Episode 19 - Lessons from the Front Lines: 922 Deposition Objections. (Then Sanctions Happened.)

Episode #19

In a November 30, 2020 Memorandum Order, a federal judge imposed sanctions against a lawyer for alleged excessive and improper objections during depositions. According to the Order, the defense attorney was accused of making 565 objections in one deposition, 187 in another, and 170 in a third, for a total of 922 in just those three. In this episode, Jim Garrity discusses the case and shares his thoughts about how many speaking or coaching objections you should tolerate before taking steps to talk it. (Hint: He says less than five.)


This episode is based on the Memorandum Order in Animal Legal Defense Fund v. Kimberly Ann Lucas, d/b/a Farmers Inn, 2020 WL 7027609, Case No. 2:19-cv-00040-PLD (W. D. Penn. Nov. 30, 2020).


The Memorandum Order is PACER docket number 141.


The Plaintiff's Motion for Sanctions is PACER docket number 109. Its Memorandum of Law in Support of the Motion for Sanctions is PACER docket number 110.


The Defendant's Brief in Opposition to sanctions is PACER docket number 120