Continual review and management of case files from inception through mediation/arbitration/trial/settlement; Prepare subpoenas compelling depositions and/or document productions; Prepare initial discovery, i.e., interrogatories, request for production, request for admissions; Prepare draft responses to discovery, including document productions and corresponding privilege logs; Prepare attorneys for depositions; Prepare depositions summaries/abstracts; Research, vet and engage with subject matter experts; Monitor deadlines for responses and timeliness; Prepare legal documents such as briefs, pleadings, fact/medical chronologies, agreements, and/or trial and/or mediation binders for use by attorneys; Investigate facts as requested by attorneys; Capture and record billable time in compliance with firm policies and client guidelines; Trial preparation - prepare trial subpoenas, trial notebooks, exhibit lists, witness lists; engage in witness management; schedule trial testimony; prepare and manipulate trial presentations and other trial-related tasks as necessary; and. Litigation Paralegal with experience in the area of insurance defense and general civil litigation who will perform a variety of duties including researching law, investigating facts, and preparing documents for attorneys according to established policies and procedures.