The Paralegal Department willcollect, organize and maintain files, including pleadings, motions, and checklists. We will maintain a litigation docket, or calendar, noting deadline dates for responsive pleadings/motions, court appearances, and other important deadlines. We will remind you and prepare you for meetings, hearings, depositions and trial.
In addition, we will provide you with the following services:
Draft complaint, interrogatories and production requests to file with court and serve upon opposing parties.
Arrange for service of process.
Draft responsive pleadings.
Participate in alternate dispute resolution, mediation, or arbitration.
Conduct or coordinate factual investigation, including interview of witnesses.
Prepare chronologies from deposition testimony, documents, and other factual records.
As necessary and appropriate, communicate and correspond with client about case status and preparation.
Document Production
Review and obtain all relevant documents in client's possession; work with attorney to determine documents to produce.
Review, index, organize, analyze, and summarize documents produced by other parties.
As necessary and appropriate, prepare additional discovery requests; follow up on outstanding discovery requests to ensure response by opposing party.
Update discovery responses as additional information is collected.
Coordinate deposition schedule with client, attorneys, and opposing counsel.
Draft notice of oral deposition and serve subpoenas; if necessary draft duces tecum language for inclusion in subpoena to acquire additional documents.
As necessary and appropriate, prepare commissions to take out-of-state depositions.
Review and assemble documents to be used in deposition.
Retain court reporter and determine need for computerized or videotaped transcript.
Attend deposition and assist attorney by taking notes and organizing
exhibits identified during depositions.
Index and summarize deposition testimony and exhibits.
Draft list of documents and testimony to use in impeaching opposition witnesses and/or identifying inconsistent information.
The Paralegal Department will collect, organize and maintain files, including pleadings, motions, 
Document Production