Although a character witness who testifies to the reputation of another person or gives an opinion of the character of another person cannot testify to specific instances of that person's conduct to bolster the character witness's testimony, an opposing party may question the character witness about specific instances of the person's conduct to show that the character witness' testimony about the character of the person was not well-founded.

Fed. R. Evid. 103(a)(1) (statement of the specific ground of the objection necessary "if the specific ground [of the objection] was not apparent from the context").A party objecting to an offer of evidence need not state the ground of its objection if the ground of the objection is already apparent.

Reyes v. Missouri Railroad Co., 589 F.2d 791, 794-795 (5th Cir. 1979) (holding, in an action for negligence, that plaintiff's prior convictions for public intoxication were inadmissible habit evidence under Rule 406 because they were "of insufficient regularity to rise to the level of 'habit' evidence." ).If a pattern of behavior is not invariable or almost invariable, it is not habit.

United States v. Jordan, 509 F.3d 191, 202-203 (4th Cir. 2007) (upholding trial court's admission of witness Brown's statements to her friend Adams as statements against penal interest because Brown's statements which....Federal Rule of Evidence of Evidence 804(b)(3) or a comparable State rule creates a hearsay exception for a statement which was at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject the declarant to civil or criminal liability, or to render invalid a claim by the declarant against another, that a reasonable person in the declarant's position would not have made the statement unless believing it to be true. A statement tending to expose the declarant to criminal liability and offered to exculpate the accused is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.