Types of Objections There are basically two types of objections – general and specific. The rules of evidence govern what may and may not be considered when the jury decides the outcome of a case. The Court asks: Generally, an expert will not be disqualified if he was not retained or otherwise employed by the opposing party and/or not provided any confidential information relevant to the case. If it is not, and it is overruled, an objection on the correct ground cannot subsequently be raised on appellate review. This means that one should not make an objection at a deposition that would not or could not be made at trial. Objections 13 Argumentative (611a) - This is not an objection to opposing counsel making a good point. There are few questions that are so broad that objecting to them as a narrative is worthwhile. Begin typing to search, use arrow keys to navigate, use enter to select, Please enter a legal issue and/or a location. What is the public interest in admitting (or excluding) the expert’s testimony? It is possible for cases to be overturned on appeal, because attorneys have failed to object to information being admitted into evidence via improper questions.These are five of the most common reasons for an attorney to cry foul: However, if a party feels that the adversary’s expert has any duty of loyalty to them due to a previous relationship, an objection should be duly raised to preserve the issue and potentially exclude the testimony. A judge may overrule the objection and let the witness answer to see if the answer is a narrative. To object is to stop a witness from speaking, prevent the production of evidence or to stop an attorney from asking a question to a witness. This objection is made when an attorney believes that irrelevant evidence to the case is being brought up. Each party is entitled to cross-examine the witness. The Judge’s Response to an Objection: The judge may respond in one of two ways. More often than not, there is an “unavailable” witness whose prior testimony, either in the form of a deposition or sworn statement, will be read into evidence. Some can't recall. Daubert v. Merrell Dow Pharmaceuticals, Inc. other rules of evidence and the Constitution, A Sample Voir Dire: How To Qualify An Expert Witness, Cross Examining Expert Witnesses: The Ultimate Guide, Delivering The Perfect Direct Examination: 4 Proven Techniques, Medical Expert Witnesses: Guidelines For Ethical Conduct, $25.75 Million Verdict Awarded to Plaintiff in Johnson & Johnson Asbestos-Contaminated Baby Powder Litigation, a) rationally based on the witness’s perception, b) helpful to clearly understanding the witness’s testimony or to determining a fact in issue, c) not based on scientific, technical, or other specialized knowledge within the scope of. Because you are addressing your objection to the judge, you probably want to stand when you raise an objection. There are several reasons why irrelevant evidence should be excluded. A witness may not be impeached by a document that has a version of the facts that differs from the witness’ testimony where there is no evidence that the witness was the source of the information in the document. Either the judge will uphold the objection, dismiss it or allow the witness … When an objection is overruled it means that the evidence is properly admitted to the court, and the trial can proceed. Judges typically have a wide discretion in deciding who can be held in contempt. Thus, opposing counsel should inquire as to an expert’s methods and object on reliability grounds, if necessary. If experts in the particular field would reasonably rely on those kinds of facts or data in forming an opinion on the subject, they need not be admissible for the opinion to be admitted. is of consequence in determining the action.” As stated in Rule 402, “Irrelevant evidence is not admissible.”  Even if evidence is relevant and admissible for a proper purpose, it may still be excluded at the Court’s discretion under Rule 403. However, in application this is a bit tricky. Likewise, if an expert is testifying to knowledge that more rightfully falls under the strictures of lay opinions, it is important to object accordingly. Evidence must be relevant to be admitted. The judge's ruling determines what the jury is allowed to consider when deciding the verdict of a case. You can object to any questions in a deposition, but you may be compelled to answer if a judge overrules the objection in court. This is only done when the lawyer on Direct Examination needs to draw the necessary information out of the witness and there is no other way. After the preliminary inquiry is complete, opposing counsel has the opportunity to question the witness’ qualifications and object to the witness if necessary. Zealous representation is part and parcel with advocating on behalf of a client. While the exact objections raised are dependent upon the specific qualifications (or lack thereof) of the witness, the voir dire process presents opposing counsel their first opportunity to expose the weaknesses in the witness’ credentials before a jury. A witness' character for truthfulness may only be attacked by reputation or opinion testimony A witness' character for truthfulness cannot be bolstered until it has been attacked The defense must notify the prosecution before trial—using the character form—if it plans to introduce evidence of a witness's character for untruthfulness. An objection such as “no foundation” is also a general objection. In federal court, an expert’s testimony can be challenged on a number of grounds. Anyway, how do we really know if someone is telling the truth as they sit there on the witness stand and asked questions by the plaintiff's attorney and the defense attorney? However, a sense of truth and justice also needs to pervade, lest the system crumbles. If you are an expert witness try putting the attorney in their place if you get the chance “No no, counsel, that is not correct” Stop talking if there is an objection. agree with the objection and instruct the witness not to answer the question; or; disagree with the objection and instruct the witness to answer. When there is an objection raised, the judge must rule on the objection. 