From JL: Defending a deposition pro se


Basic objections

  1.  Hearsay or calls for hearsay.  As soon as you hear the words “conversation”, “he said”, “she said”, think about a hearsay objection.  All you have to say is “objection, hearsay.”  you really don’t have to explain.  Hearsay is defined as an “out of court statement to prove the truth of the matter asserted.  There are many exceptions to hearsay, including “excited utterance”, you’re introducing it for other purposes, etc.
  2. Irrelevant.  If the issue has nothing really to do with your case, just say “objection, irrelevant.”  Generally matters and documents which arose more than 2 years to anything alleged in the complaint is irrelevant.  The standard is whether the information is directly relevant to your case and therefore admissible evidence or it may lead to the discovery of admissible evidence.
  3. Calls for speculation.  “Objection, calls for speculation.”  Some examples, if you are asked about how your kid felt about something.  You don’t know how someone else feels.  You don’t know what someone else is thinking.
  4. Vague.  If you really don’t understand the question, say “objection, vague” and ask the attorney or whomever to rephrase the question so you understand it.  Never answer a question you don’t understand.  You can even repeat it and make it clearer, but try to avoid that.  Make the questioner do his or her work.
  5. Compound.  “Objection compound question.”  The questioner is only allowed to ask you about one question or thing at a time.  For example,”  when did you go to your mother’s home and where did you find the lamp and was it broken then”.  This is too much and should be broken up into 3 separate questions.
  6. Calls for a legal conclusion.  These are kind of fun.  You might want to answer them anyway, but start with “calls for a legal conclusion and I am not a lawyer.”  then you can say “of course, I’m not liable” or whatever your excuse was for breaking a law or your belief it does not apply to you.

You should be following the Illinois Rules of Evidence and read those provisions carefully before your deposition

You can find the Illinois Rules of Evidence here:

Click to access C6311_Illinois_Rules_of_Evidence_Color-Coded_Guide.pdf

you might try the above book from the Daley Center Law Library

There are also many good youtube videos on how to defend a deposition and I will post some here.

Good luck to all of you who cannot afford an atty.


basic video on you tube about defending a deposition (short), 3 min

another youtube on deposition objections

this is better and more specific.  note the types of objections you can make

2 thoughts on “From JL: Defending a deposition pro se

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