Elizabeth McCarthy
Did Priscilla Hiss type the Baltimore Documents? Was forgery by typewriter possible? Here is the expert opinion of Elizabeth McCarthy, who served as official document examiner for both the Boston police and the Massachusetts State Police. This affidavit was included in Alger Hiss’s motion for a new trial.
COMMONWEALTH OF MASSACHUSETTS
COUNTY OF SUFFOLK
I, ELIZABETH MCCARTHY, of Boston, Suffolk County, Massachusetts, on oath depose and say:
I reside at 16 Porter Street and have an office at 40 Court Street, both in said Boston.
I am a qualified examiner of questioned documents. I have stated my qualifications in this respect in an affidavit executed January 22, 1952, for filing in connection with a motion for a new trial of Alger Hiss on the grounds of newly discovered evidence.
My affidavit of January 22nd dealt with the results of an experiment being conducted by the attorneys for Alger Hiss, to determine the extent to which it would be possible, as a practical matter, to build or adapt a typewriter which would so nearly duplicate the typing of another machine that qualified document examiners, comparing specimens of typing from the two machines, would be led by ordinary standards of comparison to conclude that only a single machine had been used.
* * *
Recently, Mr. Lane told me that the Government had finally agreed to let him have an expert examination made of the originals of the so-called Baltimore Documents, which had been introduced in evidence in the Hiss trials, as well as the so-called Hiss Standards [letters acknowledged to have been typed by the Hisses in the 1930s] with which Mr. Feehan, the Government’s document expert, had compared them. He asked me to compare these two sets of documents with each other, and also with specimens of typing from the so-called Hiss machine in his possession – that is, the machine which had been introduced into the trials as being the machine owned by the Hisses in the 1930s, and which had been used as the standard machine in the experiment of trying to create a duplicate. He said he wanted my opinion as to whether all three sets of documents had been typed on one machine – in which case, of course, the machine would necessarily be the so-called Hiss machine – or whether more than one machine was used and, if so, how many.
I have never examined Mr. Lane’s so-called Hiss machine, my work in connection with the construction of the duplicate having been limited to examination of specimens of typing from it and from the duplicate machine. However, since the experiment in duplication was finished, and I made my January affidavit about it, I have read Dr. Daniel Norman’s affidavit of March 7th, in which he describes and illustrates the results of his physical examination of the machine, and the grounds for his conclusion that it is a deliberately altered machine. I have made my examination of the three sets of documents in the light of my knowledge of Dr. Norman’s findings, as well as my own experience in studying the typing results of a machine deliberately created for the purpose of showing that forgery by typewriter would be possible.
Without considering the possibility of forgery, I should have concluded, by all standard tests ordinarily applied by questioned document examiners, that all three sets of documents were typed on the same machine. I should not have based this conclusion merely upon an inconsequential number of relatively identical peculiarities, but upon the more convincing fact that I find no substantial consistent deviations in type impressions as among the three sets of documents. However, my own experience has shown me that it is possible, by careful work on a machine, to eliminate almost completely the deviations which would normally have developed between its typing and that of another machine, and therefore, while I cannot say definitely that all three sets of documents were not typed on the same machine, I believe it just as possible, in the light of the observable facts, that the Baltimore Documents were typed on a machine which was not the original Hiss machine used for the Standards, but another machine made to type like the original Hiss machine. Since the typing of the Baltimore Documents so closely resembles the typing of the specimens from the so-called Hiss machine, and since Dr. Norman has furnished evidence that the machine is a deliberately fabricated one, I can only conclude that, as between the two possibilities, the forgery of the Baltimore Documents is the more likely. If the Baltimore Documents are forged, the forgery is a good one, but it is no better than I know would be possible with careful workmanship.
I have not confined my examination of the documents to a comparison of the typing for purposes of trying to reach an opinion as to how many machines were used. When Mr. Lane asked me to make this comparison, he told me that there were additional points on which he wanted my opinion. He said that, while the defense had on earlier occasions been allowed to photograph the documents in one way or another, the originals had never, so far as he knew, been made available for close and detailed expert study. He told me that, according to Chambers’ testimony at the trial, all the typewritten Baltimore Documents had been typed by Priscilla Hiss and given to him by Alger Hiss at some time between January 5 and April 15, 1938. He asked me to examine the original documents closely, and give him my opinion as to whether this testimony was correct.
I have done so, and am satisfied that Chambers’ testimony on this point cannot possibly be correct. The following are my more significant conclusions; I am prepared to support and illustrate each of them in detail on the stand if given an opportunity.
1. No one person typed the Baltimore Documents. There were certainly two typists, whose work varied sharply in evenness of pressure, typing skill, mechanical understanding and control of the machine, style habits, and other similar respects; no one person’s work could exhibit such differences. It is quite possible that more than two typists were involved.
2. Since certainly more than one person typed the Baltimore Documents, Priscilla Hiss cannot have typed them all. Furthermore, the characteristics of her typing make it perfectly clear that she was not either of the two principal typists involved. I base this conclusion to a considerable extent upon such factors, not clearly observable except from the original documents, as typing rhythm, pressure habits and variations, quality of touch, pace of typing, relative competence of the two hands, and the like. My conclusion from these factors is borne out by many other differentiating characteristics in such matters as style, mechanical skill, and habits of mind. Priscilla Hiss did not in my opinion type any of the Baltimore Documents.
ELIZABETH MCCARTHY
Sworn to before me this
19th day of April, 1952,
SIDNEY N. TOWLE, JR., NOTARY