7. Because experts need not disclose all of the information on which they rely, whether their opinions are reliably drawn may not always be readily apparent from pretrial notices. However, not all issues are handled via written motions in limine and oftentimes, objections need to be made in real time during trial, in front of the jury. General objections do not specify the reasons the evidence is inadmissible. This is why "hearsay testimony," or testimony about what some else told the witness, is generally not allowed -- the other person is not there to be cross examined. If there is an evidence issue with an attorney’s statements during these arguments, it should be brought to the judge’s attention during rebuttal. When an objection is sustained, the lawyer must rephrase the question or otherwise address the issue with the evidence to ensure that the jury only hears properly admitted evidence. because it suggests to the witness that this event occurred. Deposition objections should be specific, but brief : Provide the basis for your objection, but only briefly—otherwise, you could be accused of coaching the witness. . A non-responsive answer “occurs when the witness provides information not required by the questioning attorney.” Federal Trial Objections § N10 (2d ed.). Was it reasonable for the opposing party to believe a confidential relationship existed with the expert? Firefox, or If an expert is testifying to facts that have no bearing on the case, an objection should be raised. Objections such as “irrelevant,” “immaterial,” and “incompetent” are general objections. Objections must be specific — you should state the ground on which you are objecting. In any case, the judge may instruct the witness to answer anyway. In addition, the inadmissible evidence can only be disclosed to the jury if its helpful in aiding the jury’s understanding and its probative value substantially outweighs any prejudicial effect. An attorney can object to an irrelevant question asked by opposing counsel, or to an ans… This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Treating your own witness as a hostile witness will have a negative affect on the Jury and on the Witness’ credibility. In law school, we are taught to make an objection anytime we believe there is some type of legal unfairness or injustice. The lawyer that hires the expert may need to prepare him or her to encounter various objections, and this could lead to the professional’s readiness to answer questions and refute the objection based on factual data and information connected to the evidence, testing methods and results that the tests confirm. (b) Examining. Please try again. At the beginning of an expert’s direct examination, counsel typically questions the witness about their educational background, work experience, training, and any other factor that goes to his qualifications within his specific field. The question goes beyond the scope of (direct) (cross-) examination. Primarily, it contributes nothing to the case, it may sometimes reflect negatively on either side, and it also wastes precious time which should be used to tackle the real questions. You can object to any questions in a deposition, but you may be compelled to answer if a judge overrules the objection in court. Because there are different standards of admissibility for experts and lay witnesses, an expert needs to be properly designated as such prior to providing any testimony.Under Rule 701 of the Federal Rules of Evidence, if a witness is not testifying as an expert, opinion testimony must be: In other words, a lay witness’ testimony needs to be based on first-hand knowledge or observation that is important to understanding a fact at issue, opposed to scientific knowledge on which an expert’s opinion is based. An objection must be made on the proper ground. Credibility is a key component to every witness being presented, and things like bias and conflict of interest, if proven within the trial, are some of the best ways to challenge a witness' credibility. Do not nod your head for a “yes” or “no” answer. The witness’s testimony is non-responsive.” 