Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 1 of 86 1 1 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA 2 WEST PALM BEACH DIVISION CASE NO.: 9:20-cv-80945-DMM 3 4 STEPHEN BOVE, 5 Plaintiff, 6 vs. 7 XPO LOGISTICS EXPRESS, LLC., DEJAH XPRESS LLC, and KIMBERLY 8 SANDERS, 9 Defendants. __________________________________/ 10 11 DEPOSITION OF 12 LAURENCE S. LEVINE, PsyD. ABPP 13 Taken on behalf of the Plaintiff 14 15 16 DATE TAKEN: January 27, 2021 17 TIME: 1:03 p.m. - 3:03 p.m. PLACE: Via Zoom videoconference 18 19 20 21 22 Stenographically Reported by: 23 Lisa Gropper, R.P.R., F.P.R. Transcript Solutions, LLC 24 1555 Palm Beach Lakes Boulevard - Suite 1420 West Palm Beach, Florida 33401 25 (561)612-8700 Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 2 of 86 2 1 APPEARANCES VIA VIDEOCONFERENCE 2 3 ON BEHALF OF THE PLAINTIFF: 4 JASON GUARI, ESQ. MURRAY GUARI 5 TRIAL ATTORNEYS PL 1525 N. Flagler Drive 6 Suite 100 West Palm Beach, Florida 33401 7 jguari@murrayguari.com 8 ON BEHALF OF THE DEFENDANTS: 9 EDWARD R. NICKLAUS, ESQ. 10 EDWARD A. NICKLAUS, ESQ. NICKLAUS & ASSOCIATES, P.A. 11 4651 Ponce de Leon Boulevard Suite 200 12 Coral Gables, Florida 33146 edwardn@nicklauslaw.com 13 eddyn@nicklauslaw.com 14 ALSO PRESENT: Jessica Chavis 15 16 - - - 17 18 19 20 21 22 23 24 25 Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 3 of 86 3 1 INDEX 2 Witness Direct 3 Laurence S. Levine, PsyD. ABPP 4 (By Mr. Guari) 5 5 6 - - - 7 EXHIBITS 8 Plaintiff's Description Page 9 1 Notice of Taking Zoom Deposition 31 10 Duces Tecum 11 2 Dr. Levine's Invoice 22 12 3 Dr. Levine's Invoice for 22 deposition 13 4 Medical records 49 14 6 CNS Vital Signs Report 57 15 7 Dr. Friedman's report dated 61 16 11/12/20 17 9 Headquarters for Psychological 76 Evaluation Psychological Screening 18 Summary 19 16 Letter dated November 18, 2020 and 44 Memorandum of Retention 20 21 - - - 22 23 24 25 Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 4 of 86 4 1 THE STENOGRAPHER: The attorneys participating 2 in this deposition acknowledge that I, the 3 stenographer, am not present with the witness and 4 that I will be reporting the proceedings and 5 administering the oath remotely. This arrangement 6 is pursuant to the Supreme Court Administrative 7 Order No. AOSC20-16, and extended by AOSC20-32. 8 The parties and their counsel consent to this 9 arrangement and waive any objections to this manner 10 of reporting. 11 Counsel, please indicate your agreement by 12 stating your name and your agreement on the record, 13 beginning with the attorney for the plaintiff. 14 MR. GUARI: Jason Guari, yes, I consent to 15 this, and I represent the Plaintiff. 16 MR. NICKLAUS: Yes, this is Edward Nicklaus, 17 so agreed. 18 THE STENOGRAPHER: Doctor, would you raise 19 your right hand for me, please. 20 (Witness complies.) 21 THE STENOGRAPHER: Do you swear or affirm the 22 testimony you're about to give will be the truth, 23 the whole truth, and nothing but the truth? 24 THE WITNESS: Yes, I do. 25 MR. GUARI: Ms. Gropper, for the record, I Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 5 of 86 5 1 just wanted to let you know we have a law clerk, 2 law student here who's helping me with the Zoom. 3 So I want you to note her appearance as well. Her 4 name is Jessica Chavis. She's right over here. 5 She was the one that was helping us with 6 Dr. Garcia's deposition, because I'm not exactly 7 computer literate. 8 (Interruption by the stenographer.) 9 (Recess taken.) 10 DIRECT EXAMINATION 11 BY MR. GUARI: 12 Q Could you please state your full name. 13 A Are you referring to me, sir? 14 Q Yes. 15 A Yeah. Dr. Laurence Levine. 16 Q And what is it that you do for a living? 17 A I'm licensed as a psychologist by the State of 18 Florida and I practice in a specialty known as 19 neuropsychology. 20 Q What percentage of your practice do you find 21 that you're doing litigation-based work versus treating 22 patients? 