BART BAGGETT Handwriting Analysis of IRMA LUCIA ......DECLARATION OF BART BAGGETT I, BART BAGGETT,...

BART BAGGETT

Handwriting Analysis of IRMA LUCIA Packet

REPORT 1

--------------------------------------------------------------------------------------- 1 of 5-------------------------------------------------------------------------------- DECLARATION OF BART BAGGETT Handwriting of Irma Lucia

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DECLARATION OF BART BAGGETT

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. Attached to this Declaration are the documents labeled as

‘EXHIBIT A,’ which is my Curriculum Vitae, which is true and correct.

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.

5. KNOWN/COMPARISON DOCUMENTS OF IRMA LUCIA

(Attached as K1 through K101)

K1-K8 Photographs of Manuscript excerpts dated in 1941 containing the purported handwriting of

IRMA LUCIA.

K9-K10 A two-page photocopy of miscellaneous letters in ‘Memorias E Cartas Da Irma Lucia’ dated


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between May 18, 1941 and May 5, 1943 containing the purported handwriting of IRMA

LUCIA.

K11-K88 A seventy-eight-page copy of the Fourth Memoir from ‘Memorias E Cartas Da Irma

Lucia’ dated December 8, 1941 containing the purported handwriting of IRMA LUCIA.

K89-K100 A twelve-page copy of the Third Memoir from ‘Memorias E Cartas Da Irma Lucia’ dated

August 31, 1941 containing the purported handwriting of IRMA LUCIA.

K101 A photocopy of a miscellaneous letter in ‘Memorias E Cartas Da Irma Lucia’ dated December

29, 1955 containing the purported handwriting 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:

i. The uniquely-shaped lowercase ‘b’;

ii. The lowercase ‘t’ both in the middle of a word and at the end of a word – the t-

bar is long, often tilted upwards, and ends with a blunt pen stop;

iii. The exit stroke and formation of the lowercase ‘o’ when the letter is at the end of

a word;

iv. The closed, circular loop in the lower zone of the lowercase ‘j’ and ‘g’ – these

open loops often contain an angle and reach the baseline when forming a

---------------------------------------------------------------------------------------3 of 5--------------------------------------------------------------------------------DECLARATION OF BART BAGGETTHandwriting of Irma Lucia

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downward turn. The sizes of the loops and formation of the final stroke are

significant similarities.

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.

1. 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 (K95) and questioned document (Q1). This side-by-side comparison

is useful to see the spacing, letter connections, and letter formations.

vii. The formation of the capital letters ‘D’, ‘F’, and ‘B’;

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

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

the Q5.

ix. The uniquely looped exit stroke on the lowercase letter ‘o’ – this formation moves

upwards and forms a loop over the previous letters.

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 ‘o’, 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


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merely the existence of such a loop in a writing from this time period. The

swooped o-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 “Esperrazza”) 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.

BART BAGGETT


REPORT 2


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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






2. REQUEST


handwriting of IRMA LUCIA on 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 ‘QB1 through QB3’ and ‘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 QB1 through QB3 and Q5)

QB1-QB2 Copies of Pages 158 and 139 of the ‘Original Manuscript by Sister Lucia’ containing the

alleged handwriting of IRMA LUCIA.

QB3 A photocopy of a ‘Facsimile of Sister Lucy’s letter to Father Umberto Pasquale’ dated April

31, 1980 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.


(Attached as K1 through K101)

K1-K8 Photographs of Manuscript excerpts dated in 1941 containing the purported handwriting of

IRMA LUCIA.


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K9-K10 A two-page photocopy of miscellaneous letters in ‘Memorias E Cartas Da Irma Lucia’ dated

between May 18, 1941 and May 5, 1943 containing the purported handwriting of IRMA

LUCIA.

K11-K88 A seventy-eight-page copy of the Fourth Memoir from ‘Memorias E Cartas Da Irma

Lucia’ dated December 8, 1941 containing the purported handwriting of IRMA LUCIA.

K89-K100 A twelve-page copy of the Third Memoir from ‘Memorias E Cartas Da Irma Lucia’ dated

August 31, 1941 containing the purported handwriting of IRMA LUCIA.

K101 A photocopy of a miscellaneous letter in ‘Memorias E Cartas Da Irma Lucia’ dated December

29, 1955 containing the purported handwriting of IRMA LUCIA.

6. BASIS OF OPINION






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

to:

i. The formation of the capital letter ‘P’ has a slight variation between the known

documents and the Q5. It is not formed with a circular bowl as seen in the known

writing.

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. (This difference

also occurs in QB1 and QB2.)


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iii. The baseline of the Q5 document is significantly less organized, rhythmic, and

linear than the known writing samples (This difference is also applicable to QB3);

iv. 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.

v. 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 (See the last paragraph of K56).

vi. The words printed in lowercase in the 11th line from the bottom on Q5 (which

contains the word “Esperrazza”) 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.

b. Differences between all four (4) questioned documents, QB1-QB3 and Q5, and the

known documents include, but are not limited to:

i. The questioned documents have a loop on the lowercase letter ‘o’, 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 o-loop is a significant difference.

ii. In the known documents, the lowercase ‘h’ has an exit stroke that typically brings

the stem straight down beneath the baseline or underlines the rest of the word

beneath the baseline. This trait is missing from the majority of the appearances of

this letter in the questioned documents.

iii. In the questioned documents, the lowercase letter ‘a’ is typically rounded with a

short exit stroke/tail. In the known documents, the loop of the ‘a’ is narrow and

closed, it slants to the right, and the exit stroke is longer, creating a tail.


