PITTSBURGH EPL PARALEGAL RESPONSIBILITIESPrepare and send Litigation Hold Memo to client Send MMSEA – request social security number from client and provide to claims Send initial document request via email (at attorney discretion as attorney generally includes this in initial email) Discovery – service and answering o Once counsel have had a Rule 26 conference call, inquire as to whether discovery can be served on plaintiff (can be prepared in advance for review, edits and supplementation) Prepare Interrogatories and Request for Production of Documents to Plaintiff and serve on counsel (can be prepared in advance for review, edits and supplementation) Monitor plaintiff’s responses to our discovery. If overdue, send overdue letter. Advise attorney once discovery is received and send discovery requests to client ASAP to begin discovery process o Paralegal will complete Request for Production of Documents Request for Production of Documents Format responses, send to client, preparation of general objections and draft responses for review by attorney; work directly with client to ensure receipt of documents/answers to request for production of documents in a timely manner. Interrogatories – Paralegal will set up with general objections and certain specific objections (i.e., expert and/or emotional damage) for attorneys’ review and completion Attorneys will contact clients to complete Interrogatories o If we need additional time to respond to discovery, request extension prior to discovery due date.Draft Position Statements (at attorney discretion) Assemble/redact exhibits for Position Statements Assemble, organize and label documents received from clients in ProLaw Draft Initial Disclosures in Federal cases. Upon receipt of Plaintiff’s Initial Disclosures, pull expert information and request medical recordsOrder and monitor medical record requests (obtain information from Plaintiff’s Disclosures and Plaintiff’s responses to our Interrogatories) Follow-up with Ontellus (or other document management company), as necessary Advise Ontellus (or other document management company) to stop work once a case has been resolved Expert subpoenas (not depositions). Secretary will be responsible to schedule court reporter and videographer Perform docket search after receipt of 90-day dismissals After 90 days, email attorney and secretary notifying them of search Send FOIA requests to EEOC/PHRC/Unemployment Compensation when a case transfers from agency to litigation 5 years of Employment Law and General Litigation Experience with filing in the Allegheny County and surrounding Pittsburgh county court systems.Familiarity with billing processes on matters.