23 A Well, for all intents and purposes at this 24 stage of my career, I made the decision to discontinue a 25 clinical practice beginning in February of 2020. So at Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 6 of 86 6 1 this point my work is principally what's referred to as 2 high stakes evaluation -- evaluations, and that would 3 include those involved in some type of legal question. 4 I also see pilots for the FAA and occasionally I'm 5 referred retired NFL players. 6 Q Okay. To treat them? 7 A No, sir. I have not done treatment since 8 probably the early 1990s. 9 Q So you haven't treated patients on a regular 10 basis since the 1990s? 11 A That's correct, yeah. My work is virtually 12 entirely neurodiagnostic in nature. 13 Q Would you agree that the majority of your work 14 is expert work regarding litigation cases, the high 15 majority of your work? 16 A No. 17 Q Why wouldn't you agree with that? 18 A I think I just mentioned to you that my work 19 is at this point both legal cases to one degree or 20 another - for example, occasionally capacity cases - but 21 I also see a large number of pilots for the FAA. 22 Q What percentage of your practice are you doing 23 legal cases versus pilots? 24 A I don't really keep formal records, but I 25 would probably estimate it's in the neighborhood of Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 7 of 86 7 1 40 percent medical-legal, 60 percent pilots, something 2 like that, or maybe a little closer to 50/50. 3 Q What is it that you're doing with pilots in 4 the aviation field within your specialty? 5 A Sure. The pilots that I see have been 6 referred to me typically by their aeromedical examiner. 7 Typically, they're part of what's called the HIMS 8 program, and these are pilots whose medical conditions 9 have triggered a concerning federal air regulation; for 10 example, somebody with a history of a substance use 11 disorder, somebody who has a history of having been 12 treated for a developmental disorder of attention, an 13 individual who's been treated for post-traumatic stress 14 disorder and so on. Anything that would trigger a 15 psychological or a neurocognitive concern on the part of 16 the FAA is somebody who might be referred to me. 17 Q These pilots, are they referred to you by the 18 FAA through the HIMS program? 19 A Typically, they come through their HIMS AME, 20 their aeromedical examiner. The cases in HIMS have to 21 be coordinated by the HIMS AME. So it's up to the HIMS 22 AME to make the determination as to where the pilot will 23 go for their evaluation. 24 Q And is the decision -- within your report, is 25 the crux of your decision whether or not the pilot is Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 8 of 86 8 1 eligible to fly or not fly? 2 A I think it comes down to whether or not the 3 pilot is demonstrating evidence of a neurocognitive or a 4 psychological or a personality problem that would render 5 him or her a potential flight safety risk, and then I 6 make a recommendation as to whether or not the pilot 7 should be considered for review by the FAA for medical 8 certification or not at this time and/or whether 9 additional evaluation might be required before that 10 determination can be made. 11 Q I don't know if I understand. Who actually 12 hires you to do these examinations then; what entity? 13 A The pilot, him or herself. 14 Q Okay. Is it through some type of Workers' 15 Compensation system? 16 A No, it's a -- 17 Go ahead, I'm sorry. 18 Q Go ahead. 19 A Okay. I was going to say that it's probably 20 best conceptualized as a fitness for duty evaluation, 21 and the financial burden is on the pilot, him or 22 herself. 23 Holding a -- 24 Q So -- 25 A I was just going to say holding an FAA medical Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 9 of 86 9 1 certificate is a privilege. It's not a right. And, 2 therefore, if the pilot wishes to pursue medical 3 certification, they are responsible for all costs 4 associated with pursuit of that medical certification. 5 Q These aviation-type exams of pilots, how many 6 of those a week or a month do you do? 7 A That's a little bit hard to say. Sometimes I 8 can see two and maybe even three in a week. Sometimes 9 it might be a couple of weeks before I'll see a pilot. 