| name | deposition-objection-reference |
| title | Deposition Objection Reference |
| description | Provides a quick reference for deposition objections under FRCP 30(c)(2), including form objections, substantive objections, waiver rules, and the three exclusive grounds for instructing a witness not to answer. Use when preparing for depositions, assisting during live depositions, conducting witness prep, or analyzing deposition transcripts for objection issues. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/deposition-objection-reference |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
Deposition Objection Reference
Quick reference for making and preserving objections under FRCP 30(c)(2). Covers form objections (waived if not raised), substantive objections (preserved for trial), and the three exclusive grounds for instructing a witness not to answer.
Fundamental Rules
- Witness still answers — most objections preserve the record only; witness answers unless instructed not to
- Concise and non-suggestive — FRCP 30(c)(2) requires objections "stated concisely in a nonargumentative and nonsuggestive manner"
- Form objections waive — must be made at the deposition or lost (FRCP 32(d)(3))
- Instructions not to answer — only 3 valid grounds exist under FRCP 30(c)(2)
Proper: "Objection, leading." / "Objection, assumes facts."
Improper: "Objection, that question is confusing and compound and assumes facts..." (speaking objection)
Improper: "Objection — the witness already told you he doesn't remember that." (coaching)
Form Objections (Waived If Not Made)
| Objection | Trigger | Phrasing |
|---|
| Compound | Two+ questions in one | "Objection, compound." |
| Leading | Suggests the answer (mainly when defending own witness) | "Objection, leading." |
| Assumes facts | Presupposes unestablished fact | "Objection, assumes facts." |
| Vague | Unclear referent or undefined term | "Objection, vague." |
| Unintelligible | Question doesn't parse | "Objection, unintelligible." |
| Speculation | Asks witness to guess | "Objection, speculation." |
| Narrative | Overly broad; use sparingly | "Objection, narrative." |
| Mischaracterizes | Inaccurately summarizes testimony or document | "Objection, mischaracterizes testimony." |
| Argumentative | Debates rather than seeks facts | "Objection, argumentative." |
