Lynette Paczkowski has authored the chapters "Goals and
Strategies" and "Preparing to Defend a Deposition"
in MCLE's Massachusetts Deposition Practice Manual,
fourth edition.
The manual, updated in August 2019, trains attorneys on the best
ways to use depositions and ultimately win the case, including
how-tos on asking the right questions, negotiating challenging
topics and interjecting key objections. Lynette's introductory
chapter, "Goals and Strategies," dives into the
advantages of depositions and strategic and tactical
considerations, while Chapter 4, "Preparing to Defend a
Deposition," discusses the importance of preparation,
assessing rationale and strategy, prepping the witness and other
issues around defense.