Responsibilities include: Propounds and responds to written discovery;Review and finalize complaints; draft related pleadings, submits to process server; calendars deadlines;Drafts initial and supplemental disclosures; gather pertinent medical records and disclosures;Capture/tracks billable and non billable time in case management system;Request certified copies of medical records;Works as part of a paralegal team;Drafts Requests for Exemption and related pleadings;Drafts Notices of Depositions coordinated logistics for same;Drafts Counterclaims and Cross-Defendants Answers;Meets with clients regarding Discovery Requests and responses; andKnowledge of Microsoft Applications (Word, Outlook, Excel).