the documents submitted, it is my professional opinion
the writer represented as Known Standards Used for Comparison Chuangxia

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Cai (K1 – K20) is ELIMINATED as the hand that authored the signature of
“Cai” on the Questioned August 30, 2019 Limited Liability Company
Agreement (QD1a and QD1b), and on the Amendment to Operating
Agreement (QD2). This is the highest degree of confidence.

The SWGDOC Standard Terminology for Expressing Conclusions of
Forensic Document Examiners has been used in the preparation of the
opinions of this opinion letter. The SWGDOC provides the following nine-
level scale for expressing conclusions:

¥ Identification
¥ Strong probability
¥ Probable
¥ Indications
¥ No conclusions
¥ Indications did not
¥ Probably did not
¥ Strong probability did not
¥ Elimination

VII. BASIS FOR MY OPINION

My opinion and conclusions were based upon a careful comparison of
existing natural variations, similarities, and dissimilarities, between the
disputed Chuangxia Cai signatures on the Questioned Documents (QD1a,
QD1b, QD2), and the Known Standards Used for Comparison of Chuangxia
Cai (K1 – K20).

A partial list of the items examined include:

● Character form ● Stroke sequence
● Continuous strokes ● Individual strokes
● Air strokes ● Size/proportions of characters
● Initial & terminal strokes ● Placement of signatures

Though most people were taught to write from a specific copybook, many
individuals veered from the traditional copybook form and started to create
unique formations/additions to their writing later on in their lives. This is
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how handwriting matures and becomes recognizable as belonging to a

specific writer. It is the combination of deviations from the copybook form

that makes handwriting identifiable.

Below are full images of the disputed Chuangxia Cai signatures from the

Questioned Limited Liability Company Agreement (QD1a, QD1b) and the

Amendment to Operating Agreement (QD2).

QD1a QD1b QD2

Alleged signatures of Chuangxia Cai from the Questioned Limited Liability Company
Agreement (QD1a, QD1b).

(Continued on next page.)

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VIII. EXPLANATION OF CHINESE WRITING STYLES

Figure 1: Demonstrates 3 basic styles of Chinese handwriting. Comparable
to the English writing styles of print, print/script, and cursive, the Chinese
written language utilizes similar style designations such as
Standard/Standing (print), Walking (print/script), and Running (cursive).
Each column contains examples of the specified Chinese writing styles.

Figure 1: Three styles of Chinese handwriting. From left to right are Standard/Standing,
Walking, and Running.

IX. NATURAL VARIATIONS

Everyone’s handwriting displays natural variation. An individual cannot
write or sign a signature exactly the same way each time since they are not a
mechanical machine. Handwriting is a learned motor skill that is developed
by repetition, and is a skill that becomes more proficient as the writer
reaches graphic maturity (i.e.: a higher level of penmanship skill). Signals
from the brain can assist or interfere with normal, rhythmic writing.

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There are many causes for natural variation in handwriting. The causes
range from the type of writing instrument used, health, mood, body/hand
position of the writer, medications, and more.

Before I utilized the Chuangxia Cai exemplars, I compared the known
signatures to one another to verify that the exemplars were written by one
writer. With this process, I was able to establish the normal variations within
the known Cai exemplars. The normal variations were consistent with the
construction of Mr. Cai’s known signature styles.

The comparison charts in this report are for illustrative purposes. Larger
version of the following charts will be attached to the end of this report.

Figure 2, is a chart representing the variations of Chuangxia Cai running-
style signatures. At the top row of the chart, are Mr. Cai’s full signatures
containing his last and first name (Chinese names are written with the
surname first, and the first name last 蔡创侠). The bottom row is a simplified
variation of Mr. Cai writing his last name for his signature.

Figure 2: Natural variations between the signatures utilized by Chuangxia Cai. At the
top row of the chart, Mr. Cai writes with his full signature (蔡创侠). The bottom row is a
variation of Mr. Cai writing his last name for his signature (蔡).
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Figure 3, shows contemporaneous signatures in the running style. In the top
row, Cai 蔡 is underlined with an orange dotted line. You can see the
variation with the two known characters. K10 is written with 4 continuous
strokes, while K11 is written with one unbroken stroke. The second
character (创) this first row is highlighted by a green bracket. K10 is written
with 3 continual strokes, while K11 is executed with one solid stroke.