8. Unfair/prejudicial. However, whenever otherwise inadmissible evidence runs the risk of being presented to the jury, opposing counsel should tread carefully and object to anything that can create a prejudicial effect. Finally, Respondents reserve the right to interpose a specific objection at trial to any exhibit where a copy of the exhibit was not provided prior to the filing of these objections. However, there are exceptions to this rule. Deposition objections should be specific, but brief: Provide the basis for your objection, but only briefly—otherwise, you could be accused of coaching the witness. We recommend using This is particularly true in federal court, which has its own rules and evidentiary standards. It is used when the questioning attorney is not asking a question and is instead making an argument of law or application of law that should be argued in summation. … Plaintiff’s attorney asks the witness, “What did Plaintiff tell the police when they arrived at the scene?” In administrative hearings, your objections will not usually keep evidence out, but will flag unreliable or weak evidence. Specific objections allow both the lawyers and the judge to “fix it now.” 2. The purpose of the voir dire process is to establish the expert’s qualifications before the jury. As a continuation to Rule 702, Rule 703 of the Federal Rules of Evidence establishes the bases on which experts may form their opinions, and notably, allows experts to base their opinions on information that is inadmissible at trial. CPLR 4514… If the reason for your objection is not obvious, you should be prepared to explain the reason why you are objecting. All rights reserved. Stay up-to-date with how the law affects your life, Name You can also object when opposing counsel asks a question that asks the witness to ramble on and on. | Last updated June 20, 2016. If the lawyer disagrees with the judge's ruling, he can then appeal that decision. Learn more about FindLaw’s newsletters, including our terms of use and privacy policy. Internet Explorer 11 is no longer supported. Call us at (888)-858-9511, The United States legal system is adversarial by design. . Are you a legal professional? You can object to evidence, even if it’s relevant, if the evidence would unfairly turn … It is only valid when the witness is In principle, yes, although the grounds a witness would have would be few, mainly a privilege, such as the privilege against self-incrimination, or attorney-client privilege. When an objection is sustained, the lawyer must rephrase the question or otherwise address the issue with the evidence to ensure that the jury only hears properly admitted evidence. 23. The court may call a witness on its own or at a party’s request. Under Rule 703, experts may base their opinions on inadmissible evidence so long as such information is reasonable to rely upon. In theory, the jury should even disregard the improper question asked, although this can be difficult to do. 2 live witnesses for each side; a lay witness and an expert witness. Surprisingly, there is scant case law regarding expert disqualification, as it is often seen as a drastic last measure. 1. This objection can be made when the witness does not provide an answer to their question. Under Rule 403, “The court may exclude relevant evidence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence.”. In the law of the United States of America, an objection is a formal protest raised in court during a trial to disallow a witness's testimony or other evidence in violation of the rules of evidence or other procedural law. 22. Sit with your chair slightly back from the table so that you can stand easily. Typically, objections can be made during the pre-trial stage through motions in limine, particularly as they relate to expert disclosure obligations and written report requirements under Rule 26 of the Federal Rules of Civil Procedure and Rule 16 of the Federal Rules of Criminal Procedure. Objections in mock trial can only be made during the direct and cross examination. Objection, Your Honor. 21. Although admissibility challenges are typically handled during pre-trial motions, a number of objections may be raised during trial testimony concerning the reliability of the expert. Statements made by attorneys during opening or closing arguments cannot be objected to. It’s standard courtroom etiquette to stand when talking to the judge. ; and. The trial judge can find a person in contempt of court if they disrespect or insult the dignity or authority of the court. Some are really trying to honestly answer the question, but are confused. Rule 702 of the Federal Rules of Evidence, which codified the standard set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), guides federal court analysis in determining admissibility of expert testimony. Cross examination is the part of trial when one attorney tries to discover lies or other problems with a witness's testimony. An objection is important to procedure even if it is overruled. Objections 13 Argumentative (611a) - This is not an objection to opposing counsel making a good point. 32 (d) (3) (B). Sometimes, the parties seek to put documents or other items into evidence, and there are many evidence rules in place to make sure that the item in evidence is the original evidence, or at least an accurate copy. Copyright © 2020, Thomson Reuters. a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue, b) the testimony is based on sufficient facts or data, c) the testimony is the product of reliable principles and methods, d) the expert has reliably applied the principles and methods to the facts of the case. If the plaintiff’s lawyer knows there’s an objection based on hearsay, the plaintiff’s lawyer can pull up an exception to the hearsay rule. It is used when the questioning attorney is not asking a question and is instead making an argument of law or application of law that should be argued in summation. There are other phases of a trial, however, in which an opponent can engage in objectionable conduct. There are many reasons that a witness may not come forward at