Litigation Paralegal
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Job Description
Litigation Paralegal supporting plaintiff-side personal injury and civil litigation firm, managing discovery, depositions, and trial preparation.
Responsibilities:
- Draft written discovery including Requests for Production, Interrogatories, Requests for Admission, and Requests for Disclosure under Texas Rules of Civil Procedure
- Draft responses to written discovery received from opposing parties; review, organize, and assemble responsive documents for production
- Prepare and maintain privilege logs; coordinate redaction review with supervising attorney
- Monitor discovery deadlines and respond to or send supplemental discovery as required
- Use BriefPoint or comparable platform to manage and organize discovery responses
- Schedule and coordinate in-person and video (Zoom) depositions of fact witnesses, treating providers, corporate representatives, and expert witnesses
- Prepare and serve notices of deposition, subpoenas, and deposition topics for corporate representative depositions
- Arrange court reporters and videographers; manage remote link logistics and confirm all party appearances
- Prepare deposition summary outlines and chronological exhibit binders for attorney review
- Collect, index, and electronically organize deposition transcripts and exhibits following completion
- Draft and submit Public Information Act (PIA) requests to Texas state agencies, municipalities, law enforcement agencies, and regulatory bodies
- Obtain medical records, billing records, and employment records through HIPAA-compliant authorizations and subpoenas
- Retrieve trucking-related records including driver qualification files, ELD/GPS data, DVIRs, and maintenance logs from carriers and third-party vendors (Motive, KeepTruckin, J.J. Keller, etc.)
- Request and track HHSC, DADS, and Long-Term Care Ombudsman records in nursing home matters
- Follow up on outstanding records requests and document all correspondence and receipt dates in the case management system
- Maintain and monitor all deadlines across approximately 50 active litigation files using MyCase or comparable case management platform
- Track and calendar scheduling orders, discovery cutoff dates, expert designation deadlines, and trial settings
- Prepare and file pleadings, motions, and discovery in Texas state courts through eFileTexas; monitor TylerTech filing confirmations
- Draft routine motions (motions to compel, motions for extension of time, agreed scheduling order modifications) for attorney review and approval
- Maintain organized electronic case files; ensure all documents are properly named, dated, and categorized
- Prepare trial exhibit lists, witness lists, and deposition designations
- Organize and index trial exhibit binders (physical and electronic) and coordinate pre-trial submissions
- Assist with jury charge research, trial notebook preparation, and pre-trial briefing support
- Coordinate subpoena service for trial witnesses; maintain trial team communication log
Requirements:
- Minimum 1 year of paralegal experience in plaintiff-side personal injury or civil litigation required; 3+ years preferred
- Texas paralegal certificate, ABA-approved paralegal program certificate, or Associate's/Bachelor's degree with equivalent litigation experience
- Demonstrated proficiency drafting Texas civil discovery under the Texas Rules of Civil Procedure
- Experience with Chapter 74 expert report requirements (medical malpractice) strongly preferred
- Familiarity with FMCSA regulations and trucking litigation evidence (ELD, DVIR, HOS logs) a significant plus
- Proficiency with case management software (MyCase preferred) and eFileTexas
- Strong working knowledge of Harris County District Court local rules and procedures
- Excellent written communication, organizational, and time-management skills
- Strong work ethic with a hard-working, dependable approach to daily responsibilities
- Eagerness to learn firm processes, practice area nuances, and evolving legal technology
- Technologically proficient and comfortable adopting new software platforms, remote collaboration tools, and digital workflows
- Reliable high-speed internet connection required for fully remote work.
Benefits:
- remote/virtual position
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