In the bottom row, a light blue arrow points to the last name Cai 蔡. Both
K15 and K16 Cai’s are written with one ongoing stroke, but notice the K15
Cai resembles a cursive-like “S” and the K16 Cai appears to look like a
lowercase cursive “g.” Both are written by the same person and are natural
variations of this writer.

See the Symbol Legend on the following page for further explanation of the
highlighted markings.

Figure 3: Natural variations of one writer during contemporaneous time frames.

(Continued on next page.)
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● Symbol Legend for Figure 3. Top row (left and right side of chart are
Known signatures):

K30 is composed of 4 continuous strokes, while K11 is
written with one unbroken stroke.

K10 is written with 3 continual strokes, while K11 is
executed with one solid stroke.

● Symbol Legend for Figure 3. Bottom row (left and right side of chart
are Known signatures):

Though both K15 and K16 are written in one ongoing stroke, the
Cai in K15 resembles a cursive “S,” while in K16, it appears to
look like a lowercase cursive “g.”

X. SIMILARITIES BETWEEN THE QUESTIONED
CHUANGXIA CAI SIGNATURES AND KNOWN
STANDARDS FOR COMPARISON OF CHUANGXIA CAI

The following comparison charts will show the specified Questioned
Signature (QD1a, QD1b, QD2) on the left side of the page, and examples
selected from Known Standards Used for Comparison (K1 – K20) on the
right side.

There was a superficial similarity between the placement of the questioned
Chuangxia Cai signatures from the Questioned Documents and Chuangxia
Cai Known Standards Used for Comparison (K1 – K20).

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Figure 4, questioned signature QD1a from the Limited Liability Company
Agreement is located to the left of the comparison chart. Note the placement

of the last name Cai (ilji). It is located towards the center of the signature

line. The genuine Kl3 signature of Mr. Cai can also be found placed in the

center of the signature line.

Simil rities

QD1a Amendment Limited Liability Known Chuangxia Cal Signatures

EXISTING MEMBER:
upaatesucnaccumentationuponrequest.IalsoacKnowieage
InatI must
U.S.resident,
orotherU.S.personforU.S.taxlawpurpose.
K13
ofAccountOw
Signature
Chuangxia Cai

CinoL.Wong& Associates,
Ltd. Page4 of 9

Figure 4: Similar placement of QD1a and K13 signatures on the midpoint of the
signature line.

" Symbol Legend for Figure 4:

Note center placement of signatures.

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Figure 5. As with Figure 4, questioned signature QD1b from the Limited

Liability Company Agreement is located to the left of the comparison chart.

The placement of the last name Cai (§ji) is located near the center of the

signature line. The genuine Kl3 signature of Mr. Cai can also be found

placed in the center of the signature line.

Simil rities

QD1b Amendment Limited Liability Known Chuangxia Cal Signatures

TRANSFERRING MEMBER:
updatesucncocumentation InatI mus1
uponrequest.Ialsoacknowledge
U.S.resident,
or otherU.S.personforU.S.taxlawpurpose.
K13
ofAccountOw
Signature

OnoL Wong&Associates,
Ltd. PageSof 9

Figure 5: Similar placement of QD1b and K13 signatures on the midpoint of the
signature line.

" Symbol Legend for Figure 5:

Observe center placement of signatures.

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Figure 6. As with Figures 4 and 5, the questioned signature QD2 from the

Amendment to Operating Agreement is located to the left of the comparison

chart. The placement of the last name Cai (§jE) is close to the center of the

signature line. The genuine Kl3 signature of Mr. Cai is orientatedina

similar manner.

Simil rities

QD2 Amendment Operating Agreement Known Chuangxia Cal Signatures

upoatesucncocumentationuponrequest.Ialsoacknowledge
inat I must
orotherU.S.personforU.S.taxlawpurpose.
U.S.resident,
K13
ofAccountOwk
Signature /

OnoL Wong& Associates,
Ltd. Page6 of 9

Figure 6: Similar placement of QD2 and K13 signatures on the midpoint of the signature
line.

" Symbol Legend for Figure 6:

Near center placement of signatures.

