Paralegal
Current• Draft contracts, correspondence, motions for summary judgment, responses to motion to dismiss, responses to motion for summary judgment, petition for declaratory judgment, pleadings, and various other motions;• Draft wills, probate documents, including applications, oath, proof of death, objection to inventory, affidavit of compliance, notice to creditors, and inventory or affidavit in lieu of inventory;• Work on mediation preparation including drafting mediation statements and coordinating mediation schedules; • Draft deposition notices, discovery requests, and prepare discovery answers for ongoing litigation, including coordination of scheduling of witnesses, serving non-party witnesses with subpoena and subpoena duces tecum; • Prepare deposition logs, production logs, trial notebooks, deposition excerpts, witness lists, motions in limine, jury charges, and various other litigation related projects; • Work on coordination of trial witnesses and deposition witnesses and calendaring deadlines; • Draft guardianship documents including application, proof of service, motion for ad litem and motion for independent medical examination; • Interview and work with clients and witnesses to gather information;• Work with video preparation for trial; • Research and analyze case law; research statutes to verify requirements and research local rules;• Work on complex guardianship and probate matters;• Work on complex and contested probate and guardianship matters;• Work with Photoshop to create exhibits to present at trial; and• Coordination of trial preparation.