When can a witness deny that they have any memory of the event?

When a witness does not recall or remember an event, there is no "inconsistency" within the meaning of Evidence Code section 1235. (People v. Sam (1969) 71 Cal.2d 194, 210; People v. Price (1991) 1 Cal.4th 324, 413-414 [substantial evidence supported determination that witness was truthful when he testified he could not remember many facts about his relationship with the victim as the lack of memory was neither total nor suspiciously selective].) But, " '[w]hen a witness's claim of lack of memory amounts to deliberate evasion, inconsistency is implied.' " (People v. Ledesma (2006) 39 Cal.4th 641, 711.) A trial court is not required to expressly find inconsistency or evasiveness before overruling a hearsay objection; on appeal we will infer from the ruling that the trial court made the necessary implied factual findings. (Id. at p. 710.)