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 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

• 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.