California trial objections cheat sheet

Irrelevant to the Subject matter: C. Calls for Narration or Lengthy Explanation. Calls for Speculation or Conjecture. Leading if not an adverse witness. Vague and Ambiguous: Deyo v. Kilbourne 84 CA 3d pdf. Answer is known to propounding party: Alpine Mut. Water Co. Argumentative: C. Asked and answered: Coy v. Assumes facts not in evidence: West Pico Furniture v.

Calls for conclusion: C. Insufficient foundation: C. Irrelevant to the issues : C. Calls for a narrative: C. Calls for an opinion: C. TRIAL Discovery Closes with the exclusion of expert lists, and expert depositions — 30 days before trial, or after non-binding arbitration. Experts Must Be Demanded — 70 days before trial or within 10 days of setting trial date, whichever is closer to trial date. Experts Must Be Disclosed — 50 days before trial or 20 days after service of demand, whichever is closer to trial date.

Notice to Appear at Trial to party [No documents] — 10 days before trial, send notice with time and place to attorney. Notice to Appear at Trial to party [With documents] — 20 days before trial, send notice with time and place to attorney. Opposition to noticed motion — must be filed and served 9 court days before hearing.

Reply to noticed motion — 5 court days before hearing. Ex Parte Motion — Opposing party must be notified by A. Note: This is a minimum. Check local rules for more strict notice periods. Opposition is 14 days before the hearing [ CCP c b 2 ]. Reply is 5 days before hearing. How To. Objections to Evidence: California. Misstates the Testimony , Cal. Incomplete , Cal.

Where part of a declaration, deposition, or writing is entered into evidence, another party may enter its entirety in evidence to make it understood. Inadmissible Speculation and Conclusions , Cal. Attorney v. Civil Serv. Comm'n of County of Los Angeles , 55 Cal. First Am. Registry , Inc. Inadmissible Hearsay , Cal. The alleged statements are out of court statements sought to be used for the truth of the matter asserted.

Irrelevant and Prejudicial , Cal. Improper Legal Conclusion. Hayman v. Block, Cal. Improper Expert Testimony or improper opinion evidence that does not lay a foundation as to the individual's special knowledge, skill, experience, training, and education or a statement of the basis of the opinion , Cal.

County of Los Angeles , Cal. Lund , 18 Cal. Lack of Authentication , Cal. The documents are not authenticated, or have not been produced in discovery.