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iv. In the known documents, the capital letter ‘S’ consistently has a curl at the top of

the letter. This trait is missing from the questioned documents.

c. QB3 has an angular loop on the lowercase ‘g’ which is a significant difference.

d. The writing of the questioned documents QB1 through QB3 and Q5 are internally

consistent.

e. The differences between the handwriting on the questioned documents 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 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 handwriting, or it was

intentionally created to look similar to the author’s known writing.

• It is highly probable that IRMA LUCIA did not write the questioned documents, QB1 through

QB3. These are highly likely documents 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 handwriting, or it was intentionally created to look similar to the author’s known writing.

• It was determined that the questioned documents, QB1 through QB3 are consistent with the

writing of the author of the questioned document Q5.

BART BAGGETT


REPORT 3

--------------------------------------------------------------------------------------- 1 of 4-------------------------------------------------------------------------------- DECLARATION OF BART BAGGETT

Signatures of Irma Lucia

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1. I am over the age of eighteen (18) and I am not a party to the matter of Signatures of Irma Lucia. If






2. REQUEST


signatures of IRMA LUCIA on a document with signatures clipped from other documents dated 1967 and

1969.

3. ATTACHMENTS

Attached to this Declaration is the questioned document of IRMA LUCIA, labeled as ‘QC1’, which is true

and correct. The known documents of IRMA LUCIA are attached and labeled as ‘KC1 through KC4’,

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

(Attached as QC1)

QC1 A one-page copy of a document with signatures clipped from other documents dated

approximately 1967 and 1969 containing the alleged signatures of IRMA LUCIA.


(Attached as KC1 through KC4)

KC1-KC4 Copies of documents with signatures clipped from Memorias dated between 1927 and

1954 containing the purported signatures of IRMA LUCIA.

6. BASIS OF OPINION





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known standards and questioned document(s). The conclusions of the expert opinions are derived from

the ASTM Standard Terminology for Expressing Conclusions for Forensic Document Examiners.

7. OBSERVATIONS

a. The questioned and known signatures were compared using the traditional side-by-side

method using the best possible resolution of the copies available and enlarged 400

percent.

b. The first name in the questioned signatures is not written as Maria, as shown in the known

signatures. The writer uses the prefix ‘Sr’ which is most likely a truncated version of the

word ‘Señorita’. While this would be a reasonable option for an unmarried woman, the

use of the ‘Sr.’ prefix is not found in the comparative signatures.

i. Therefore, the formation and stroke features of the letter ‘S’ have no comparative

value in this side-by-side analysis.

1. The letter ‘S’ is found in other previously viewed known documents, and

the most common structure of the letter ‘S’ in the handwriting of Irma

Lucia is a standard non-elaborate printed ‘S’ with a curl on the beginning

stroke.

2. Therefore, this formation of the letter ‘S’ is a different choice of structure

and formation than that of Irma Lucia’s other known writings.

ii. However, the ‘r’ in ‘Sr.’ is useful in comparison to the ‘r’ in the names ‘Irma’ and

‘Maria’ in the known samples provided.

1. The general structure and form of the ‘r’ in the known signatures are

similar to that of the 1967 signature in the questioned writing. In fact, the

top of the ‘r’ forms a roof-top overhang facing toward the left side of the

page. (One could say it resembles a flag in the known documents.)



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2. While this is similar in letter form, the slant is different. Also, one has to

consider whether or not this formation is a class characteristic or a unique

characteristic.

3. The 1969 signature in the questioned writing displays a rounded ‘r’ in ‘Sr’

which is a striking difference when compared to the known exemplars.

c. The most striking difference is the concave baseline shapes in the questioned signatures

compared to the razor sharped angles formed in the known signatures.

i. I have taken into consideration the writing instrument (fountain pen in both sets

of exemplars).

d. The baseline of the known handwriting of Maria Lucia is incredibly straight, precise, and

angular throughout the entire timeline. However, the questioned signatures are arcaded,

rounded and displays an unstable baseline. These are major differences.

e. The general starting point and direction of the pen is similar in the first letter of the name

‘Lucia’. However, that is where the similarities end.

i. The slant of the letters is different.

ii. The angle of the downstroke is different.

iii. The space between the capital ‘L’ and the lowercase ‘u’ is different.

iv. And, like most of the questioned signature baseline connections, there is a no

sharp angle in the questioned signatures as it appears in the ‘L’ of the known

signatures.

f. In the questioned signatures, the middle letters of the name ‘Lucia’ appear to be a series

of circular cursive ‘e’ formations which are fluid and natural for the writer. However, the

known signatures do not contain circular fluid motions for the letters; there are clear start

and stop strokes that form angles (not loops). This is a striking and obvious difference in

the two different writers’ natural habits.

g. The letter lowercase letter ‘a’ in the name ‘Lucia’ in the 1967 questioned signature is of

similar slant, formation, and overall shape to the known signatures.

BART BAGGETT Handwriting Analysis of IRMA LUCIA ......DECLARATION OF BART BAGGETT I, BART BAGGETT,...

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