Responsibilities include:

• Propounds and responds to written discovery;
• Review and finalize complaints; draft related pleadings, submits to process server; calendars deadlines;
• Drafts initial and supplemental disclosures; gather pertinent medical records and disclosures;
• Capture/tracks billable and non billable time in case management system;
• Request certified copies of medical records;
• Works as part of a paralegal team;
• Drafts Requests for Exemption and related pleadings;
• Drafts Notices of Depositions coordinated logistics for same;
• Drafts Counterclaims and Cross-Defendants Answers;
• Meets with clients regarding Discovery Requests and responses; and
• Knowledge of Microsoft Applications (Word, Outlook, Excel).