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Objections 2nd Ed Guidebook


This guidebook is a 2nd edition of the updated version of its predecessor, the Missouri Evidence Handbook, published in 1996. Like the Evidence Handbook, the Objections Guidebook is organized around the prevalent objections made in the course of a trial; the recommended forms for objecting; general rules, exceptions, considerations, and factors in decisions on admission; special instances and subsidiary rules; and caveats regarding peculiarities likely to be encountered from time to time. Topics are arranged alphabetically. for quick reference.

The 2nd edition includes updated legal authorities, objection examples, and a new section on objection to virtual appearance. It also includes an entirely new Part 2 – Making a Proper Record in Criminal and Civil Cases – which provides practice tips and tactical considerations regarding making objections, offers of proof, rulings, making a record to preserve errors for appeal, strategies regarding the use of pretrial motions, and more.

The Missouri Bar is grateful to the co-authors of this edition of the Objections Guidebook, Judge Deborah Daniels and James R. Wyrsch.

2022 (86 pages)

MoBar Price $50  |  eGuidebook




Part 1: Objections

  • Objections
  • Argumentative Question
  • Best Evidence
  • Calling for a Narrative Response
  • Character Evidence (Relevance)
  • Competency
  • Demonstrative Evidence
  • Form of the Question
  • Hearsay
  • Hearsay – Exceptions
  • Impeachment
  • Leading / Suggestive
  • Offer of Proof
  • Opinion
  • Parol Evidence Rule
  • Privilege
  • Refreshed Recollection
  • Rehabilitation
  • Relevance (Including Materiality)
  • Specific Problems in Civil and Criminal Cases
  • Arguing an Adverse Inference Because of Spoliation of Evidence
  • Absence or Presence of Prior Accidents
  • Collateral Source Rule
  • Subsequent Remedial Measures Relevance
  • Plea Discussions
  • Settlement Negotiations: Compromise and Offer of Comprise
  • Non “Scientific” Experiments
  • Virtual Appearance
  • Waiver of Objection

Part 2: Making a Proper Record in Criminal and Civil Cases

  • Offers of Proof
  • Motions in Limine
  • Occurrences That Won’t Show Up on Record
  • Motions to Suppress and the Problem of “Taking with the Case” in Criminal Case
  • Expert’s Qualifications
  • Pretrial Motions Other Than Motions to Suppress in a Criminal Case
  • Discovery
  • Constitutional Questions
  • Motions for New Trial
  • Motions for New Trial in Civil and Criminal Cases Alleging Ethnic or Religious Bias in Jury Deliberations
  • Motions for Judgment of Acquittal
  • Motions for Directed Verdict and Motions for Judgment Notwithstanding the Verdict in Civil Cases
  • Notwithstanding the Verdict in Civil Cases
  • Preservation of Instructional Error
  • Closing Argument
  • Bench Trials
  • Motions for Remittitur and Additur
  • Motion to Amend the Judgment
  • Motion to Obtain Relief from Judgment
  • Sentencing Issues