Paralegal

JOB DESCRIPTION

PITTSBURGH EPL PARALEGAL RESPONSIBILITIES


* 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 o 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 o 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 o 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).


* Secretary will be responsible to schedule court reporter and videographer


* 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

QUALIFICATIONS



* 5 years of Employment Law and General Litigation Experience with filing in the Allegheny County and surrounding Pittsburgh county court systems.


* Familiarity with billing processes on matters.

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