Braden S. Allen

• Continue to perform all essential functions of Paralegal (described below) and also oversee/assist legal support staff on other files as needed
• Perform conflicts checks for new matters and assist Managing Partner with evaluating staff's current workload to appropriately assign new files
• Conduct quarterly meetings with paralegals and other legal support staff to relay any changes to local rules or court forms, ensure staff has resources needed to perform duties efficiently, and ensure routine pleadings and correspondence prepared by legal support staff are done consistently firm-wide
• Assist shareholders in preparing client development materials and coordinating meetings with potential new clients
• Training new paralegals and other legal support staff as needed

• Draft pleadings, motions, discovery, briefs, memoranda, and correspondence
• Assist with case management, strategy, and progression
• Assist attorneys in deposition preparation including drafting witness questions and compiling necessary exhibits to be offered during depositions
• Assist with all aspects of discovery including preparing discovery requests, objections and responses, issuing all types of subpoenas, and coordinating depositions
• Assist in the collection, review, and production of documents during the discovery phase of litigation
• Prepare for and attend client meetings, document productions, depositions, hearings and trials
• Prepare summaries of depositions, documents and medical records
• Perform legal and nonlegal research
• Handle routine correspondence with client including regular status reports on litigation
• Assist with trial preparation by identifying and marking trial exhibits, preparing outlines for direct and cross examination of witnesses, coordinating necessary travel arrangements and various resource needs for trial, and preparing witnesses and experts to testify at trial

• Scrutinize medical records and prepare legal memoranda summarizing treatment for use at hearings
• Perform extensive background investigation on potential clients