Objection Briefs

[Kelli Combs (admin)]

If anyone has any objection briefs to add, please do.

I do "incomplete hypothetical" as HOIP.
"Calls for speculation" as KAUPZ
"Calls for a legal conclusion" as KAULZ
"Beyond the scope" as BOEP
"Assumes facts not in evidence" as SMAZ
"Lack of foundation" as LOEF
"Lacks foundation" as LOEX
"Object to form" as BOERM

Anyone else have any to add?

[Debera Anne Doran]

Not calculated to lead to discoverable evidence = N-KD

[Jennifer Milne]

I LOVE THIS BRIEF.  For some reason, my brain and my hands just can't communicate when this phrase comes up.  Thanks for sharing.

[Laura Mellini]

I like that.  I'm going to use it.  But I think I usually hear the one "not calculated to lead to the discovery of admissible evidence"?  Maybe NAKD?  

[Gigi Cassis]

These are great. Thanks everyone. Please keep them coming.

[Keith Rowan II]

Here's the list I have compiled:

I object IB
I'm going to object AOIBT
to object TOB*
objection, Your Honor OURN

assumes facts not in evidence SAOUVD
assumes a fact not in evidence SAVD
beyond the scope YOEP
not within the issue NOIRB
not within the issues NOIRBZ

calls for a conclusion KLAOUX (* makes calling)
calls for a legal conclusion KLAOULX (KLAOUBLGS)
calls for speculation KLAEX (* for calling)
speculation SPEX

no foundation NOUNGS
no proper foundation laid NOPD (* adds has been)
lack of foundation LAFX or LAFNGS
without foundation WOUNGS
lack of LAFK

relevance REVLS
relevancy RAEVLS
vague and ambiguous VAIB
ambiguous GAOUS
ambiguity GAOUT

any objection NAOX
same objection SAOX or SAIX
standing objection STOX

upon the PONT
upon the ground POEG
on the ground OEGD
upon the issues thus joined POIJ
upon them POFM
upon which POFP

Objection overruled JAOULD
Objection sustained JAEND
overruled VAOULD
sustained STAEND
the objection is overruled THAOULD
the objection is sustained THAEND


form of the question FOFK
object to the form of the question JORK
object to the form JORM
to the form TOFRM
as to the form STOFRM

motion to strike MOEGS*
that answer THANS
from the record FR-MD

THE COURT: Sustained .......Court stroke plus AE
THE COURT: Overruled .......Court stroke plus OE

[Sharla Preciado]

Wow, Keith. I'm impressed.

[Keith Rowan II]

Thanks!

[Stacy Tegner]

Okay, I'm editing a horrendous objection-filled depo and thought I'd share some new ones I came up with on the fly at the depo. I already brief almost all the objections, but this atty was so fast, that I had to incorporate even more:

OBS ~ Objection. Vague and ambiguous.
OFBGS ~ Objection. Calls for speculation.
VAEUBT ~ Vague and ambiguous as to time. (I already do VAEUBS for vague and ambiguous.)

Never heard these two before, but the atty loved them:
Impermissible form of a leading question ~ PERD
Impermissible form of a leading question without proper foundation ~ PERTD

I think there were others, but that's what I'm running across now and thought I'd share ~ plus, I like to procastinate working on this one ~ it gives me a headache ~ and it's an expedite, of course!

[Cathryn Bauer]

document speaks for itself = DOEUKS

 

vague and ambiguous = S-RAMS

 

incomplete hypothetical = PHREUP

 

calls for speculation = KAUPS

 

not calculated to lead to the discovery of admissible evidence = NUKS/NUKS

[Naola "Sam" Vaughn]

Object to the form of the question = OERMGS

Object to the form = OERM

Object to form = ORM

Objection, form = O*J

Calls for speculation = KAILGS

Calling for speculation = KAILG

Incomplete hypothetical = NOIP

Calls for a legal conclusion = KELGS

Calling for a legal conclusion = KELG

lack of foundation = LOFX

lacks foundation = LA*X

vague and ambiguous = VO*US

 

 

[Mya Temple]

object - OBT

object to form - BOERM

object to form of the question - JORK

object to the form - BO*ERM

object to the form of the question - BO*ERMGS

objected - OBTD

objection - O*BGS

objection overruled - JAOULD

objection sustained - JAIND

objection, Your Honor - OURN

[kathy - iamwrdsmth]

I use initial SKW- for the word objection, then add the ending 

and add HR for the "calls for"

SKWAUPB/ objection. Compound

SKWAUPL/ Objection. Expert testimony

SKW-PBGS/ objection. Foundation

SKWOPBGS/ objection. No foundation

SKWAPBGS/ Objection. Lack of foundation

SKW-PBGZ/ Objection. Lacks foundation

SKWAOEG/ objection. Leading

SKWAUG/ Objection. Leading and suggestive

SKW-PH-FTS/ objection. Misstates

SKW-PLDZ/ objection. Misstates the evidence

SKW-PLTS/ objection. Misstates the testimony

SKW-OEBGT/ objection. Motion to strike

SKW-OFBGT/ objection. Move to strike

SKWAEURT/ Objection. Narrative

SKWEPBG/ objection. No question pending

SKWAOEFLS/ Objection. Document speaks for itself
SKWOEPT/ OBJECTION. Outside the scope

SKWOUP/ Objection. Outside the scope

SKW-FRB/ Objection. Overbroad
SKWOEFRB/ Objection. Overbroad

SKW-LS/ objection. Relevance 

SKW-LZ/ objection. Relevancy

SKWEBGS/ objection. Speculation

SKWAEF/ objection. Speculative

SKW-BS/ objection. Vague and ambiguous

SKWAEUGT/ objection. Vague as to time

SKWOPBS/ objection. Nonresponsive

SKWAOUPLDZ/ objection. Assumes facts not in evidence

SKHRAUGS/ objection. Calls for a legal conclusion

SKWHRAERS/ objection. Calls for hearsay

SKWHRAEBGS/ objection. Calls for speculation