concurring.
I concur. The record demonstrates that the contact between Dr. Brungardt and the five-year-old child was actually for the physician to provide medical diagnosis and treatment, R.S. v. Knighton, 125 N.J. 79, 592 A.2d 1157 (1991), and not artificially arranged to create admissible hearsay evidence during investigative activities. The hearsay exception, W.R.E. 803(4), specifically allows statements relevant to diagnosis or treatment. Stephens v. State, 774 P.2d 60 (Wyo.1989); Annotation, Admissibility of Statements Made for Purposes of Medical Diagnosis or Treatment as Hearsay Exception Under Rule 803(4) of the Federal Rules of Evidence, 55 A.L.R.Fed. 689 (1981). The distinction between a treating or testifying physician cannot be entirely ignored. See Brown v. Com., 812 S.W.2d 502 (Ky.1991). Cf. Drumm v. Com., 783 S.W.2d 380 (Ky.1990). At the very least, we need to apply the “less inherent reliability” rule. Morgan v. Foretich, 846 F.2d 941, 952 (4th Cir.1988), Powell, A.J., concurring in part and dissenting in part; Drumm, 783 S.W.2d at 385.
However, I am far less comfortable with a further expansion of conviction by non-hearsay hearsay evidence which permits the additional testimony of the foster mother, the social worker, and then additionally the undersheriff. Realistically, their testimony was presented under W.R.E. 801(d)(1)(B) to bolster the testimony of the victim. This means the more people the victim can be arranged to talk to, the more evidence that can thereby be created. There should be a limit to this process. United States v. Mock, 640 F.2d 629 (5th *369Cir.1981). Similarly, see McGowan v. Cooper Industries, Inc., 863 F.2d 1266 (6th Cir.1988). We reach the stage described by 4 Wigmore, Evidence § 1124 (Chadboum rev.1972) (emphasis added):
When the witness has merely testified on direct examination, without any impeachment, proof of consistent statements is unnecessary and valueless. The witness is not helped by it; for, even if it is an improbable or untrustworthy story, it is not made more probable or more trustworthy by any number of repetitions of it.
The limitation governed by W.R.E. 403, “needless presentation of cumulative evidence,” should not disappear when recitation of what another witness has said is presented under the umbrella of W.R.E. 801(d)(1)(B). “Like most kinds of evidence, prior consistent statements offered under Rule 801(d)(1)(B) are excludable pursuant to Rule 403 where probative worth seems substantially outweighed by dangers of prejudice or confusion, or by considerations of avoiding delay or waste of time.” 4 D. Louisell & C. Mueller, Federal Evidence § 420 (1991 Supp.).
I concur in this decision because of the clarity of the victim’s testimony which was not realistically contradicted by any expressed or implied charge of recent fabrication or improper influence. The testimony of the sister-in-law and the doctor was likewise clear and convincing. Consequently, I agree with the majority that the additional testimony was, at worst, “merely cumulative.”