If the witness would have simply answered "yes," "no," or "I don't know" to my questions, we could have been finished in about 3 hours. Instead, she acted like this, and it took 6 hours:
* * * *
Me: While Mr. X worked for you, did Mr. X receive training in Y?
Witness: I have no personal knowledge of that.
Me: Do you have any kind of knowledge, other than personal knowledge, regarding whether Mr. X received training regarding Y?
Witness: No.
Me: So would it be fair to say that you do not know whether Mr. X received training in Y while he worked for you?
Witness: Well, I have no personal knowledge about that.
[Editor's note: her emphasis, not mine!]
Me: Is there some kind of knowledge other than personal knowledge that you do have regarding whether Mr. X received training in Y while he worked for you?
Witness: No.
Me: So then, if you have no personal knowledge and no other kind of knowledge, do you have any knowledge about it at all?
Witness: Well, I have no personal knowledge about it.
Me: When I asked you whether Mr. X received training in Y while he worked for you, is there some reason that you could not simply respond "I don't know" or "I don't have any knowledge about it"?
Witness: I'm just trying to make things clear.
Me: It would make things very clear if you could simply answer "yes," "no," or "I don't know" to my questions. Do you think you can do that, so that things will be more clear and so that we can finish this deposition in a reasonable amount of time?
Witness: OK.
[Editor's note -- she's already not complying...]
Me: Did Mr. X receive training in Y while he worked for you?
Witness: I have no personal knowledge about that.
* * * *
Holy crap.
Can you spell "I-N-T-E-N-T-I-O-N-A-L-L-Y O-B-T-U-S-E" ?
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