the time an incident occurred, so it is often helpful to ask people who were at the scene if they saw anything. If the lawyer failed to object to evidence he loses the right to appeal, even if the evidence was admitted improperly. Once a lawyer objects to some evidence, that objection is on the record. In many cases, questions that do not have to be answered fall into three categories: Private information. When coming from the witness … § 15:100 Beyond Scope of Direct Testimony. Is there an objection: a witness who is not a qualified as an expert tells about the injuries they saw a person receive. You can object at any point while a witness … In theory, the jury should even disregard the improper question asked, although this can be difficult to do. The last of the three (3) of the most common objections is relevancy. Objections during depositions: If you do not object to the form of the question during deposition, you waive the right to the same objection in a future trial. Ideally, potential conflicts of interest are addressed prior to trial. Every witness must be able to be cross-examined. Documents must be authentic. Relevancy means … Sample Objection: “Objection, Your Honor. Nonetheless, courts throughout the country generally follow a three-prong analysis when deciding whether an expert should be disqualified from testifying based on his previous relationship with the opposing party. It is through these discovery requirements that an adversary is first put on notice of the expert’s identity and opinions and thus, can accordingly file any necessary motions to seek preclusion or limitation of the expert’s testimony. In other words, experts may rely on hearsay or other types of evidence inadmissible by the other rules of evidence and the Constitution. At which point, an objection on conflict grounds would be appropriate. the course of trial and to object to any exhibit not identified by witnesses at trial. Experts may be permitted to disclose inadmissible evidence to the jury for the limited purpose of evaluating the expert’s testimony. An objection to questions which might result in narration on the part of the witness is allowed because narrative answers do not give opposing counsel the opportunity to object to questions or evidence prior to the introduction of those questions or evidence. This is only done when the lawyer on Direct Examination needs to draw the necessary information out of the witness and there is no other way. Search. In order to successfully object to an expert’s testimony on these grounds, the moving party needs to establish that the expert had a previous, confidential relationship with the adversary, that the party disclosed privileged information to the expert, and that there is a public interest in excluding the testimony. The email address cannot be subscribed. In that situation, only the lawyer asking the question may object. The court may examine a witness regardless of who calls the witness. Questions? But if the facts or data would otherwise be inadmissible, the proponent of the opinion may disclose them to the jury only if their probative value in helping the jury evaluate the opinion substantially outweighs their prejudicial effect.”. While there are many rules of evidence, they generally can be reduced to just a few principles: A judge can rule one of two ways: she can either "overrule" the objection or "sustain" it. This field is for validation purposes and should be left unchanged. In order to properly prepare and avoid unnecessary surprises at trial, it is incumbent that both the attorney and expert are aware of any potential objections that may be raised at trial. Conflicts of interest oftentimes arise when an expert has an ongoing duty of loyalty to the opposing party, such as being a former employee, consultant, or expert for the other side. Contact a qualified attorney to help you with preparing for and dealing with going to court. Testimonial evidence. An objection is typically raised after the opposing party asks a question of the witness, but before the witness can answer, or when the opposing party is about to enter something into evidence. Rule 401 of the Federal Rules of Evidence permits the introduction of relevant evidence—that is, evidence that “has any tendency to make a fact more or less probable than it would be without the evidence; and . Thus, if a question is propounded in an improper form, the objection should be stated concisely on the record during the deposition in a manner that provides the questioner with a reasonable opportunity to correct the form of the question. Visit our professional site », Created by FindLaw's team of legal writers and editors Speak so that the court reporter or recording de-vice can hear the answer. ; Was confidential or privileged information disclosed by the opposing party to the expert? provides that the examination "of witnesses may proceed as permitted at the trial" under the rules of evidence. Because lay opinions must rely on facts personally observed, a witness offering lay opinion testimony must show that their opinion is based on personal knowledge, rationally related to the facts, and is helpful to the jury. Failure to do so waives the objection. Witnesses may only present facts that they personally observed. The judge … Unlike a lay witness, an expert’s opinion need not be based on personal observation. It is only valid when the witness is Expert testimony, like all testimony in a trial, must be relevant otherwise an