10 So it just all depends on whatever's going on. 11 Q On the yearly average, approximately how many 12 do you do per week, per year? Do you have any estimate 13 of that? 14 A I do not at this time, no. I'd probably have 15 to go back and count it all up to give you a reasonable 16 estimate. 17 I can tell you that the frequency of these 18 evaluations has increased probably in the last couple of 19 years and -- I'm just a little bit busier with those in 20 the last few years. 21 Q Okay. And how long have you been doing these 22 such aviation-type evaluations? 23 A Boy, I think I started doing these evaluations 24 probably back in the early to mid-1990s, and they were 25 very, very occasional back then, rare, two or three a Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 10 of 86 10 1 year, four a year, if -- if even that, and they were not 2 as extensive at that time. And as I say, I think the 3 frequency of these evaluations for me personally has 4 increased over the last two to three years. 5 Q Would you agree that you at least do these 6 types of evaluations regarding pilots at least once a 7 week now, nowadays? 8 A It all depends. I'm not seeing any pilots 9 this week and I think I have one next week. 10 Q And pilots pay you for this evaluation so that 11 way they could show their worthiness to potentially fly 12 to the FAA and/or to their employers? 13 A The -- let me see the best way to answer that 14 question or maybe to reframe the question. 15 As I said earlier, the pilot will have a 16 condition that triggers a concern on the part of the FAA 17 relative to safety for the operation of an aircraft. As 18 such, that condition is out there. I'm not doing a 19 clinical examination. That determination has already 20 been made by somebody else. The FAA will communicate to 21 the pilot that, if they wish to pursue medical 22 certification, the FAA will review their file, but as 23 part of that review they will need to undergo certain 24 types of examinations, in my case -- typically a 25 psychiatric, which would be done by a medical Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 11 of 86 11 1 professional, and a psychological or a neurocognitive or 2 neuropsychological evaluation. 3 So if -- if the pilot wishes to pursue that 4 medical certification, they will interact and coordinate 5 with their HIMS AME, for example, and the HIMS AME will 6 provide them my name. 7 In some cases, the pilot will get 8 correspondence from the FAA and locate me through the 9 list that the FAA provides or the HIMS organization 10 provides. 11 Q But that's not the answer to my question. I 12 want to know who pays you to do these examinations. 13 A I've already answered that. The pilot does, 14 sir. 15 Q You answered that you're retained by the 16 pilot, but I want to know who actually pays you, sir. 17 A The pilot pays me, sir. 18 Q Okay. And how long are these examinations? 19 How long do they take on average? 20 A It depends on the referral question. They can 21 take -- if it's a re-evaluation -- some pilots have to 22 come in every year for re-evaluation. That can take 23 maybe an hour. All the way up to a couple of half days 24 that might require eight to ten hours. 25 Q The type of evaluation that you did of our Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 12 of 86 12 1 client, Stephen Bove -- 2 Do you remember Stephen Bove? 3 A I do. 4 Q Okay. Did you videotape that evaluation or 5 no? 6 A I did not, no. 7 Q We're in federal court. Do you know if the -- 8 not you, but if anybody videotaped this evaluation of 9 Mr. Bove? 10 A I'm sorry, what, sir? 11 Q I just want to know if anyone videotaped -- 12 even though you didn't do it, did anyone videotape the 13 evaluation of Mr. Bove? 14 A There were no third parties present during the 15 course of the examination. If Mr. Bove himself 16 video-recorded the examination, I was not aware of it 17 and it would have been done without my knowledge. 