Q: What kinds of objections are allowed at DEPOSITIONS?

A: This is an excellent question about deposition objections in California civil litigation. Let me break down the key points and provide some clarification:

1. Types of objections generally allowed in depositions:

The attorney you mentioned is largely correct. The most common and widely accepted objections in depositions are:

a) Privilege (including attorney-client, spousal, etc.)

b) Form of the question (vague, compound, argumentative, etc.)

2. Relevance objections:

There's some nuance here that might explain the conflicting information you've encountered:

a) In California, relevance objections are generally discouraged during depositions, but they are not strictly prohibited.

b) The rationale is that depositions are meant to be broad discovery tools, and relevance is often determined in the context of the entire case, which may not be fully apparent during the deposition.

c) However, if a line of questioning is clearly irrelevant or appears designed to harass the witness, an attorney might still object on relevance grounds.

3. Limits on irrelevant questions:

While relevance objections are discouraged, there are still protections against abusive or overly irrelevant questioning:

a) California Code of Civil Procedure § 2025.420 allows a party to seek a protective order before the deposition to limit its scope.

b) During the deposition, an attorney can object to questions that are clearly harassing or made in bad faith.

c) If questioning becomes excessively irrelevant or abusive, an attorney can suspend the deposition and seek court intervention under CCP § 2025.470.

4. Best practices:

a) Most experienced attorneys will make "form" objections and only rarely object on relevance grounds during a deposition.

b) They may state "objection, relevance" for the record but still allow the witness to answer unless the question involves privileged information or is clearly harassing.

c) Substantive objections, including detailed relevance arguments, are typically reserved for motions to the court later.

It's worth noting that deposition practices can vary somewhat between jurisdictions and individual judges. If you're involved in a case, it's always best to consult with your attorney about the specific practices in your court.