the descriptions were provided by a mysterious individual who shall remain nameless.
All important details such as names and locations have been deleted.
Plaintiff appeared for her deposition in a pink sweater and black pants. She has shoulder length straight brown hair, brown eyes, and wears glasses. She is short and very thin. She appears very young. Although she was somewhat pleasant, she has an apparent edge to her. In addition, a good deal of her testimony contradicted the medical records. She will likely make a fair to good witness, although the infant is likely to draw sympathy from a jury.
Dr. ______ is the attending physician who oversaw the care of the co-defendant Certified Nurse Midwife (CNM) __________ at _________ during the labor and delivery of the infant plaintiff on April 11 and 12, 2005. Dr. _______ is an attractive Caucasian woman, appearing to be in her early 40s. She appeared for her deposition casually dressed, in black pants and a long sweatshirt cardigan with very little makeup. She did not appear nervous, but instead almost annoyed to be there. She made it known that she flew in from Florida for the deposition the night before and had a plane to catch that afternoon. She testified mostly from the hospital chart from ___________, although she testified that she had some independent recollection of the events. At times she appeared as an intelligent witness and took her time to look through the chart before answering questions. However, at certain questions posed, Dr. _______ took long pauses and made sarcastic gestures. Dr. ________ would make an average to good witness as she was intelligent but had an attitude.
The plaintiff, ____, is a 54 year-old overweight female of Puerto Rican descent, who appeared for her deposition casually dressed
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