Deposition objections?

Here's another great question from my defunct website.  When you're in the deposition room, you're going to hear objections.  Lots and lots of objections... Today's archive question comes from user GRUNDYALEX:


Deposition objections?

What objections are court reporters likely to hear during depositions?

After 2908 views and 4 responses, the Best Answer with 7 votes comes from GREGADELSON


In many states they want only Object to the form of the question.

In other states they state all of their objections on the record at the time of the deposition.  In court you are going to hear the full objections, so why don't we get to it.  Somewhere I have a listing of just about every objection you are likely to hear.  If I can locate my sheet, I am going to give them to you.  Most of them are one-strokers and once they are incorporated, you are going to think you died and went to heaven.  I am going to start off with some very basic stuff, so just go with it.

I will object - EU*-B

I object - EU-B

Overruled - OFERLD

Overrule - OFRL

Sustain - STAEN

Foundation - TPOUPBGS

No foundation - TPHOUNGS

Vague and ambiguous - SRAUEBS

Ambiguous - TKPWAOUS

Ambiguity - TKPWAOUT

Assumes faacts not in evidence - SUFS

Assuming facts not in evidence -SUFS/G

Assumes a fact not in evidence - SAUFS

Assumed a fact not in evidence - SAUFD

Leading and suggestive - HR*UG

Circumstantial evidence - SKEFD

Same objection - SAOBGS

Hearsay - HAERZ

You may answer - UPLS

You can answer -  UBGS

Nonresponsive - TPH-R

To answer - TAONS

Not to answer - TPHAOPBS

May answer - PHAEPBS

Instruct the witness - STREUPBS

I offer - IFR

I offer in evidence - IFRND

In evidence - TPHEFD

Move to - MAOFT

Strike out - STROUT

Strike the answer - STRAPBS

Irrelevant - EURT

Immaterial -EUPLT

For the purpose of - FORP

Calls for a conclusion - KAULS/K-K
Calling for a conclusion - KAULD/K-K

Self-serving - S-FG

Self-serving declaration - S-FGD

Declaration - TKHRAEUGS

To the effect - TOEFBGT

So marked - SPHARBGD

Motion granted - PHOG

Motion denied - PHOD

To the form - TOEFM

To the form of the question - TOEFM/KWE

To the form of your question - TOEFM/KWROURBG

To the form of that question - TOEFM/THABG

As to form - STOEFPL

Instruct the witness - SWEUT

Not to answer - TPHOPBS

Instruct him not to answer - STREUPL/TPHOPBS

Instruct her not to answer - STRER/TPHOPBS

Direct him not to answer - TKREUM/TPHOPBS

Direct her not to answer - TKRER/TPHOPBS

I am going to object - EUPL/GOEB

I am going to object to the question - EUPL/GOEB/KWE

Not calculated to lead to - KHRAEUTD/KHRAEUTD

Discoverable evidence - TKFRBLD

Strike that - STREU*P

Don't answer - TKAOPBS

And I object - SKPEUB

Inconsistent - TPHEUBGT

Inconsistency TPHEUBGTS

I object to the form - PWOEURPL

Object to the form - PWORM

Of the question - TPEBG

Of this question - TPEUBG

Of that question - TPABG

Attorney-client privilege - TAOEUJ

Attorney-client - TAOEUPBT

Admissible evidence - MEUBLD

Work product - WRUBGT

Conjecture - K-JT

Assumption - SUPLGS

Fair and impartial - TPAEURP

Standard of care - ST-FBG

(and so forth - SKPOFRT)


Work these into your system a little at a time.  If you guys would like

I will list ortho terms and straighten out once and for all how to write

fast medical.  I know you have probably thought about it, but once that

miserable medical is over, it is out of mind.  Well, let's fix it once and for






Oh, we hear them all!

Object:   Objection.  Assumes facts not in evidence.  Assumes facts.  Misstates the witness's testimony.  Misstates the witness.  Misstates prior testimony.  Vague.  Vague and ambiguous.  Ambiguous.  Calls for legal conclusion.   Calls for expert opinion.  Beyond the scope of the witness's expertise.   Beyond the scope of the examination. 

Not reasonably calculated to lead to the discovery of admissible evidence.  Object to the form.   Object to the form of the question.   The question is vague.   Calls for speculation.  Lack of foundation or lacks foundation.  No foundation.

Asked and answered.   Asked mulitple times.   Harassing.  Unintelligible.   Compound.   Argumentative.   Arguing with the witness.    Attorney-client privilege.   Work product.  Privacy.   Invasion of privacy.   Marital privilege.

There's more, but I can't think of them right now.

You'll want to get as many one-stroke briefs for these as you can, and then they become fun!


More often than not, when you're attending a deposition, the attorneys will have agreed beforehand that the only objections that are raised will be with response to the form of the question and not to the types of questions that are asked. In other words, while you're in a trial, there may objections to the witness' ability to comment on something; you're unlikely to hear these during a deposition.

The objections that you'll hear in a deposition are going to be related to the way that a question is asked. Most of the objections that you'll hear will be because the questions are leading the witness - aimed at bringing an answer that the attorney asking them wants the witness to give. Additionally, there may be objections to argumentative questions - cases where the attorney asking the question seems to be picking a fight with the person giving testimony - as well as to compound questions in which it seems like the attorney is asking more than one question at the same time. Ambiguous questions that don't seem to actually have an answer and questions based on facts that haven't yet been determined also can lead to objections from opposing counsel. The other objections that you hear will be when one of the attorneys seems to mischaracterize what the witness had already said - when the words of the witness are twisted in an effort to make a point. 


Wow! You do hear them all! Thanks so much for the *instruct the witness* brief.. You don't know how long I've waited for a brief for that phrase. Awesome!

Good idea on the ortho terms, Gregorio, thanks! I'm going to post a question regarding medical briefs and I would love to see your list as well as hear your advice about writing fast medical deps.

Todd, I will start working on that sometime this weekend. We will also talk about briefing on the fly.


Monday, June 2, 2014

Todd Olivas

Todd Olivas is a court reporter and entrepreneur.
He founded TO&A in 2003.

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