Analyze suit referral letter from major retailer• Subpoena medical and billing records and compile into special damages chart• Prepare correspondence including reports to client and mediation summaries• Review surveillance video and preserve stills• Prepare Answer and Affirmative Defenses along with discovery requests• Conduct on-line research utilizing Lexis/Nexis

Assist attorneys with handling legal matters.• Review claim file documents and organize chronologically.• Draft initial memorandum chronologically detailing events of the loss.• Review Plaintiff’s discovery requests including Requests for Admissions, Interrogatories andRequests for Production and draft all responses.• Draft discovery requests to propound on Plaintiff.• Draft Notices of Production from Non Parties and Subpoenas Duces Tecum.• Analyze claim file for relevant documents to be used in Examinations Under Oath and depositions.• Index the relevant documents and compile them into hearing binders.

Review collateral documents for details including names, addresses, proper endorsements onthe Note and Allonges and for Bailee letter accuracy prior to execution of same.• Update internal databases with the relevant information and notify partnered teams of receipt ofthe collateral.• Review dockets for upcoming events. trial packages for non-jury trials.• Draft and e-filed the appropriate orders and notices.• Assemble, review and organize the appropriate exhibits to be used at trial.• Prepare a trial check list and email it to the attending attorney and the designated witness alongwith copies of the assembled exhibits.

Drafted pleadings, motions and discovery responses.• Conduct Department Of Defense searches, obtain and calculate final judgment figures.• Draft cost affidavits, attorneys’ fees affidavits, Plaintiffs’Attorneys’Affidavits.• Schedule and prepare witnesses for testimony at trial.• Review county dockets for upcoming events.• Draft and serve appropriate orders and notices.• Communicate with judicial assistants to confirm hearings and/or resolve case related issues.• Communicate with clients via LPS, Serengeti and e-mail.

Manage 350 contested foreclosure cases.• Primary emphasis on review, analysis and case update.• Designated as the primary conduit for compiling and delivering two monthly reports to a majormortgage servicer.• Communicated with local counsel to obtain monthly status update.• Analyze and compile the data into Excel spreadsheets.• Review and analyze pleadings, discovery requests including e-discovery preservation request.• Analyze loan documents, conduct legal research and draft responses to pleadings, discoveryrequests and motions.

Manage 130 cases involving eminent domain, condemnations, partitions, quiet title, originationand servicing issues, contested foreclosures and retail banking matters.• Draft documents and pleadings for various matters filed in circuit and federal courts.• Correspond with and tender claims to title insurers; monitor progress with assigned counsel.• Analyze documents and drafted pleadings, motions and discovery requests including e-discov-ery requests.

Manage 200 litigated mortgage cases. Settled 30-40% of the cases in the early stages of litiga-tion; leading to an average savings of $4,000 per case fees and costs.• Draft pleadings, discovery and settlement agreements.• Assist in-house and outside counsel with defense strategy.• Designate and prepare witnesses for mediations, depositions and trials.