In People v. Adan (2000) 77 Cal.App.4th 390, Adan was examined by two doctors, Dr. Koegler and Dr. Strait. (Id. at p. 392.) Dr. Koegler testified that he believed Adan was exaggerating his symptoms; Dr. Strait testified that he believed Adan was malingering. (Id. at pp. 392-393.) The Court of Appeal held that such testimony did not run afoul of Penal Code section 29 because "testimony that Adan was a malingerer did not establish the required intent to defraud." (Id. at p. 393.)