By Hon. Robert J. Trentacosta

Objections to the Form of Questions

• Ambiguous or unintelligible
• Argumentative
• Asked and Answered
• Assumes facts not in evidence
• Calls for a narrative
• Calls for speculation or conjecture
• Compound
• Leading

Objections to Proffered Evidence

• Cross-examination exceeds the scope of direct examination
• Cumulative
• Calls for an inadmissible lay opinion
• Hearsay
• Improper Impeachment
• Improper Rehabilitation
• Irrelevant
• Lack of personal knowledge of witness
• Lack of Foundation
• Question calls for information that is privileged

Motions to Strike

• Answer is non-responsive to the question
• Answer violates court’s previous in limine rulings.