Lizette V. Gruma

Preparation of medical chronologies and radiology chronologies: High-level summary or case overview, complete timeline of events, impairment rundown detailing a patient's medical history and relevant information for each body system, supplemental documents such as diagnostic and therapeutic procedures, medication, surgery, lab results and images.

• Preparation of new file by researching the court docket, Judges’ procedures and contact information for all parties involved
• Draft pleading template
• Prepare, organize, store, and retrieve case files, which may include evidence, depositions, pleadings, exhibits, and other documentation
• Drafts motions, discovery, affidavits, notices; file documents with the Court
• Assists attorneys with depositions, mediation and trial preparation
• Summarize deposition transcripts and medical summaries
• Download caselaw from Westlaw as cited in pleadings to serve as an attachment or for attorneys’ review
• Review, organize voluminous documents
• Prepare responsive documents to Request for Production
• Prepare documents for Independent Medical Examinations
• Review all eservice filings received from Court
• Calendar deadlines and save court filings in ProLaw
• Preparation of Binderteks for Judges’ and attorneys’ review/reference
• Scheduling of hearings, depositions, mediation, meetings
• In-House Office Administrator

• Obtain, review, organize, and analyze preliminary documentation and information regarding facts of lawsuit
• Review rules of procedure in court where action will be filed
• Draft interrogatories, requests for admissions, requests for production of documents, and requests for examination or inspection
• Obtain written reports/analyses of physical evidence, injuries, issues, and financial evaluations
• Gather, organize, summarize and analyze factual data collected
• Draft responses to discovery requests
• Examine and, if necessary, obtain public records relevant to facts of lawsuit
• Conduct research to locate, communicate with, interview, and retain expert witnesses
• Prepare chronologies from deposition testimony, documents, and other factual records
• Assist attorney in reviewing documents for privilege; draft log of privileged documents for production to opposing counsel in lieu of producing actual documents
• 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
• Draft outline of questions for examining of witnesses at depositions
• Review and assemble documents in preparation for 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
• Preparation of binders for hearings, depositions and mediation
• Correspond with clients (Personal Injury cases)

• Company Overview: Freelance Tobacco and Complex Civil Litigation Paralegal
• Freelance Tobacco and Complex Civil Litigation Paralegal