by R. Rogge Dunn and Karen Hirschman

Admit Your Evidence and Exclude or Minimize Theirs

Most evidentiary rulings are within the judge’s discretion, and are made in seconds. Bad rulings are rarely reversible. As a result, you need to bring all your admissibility ammunition to bear at the moment of objection. Rogge Dunn and Karen Hirschman’s Trial Objections increases your firepower with pattern objection language, explanatory comments, tactics for exclusion, arguments for admission, foundational elements, supporting authority, and practice tips for:

Voir dire
Opening statements
Documentary evidence
Demonstrative evidence
Hearsay evidence
Attorney misconduct
Examination of witnesses
Privileges
Closing arguments
And much more...

Trial Objections explains when and how to make and meet objections more successfully. This quick-reference book covers the full range of objections, complete with more than 100 pattern objections, tactics, forms, suggested responses, necessary foundations, and hundreds of state and federal cases. It also includes a handy quick reference guide.

Each objection is organized by headings to help you quickly find the information you need.

Tactics
Use these arguments to fight admission of the opposition’s evidence, or to minimize its impact. Included are alternative strategies and what you need to put on the record.
Response
Never let an unforeseen objection catch you flat-footed again. Anticipate, preclude and meet objections with the author’s expert strategies for counter-attack.
Foundation
Bulleted steps for laying foundations. Frequently included are model questions for trouble-free admission. Use these lists to look for omissions when opposing foundations.
Pattern Objections
Model language for over 110 objections. Use the language provided... or tailor it to fit your situation. Big headings and logical organization take you to the right objection in seconds.
Comments
Authors Rogge Dunn and Karen Hirschman explain the application, scope, and purpose of the governing rules. He also offers practical advice based on his decades in the courtroom to help you anticipate possible problems.
Practice Tips
Elevate your advocacy with the cautions, strategies, and effect of related rules provided here.
Foundation
Organized by jurisdiction, these federal and state authorities speed trial preparation and help you cite supporting law in the courtroom.

Trial Objections has trial-tested pattern language that gives you a concise statement of almost every objection you might need in court and includes foundation checklists, tactics and the latest cases, which you’ll need for successfully making and defending objections. With this annually-updated, briefcase-sized book, you’ll be prepared for court. Trial Objections brings you:

Index of Objections. A quick-reference to any objection. Simply find the relevant subject area and flip to that section for the objection, case or tactics you need to master the moment.
An overview of objections in general (§§100-144). This part of the book covers making and timing your motions in limine, making effective motions to strike, curative and limiting instructions complete with samples, and demanding offers of proof.
Objections during the preliminary stages of trial (§§200-281). This section includes pattern language, tips, tactics and cases for the many possible objections you might need to make during jury selection and opening statement.
A thorough, detailed section on objections to demonstrative, documentary and hearsay evidence (§§300-365). This material covers all aspects of demonstrative and documentary evidence, and provides you with a wealth of detail on hearsay evidence, hearsay within hearsay, and non-hearsay evidence.
Objections to witnesses (§§400-455). This section is filled with methods, foundations, and all you’ll need for making and meeting objections based on witness competence. Also included are all the objections you’ll make while opposing counsel is examining the witness. The book goes on to cover objections used to attack the qualifications of an expert witness, use of the expert and/or his testimony. Next, you’ll find complete coverage of protecting and objecting to privileged evidence.
Attorney and Judicial Misconduct are covered in §§500-514, Summation and Closing Argument in §600, and Indexes are at the back of the book.
Forms, explanation, and CD-ROM. This section of the book describes the forms included on the enclosed disc and their uses. The forms include motions in limine, jury questionnaires and other pleadings for use at the pre-trial hearing, on the eve of trial and during trial.

Trial Objections is designed to be used when you’re working on a case that goes to trial. Slip it into your briefcase—it weighs less than two pounds and measures only 9x6 inches—and see whether it bolsters your courtroom abilities. You’ll feel better prepared, and more able to defend your position with the tactics, key cases and foundations that support your point.

The book now features all of the forms on an easy-to-use forms disk—over 30 forms in all.

Updated annually. ISBN 0-58012-018-0 Book price: $99.00

Reviews

"The format in which the authors present the information is the most attractive attribute of the book. Each broad category of evidence addressed, such as "demonstrative evidence," contains specific, bold-faced objections for use as to specific items in that category, such as "charts, diagrams, graphs, or maps." Brief, identifiable sections on substantive commentary, tactics, responses, evidentiary foundations and case annotations follow each objection. The color-coded tabbing in the book makes each category easy to locate and the tables of contents for the chapters within each category provide easy access to the specific objections."

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