Commercial Litigation Attorney amp Paralegal

FL - West Palm Beach

General Role of the Paralegal / Secretary

File analysis and work-up on existing files, including the compilation of lists for non-party subpoenas.

Reviewing and answering all discovery, including expert discovery, requiring a response; Rogs, RTP, RFA

Compilation of Witness, Expert and Exhibit lists for trial

Prepare summaries and Chronologies of voluminous records.

Deposition Annotations / summaries

Legal research

Document production as assigned by the attorney

Trial preparation as directed by the attorney

Open a new file and organize client materials

Diary all important dates such as response to complaint, response to the amended complaint, Mediation, discovery deadlines, expiration of settlement offers, trial deadlines and any other deadline imposed by the Rules of the procedure or court order.

Immediate notification to the attorney of receipt of trial orders

Immediate notification of records received pursuant to subpoenas issued.

Notification of discovery response deadlines for Rogs, RTP, RFA, with 15 & 7 day diary reminders created

Notification of Trial discovery deadlines including witness, expert, exhibit lists due, Discovery cut-off, last day of OOJ / PFS, with 30 15 & 7 day reminders

Notification of other conferences, dates and / or deadlines per attorneys request

Index and organize any and all discovery received from Plaintiffs / Co-Defendants

Create Trial notebooks for ALL TRIAL DOCUMENTS including

• Trial Orders IMMEDIATELY UPON REQUEST
• Witness / Exhibit / Expert List from all parties
• Pre-mark exhibits in compliance with Judge's or divisional instructions.

Create diary slips for mediation, pre-mediation conferences, and reminders as above.

Due dates of all discovery.

All trial scheduling, as above.

All depositions of Plaintiffs, Co-defendants, non-parties and expert witnesses.

Create daily mail folders.

Scanning, coping, mail and filings with the court,

Daily timesheets.