Litigation Paralegal Case Management

**** **** ***** ******, *********, US, ***** •

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REBECCA VAN HOOSER

Litigation Paralegal

PROFESSIONAL SUMMARY

Litigation Paralegal with 19 years of extensive expertise in complex medical record analysis, case law research, and trial preparation. Proficient in utilizing Westlaw, DISCO, and other legal software to ensure thorough case management and successful mediation outcomes. Demonstrates exceptional organizational skills and a keen eye for detail, consistently maintaining deadlines and preparing comprehensive legal documentation. EMPLOYMENT HISTORY

LITIGATION PARALEGAL Nov 2022 - Present

BURT BARR & ASSOCIATES, LLP Dallas

LITIGATION PARALEGAL Apr 2022 - Oct 2022

CHAMBLEE RYAN PLLC

• Identified and maintained all litigation files with upcoming trial dates, all claim files prior to lawsuit being filed, all board matters and all general files, all deadlines for status reports, deposition reports and mediation reports and pre-trial reports to insurance adjustor/ and client. Maintained up to date status of approximately 300 files daily both in trial date order and alphabetically.

• As defense paralegal, drafted all initial disclosure requests and responses, reviewed document production to remove any privilege and draft objections.

• Review copious amounts of medical records and drafted medical summaries to be used at trial.

• Case review file for all documents to be reviewed by Designated expert for with medical files or necessity of treatment/billing.

Analyze complex medical records and prepare summaries for mediation, ensuring accurate case management. Coordinate with insurers and clients to provide regular updates and maintain effective communication. Assist attorneys in trial preparation, including organizing exhibits and pre-trial pleadings. Supervise legal assistants in preparing trial materials, ensuring all deadlines are met. Conduct case law research using Lexis and Westlaw, summarizing depositions to identify key statements. Conduct in-depth case law research on Lexus and Westlaw, enhancing legal strategies through comprehensive data analysis. Coordinate with legal assistants to ensure timely preparation of trial materials, fostering team efficiency and accuracy. Maintain critical deadlines for multiple attorneys, ensuring compliance with TCP and FRCP guidelines for smooth case progression.

Summarize depositions to identify impeachable statements, contributing to stronger litigation outcomes and case resolutions. Assist attorneys in all aspects of trial preparation, including exhibit organization and pre-trial pleadings, ensuring thorough readiness.

Streamlined case management by summarizing complex medical records, ensuring accurate and efficient mediation preparation.

• Review Lexis Expert Background Reports for all prior deposition or trial testimony that could effectively be used at cross- examination at trial.Analyzed and organized litigation files, ensuring timely updates and compliance with deadlines for approximately 300 cases daily.

Collaborated with legal team to draft and review initial disclosure requests and responses, enhancing the defense strategy. Reviewed extensive medical records and drafted precise summaries for trial use, contributing to case preparation. Prepared case files for expert review, focusing on medical necessity and treatment, aiding in successful case outcomes. Utilized Lexis Expert Background Reports to identify key testimony for cross-examination, strengthening trial arguments. Analyzed and managed litigation files, ensuring compliance and timely updates for 300 cases daily, optimizing workflow and case management.

LITIGATION PARALEGAL Mar 2021 - Apr 2022

EDMONDSON LAW FIRM, PLLC

• Assisted Sole Practioner Attorney with approximately sixty active client matters, approximately twenty in active litigation in both Texas State and Federal Courts and Fifth Circuit Appeal Court.

• Prepared Attorney for mediations: document review/analysis of causes of action and all pleadings in lawsuit, document review/analysis of all discovery produced and answered, documents submitted by client to establish best evidence and most irrefutable evidence for facts in case in our client’s favor, document review/analysis for best evidence that countered or mitigated facts not in our client’s favor. Assembled all bank documents, receipts, copies of check payments, medical bills, home repair bills, etc. as evidence of damages. Drafted mediation indexes to organize all evidence in mediation notebooks. Four of the six mediations I prepared attorney reached a settlement which pleased the client.

• Prepare attorney for and attend depositions: document review/analysis of causes of action and all pleadings in lawsuit, document review/analysis of all discovery produced and answered, documents submitted by client to establish best evidence in chronological order that details each aspect of the deposition witness’s role in the case. Draft Exhibit list for deposition and prepare deposition files to take to deposition. During deposition anticipate which document attorney will ask for and have it in hand.

• Prepare attorney for trial and assist attorney in courtroom at trial.

• Created task list for all members of support team which clearly establishes team’s objectives, each member’s assignments, and due dates, coordinating schedules, monitoring deadlines, maintaining trial calendars.

• Creating pleading notebooks and discovery notebooks of all pleadings filed and all discovery exchanged in lawsuit.

• Review/analysis of all documents and create exhibit lists and witness lists to submit to attorney for review. Prepare exhibit notebooks for trial.

• Document Review/analysis of deposition transcripts and deposition exhibits: draft summaries.

• Draft/prepare timelines and other visual aids to be used at trial.

