Martina Bryan Email & Phone Number

Tampa, FL, US

• Prepare affirmative defenses, replies, witness and expert disclosures, exhibit lists, initial written discovery requests, expert discovery, summons, subpoenas, requests for copies, and notices.
• Review and analyze voluminous construction project files to identify relevant and key documents in support of claims and defenses, and prepare corresponding memoranda and chronologies summarizing records.
• Draft tender correspondence and related supplemental demands, and organize policy information, as well as prepare, update, and organize additional insured tender communications chart.
• Review and track written discovery requests and responses to ensure documents are timely received and analyze such materials to determine necessary supplemental discovery (e.g., non-party subpoenas duces tecum).
• Analyze and prepare client documents for production, including bates stamping and redaction of privileged information.
• Perform public records requests to obtain building department records and information regarding construction projects.

Orlando, Florida, US

• Prepare affirmative defenses, replies, witness and expert disclosures, exhibit lists, initial written discovery requests, expert discovery, summons, subpoenas, requests for copies, and notices.
• Review and analyze voluminous construction project files to identify relevant and key documents in support of claims and defenses, and prepare corresponding memoranda and chronologies summarizing records.
• Draft tender correspondence and related supplemental demands, and organize policy information, as well as prepare, update, and organize additional insured tender communications chart.
• Review and track written discovery requests and responses to ensure documents are timely received and analyze such materials to determine necessary supplemental discovery (e.g., non-party subpoenas duces tecum).
• Analyze and prepare client documents for production, including bates stamping and redaction of privileged information.
• Perform public records requests to obtain building department records and information regarding construction projects.

Orlando, Florida, US

• Prepared answers and affirmative defenses, witness and exhibit lists, expert witness lists, pre-trial reports, discovery requests and responses, Rule 26 initial disclosures, motions to compel, subpoenas, writs.
• Performed legal and administrative duties, including preparation of correspondence and reports, and electronically filed legal documents with state and federal courts.
• Prepared chronological summaries and charts of medical records.
• Assisted with trial preparation, including redacting and preparing exhibits, attendance at pre-trial meetings and trial, and managed exhibits entered into evidence at trial.
• Prepared records to be produced in response to request for production.
• Performed social media searches.

US

• Prepared pleadings, motions, interrogatories, responses, subpoenas, writs, notices, witness and exhibit lists, and orders.
• Reviewed medical, employment, school, and criminal records, and prepared chronological summaries of records.
• Performed social media and criminal history research, and prepared chronological summaries of records.
• Assisted with mediation, hearing and trial preparation, and attended pre-trial meetings.
• Prepared case exhibits in advance of trials, including redaction of confidential information.
• Prepared records to be produced in response to request for production.

Orlando, FL, US

• Prepared pleadings, motions, discovery, orders, correspondence, and trial exhibits.
• Assisted with document production and hearing preparation.
• Prepared hearing binders.

Orlando, Florida, US

• Prepared pleadings, motions, discovery, subpoenas, writs, notices, and orders.
• Performed legal and administrative duties, including preparation of correspondence and related duties as assigned, and electronically filed legal documents.
• Assisted with document production and trial preparation, including trial exhibits.
• Analyzed documents produced in response to requests for production.
• Translated medical and legal documents for clients.
• Performed Office Manager, Human Resources, and Accounting duties, such as supervision of office staff, assist with hiring, payroll, accounts payable / receivable, settlement distributions, monthly billing, and prepared.

Technical Degree, Office Management And Supervision

Business / Accounting (High School Diploma)