Paralegal

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 plaintiffs 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 Plaintiffs Initial Disclosures pull expert information and request medical records

• Order and monitor medical record requests (obtain information from Plaintiffs Disclosures and Plaintiffs 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

• 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.