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. • Conduct public records research to obtain and analyze condominium documents and restrictive covenants, notices of commencement, certificates of occupancy, warranty deeds, and liens. • Conduct internet investigation of witnesses and corporate entities to prepare summons and assist attorneys in deposition preparation.

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. • Conduct public records research to obtain and analyze condominium documents and restrictive covenants, notices of commencement, certificates of occupancy, warranty deeds, and liens. • Conduct internet investigation of witnesses and corporate entities to prepare summons and assist attorneys in deposition preparation. • Prepare chronological summaries of medical records, employment records, and medical bills. • Prepare records and notebooks for depositions.

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, notices, and orders.• 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.• Engaged private investigator to conduct surveillance and coordinated activities associated with same.• Communicated with clients, opposing counsel, and expert witnesses.• Prepared medical records and diagnostic studies to provide to expert witnesses.• Translated correspondence and direct correspondence with governmental offices in Germany regarding official forms, legal notices, demand letters, and remittance.

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 and maintained standard operating procedures.

Technical Degree, Office Management And Supervision

Business / Accounting (High School Diploma)