Associate
CurrentAnalyze complaints to prepare responsive pleadings. Propound and respond to written discovery. Evaluate medical and billing records to independently negotiate settlements. Participate in settlement negotiations with co-defendants for complex actions. Draft motions and oppositions to motions for summary judgment. Participate in trial preparation by drafting motions in limine, witness lists and examination lines. Take depositions of percipient witnesses and participate in depositions of expert witnesses. Counsel clients about litigation strategy by preparing written reports and through telephone conferences.