Heather Cruz Email and Phone Number

• Design, implement and oversee a long-term strategic roadmap that addresses process improvements around resource allocation, technology adoption and workflow that will improve efficiency and effectiveness of the Legal team;• Manage Legal administrative staff and paralegals to ensure consistent application of applicable process and procedures, and to maximize efficiency; • Manage projects on key initiatives including case and claim management, e-discovery, data preservation, document management, litigation holds, knowledge management, information governance, and other areas as needed;• Identify, implement, and manage technologies/platforms to support the Legal team, including, but not limited to documents and information management and retention, legal matter management, eDiscovery, and other resources and systems;• Manage total departmental spend including budgeting, forecasting, budget-to-actual variance management and all third-party expenditures;• Work with Finance, IT, and external vendors to ensure that data supporting departmental dashboard and KPIs are collected in an accurate manner and made available for use in a timely fashion;• Assist with litigation and claims management including file management, data collection and preservation (including ESI), legal holds, discovery requests, communication with outside counsel and Third-Party Administrators, and any other support needed throughout all phases of a claim and/or litigation.• Research, analyze and compile complex data sets into detailed legal and financial (internal and external) reports and assist with any other analysis and presentations needed to fulfill corporate reporting and governance obligations.

• Support the Legal Team in a broad range of legal matters, including intellectual property, employment and labor, environmental, immigration, administrative charges and litigation;• Define and drive strategic and operational initiatives, including implementation and management of e-billing software and leading a records and information management project;• Identify and implement legal department tools to streamline new or existing processes and optimize workflows;• Manage legal department budget, including outside counsel usage and spend, reporting monthly accruals, forecasting and budget variances;• Manage outside counsel relationships, including drafting billing guidelines, issuing engagement letters, conducting RFPs, and negotiating fees and AFAs;• Manage the design, implementation and training for any new legal technology;• Develop, design and report on key metrics;• Member of cross-functional Policy Committee that develops and enforces company-wide policies;• Collect trademark specimens, assist outside counsel with trademark and patent filing documentation, create IP reports, manage payment of maintenance fees and renewals, and related IP tasks;• Litigation management, including managing legal hold process, file maintenance, process service distribution, and document collections, including ESI; conducting fact-finding and witness interviews, reviewing discovery documents, responding to subpoenas, drafting legal documents, and related tasks;• Collaborate with HR, sales, marketing, support, service, EHS&S, IT, finance, and plant leaders as well as other various business units.

• Draft, maintain, review and recommend revisions to all RIM related policies, processes and procedures, as needed, to ensure compliance with relevant federal, state and local laws, rules and regulations, and industry best practices;• Implement a communications and training plan, including providing training to all business units on aspects of the RIM Program and responding to and assisting company personnel with questions regarding RIM policies, processes and procedures;• Lead physical records storage operations, including managing facility usage, inventory, and tracking programs. Coordinate and assist business units with planning storage, retention, and destruction of physical records;• Provide management and direction to RIM Coordinators with applying retention periods to their physical and electronic records based on the records retention and disposition schedule;• Coordinate with and assist IT with maintenance of structured and unstructured data, incorporation of lifecycle management requirements into information management systems design and implementation of RIM requirements during systems decommissions;• Participate in compliance testing and audits relating to RIM policies, processes and procedures;• Collaborate with Procurement and Legal during the contract approval process as it relates to implementation of RIM requirements;• Lead project team in the selection of RIM infrastructure solutions as part of the company’s information management initiative.

• In-house corporate Paralegal working in a highly regulated financial services industry;• Maintain working knowledge of current FINRA and state regulatory rules, federal and state statutes and laws, as well as the firm’s written supervisory procedures, compliance and compensation policies;• Create and maintain various summaries and reports regarding EEOC, federal and state agency claims, audits, litigation cases, legal holds, and insurance claims;• Manage the company’s debt collection docket by gathering information and partnering with accounting and outside counsel to evaluate and resolve issues, negotiate settlements, prepare repayment agreements, lead monthly status call, and review and approve invoices;• Assist in internal investigations regarding employee relations matters, including discrimination allegations, complaints, corrective actions and terminations;• Research and analyze facts regarding customer complaint matters, including creating fact timelines, conducting extensive document and ESI searches, and collaborating with outside counsel, supervising principals, compliance and other home office personnel, verbally and in writing, to determine and execute course of action to resolve matter;• Draft legal documents, including settlement, severance and separation agreements, continuing obligations letters, research memorandum and legal holds;• Assist with design, creation, and implementation of an enterprise-wide email management program, including collaborating with all business units to review and access email use and retention requirements;• Proactively review legal and business operations processes to identify risks and develop and implement solutions to improve accuracy and efficiency;• Regularly communicate with members of the company’s senior management team.

• Assisted in all phases of litigation, including conducting fact and background investigations, review and analysis of case documents for production (determining privilege and responsiveness), summarized depositions and medical records, conducted witness interviews, and supported attorneys in the courtroom;• Drafted legal documents, including disclosures, privilege logs, protective orders, bill of costs, deposition notices, subpoenas, declarations, witness and exhibit lists and discovery requests and responses;• Managed large-scale document and ESI reviews and productions, including collection, organization, analysis, redaction and retention of client documents;• Extensive experience creating complex databases and reports in MS Access and analyzing large volumes of data in MS Excel;• Analyzed data to prepare damage calculations to facilitate settlement negotiations;• Directed and oversaw Paralegal Assistants.