Handwriting Analysis

EXCERPT FROM REPORT 1

I, BART BAGGETT, hereby declare: 1. I am over the age of eighteen (18) and I am not a party to the matter of The Writing of Irma Lucia. If called as a witness, I could and would competently testify to all of the facts, statements and opinions set forth in this declaration and the attached exhibit based on my personal knowledge except where based on my information and belief, and, as to matters stated on my information and belief, I believe them to be true and correct to the best of my knowledge.

2. Request

I am submitting my declaration to advise the Court of my conclusion regarding the authenticity of the handwriting of IRMA LUCIA on a four-page Handwritten Letter dated January 3, 1944 and a one-page Handwritten Letter dated December 27, 1969.

3. Attachments

Attached to this Declaration are the letters which are the questioned documents of IRMA LUCIA, labeled as ‘Q1 through Q5’, which is true and correct. The known documents of IRMA LUCIA are attached and labeled as ‘K1 through K101’, which is true and correct. Attached to this Declaration are the documents labeled as ‘EXHIBIT A,’ which is my Curriculum Vitae, which is true and correct.

4. QUESTIONED DOCUMENT(S) (Attached as Q1 through Q5)

Q1-Q4 High-quality color photocopies of a four-page Handwritten Letter dated January 3, 1944 containing the alleged handwriting of IRMA LUCIA.

Q5 A one-page copy of a one-page Handwritten Letter dated December 27, 1969 containing the alleged handwriting and signature of IRMA LUCIA.

6. BASIS OF OPINION

The basis for handwriting identification is that writing habits are not instinctive or hereditary but are complex processes that are developed gradually through habit and that handwriting is unique to each individual. Further, the basic axiom is that no one person writes exactly the same way twice and no two people write exactly the same. Thus, writing habits or individual characteristics distinguish one person’s handwriting from another. A process of analysis, comparison and evaluation is conducted between the known standards and questioned document(s). Overall class characteristics from native Portuguese writers of the time period were also a consideration. The conclusions of the expert opinions are derived from the ASTM Standard Terminology for Expressing Conclusions for Forensic Document Examiners.

7. Observations

a. Similarities between the known writing of Irma Lucia and Q1-Q4 include, but are not limited to:

v. The scissor-like angles at the baseline which form connectors between letters. This is a unique and consistent pattern which also helps reveal the overall rhythm of the writing. The spaces and sharp angles are consistent in the known writing.

The unique baseline arcades and overall rhythm of the Q5 document is one of the significant differences that lead to my conclusion (that differs from my conclusion for Q1-Q4) on this document.

vi. The unique starting point and formation of the lowercase ‘p’. This is observable in the entire the phrase “parte do segredo” which appears in both the known Manuscript (K92) and questioned document (Q1). This side-by-side comparison is useful to see the spacing, letter connections, and letter formations.

Samples

viii. The formation of the capital letter ‘P’;

1. This formation has a slight variation between the known documents and the Q5.

b. Differences between the known writing of Irma Lucia and Q5 include, but are not limited to:

i. The Q5 document has a loop on the lowercase letter ‘d’, but the shape is much more narrow, often closed, and pointed. This is a common class characteristic of the time period, so the details of the formation are much more relevant than merely the existence of such a loop in a writing from this time period. The swooped d-loop is a significant difference.

ii. The Q5 document contains many vertically-slanted upstrokes on the lowercase letters ‘t’ and ‘l’. This is a significant difference than the consistent rightward-slanted formations of the hundreds of pages of known exemplars.

iii. The baseline of the Q5 document is significantly less organized, rhythmic, and linear than the known writing samples;

iv. The capital letter ‘P’ is not formed with a circular bowl as seen in the known writing;

v. The capital ‘F’ in the Q5 document contains a curved top bar and downstroke which is not consistent with the known writer’s formation of the capital letter ‘F’. The known writer uses three distinct strokes to form the ‘F’, not two.

vi. The final stroke of the loop on the lower zone letters ‘g’, ‘j’, and ‘y’ have a curve and seem to be longer, fuller, and overall slightly different in formation from that of the known documents.

vii. The words printed in lowercase in the 11th line from the bottom on Q5 (which contains the word “Esperanca”) is a variation in writing formation within the questioned document that is unaccounted for. The printed letters do not match the writer of the rest of the questioned document.

c. The differences between the handwriting on Q5 and the known documents of Irma Lucia are not the result of typical decreases in muscular movement related to diseases of old age or simply the number of years between reliable samples. While many strokes and letters are consistent with the “class characteristics”, the overall rhythm and baselines and connections are not consistent with the same writer.

8. Opinion

Based upon my thorough analysis of these items, and from an application of accepted forensic document examination tools, principals and techniques, my professional expert opinions are as follows:

It has been determined that IRMA LUCIA has been identified as the author of questioned documents, Q1 through Q4.

It is highly probable that IRMA LUCIA did not write the questioned document, Q5. This is highly likely a document written by another person with many similar characteristics in letter form and letter structure. It is not possible to know if this is the author’s natural signature, or it was intentionally created to look similar to the author’s known writing.

9. Declaration

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on this 31st day of December 2018, in Sherman Oaks, California 91403.

Bart Baggett, Declarant.