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XI. DIFFERENCES BETWEEN THE QUESTIONED
CHUANGXIA CAI SIGNATURES AND KNOWN
STANDARDS FOR COMPARISON OF CHUANGXIA CAI

Figure 7, Row #1 displays great consistency amongst Questioned
Signatures QD1a, QD1b, and QD2. The green chevrons highlight the first
stroke of the Cai character. This stroke, in the Questioned Signatures is
constructed like a backwards “7.” But as demonstrated by the red chevron,
the known Cai (K5) is written in one vertical stroke that leans slightly to the
left.

Row #2 concentrates on the mid-section of the Cai character. The green
parentheses in Questioned Signatures QD1a, QD1b, and QD2 show an x-ing
formation. But in the known Cai (K6), a lowercase “y” formation is shown
between the red parentheses.

Row #3 the green bracket on Questioned Signatures QD1a, QD1b, and QD2
calls attention to the empty zone in lower left quadrant of the character. In
the known Cai (K6), the lower left quadrant (red bracket) consistently
contains writing movement in the area, which creates aesthetic balance.

Figure 7 (Row #1 – #3): Inconsistencies between Questioned Signatures QD1a, QD1b,
QD2 and known signatures of Chuangxia Cai.
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● Symbol Legend for Figure 7, Row #1:

The left vertical stroke in the three Questioned Signatures is
constructed like the number “7.”

The left vertical stroke in Known Signature K5 is written with a
single stroke.

● Symbol Legend for Figure 7, Row #2:

The mid-section of the three Questioned Signatures is shaped with
an “X” type formation.

The mid-section of Known Signature K6 utilizes a lowercase “y”
formation.

● Symbol Legend for Figure 7, Row #3:

The lower left quadrant of the three Questioned Signatures is empty.

The lower left quadrant of Known Signature K6 contains writing
movement.

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Figure 8, Row #4, in the upper right quadrant of the Questioned Signatures
(QD1a, QD1b, and QD2), the green parentheses isolate an area that is
written with two strokes, or two connected strokes. Conversely, the upper
right quadrant of the Known Signature (K6) is part of a fluid writing
movement that is not composed of multiple strokes.

Figure 8, Row #5, the green arrow points to the downward “hook” in the
writing in the upper quadrant of the Questioned Signatures (QD1a, QD1b,
and QD2). In the Known Signature (K6), the downward “hook” does not
exist.

Figure 8, Row #6, in Questioned Signatures (QD1a, QD1b, and QD2) the
final writing movement consists of a figure that resembles a leftward leaning
number “2.” In the Known Signature (K6), the final movement is more
similar to a reverse number “2.”

Figure 8 (Row #4 – #6): Inconsistencies between Questioned Signatures QD1a, QD1b,
QD2 and known signatures of Chuangxia Cai.

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● Symbol Legend for Figure 8, Row #4:

The upper right quadrant of the Questioned Signatures is
written with two strokes, or two connected strokes.

The upper right quadrant of Known Signature K6 is not written
with multiple strokes.

● Symbol Legend for Figure 8, Row #5:

The upper right quadrant of the Questioned Signatures contains a
downward “hook.”

The upper right quadrant of the Known Signature K6 does not
contains a downward “hook.”

● Symbol Legend for Figure 8, Row #6:

The final writing movement of the Questioned Signatures
resemble a leftward leaning number “2.”

Instead, the final writing movement of Known Signature K6
resembles the number “2” written in reverse.
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Figure 9, Row #7, the green brackets in Questioned Signatures QD1b and
QD2 highlight the lower loop in the portion of writing that resembles the
number “2.” Note that the flattened loops have green brackets that open
upwards and to the left. Contrarily, in the Known Signature (K5), when a
flattened loop is utilized in the lower portion of the writing, the slant of the
loop leans rightward (see red bracket).

Figure 9, Row #8, the bottom of Questioned Signature QD1a is in the shape
of a narrow teardrop which is designated by a green “U.” When the same
area is examined in the Known Signature (K6), the teardrop shape is more
pronounced and enlarged.

Figure 9, Row #9, the Questioned Signatures QD1a, QD1b, and QD2
employ the “Walking” writing style which is similar to English print/script
writing. In the Known Signatures of Mr. Cai, the writing style commonly
used is “Running” which relates to English cursive writing.