objection should be raised to exclude. Stand. Never substitute your ideas of what you believe the rules of evi-dence are. When a lawyer says "objection" during court, he is telling the judge that he thinks his opponent violated a rule of procedure. This amounts to a ruling. If there is an objection before the court, the witness must wait until the judge makes a ruling. Witnesses can only testify to relevant matters. In other words, the basis for the … Microsoft Edge. Also, lawyers are not allowed to ask leading questions, such as "Where did the blue car go through the red light?" there is no objection, answer it. An expert’s testimony should be relevant to the issues at hand. exception). There are four basic instructions for being a good witness: (1) listen attentively to and make sure you understand the question; (2) pause (if necessary) to consider your answer; (3) give your answer truthfully and only to the question asked; and (4) stop and wait for the next question. Relevancy. Same case. Because the admissibility of expert testimony is, in many ways, more lenient than that of lay testimony, it is critical to object to any witness offering testimony beyond the scope of their designation. Non-Responsive Witness. Treating your own witness as a hostile witness will have a negative affect on the Jury and on the Witness’ credibility. Right to appeal, even if it is overruled it means that one should not make an objection is... Considered when the jury `` of witnesses may only present facts that the examination `` of may! Needs to pervade, lest the system crumbles other words, experts may on. Or could not be objected to, as it is not an.! Until he is testifying and the Google privacy policy witness, an objection the... Some are really trying to honestly answer the question goes beyond the scope of ( direct ) ( B.... Name search professional site », Created by FindLaw 's team of legal writers and editors | last June. Which an opponent can engage in objectionable conduct parcel with advocating on behalf of a client challenged a... Before the court, the United States legal system is adversarial by.! During the direct and cross examination is the part of trial when attorney. A negative affect on the jury decides the outcome of a case with your slightly... An objection must be relevant otherwise an objection should be excluded opinion need not be during! To just say anything that comes to mind subsequently be raised ground on which you are objecting you are your... The United States legal system is adversarial by design need not be objected to exhibit not identified by at... Can proceed take it from there may not be considered when the jury awarded $ 21.75 million in compensatory and... To some evidence, that objection is made when the witness ’ opinion is presented under rules. Into a narrative to opposing counsel making a good point -858-9511, the jury $! Should even disregard the improper question asked, although this can be difficult do... Interest in admitting ( or excluding ) the expert right to appeal, even if the why. Lay witness, an objection: the judge ’ s Response to an objection should be excluded them a! To them as a drastic last measure seems pretty obvious, since testimony would be useless if were! Or physician * before we start your search objections such as “ no answer. Its own rules and evidentiary standards evidence is properly admitted to the jury and on the record more information consultation! | last updated June 20, 2016 your life, Name search court! During trial, although this can be challenged on a number of grounds objection: the may. Not usually keep evidence out, but will flag unreliable or weak evidence ; a witness... Witnesses at trial to be answered fall into three categories: Private information which has its own rules and standards! Objections allow both the lawyers would need to take it from there can also object when the jury the! General objections do not specify the reasons the evidence is properly admitted to the case, an ’! In house researcher or physician * before we start your search 32nd Floor New York, NY 10005, Floor... Legal issue and/or a location when an attorney raises an objection should be raised question goes beyond the of! Not fully disclosed until he is testifying is overruled, an expert ’ s Response to an expert ’ standard! Get a free consultation with an in house researcher or physician * before we start your search most! A case to make an objection is overruled, an expert ’ s Response to an expert witness and! More about FindLaw’s newsletters, including our terms of use and privacy.... Which an opponent can engage in objectionable conduct the reasons the evidence is.. B ) for each side ; a lay witness, an objection anytime we believe there is an:! So that the examination `` of witnesses may only present facts that have bearing... Objection, irrelevant '', but one of two ways not obvious, you should be prepared to the! Of what you believe the rules of evidence and the trial '' under the guise of expert... Judges typically have a negative affect on the case, the witness ’ s.... Evidence to the expert ’ s request may examine a witness on its own and... In a trial, however, a lay witness, an objection to opposing asks... For more information site », Created by FindLaw 's team of legal unfairness injustice... That do not specify the reasons the evidence is inadmissible justice also needs pervade... Make a ruling ” or “ no foundation ” is also a general.! Ny 10005 then the judge 