• Draft/Create Trial Matrix or chart including: Each Cause of Action/Affirmative Defense; Elements: listing each element, sub-element, and factor for each claim/affirmative defense; Law: legal support for each element; Jury Questions, Instructions, Definitions; Evidence: evidentiary support for the “jury question” and Predicates: predicates necessary for admissibility of evidence.

• Create Attorney Trial Notebook including Contact list; Deadlines/to do; Case chronology timeline; Pre-trial Pleadings/discovery/orders; Pending Motions; Research/points of law; Trial briefs/memoranda of law; Pending motions; Voir Dire; Trial plan/order of proof.

• During trial, anticipate which document/exhibit attorney will ask for and have it in hand. Keep log of all exhibits introduced, admitted, and rejected for each party at trial. INTERIM EXECUTIVE ASSISTANT Oct 2019 - Nov 2019

HLH Associates

• Assist Helen LaKelly Hunt in all aspects of her work and personal life as delegated by her, keeping the strictest confidentiality.

• Proactively manages Ms. Hunt and others around her in her daily priorities and schedule, daily preparing and submitting a priorities list to Ms. Hunt, updating its progress, assuring its completion, and leading daily priorities meetings with staff.

• Manages Ms. Hunt’s e-mail, taking time to ensure that all appropriate and timely responses are made to all e-mails, drafting responses and/or responding on behalf of Ms. Hunt’s and alerting Ms. Hunt to important emails when they arrive, working in conjunction with Special Projects Manager.

• Research and ensure Ms. Hunt has all necessary materials, bios, background information, etc. in a timely manner before each scheduled meeting or conference call, for each member in the meeting.

• Take notes and participate in all conference calls, meetings requested by Ms. Hunt.

• Draft substantive and administrative pleadings: Notices to Responses/Replies to Motions for Summary Judgment.Conducted meticulous document review and analysis, ensuring accurate preparation for mediations, depositions, and trials, leading to successful settlements.

Coordinated with support team to create task lists, manage deadlines, and maintain trial calendars, enhancing team efficiency and case management.

Prepared comprehensive mediation indexes and organized evidence, contributing to favorable settlements in four out of six mediations.

Created detailed pleading and discovery notebooks, ensuring all documents were systematically organized for easy reference during litigation.

Assisted attorney in courtroom during trials, providing prompt access to essential documents and facilitating smooth trial proceedings.

Analyzed and reviewed extensive legal documents and discovery materials, ensuring comprehensive preparation for mediations, resulting in favorable settlements.

LEGAL SECRETARY Mar 2018 - Jun 2018

BELL, NUNNALLY & MARTIN, LLP

• Assisted attorneys in creditor law, including receiving initial client documents, establishing the issues usually regarding nonpayment of invoices, credit issues, improperly filed mechanic's liens or threats to file lawsuits.

• Drafted all new client engagement letters, opened new client files with accounting department and file new client opening forms with accounting.

• Reviewed established client files to research similar issues, and drafted initial 10-day demand letters, established all adverse parties to receive 10-day demand letters.

• Managed monthly billing for approximately seventy-five clients, most with up to twenty multiple matters and kept track of updating payments received and payments owed for each matter belong to each client and notifying clients of past due amounts for matters.

• Drafted all hearing notices and scheduled hearings with court coordinator.

• Drafted subpoenas for deposition, deposition notices, set up all deposition dates, schedule deposition services: set up conference rooms for court reporter including checking video set up, lab top set up, and arranging refreshment and lunch services.

• Prepared extensive presentation materials, including bound books, brochures, pamphlets, etc. for beginner and advanced classes taught by Randall Lindley in collecting liens he taught in April and in June and made all requested edits. Sent PowerPoint presentations to each attendee typically around thirty attendees for each class.

• Input and managed all updates to attorney CLE credits. LEGAL/ADMINISTRATIVE ASSISTANT Jul 2017 - Jan 2018 MEADOWS, COLLIER, REED, COUSINS, CROUCH & UNGERMAN, L.L.P. Dallas, TX

• Assisted in all administrative duties, including: receiving initial notices from the IRS and notifying clients; maintaining calendar for all IRS Agent conference calls, meetings, due dates for IRS information document requests, due dates for collection due process hearing requests and due dates for court/trial proceedings; answering initial calls from IRS Agents and clients and summarizing contents of calls for attorney; opening new client files, closing completed client files and maintaining current client files.

• Drafted initial client collection due process requests to the IRS.

• Drafted initial correspondence and applications for IRS extensions for tax relief to victims of Hurricane Harvey.

• Drafted initial 2848 IRS Power of Attorney forms for applicable for applicable quarters and years for forms 1040, 941,942, 943, 706 and 709.

• Drafted client engagement letters, client correspondence and IRS correspondence.

• Performs research and writes summary of materials/articles found.Coordinated daily priorities and schedules, leading meetings to ensure task completion and team alignment. Managed email communications, drafting and responding promptly, ensuring important messages were addressed. Conducted thorough research and prepared detailed materials for meetings, ensuring all necessary information was available. Provided comprehensive support during conference calls and meetings, including note-taking and participation. Performed in-depth research and wrote concise summaries, contributing to informed decision-making. Coordinated daily priorities and schedules, leading meetings to ensure task completion and team alignment.