18 Q What's the type of -- how do you categories 19 the type of evaluation that you did of Mr. Bove? 20 A It was a neuropsychological evaluation, 21 neurocognitive evaluation. 22 Q And in the 40 to 50 percent of the work that 23 you do professionally, approximately how many of these 24 types of examinations do you perform per week? 25 A Again, it just -- it just depends -- Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 13 of 86 13 1 Q What's so funny? It's a valid question. 2 A Are you done? 3 Q I don't understand -- I just want to know how 4 often you do these neuropsyche or neurocognitive 5 evaluations for people who are involved in litigation. 6 A Again, as I answered before, it just depends 7 on what the schedule is. I can go weeks without seeing 8 an individual in such an examination and occasionally 9 there might be two individuals that will need -- that 10 happen to be scheduled during a week. 11 Q Approximately how many do you do of these per 12 year, sir? 13 A Again, I don't have accurate numbers for that. 14 I -- pretty much the same response I gave to you 15 relative to the FAA evaluations. I'd have to go back 16 and count. But I'm not -- I'm not doing these on and on 17 and on during the month. They -- they come as they 18 come. 19 Q So you don't have any estimate as to averages 20 per month of these types of examinations that you did of 21 Mr. Bove on a monthly basis within the last year, two or 22 three? You don't have that? 23 A Well, this has been an unusual year, and then 24 in past years I was doing other things including 25 clinical work. So again my -- my schedule has really Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 14 of 86 14 1 been rather dynamic over the last three years and it's 2 changed a good bit. So no, I don't really have an 3 accurate answer and I would not want to mislead you. 4 Q Would you agree that you do at least one of 5 these neuropsychological evaluations per month? 6 A That's probably reasonable, at least one. 7 Q Would you agree that you at least do four per 8 month? 9 A No. I think that's probably overstating it. 10 Q Dr. Levine -- 11 Am I saying your name correct, or it's Levine 12 [pronouncing]? What is it? 13 A Levine works, thank you. 14 Q Dr. Levine, you used to treat patients a 15 little bit more in these types of cases, did you not? 16 A I'm sorry, could you repeat that, sir? 17 Q You used to treat patients in these types of 18 cases as an examining physician (inaudible) types of 19 cases? 20 A I didn't get the question, sir. You were 21 breaking up. 22 THE STENOGRAPHER: Yes. I didn't either. 23 BY MR. GUARI: 24 Q I think because I'm getting a call. 25 Okay. The type of evaluation that you did of Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 15 of 86 15 1 Mr. Bove, you would be a treating physician and did 2 plaintiff -- you testified on behalf of plaintiffs in 3 the past, have you not? 4 A I -- I have testified on behalf of plaintiffs 5 in the past, yes. I have done examinations at the 6 request of plaintiff's attorneys, that is correct. 7 Q Would you agree that over the years your 8 practice has pivoted to -- of the 40 to 50 percent of 9 your time doing this, these neuropsyche and 10 neurocognitive evaluations, that for a large majority 11 you are doing defense examinations; would you agree with 12 that? 13 A I didn't catch the last few words, Mr. Guari. 14 I'm sorry. 15 Q Would you agree that your practice has pivoted 16 over the last ten or so years where you're doing less 17 treating physician work and doing more defense 18 compulsory medical examination work? 19 A Okay. Well, that's a -- that's not an 20 agree-or-disagree question. 21 As I indicated before, any treatment I did, 22 that was way, way, way back in the very early 1990s, 23 late 1980s. 24 In the last ten years, I was working half time 25 at the West Palm Beach VA Medical Center, which I left Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 16 of 86 16 1 at the end of April in 2018. I retired from the VA 2 after years of service there. I continued in my private 3 practice doing clinical work, typically evaluations for 4 suspected dementia. 