Description

• Prepare and send Litigation Hold Memo to client
• Send MMSEA - request social security number from client and provide to claims
• Send initial document request via email (at attorney discretion as attorney generally includes this in initial email)
• Discovery - service and answering
  • Once counsel have had a Rule 26 conference call, inquire as to whether discovery can be served on plaintiff (can be prepared in advance for review, edits and supplementation)
    • Prepare Interrogatories and Request for Production of Documents to Plaintiff and serve on counsel (can be prepared in advance for review, edits and supplementation)
    • Monitor plaintiff's responses to our discovery. If overdue, send overdue letter.
      
  • Advise attorney once discovery is received and send discovery requests to client ASAP to begin discovery process
  • Paralegal will complete Request for Production of Documents
    • Request for Production of Documents
      • Format responses, send to client, preparation of general objections and draft responses for review by attorney; work directly with client to ensure receipt of documents/answers to request for production of documents in a timely manner.
        
    • Interrogatories - Paralegal will set up with general objections and certain specific objections (i.e., expert and/or emotional damage) for attorneys' review and completion
      • Attorneys will contact clients to complete Interrogatories
        
• If we need additional time to respond to discovery, request extension prior to discovery due date.
• Draft Position Statements (at attorney discretion)
• Assemble/redact exhibits for Position Statements
• Assemble, organize and label documents received from clients in ProLaw
• Draft Initial Disclosures in Federal cases.
• Upon receipt of Plaintiff's Initial Disclosures, pull expert information and request medical records
• Order and monitor medical record requests (obtain information from Plaintiff's Disclosures and Plaintiff's responses to our Interrogatories)
• Follow-up with Ontellus (or other document management company), as necessary
• Advise Ontellus (or other document management company) to stop work once a case has been resolved
• Expert subpoenas (not depositions).
• Perform docket search after receipt of 90 day dismissals
  • After 90 days, email attorney and secretary notifying them of search
    
• Send FOIA requests to EEOC/PHRC/Unemployment Compensation when a case transfers from agency to litigation
  
• Responsible for billing the appropriate file as work is performed
• Responsible for electronic filing of court pleadings
• Responsible for preparing the case file for trial proceedings
• Responsible for updating data and documenting communications in case file
• Responsible for utilizing AI where necessary