Paralegal

PATRICK DANIEL LAW Houston, Texas
• Nationwide Practice  ——————————————— NOW HIRING Senior Litigation Paralegal Position

Type:
Full‑Time

Location:

Houston, TX (In‑Office)

Experience:

5+ Years
Required Compensation:
Up to $95,000 (DOE)

• Conduct thorough review of new client files; obtain, index, and organize all client‑provided documents and records relevant to the litigation.
• Collaborate with attorneys on factual background analysis and recommend areas for further investigation.
• Calendar all statutes of limitations (SOL), scheduling orders, court deadlines, and critical case milestones.
• Maintain organized, fully digital case files in the firm’s case management system with detailed indexing for efficient retrieval.

• Draft initial complaints/petitions, motions to compel, and other procedural pleadings under attorney supervision.
• Prepare and file pre‑trial motions, scheduling motions, and motions for trial settings in state and federal courts.
• Ensure all filings comply with local rules, formatting requirements, and electronic filing (e‑filing) procedures.

• Prepare initial written discovery (interrogatories, requests for production, requests for admission) and coordinate timely responses to opposing parties.
• Work directly with clients to gather information and draft responses to interrogatories and document requests; review and revise client answers with attorneys.
• Organize, Bates‑stamp, and manage large‑scale document productions, including electronic discovery (e‑discovery) projects.
• Coordinate deposition scheduling: draft notices, prepare subpoenas, secure court reporters and conference facilities, and prepare deposition exhibits.
• Schedule and coordinate witness interviews; in certain cases, conduct initial witness interviews under attorney direction.

• Research and compile background information on opposing party expert witnesses.
• Assist in identifying and retaining plaintiff’s expert witnesses; coordinate engagement letters and fee arrangements.
• Schedule expert consultations and prepare transmittal packages with all relevant case materials for expert review.
• Draft initial correspondence to experts and manage ongoing expert communications.

• Prepare, organize, and mark all exhibits for depositions and trial.
• Build and maintain electronic trial notebooks and trial presentation materials using trial technology software (e.g., Trial Pad, Trial Director, or equivalent).
• Synchronize video depositions with transcripts; perform video and deposition editing as needed for trial presentation.
• Conduct jury venire research, review jury questionnaires and jury lists, and assist attorneys with voir dire preparation.
• Attend trial with the attorney and provide real‑time litigation support throughout the proceedings.

• Prepare initial drafts of releases, settlement agreements, and dismissal entries.
• Assist with mediation preparation, including mediation statements and exhibit binders.
• Prepare notices of appeal, order the record on appeal, and draft motions to supplement the record and motions for extension of briefing deadlines.

• Retain and coordinate with private investigators, process servers, and outside vendors as needed.
• Locate and contact witnesses; arrange service of process and prepare motions to appoint process server when necessary.
• Conduct limited legal research and comprehensive witness/background research.
• Manage file closure procedures: ensure all files are scanned, digitally archived, and transitioned to closed‑file storage with detailed indexes.

• Bachelor’s degree (Paralegal Certificate from an ABA‑approved program is a plus).
• Minimum 5 years of experience in plaintiff’s personal injury litigation (catastrophic injury, products liability, or trucking litigation experience strongly preferred).
• Strong command of litigation terminology, civil procedure, court rules, and filing requirements in Texas state and federal courts.
• Proven ability to manage a heavy caseload independently while meeting multiple…