Of Counsel attorney assisting in commercial litigation matters.

• Developed litigation and organizational procedures for start-up first-party insurance litigation firm. • Daily interaction with multi-cultural clients utilizing fluency in Spanish.• Managed team of paralegals and attorneys to efficiently progress matters to their conclusions.• Managed case load representing home and commercial property owners.• Experienced in declaratory action litigation for both Plaintiffs and Defendants.• Gained exposure to legal malpractice litigation.• Handled commercial litigation disputes.

• Managed heavy case load representing home and commercial property owners.• Litigated high volume of matters in Federal Court, including but not limited to, the Southern District of Florida.• Assisted in trial preparation including, but not limited to, document production such as witness and exhibit lists, pretrial stipulations, jury instructions, etc.• Worked closely with paralegals and other support staff to coordinate litigation efforts.• Researched a variety of legal issues relevant to substantive and procedural law.• Routine hourly billing and corresponding task assignment and completion.• Prepared, reviewed and approved discovery responses and motions, including summary judgments and responses thereto.• Reviewed litigation cases and developed strategy action plan.• Regularly negotiated with opposing counsel to reach settlements and resolutions.• Prepared and participated in countless depositions, mediations, and hearings, including special set hearings.

• Litigated on behalf of home and commercial property owners including condominium owners against associations.• Deposed insurance adjusters, corporate representatives, experts, and third-party neutral witnesses. • Defended depositions of Plaintiffs, Plaintiffs’ experts, and Public Adjusters.• Prepared necessary motions to keep litigation moving forward, including Motions for Summary Judgment, Motions to Strike Affirmative Defenses, Motions in Limine, Motions to Overrule Discovery Objections.• Drafted necessary responses to Motions for Summary Judgment, Motions to Compel, and Motions to Dismiss the Complaint on behalf of Plaintiffs. • Attended and argued all necessary motions at open motion calendar and special set hearings.• Conducted initial client interviews, initial case evaluation, and developed the strategy.• Trial experience and preparation which included production of trial documents such as Witness, Exhibit and Expert Witness lists.• Managed support staff including law clerks and paralegals.

• Experienced in first party homeowner breach of contract and tort, specifically wrongful death litigation and in construction litigation.• Conducted initial reviews of case assignments, initial client interview conferences and follow up memorandum reflecting case facts, preliminary litigation strategy and estimate of billable hours.• Drafted countless pleadings, motions, order, memorandums of law, discovery requests and responses, etc.• Regularly argued motions in the 11th Circuit Court for Miami Dade County, 17th Circuit Court for Broward County and Miami Dade County Court. • Experienced in taking and defending depositions.• Attended hearings regularly to argue a broad range of motions, including summary judgments, dismissals, discovery.• Negotiated settlements informally, mediations, and various alternate dispute resolutions• Trial preparation and production of trial documents such as Pretrial Disclosures, Witness, Exhibit, Expert Witness lists.• Drafted jury instructions and verdict forms and reviewed with witnesses• Updated case status to ensure litigation progression and development.• Interacted regularly with firm staff to create, implement, and oversee efficient, functional case management procedures.

• Worked primarily on homeowner litigation and personal injury claims, with some experience in immigration, divorce proceedings and negligence actions. • Produced settlement packets for personal injury claims, used directly in resolving clients’ claims with insurance adjusters.• Conducted client interviews to gather facts surrounding cases. • Drafted motions, complaints and other pleadings. • Worked directly with clients to respond to all discovery and for deposition preparation. • Assisted in negotiating settlements, preparing in-house reports, balancing the legal arguments and conducting settlement conferences.

• Performed pro bono hours helping low income immigrants needing legal advice and services. • Contacted potential clients to schedule and perform preliminary client interviews. • Assisted in determining a potential client’s eligibility for free legal services provided.