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New York Objections

Publisher: James Publishing

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2018 Edition
ISBN: 9781945421815
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ISBN: 9781945421815
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New York Objections

Specially Designed for Courtroom Use

Winning at trial means getting your evidence in and keeping the opposition's evidence out — or at least minimizing its impact. Most evidentiary rulings are within the judge's discretion, and are made in seconds. Bad rulings are almost never reversible. In sum, victory goes to the lawyer who can prevail on the big objections in the heat of battle. The key is knowing why, when and how to object and how to respond — at a moment's notice — with supporting authority at your fingertips. That's where Justice Freedman's New York Objections comes in. Like no other resource, New York Objections uses a courtroom-friendly format to cover more than 100 trial objections with clear, concise explanations, practice tips, and cautions — plus the rules, statutes, and cases that comprise and construe New York's rules of evidence.

Pattern Objections

Model language for more than 100 objections. Use the language provided — or tailor it to fit your specific situation. You can turn to the model language you need in seconds.


Justice Freedman comments on each objection. She explains the practical application, scope, and purpose of the governing rules. And she describes the circumstances in which each objection is proper and most effective.

Practice Tips & Cautions

Justice Freedman provides ample practice tips and cautions, alerting you to common mistakes and important strategies. And the book's format makes them easy to spot.


The facts and holdings of 1500 cases (about 15 per objection) are summarized so you can quickly find supporting authority.


Opposing counsel objects — and thanks to New York Objections, you have the ammunition to respond. Better yet, Justice Freedman explains how to anticipate and preclude objections before they are made. And she tells you what reactions to expect from the judge, how to meet alternative admission procedures, and more.


New York Objections tells you how to meet the foundation requirements for specific types of evidence. You'll find instructions on how to lay your foundation and spot weaknesses in your opponent's.


Anticipate evidence problems and plan your strategies. Justice Freedman's advice and insights give you the best chance of success. They include alternative arguments, judicial perspectives and preferences, and what you need to put on the record.   Without a self-contained evidence code, New York attorneys must marshal far-flung rules, statutory provisions, and ever-developing common law. Other evidence books are full-blown academic treatises — not well-suited for handling courtroom exigencies. New York Objections bridges the gap. Organized by topic, it explains New York's evidence rules, citing all the state's relevant rules, statutes, and more than 1,500 New York cases directly on point. Don't let opposing counsel's objection block the admission of critical evidence. And don't be caught off guard when opposing counsel offers evidence you could have kept out — had you made the proper objection. Whether you're in the courtroom or preparing for trial, New York Objections will help you use the rules of evidence to their best advantage. Written by a respected New York trial judge, this book has the most comprehensive coverage of New York objections ever published. New York Objections is what you need to:

•   Preclude trial objections through motions in limine.
•   Evaluate the admissibility of the opposition's evidence.
•   Decide when to object, and when to remain silent.
•   Preserve the record for appeal.
•   Respond to objections — on the spot, and with authority.
•   Draft briefs on evidentiary objections and motions.
•   Prevent jury exposure to adverse inadmissible evidence.

Table of Contents

Objections and Related Procedures
Jury Selection
Opening Statement
Relevance and Materiality
Confusing, Prejudicial, and Cumulative
Character and Habit
Real Evidence
Photographs, Recordings, and X-Rays
Parol Evidence
Demonstrative Evidence
Witness Competence
Witness Examination
Expert Witnesses
Judicial Conduct
Attorney Conduct
Submission to Jury
Objecting During Depositions