| name | deposition-objections |
| title | Deposition Objections |
| description | Provides deposition objection reference under FRCP 30(c)(2) covering form objections, substantive objections, instructions not to answer, and strategy for taking and defending depositions. Use when preparing for depositions, making or responding to objections during testimony, defending witnesses, handling 30(b)(6) corporate representative depositions, or drafting deposition-related motions. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/deposition-objections |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | litigation |
| language | en |
Deposition Objections
Quick reference for making, defending, and responding to deposition objections under the Federal Rules of Civil Procedure. Applies to federal practice; verify local rules for state court.
Prerequisites
- Identify deposition type: fact witness, expert, or 30(b)(6) corporate representative
- Review operative protective orders and court-ordered topic limitations
- Confirm applicable privileges and protected communications
- Have FRCP 30(c)(2) and 30(d)(3) ready for citation
Core Rules
- Most objections preserve, not block — witness answers; ruling comes at trial or on motion
- Concise and non-suggestive — FRCP 30(c)(2) requires objections "stated concisely in a nonargumentative and nonsuggestive manner"
- Form objections waive if not made — per FRCP 32(d)(3)
- Instructions not to answer — only 3 valid grounds under FRCP 30(c)(2)
Proper: "Objection, form." / "Objection, leading." / "Objection, assumes facts."
Improper (speaking): "Objection, the question is confusing and compound and assumes facts not in evidence."
Improper (coaching): "Objection, the witness already told you he doesn't remember that meeting."
Objection Reference Table
Form Objections (waived if not made at deposition)
| Objection | Phrasing |
|---|
| Compound | "Objection, compound." |
| Leading | "Objection, leading." |
| Assumes facts | "Objection, assumes facts." |
| Vague / Ambiguous | "Objection, vague." |
| Calls for speculation | "Objection, speculation." |
| Calls for narrative | "Objection, narrative." |
| Mischaracterizes testimony | "Objection, mischaracterizes the witness's testimony." |
| Argumentative | "Objection, argumentative." |
| Asked and answered | "Objection, asked and answered." |
