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Location : Arizona - Phoenix
Refer to Job # OUJF708419
Pre-Litigation Paralegal The candidate will back-up to Legal Assistants in sorting and responding to incoming telephone calls; forwarding calls when appropriate and applicable; sort and file daily mail. Will review files as received that are entering litigation this review also includes identifying potential defendants to be named in the lawsuit. Request missing documentation, it becomes the responsibility of the Paralegal to follow up on receipt of responses. Create a to-do for follow up. Review, index, organize and summarize documents produced by other parties and medical health care providers when appropriate prepare medical notebook. Obtain, review, and organize damage information; calculate damages (medical expenses, lost wages, household expenses, consortium claims and property damages) prepare, maintain and update damages summaries. Develop information and acquire records not obtained pre-suit for wrongful death, i.e. supporting evidence regarding sibling and/or child/parent economic claims. Prepare and forward demand packages to insurance carriers or defense attorneys. Meet with client; coordinate the collection and review of client files; gather, organize, summarize and analyze documentation collected. Forward discovery to client. Draft responses/answer discovery to interrogatories, requests for admissions requests for production. Draft and serve supplemental discovery directed to the defendant, including expert trial interrogatories, requests for site inspection, non-party production requests served by plaintiff upon non-parties and obtain service of non-party production subpoenas. Prepare and file motion for mediation and notice for trial (if not already done on the file). Prepare affidavits of documents and maintain document files and case correspondence. Conduct research to locate, communicate with, interview and retain expert witnesses. Obtain written reports/analysis of evidence, injuries, issues and financial evaluations from expert witnesses. As necessary and appropriate, communicate and correspond with client about case status, Judicial procedures, court appearances and preparation. Schedule depositions, meetings, client interviews, hearings and attend as required. Prior to client deposition, confirm discovery responses have been completed. Read and summarize depositions, medical records and other documents as requested. Assist in preparing pretrial and trial motions (motions in liming, protective order, preclude evidence to be admitted at trial, etc.) or responses to same received from defense. Prepare mediation statements and mediation statistics (obtain costs and prepare overall summary of file including specials, liens, lops, priors, pertinent information) update filing and organize file in preparation for conference. Comply with all pretrial and trial order deadlines including expert witness disclosures, trial witness and exhibit lists, pretrial statements stipulations. Prepare trial exhibits, demonstrative charts, blow ups, etc. Prepare trial notebook. Prepare voir dire, jury instructions and verdict forms. Prepare and serve subpoenas for trial upon witnesses and under direction of the attorney, communicate with witness regarding trial attendance/appearance at trial. Organize, mark, and index trial exhibits. Draft, review and file pleadings, petitions, briefs, arguments, pleadings and other documents applicable to obtaining approval of minor settlements, guardianship and estates for attorney s litigation case load relevant to court actions. Research procedural, administrative and case law. Conduct computer assisted legal and factual research using online resources such as West law, Lexis, etc. Investigate facts and law of cases to determine causes of action and to prepare cases. Gather and analyze research data such as statutes, decisions and legal articles, codes and documents. Attend and assist attorney at trial. Translate as appropriate Familiar with relevant laws as it applies to personal injury claims, motor vehicle accidents and insurance is needed. Computer skills including knowledge of Microsoft Word and legal software is plus. Knowledge of medical terms and traumatically induced conditions is preferred.
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