• Organized and coordinated document productions.• Prepared Indexes of produced documents.• Prepared and updated Chronologies of Events.• Reviewed and gathered relevant documents for Motions and other Court submissions.• Organized exhibits for Pleadings and other Court submissions. • Researched relevant information on witnesses, adversaries, arbitrators, mediators.• Researched public records.• Digested and summarized Deposition Transcripts for use by attorney.• Coordinated and filed pleadings with the Court knowing associated rules.• Drafted letters to clients.• Drafted Settlement Agreements and prepared Medication submissions.• Organized and tracked documents received from clients and Court.• Conducted computerized research (Internet, Westlaw)• Proofread and edited documents for grammar, content and redactions.• Trial Preparation.• Organized and indexed Trial exhibits and other supporting documents.• Organized witness binders for Trial.• Coordinated witness review of relevant documents being used at Trial before attorney meet with them.• Prepared and organized trial exchanges (set-up documents, proofread submissions, pull relevant information from documents previously submitted, etc.)• Coordinated trial set-up (projector, computers, all documents needed, easel, etc.)• Organized logistics (transport set-up to courthouse, make sure connections are working, etc.)

Pre-litigation Procedures, (PIP), Premise liability cases, automobile accidents, contracts, fall down, dog bites and wrongful deaths, etc. Discovery Tools including interrogatories, demands for production of documents, requests for admissions, depositions, demands for inspection of property and demands for medical examinations. Motion Practice including motion to enter default judgment and schedule proof hearing, file amended complaint adding new party/new claim against an existing party, consolidate cases on the issue of damages, strike answer with/without prejudice for failure to provide discovery, compel more specific answers to interrogatories/produce insurance information/incident report/deposition, strike answer for failure to respond to demand for production of documents, fix date for service of expert’s report, extend discovery/reopen discovery, partial summary judgment on issue of liability. Trial including scheduling witnesses, preparing the pretrial exchange and trial memorandum and making sure that doctor/expert is available. Settlement and Post-Trial including settlement closing statements, various letters that can be used to obtain and disburse settlement money, and motion to enforce settlement, letters notifying court that case has settled, adversary confirming settlement, medical witness that case settled, medical provider requesting compromise of bills, stipulation of dismissal with prejudice, warrant to satisfy judgment and letter to court to docket a judgment. Uninsured/Underinsured Motorist including initiating, pursuing, and perfecting a claim for uninsured or underinsured motorist benefits. Longworth letter to UIM carrier regarding proposed settlement, Zirger letter to UIM carrier regarding potential UIM claim, UM/UIM Arbitration Statement and filing of complaint.Workers’ Compensation and Social Security Disability – Title II.