5 In the last several years, oh, I want to say 6 maybe 2017, '18 and on into '19, I saw roughly 55 or so 7 retired NFL players as part of the concussion 8 settlement, and I was doing medical-legal work and 9 starting to ramp up the FAA work as the referrals 10 started to come in for those types of evaluations. 11 In 2018, the number of FAA referrals started 12 to creep up. I left the VA at the beginning of -- of 13 May, started to do medical-legal work as available, when 14 it would come in from whomever would refer it, and that 15 continued through 2019. 16 And then in 2020 we had the Covid -- we have 17 the Covid situation, and I shut down my practice for 18 several months. 19 Q Okay. 20 A So it's -- it's been very dynamic I guess is 21 what I'm trying to say. 22 Q You testified early on in the first 24 minutes 23 of this questioning that about 40 or 50 percent of the 24 time you're doing these examinations like you did of 25 Mr. Bove. Over the last three years, what percentage Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 17 of 86 17 1 would you find yourself doing them for the defense or 2 doing them for a plaintiff in a personal injury lawsuit? 3 A Sure. I would have to say that probably no 4 more than five percent would be -- of those kinds of 5 evaluations would be seen on part of the plaintiff. 6 Most of my work is done on behalf of the defense in 7 which litigation is involved. 8 And again excluding cases, for example, of 9 capacity or those kinds of things. 10 Q And do you currently -- of that five percent 11 of your litigation-based work, do you currently see 12 patients who are plaintiffs in these types of cases and 13 are the treating physician or the treating doctor? 14 A I don't do treatment, Mr. Guari. I have not 15 done that as you know for decades. I don't see patients 16 per se. I see individuals who come in for -- for 17 examinations. I would refer to them as examinees. So 18 in that regard I'm not doing any clinical work. 19 Q When you do -- 20 A That was -- that was -- 21 Q I got it clear as day now. 22 When you do the five percent work on behalf of 23 plaintiffs, you're doing examinee work but you're hired 24 by the plaintiff in the case but you're not the treating 25 doctor. I get it. Is that correct? Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 18 of 86 18 1 A That's a reasonable way to frame it, yes, sir. 2 Q Now, how often do you do that in the last 3 three years? 4 A Again, relatively rarely. Relatively 5 infrequently, as I've mentioned. For those cases where 6 it's explicit that the individual has come in at the 7 behest of their attorney, you know, it's probably no 8 more than five percent. 9 And again not counting capacity cases. 10 Q In those five percent of the times that you do 11 examinations on behalf of plaintiffs, is the payment 12 arrangement different than when you do defense work, 13 i.e. letters of protection or you take forbearance 14 agreements or anything like that, or you need to get 15 paid upfront? 16 A The latter. 17 Q The latter, okay. 18 So did you ever in your career do treating 19 neuropsyche work where you were a treater and testified 20 on behalf of people who were involved in litigation that 21 were plaintiffs? 22 A Again, technically I guess from a legal 23 perspective I would be considered, quote/unquote, a 24 treating provider and the answer would be yes, but again 25 it would be for a neurocognitive assessment to assist in Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 19 of 86 19 1 the determination of their diagnosis. 2 Q Okay. As far as your time into this case, do 3 you have a bill for services for your time into the 4 case? 5 A I do, sir. 6 Q I'm going to share with you what's marked as 7 Plaintiff's Exhibit No. 2. 8 A Okay. 9 Q Is what I've marked Plaintiff's Exhibit No. 2 10 a fair and accurate copy of your current invoice for 11 time into this case, something we just received from 12 defense counsel? 