Figure 9 (Row #4 – #6): Inconsistencies between Questioned Signatures QD1a, QD1b,
QD2 and known signatures of Chuangxia Cai.

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● Symbol Legend for Figure 9, Row #7:

Questioned Signature QD1b has a flatten lower loop that angles
slightly leftward.

Questioned Signature QD2 has a flatten lower loop that angles
leftward.

Known Signature K5 contains a flatten loop that angles rightward.

● Symbol Legend for Figure 9, Row #8:

Questioned Signature QD1a contains a narrow teardrop shape.

Known Signature K6 utilized a teardrop shape with a large, rounded
base.

● Symbol Legend for Figure 9, Row #9

The Questioned Signatures are written in “Walking” style (ie:
print/script).

The Known Signatures of Mr, Cai embody the “Running”
style (ie: cursive).

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XII. SUMMARY

After a systematic examination was completed with the Questioned and

Known Signatures of Chuangxia Cai from documents signed under similar

conditions (ie: everyday business correspondence documents), I was able to

come to a conclusive opinion. The writer of the Known Standards for

Comparison Chuangxia Cai (K1-K20) is eliminated as the writer of the

Questioned Signatures QD1a, QD1b, and QD2.

1) Though there was a similarity between the Questioned Signatures

QD1a, QD1b, and QD2, and Kl3 concerning center placement, center

placement of a signature on a signature line containing one character

is not uncommon amongst Chinese writers.

2) There were 9 overwhelming significant differences between the

Questioned Signatures QD1a, QD1b, and QD2, and Kl-K20.

3) Disguised writing was not an issue. Kl-K20 did not execute the

Questioned Signatures. The Questioned Signatures QD1a, QD1b, and

QD2 were written very fluently, and were all written by one writer.

4) The author of the Questioned Signatures QD1a, QD1b, and QD2
wrote the Cai signature with 7 interrupted strokes, while the Known
Kl-K20 signatures were written with 4-6 complete strokes.

5) The author of the Questioned Signatures QD1a, QD1b, and QD2
"Walking"
wrote the Cai signature in a style which is different than
"Running"
the style of writing that is utilized in the Known Kl-K20

signatures.

Please produce any original documents for review before trial.

I reserve the right to supplement this report if additional information arises.

Cina L. Wong, CD
President

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CINA L. WONG & ASSOCIATES, LTD.

COURT QUALIFIED DOCUMENT EXAMINER

SWGDOC.org

Standard Terminology for

Expressing Conclusions

for Document Examiners
FILED: SUFFOLK COUNTY CLERK 04/12/2024 11:02 AM INDEX NO. 623377/2021
NYSCEF DOC. NO. 72 RECEIVED NYSCEF: 04/12/2024

SWGDOC Standard Terminology for Expressing Conclusions of Forensic Document Examiners

1. Scope
1.1 This terminology is intended to assist forensic document examiners in expressing conclusions or opinions based on
their examinations.
1.2 The terms in this terminology are based on the report of a committee of the Questioned Document Section of the
American Academy of Forensic Science that was adopted as the recommended guidelines in reports and testimony by
the Questioned Document Section of the American Academy of Forensic Science and the American Board of Forensic
Document Examiners.1

2. Referenced Documents
2.1 Standards
SWGDOC Standard for Scope of Work of Forensic Document Examiners

3. Significance and Use
3.1 Document examiners begin examinations from a point of neutrality. There are an infinite number of gradations of
opinion toward an identification or toward an elimination. It is in those cases wherein the opinion is less than definite
that careful attention is especially needed in the choice of language used to convey the weight of the evidence.
3.2 Common sense dictates that we must limit the terminology we use in expressing our degrees of confidence in the
evidence to terms that are readily understandable to those who use our services (including investigators, attorneys,
judges, and jury members), as well as to other document examiners. The expressions used to diffe

Case Info

Judge

Maureen Liccione Track Judge’s New Case

Case No.

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Document Filed Date

April 12, 2024

Case Filing Date

December 17, 2021

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Exhibit,Appendix: Chuangxia Cai v. Xiao He Liu, Does 1-50

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