Deposition Objections

by Joseph A. Ranney

Solving deposition problems

• Verbal and non-verbal coaching of the witness

• Colloquies and stipulations among counsel

• Instructing the witness not to answer

• Disruptive or inappropriate objections

• Production of privileged or confidential documents

   Perhaps because depositions are as close to a trial as many cases will get, deposition disputes have grown more heated and difficult to resolve. 

   Here is a portable and affordable volume that provides practical guidance for resolving many of the more contentious disputes.  Joseph A. Ranney’s Deposition Objections offers help with these issues and objections:

Procedural issues

• 13 examples of when it is and when it is not appropriate to ask the court for a supervisory ruling.  §15:03

• When to instead adjourn and move for a protective order.  §15:04

• How to lay the groundwork for a supervisory ruling.  §15:05

• When is it okay to instruct a witness not to answer?  §16:01 et seq

• Techniques for stopping bad attorney behavior at depositions.  §16:03

• Checklist of steps to take before adjourning a deposition.  Form 16-2

• When are you on safe ground when making a speaking objection?  §17:27

• Guidelines for responding to a speaking objection.  §17:40

• Sample language for putting stipulations on the record.  Form 18-2

Grounds for objecting

• The limits of the attorney-client privilege, §4:01-05, with checklist of when it does and does not apply, Form 4-1

• What are the limits of work-product immunity? §§5:01-04

• How to resolve work-product disputes during a deposition.  §5:25

• Issues in formulating protective orders and common solutions.  §6:10

• Quick-reference chart showing the confines of professional privilege.  Form 9-1

• What is the scope of the privacy privilege?  §§10:01-03

• Making the balancing calculation in legal process privilege objections, with examples, §11:44.  Summary checklist, Form 11-1

• The 5 situations when a relevance objection is proper.  §12:02

• Methods for resolving relevance disputes.  §§12:20-21

• Handling attorneys and witnesses who play the dictionary game.  §13:05

• How many times should you allow a question to be asked?  §13:11

• Preparing witnesses for loaded questions.  §13:23

• Should you instruct the witness not to answer a legal theory disclosure question?  §14:11

• Are evidence identification questions allowed?  What to consider when making the judgment call.  §§14:30-31

• The line between permissible and impermissible position disclosure questions.  §14:40

Updated annually. ISBN _________________. Book Price: $69

Related Titles:

How to Prepare for, Take and Use a Deposition

Deposition Checklists and Strategies

Guerilla Discovery

Handling Federal Discovery

Model Interrogatories

Triple-Threat Discovery Forms

Deposing & Examining Doctors

Exposing Deceptive Defense Doctors