Speaking Objection

Speaking Objection

Speaking Objection

Speaking objections go beyond a concise statement of the ground, adding explanation, argument, or factual commentary that signals how the witness should respond. Rule 30(c)(2) requires objections to be concise and non-argumentative.

They are a recognized form of witness coaching.

Alternative Names:

Coaching Objection, Suggestive Objection

Why it Matters?

These objections are the most common deposition misconduct and the easiest to document, since the transcript records exactly what was said. Building a record of the pattern, with page and line citations, supports a motion for sanctions and additional deposition time. Where the practice is persistent, suspending the deposition and calling the court is more effective than continuing while accumulating objections.

Frequently asked questions

Why are speaking objections effective coaching?

Why are speaking objections effective coaching?

Because they signal to the witness how to answer while appearing as a legitimate objection on the record.

How should they be addressed?

How should they be addressed?

By documenting the pattern with page and line citations for a sanctions motion, or by suspending and calling the court if persistent.