Litigation Paralegal
Resume:
Andrea P. Hart
Post Office Box ****
Stone Mountain, GA 30086
**********@*****.***
**/ **** – 02/2015
EMPLOYMENT: Contract Positions
Litigation Paralegal (Contract Positions)
Higher Education, Office of the General Counsel, Board of Trustees ;
Specializing in multi-state wrongful death and soft-tissue lawsuits;
Draft Complaints/Amended Complaints;
Conduct legal research;
Draft and respond to Discovery;
Frequent communication with clients;
Regular communication with judges’ staffs;
Regular communication with opposing counsel/staff;
Regular communication with medical and other providers; and,
Hearings and trial preparation.
Specialty areas included: Tractor-trailer truck accidents, automobile accidents, slip and
fall, and premises liability, and medical mal-practice matters, Georgia and Florida practice,
e-discovery.
10/2005 – 11/2013
GWINNETT COUNTY DEPARTMENT OF LAW
Litigation / Transactional Paralegal
Government Defense and P laintiff’s litigation paralegal;
Real Estate Closings;
Investigated personal injury claims/lawsuits filed against county/employees;
Interviewed and memorialized claims internal/externa l witness interviews/statements;
Determined liability and recommended settlement amount;
Timely responded to Open Records Requests ;
Drafted pleadings to include: complaints and ans wers;
Drafted affidavits and discovery;
Conducted extensive statutory, case law, ordinance, and Internet researches;
Responsible for extensive e-discovery production in Service Delivery Strategies lawsuit;
Trial/deposition/mediation preparation, assistance, and participation;
Investigated employee and citizens’ claims/lawsuits;
Assisted in gathering and reviewing EEOC documents;
Regularly included in case strategy meetings;
Worked and communicated with outside counsel as needed;
Routinely communicated with internal and external clients;
Assisted with identifying legal issues for state and federal matters;
Secured, analyzed, and produced evidence;
Responded to internal client needs for research and assistance;
Reviewed new and old legislation to assist department s with compliance;
Drafted policies and procedures for departments as needed;
Conducted post-judgment collections to include default/judgment garnishment pleadings;
Skip traced absentee prop erty owners, tax evaders, etc.;
Research routinely used in winning motions for summary judgment;
Drafted memoranda and general legal/business correspondence;
Drafted and complied real estate closing package d ocuments for FEMA grant program;
Trained others and reviewed work for FEMA grant program; and,
Reviewed/edited County’s federal litigation “hold” policy.
Practice areas included: labor and employment law, risk management claims/suits, insurance
defense, zoning litigation, breach of contract/post-judgment collections, section 1983
claims/suits, condemnations, some bankruptcy, certain real estate transactions (FEMA Grant
Program); and county/state government law.
4/2004 – 9/2005
FELLOWS, JOHNSON & LA BRIOLA, LLP
Civil Litigation Paralegal
Plaintiff’s and Defense paralegal;
Supervised shared legal assistant;
Assisted with trial preparation;
Drafted complaints and answers;
Routine communication with clients;
Performed legal research and analyzed evidence;
Regular interaction with outside legal professionals; and,
Post-judgment collections from complaint to default to asset /party search and locate.
Practice areas included: construction, asbestos defense, medical malpractice,
Breach of contract/post-judgment collections, insurance defense, and maritime law.
5/2002 – 4/2004
NAKAMURA, QUINN & WALLS, LLP
Labor and Employment Paralegal
Paralegal/Administrator;
Prepared EEOC charges, complaints, motions;
Drafted discovery and other legal documents; and,
Managed office; prepared time and billing statements for Atlanta office.
4/2001 – 7/2003
THE MACKENZIE AGENCY (Contract)
Investigative Agency
Paralegal/Investigator drafting post-conviction relief reports; and,
Interviewed references, retrieved and reviewed transcripts and other court documents.
LAW OFFICE OF BRENDA JOY BERNSTEIN (Contract) 5/2001 – 10/2001
Criminal Defense Paralegal
Contract criminal defense paralegal;
Reviewed evidence, conducted initia l interview of new clients; and,
Communicated with probation officers, district attorneys’ offices; and judges/staffs.
ASSOCIATIONS: GEORGIA ASSOCIATION OF PARALEGALS
(GAP)
Chair, GAP Technology Conference, 2007
PACE Registered Paralegal, February 2006
PACE Scholarship Award Recipient, 2004
Member, Since 2001
GEORGIA COUNCIL OF COURT ADMINISTRATORS
(GCCA)
Member, 2001
EDUCATION: THE NATIONAL CENTER FOR PARALEGAL TRAINING, INC.
ABA Approved Paralegal Certificate, Civil Litigation Major, With Honors
OBERLIN COLLEGE AND CONSERVATORY OF MUSIC
Bachelor of Music, Voice Performance,
CLE COURSES Nuts & Bolts of Local Government Law, ICLEGA; Winning Settlement Demand ATTENDED:
Packages, ICLEGA; Georgia Auto Insurance, ICLEGA; Labor and Employment Law Institute,
ICLEGA; Electronic Discovery, ICLEGA; Georgia Laws of Torts; ICLEGA; E-Discovery, GAP;
Employee Blogging, Emory Center for Lifelong Learning
LEGAL SKILLS/ Comfortable drafting policies and procedures, as well as various pleadings and discovery t o include:
CERTIFICATIONS: complaints, all types of discovery, motions, and memoranda. Adept at researching statutory and case
law, summarizing depositions and fully familiar with filing procedures in federal and state courts and
service of process rules. Familiar with family law, employment law, governmental/municipal law, debt
collection law/procedures, criminal law, eminent domain, risk management. PACE Registered Paralegal
since February 2006. Experienced and sworn superior court deputy clerk. Notary public.
PRACTICE AREAS: Labor and employment law, property damage, personal injury, zonin g litigation, p ersonal injury, Property
damage, condemnations, government law, construction, asbestos defense, contracts, medical malpractice,
breach of contract/collections, insurance defense, Section 1983, bankruptcy, criminal defense,
government, real estate transactions, (FEMA Grant Program); and family law.
SOFTWARE: Microsoft Suite, Client Profiles, TimeSlips, Needles, Lexis Nexis, West Law
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