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There are only a couple dozen common evidence objections that are likely to be

used in most trials. Every experienced civil trial lawyer hears them over and over.

There are a number of other objections that can be made. Some evidence texts give

lists of 1! or more. "ut for all practical purposes# there are only the basic two

dozen that you need to remember with un$uali%ed certainty and sure familiarity. &ut

a copy of this '(orm) *bjections +hecklist, in your trial notebook behind Tab 1-#'aw.,

WARNING. /ost objections are not allowed to be made during depositions. (or the

much shorter list of valid or invalid objections during depositions refer to the

discussion in 0!.2 of this book.

(ollowing this alphabetical listing is a short discussion# in order# of each of the

objections# in the format of 314 a form statement of the individual objection# 354 a

short discussion for $uick reference# and then 324 a form response to the objection.

The Basic Two Dozen: Quick alphabetical list for reference anrefresh!ent.

1. 6dmitted.

5. 6rgumentative.

2. 6ssumes facts not in evidence.

. "est evidence rule.

. "eyond the scope of direct 7 cross 7 redirect examination.

-. +ompleteness.

8. +ompound $uestion 7 double $uestion.

9. +onfusing 7 vague 7 ambiguous.

:. +ounsel is testifying.

1!.(orm.

11.(oundation.

15.;earsay3rules 9!1# 9!5# 9!2 and 9!4.

12.

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18./isstates evidence 7 mis$uotes witness 7 improper characterization of

evidence.

19.=arrative.

1:.*pinion3rules 8!1 and 8!54.

5!.&retrial ruling.

51.&rivileged communication.

55.&ublic policy.

52.>ule !23undue waste of time or undue prejudice7immaterial7irrelevant7

repetitive 7 asked and answered 7 cumulative 7 surprise4.

5.Speculative.

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