Deposition Objections
by Joseph A. Ranney
Solving deposition problems
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Verbal and non-verbal coaching of the witness
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Colloquies and stipulations among counsel
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Instructing the witness not to answer
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Disruptive or inappropriate objections
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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
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13 examples of when it is and when it is not appropriate to ask the court for a supervisory ruling. §15:03
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When to instead adjourn and move for a protective order. §15:04
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How to lay the groundwork for a supervisory ruling. §15:05
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When is it okay to instruct a witness not to answer? §16:01 et seq
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Techniques for stopping bad attorney behavior at depositions. §16:03
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Checklist of steps to take before adjourning a deposition. Form 16-2
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When are you on safe ground when making a speaking objection? §17:27
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Guidelines for responding to a speaking objection. §17:40
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Sample language for putting stipulations on the record. Form 18-2
Grounds for objecting
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The limits of the attorney-client privilege, §4:01-05, with checklist of when it does and does not apply, Form 4-1
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What are the limits of work-product immunity? §§5:01-04
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How to resolve work-product disputes during a deposition. §5:25
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Issues in formulating protective orders and common solutions. §6:10
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Quick-reference chart showing the confines of professional privilege. Form 9-1
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What is the scope of the privacy privilege? §§10:01-03
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Making the balancing calculation in legal process privilege objections, with examples, §11:44. Summary checklist, Form 11-1
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The 5 situations when a relevance objection is proper. §12:02
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Methods for resolving relevance disputes. §§12:20-21
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Handling attorneys and witnesses who play the dictionary game. §13:05
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How many times should you allow a question to be asked? §13:11
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Preparing witnesses for loaded questions. §13:23
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Should you instruct the witness not to answer a legal theory disclosure question? §14:11
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Are evidence identification questions allowed? What to consider when making the judgment call. §§14:30-31
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The line between permissible and impermissible position disclosure questions. §14:40
Updated annually. ISBN _________________. Book Price: $69
B6
Reviews
"Deposition Objections is unique because of its practical and extremely useful checklists and guides and its CD-ROM of forms.
Attorneys use this book because it saves time and provides checklists and practice tips that offer ways to handle difficult situations.
"
— Kevin Miles, AALL Spectrum
Related Titles:
How to Prepare for, Take
and Use a Deposition
Deposition Checklists and
Strategies
Exposing Deceptive Defense Doctors