13 A Yes, sir. 14 Q Okay. Do you have plans to do any other work 15 in this case or have you been asked to do any other work 16 in this case? 17 A I have. 18 Okay. So -- hold on one second. I'm going to 19 get rid of that bill. Let me see, make sure I can do 20 this. 21 Yeah, can you -- can you just eliminate that 22 bill? I'll agree that's what I've got, and then I'll -- 23 I'll respond to your question. 24 There you go. Perfect, thank you. 25 Let me see if I can -- if I lose you, I'll go Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 20 of 86 20 1 right back in. 2 Okay. So yeah, that was accurate through the 3 11th of January. On the 26th of January, I prepared 4 some of the documents for the subpoena for an additional 5 half hour, and I had a telephone call with Mr. Nicklaus 6 also yesterday to review the subpoena items to make sure 7 that I was being compliant, for an hour, and I probably 8 spent about an hour and a half this morning reviewing my 9 reports in this case and, you know, making sure 10 everything was where it needed to be. 11 So I'm probably looking at an additional three 12 hours subsequent to 11 January. 13 Q At how many hours per -- how many dollars per 14 hour? 15 A 350 an hour for the records review and all 16 non-testing services. 17 Q So that's approximately three times 350; is 18 that what you're saying? 19 A Yeah. That would be $1,050. 20 Q Has your January -- or your 3 January 2021 21 report been modified or amended or changed in any way, 22 shape or form, or added to? 23 A I would have to say today when I was looking 24 over the Word document, I changed a couple -- I took out 25 a couple of hyphens in there, just a couple of Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 21 of 86 21 1 punctuation marks. But the original report, the PDF, 2 has not been changed at all. That's the report you have 3 and that's the report on which I'll rely. 4 Q Were you born -- 5 A Only because I'm -- 6 Go ahead. 7 Q Were you born in the United States? 8 A Was I born in the United States? Yes, sir. 9 Q Yes. Okay. So you're a veteran? 10 A No. Why do you say that? 11 Q Okay. Well, I just -- I don't understand why 12 you put 3 January 2021 when we all say January 3, 2021. 13 I just didn't understand why you do that. 14 A Probably an affectation I picked up working 15 with my supervisor, you know, 35 years ago. 16 Q Okay. So what is your total bill for services 17 as of this date? 18 If we add the 8,850 for your time plus 1,050, 19 is your bill for services 1,050 plus 88 -- 20 A 9,900 is what I come up with. 21 Q Do you have any other documents to review? 22 A Do I, sir? 23 Q Yes. 24 A None of which I am aware. 25 Q Have you been asked to render any additional Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 22 of 86 22 1 opinions other than that is contained in your January 3, 2 2021 report? 3 A No, sir, not unless you ask me something. 4 I'll do my best to try to respond to you. 5 MR. GUARI: Okay. So Plaintiff's Exhibit 6 No. 2 I want to attach to the deposition 7 transcript. I showed you guys it. 8 (Plaintiff's Exhibit 2 was subsequently 9 received by the stenographer and marked for 10 identification.) 11 BY MR. GUARI: 12 Q You don't have an updated bill there? 13 A I can send that along, but it will -- 14 MR. NICKLAUS: Jason, I don't mean to 15 interrupt, excuse me, but I want to make sure that 16 you are aware that the doctor's added a bill for 17 the deposition today. I think it's -- 18 MR. GUARI: Yeah. I was going to -- 19 MR. NICKLAUS: -- for 1,500, and I know that 20 you were going to pay that, but we went ahead and 21 paid it, so you can just reimburse us for it. 22 That's okay. 23 MR. GUARI: Okay. So we're going to have that 24 marked Exhibit No. 3. 25 (Plaintiff's Exhibit 3 was subsequently Case 9:20-cv-80945-DMM Document 108-3 Entered on FLSD Docket 02/26/2021 Page 23 of 86 23 1 received by the stenographer and marked for 2 identification.) 3 BY MR. GUARI: 4 Q While we're looking at this, how often do you 5 find yourself deposed in cases? 6 A Fairly infrequently.