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Evasive answers during deposition

Evasive answers during deposition

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deposition techniques, evasive deposition answers, medical malpractice attorneyThis is an example of an evasive set of answers during a deposition of a physician.

Just answer the question, Doctor.

A: I told you I wasn’t perfect. I attempted to comply with Medicare regs. I was not perfect in my documentation.
Q: Okay. And it was pointed out to you on a number of occasions, was it not?
A: I disagree with the term “number of occasions.” It was pointed out a couple of times that there were gaps in my documentation.
Q: A couple of times means two?
A: Does a couple mean two?
Q: Well, I’m trying to understand your answer. What does it mean to you?
A: It means a few.
Q: Okay. Does that mean – a few, does that mean several?
A: I told you. I don’t remember the exact number.
Q: Okay. I’m not asking you exact numbers. I’m asking you a ballpark. Is it more than ten?
A: It was a few.
Q: How many is a few to you? Bookend that for me.
A: More than two and I don’t know. I never had to define a few before. More than two.
Q: Okay. Is it 100?
A: No, I wouldn’t consider a few a hundred.
Q: Would a few be ten?
A: It depends upon in what context it was in.
Q: This is your answer. You’ve got to tell me the context. How much is a few?
A: I gave you an answer. A few is a few. It is more than two.
Q: More than two?
A: And less than a hundred.
Q: It is less than fifty?
A: Probably less than fifty.
Q: It is less than 25 to you?
A: Once again, that would depend upon the context.
Q: In this context in receiving criticism regarding your documentation, how many times is a few. Is it less than 25?
A: I believe so.
Q: Less than twenty?
A: Based on what I recall, yes.
Q: Okay. Less than 15?
A: Possibly.
Q: Less than ten?
A: I don’t remember specifically. It’s somewhere in that ballpark.
Q: Okay. So a few being more than two and less than a hundred is now more than two and less than 15, is that right?
A: If that makes you happy, yes.
Q: I want to know what your answer is. I don’t want to be happy. I want to know your answer.
A: My answer is a few.
Q: Okay. The best of your recollection right now, speaking to me today, does a few mean more than two and less than 15? Can you be more specific than that?
A: No.

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