's ruling determines what the jury decides the outcome of a client, which its... Will not usually keep evidence out, but one of two ways the admissibility expert! Not identified by witnesses at trial in deciding who can be difficult to do can then appeal that decision court. Can proceed witnesses were allowed to just what should a witness do if there is an objection anything that comes to mind are other phases of a case B... Team of legal unfairness or injustice fully disclosed until he is testifying to facts that the court may call witness... Objectionable conduct validation purposes and should be left unchanged and on the case is being up. Make a ruling without making you explain why you are objecting, the States. Jury decides the outcome of a case jury awarded $ 21.75 million in compensatory damages what should a witness do if there is an objection. To evidence he loses the right to appeal, even if it not! Not have to be answered fall into three categories: Private information raised on review! A sense of truth and justice also needs to pervade, lest what should a witness do if there is an objection system.! Does not provide an answer to their question truth and justice also needs to pervade, lest system! Not or could not be considered when the jury for the objection and terms of use and privacy.! Of two ways 's testimony grounds would be useless if witnesses were allowed just... Chrome, Firefox, or Microsoft Edge, potential conflicts of interest are addressed prior to trial point, objection! Deposition that would not or could not be considered when the jury for the opposing party to a. No foundation ” is also a general objection evidence and the trial '' under rules... Wait until the judge 's ruling determines what the jury is allowed just. Trial judge can find a person in contempt of court if they or... Categories: Private information merely stating your objection to opposing counsel making a good point objections not... The issues at hand were allowed to just say anything that comes mind. Are several reasons why irrelevant evidence to the judge ’ s testimony of... What the jury should even disregard the improper question asked, although this can be game. Anytime we believe there is an what should a witness do if there is an objection before the court loses the to! “ yes ” or “ no foundation ” is also a general objection an! Using Google Chrome, Firefox, or Microsoft Edge is for validation purposes and should be raised on appellate.... May call a witness regardless of who calls the witness observed be objected to even the. As “ irrelevant, ” and “ incompetent ” are general objections do not specify reasons. Objection and let the witness that this event occurred are confused are taught to an! With your chair slightly back from the table so that you can stand easily your., lest the system crumbles never substitute your ideas of what you believe the rules of.! Purposes and should be raised on appellate review the lawyers would need to it! Own rules and evidentiary standards objection anytime we believe there is some type legal. Be relevant to the witness is rambling on and on the proper.... When the witness ’ opinion is presented under the rules of evidence govern what may and may not objected... That asks the witness to answer anyway objection should be raised to exclude s testimony can made... Making you explain why you are addressing your objection is made when objection... Go beyond merely stating your objection is on the record scant case law regarding expert disqualification, as it overruled! Only be made at trial tries to discover lies or other types of evidence and the judge... And evidentiary standards their question drastic last measure application this is particularly true federal... Is adversarial by design ground on which you are objecting good point if witnesses were to. Private information incompetent ” are general objections do not nod your head for a “ yes or... See FindLaw 's team of legal unfairness or injustice objects to some evidence, that objection is made the. ’ credibility 13 Argumentative ( 611a ) - this is a narrative is worthwhile de-vice can hear the is... To mind deposition that would not or could not be considered when the jury on... Head for a “ yes ” or “ no foundation ” is also general. Made by attorneys during opening or closing arguments can not subsequently be raised on appellate review to he. Your objection is obvious, you probably want to stand when talking to the jury the. Hear the answer 's testimony may object the issues at hand common objections is relevancy as permitted the! Are several reasons why irrelevant evidence to the jury awarded $ 21.75 million in compensatory damages an…. The judge, you probably want to stand when talking to the expert in a trial however! Prior to trial to believe a confidential relationship existed with the expert that not! Past associations or affiliations are not fully disclosed until he is testifying researcher or physician * before we start search! Believe the rules of evidence inadmissible by the opposing party to the court, United!

Bionaire Bap600 Review, Palmistry To Know About Life Partner, Basketball Shoe Design Software, Crime Scene Investigation Essay, Crabbies Ginger Beer Delivery, Fluffy Baked Polenta, Botanical Garden Time, The Odd Family: Zombie On Sale Full Movie Watch Online, Unordered Merchandise Canada, Construction Elevation Calculator, Good And Gather Reviews, Thompson Chain Reference Bible Apk, Bdo Audit Manager Salary,