• Responsible for drafting, revising, and ECF filing of motions, discovery requests/responses, and correspondence.• Assist with review and production of electronic discovery using various e-discovery tools.• Assist with preparation of witnesses for depositions, hearings, mediations, and trials.• Assist with depositions, hearing and trial preparation.• Effectively prioritize assignments, manage a substantial workload and interact with all management levels and clients.

• Responsible for drafting, revising, and finalizing complaints, motions, discovery requests/responses, and correspondence.• Responsible for ECF filing of bankruptcy pleadings such as motions for relief, proofs of claim and adversary proceedings.• Assist with review and production of electronic discovery using such tools as Summation, Casemap and Relativity.• Assist with preparation of witnesses for depositions, hearings, mediations, and trials.• Assist with depositions, hearing and trial preparation.• Effectively prioritize assignments, manage a substantial workload and interact with all management levels and clients.

• Responsible for drafting, revising, and finalizing complaints, motions, discovery requests/responses, and correspondence.• Responsible for ECF filing of federal pleadings such as complaints and motions.• Responsible for states pleadings such as complaints and motions.• Responsible for ECF filing of bankruptcy pleadings such as motions for relief, proofs of claim and adversary proceedings.• Assist with review and production of electronic discovery using such tools as Summation, Casemap and Relativity.• Assist with preparation of witnesses for depositions, hearings, mediations, and trials.• Assist with depositions, hearing and trial preparation.• Effectively prioritize assignments, manage a substantial workload and interact with all management levels and clients.

• Responsible for drafting, revising, and finalizing complaints, motions, discovery requests/responses, and correspondence.• Responsible for drafting, revising and finalizing Forbearance Agreements, Security Deeds, and UCC Financing Statements.• Responsible for ECF filing of bankruptcy pleadings such as motions for relief, proofs of claim and adversary proceedings.• Assist with review and production of electronic discovery using such tools as Clearwell and Summation.• Assist with preparation of witnesses for hearings, mediations, and trials.• Assist with hearing and trial preparation.• Effectively prioritize assignments, manage a substantial workload and interact with all management levels and clients.

• Conduct internal fact gathering and investigation including responding to discovery requests.• Responsible for reviewing and editing pleadings.• Assist in identifying and coordinating witness appearances at trial and depositions.• Responsible for updating case status and significant events on litigation database.• Provide support by serving as an interface between outside counsel and internal clients.• Effectively prioritize assignments, manage a substantial workload and interact with all management levels.

Paralegal – Retail Group 2004 to 2005• Responded to requests for legal services from the Community Banking offices.• Reviewed legal documents such as wills, trusts and powers of attorney. • Advised the Community Banking offices on account opening, closing and servicing.• Assisted in responding to customer complaints; gathering records and information and drafting responses.• Drafted and reviewed policies related to retail bank practices.Investigator/Paralegal 2001 to 2004• Investigated fraud claims against the bank and its subsidiaries.• Collaborated with law enforcement and other banks to recoup losses and/or prevent further loss. • Interviewed involved parties and negotiate settlements for both internal and external bank matters.• Provided LP&S training to Community Banking and other lines of business.• Addressed control concerns and/or identified potential risk factors within the bank.• Responded to bank robberies and/or bank burglaries.