“she will not recall a lot of things...”
She has such a bad memory...like it’s been wiped with a rag.
See Federal Rule of Civil Procedure (d)(1) at link above:
(d) Duration; Sanction; Motion to Terminate or Limit.
(1) Duration. Unless otherwise stipulated or ordered by the court, a deposition is limited to 1 day of 7 hours. The court must allow additional time consistent with Rule 26(b)(1) and (2) if needed to fairly examine the deponent or if the deponent, another person, or any other circumstance impedes or delays the examination.(p) She will profess to have little or no recollection, and it will take so much time to try to refresh her recollection with documents, that it is likely nothing will come of this, unless the deposition time is extended significantly.