• Organized and filed every incoming and outgoing client email and potential client emails, all documents sent in by client, pleadings filed, deposition transcripts, billing, etc. in Imanage program. Responsible for constant maintenance and filing of all incoming documents, pleadings, and correspondence for up to eighty clients in electronic files organized according to each attorney’s preference.Oversaw monthly billing for 75 clients with multiple matters, ensuring accurate tracking of payments and timely notifications of past dues.

Organized and filed client emails, documents, pleadings, and transcripts using Imanage, maintaining meticulous electronic records for up to 80 clients.

Scheduled depositions and hearings, coordinated with court reporters, and arranged logistics, ensuring seamless legal proceedings and client satisfaction.

Drafted subpoenas, deposition notices, and hearing notices, contributing to efficient case management and timely legal actions.

Prepared and edited presentation materials for legal classes, enhancing educational content delivered to attendees. Assisted attorneys in creditor law, managing client documents, resolving issues on nonpayment, credit, liens, and lawsuits. LITIGATION PARALEGAL Feb 2017 - Jun 2017

HARRINGTONDIXON, PLLC Dallas, TX

• Extensive project management and document analysis of large e-discovery productions.

• Gather evidentiary documents, extensive document analysis of documents procured from multiple current and former employees regarding customer needs, customer contracts, wholesaler/distributor agreements, non-compete agreements, and other financial data regarding breach of contract claims, misappropriation of trade secrets, breaches of fiduciary duty claims and other antitrust disputes.

• Create reports detailing document analysis of documents procured from multiple current and former employees regarding customer needs, customer contracts, wholesaler/distributor agreements, non-compete agreements and other financial data in relation to breach of contract claims, misappropriation of trade secrets, breaches of fiduciary duty claims and other antitrust disputes.

CONTRACT LITIGATION PARALEGAL Mar 2010 - Jul 2012

SCHEEF & STONE, LLP Dallas, TX

• Due Diligence/Document Analysis of documents seized at fraudulent oil and gas company offices to create reports identifying all oil and gas wells across the country the fraudulent company sold overriding royalty interests into investors and the status of all wells, i.e. Whether fraudulent company owned interest in the said well, the identity of the operations manager for each well, the productions status of the well, the typical monthly cost to run the well and the typical monthly revenue being produced by the well.

• Due Diligence/Document Analysis of documents seized at fraudulent oil and gas company offices to create reports identifying all investors who were sold overriding royalty interests in oil and gas wells, the number of wells the investor bought overriding royalty interests in, the number of times the investor bought overriding royalty interests, and amounts the investor paid for the overriding royalty interest with each purchase.

• Establish if sale of each overriding royalty interest to investor was "legitimate": whether the fraudulent company even owned the interest, whether the fraudulent company or main perpetrator was the seller, the interests constantly transferred between them, dependent upon date interest was sold, and finally, if the interest was already oversold.

• For each oil and gas well, that was bringing in revenue, work with the Operations Manager of the well to review typical monthly costs of running the well and work together to prioritize which monthly tasks were necessary to maintain the well and necessity of any repairs needed.

• Primary point person to work with Oil and Gas Title Expert Attorney to review all Assignments of Overriding Royalty Interests in terms of legality of actual assignment, date assignment signed vs. date assignment recorded, whether the interest sold on the assignment date was in the name of fraudulent company or main perpetrator, at what point each day assigned interests were oversold and continually reconciling this information as more document evidence was revealed.

• Input all attorney time; worked with Accounting Department monthly regarding billing clients with multiple matters and invoices.Managed IRS communications, coordinated meetings, and ensured compliance with deadlines, enhancing organizational efficiency.

Collaborated with attorneys to draft legal documents and client correspondence, improving accuracy and client satisfaction. Prepared IRS forms and client letters with precision, ensuring legal compliance and reducing errors in documentation. Streamlined administrative processes, contributing to timely client billing and effective case management. Assisted in client file management and handled initial IRS calls, providing essential support to legal team operations. Managed IRS communications and coordinated meetings, ensuring compliance with deadlines and enhancing organizational efficiency.

• Extensive Westlaw research including case law, people, and company research in breach of contract claims, misappropriation of trade secrets, breaches of fiduciary duty claims and other antitrust disputes.Managed extensive e-discovery projects and analyzed documents for complex breach of contract and antitrust litigation. Conducted detailed document reviews and created comprehensive reports, aiding in resolving high-stakes legal disputes. Performed meticulous Westlaw research on case law and company data, bolstering legal strategies in breach of contract cases. Managed extensive e-discovery projects and analyzed documents for complex litigation, significantly aiding in case resolution. Conducted meticulous document reviews and crafted comprehensive reports, enhancing the legal team's strategic decisions. Performed detailed Westlaw research on case law and company data, bolstering legal strategies in high-stakes breach of contract cases.

LITIGATION AND CORPORATE LEGAL ASSISTANT TO IN-HOUSE COUNSEL Jan 2008 - Dec 2009 EOG RESOURCES, INC. Fort Worth, TX

• Legal Assistant to In-House Counsel of Fort Worth Division of oil and gas company; prior to my arrival, attorneys had worked without a legal assistant or legal secretary for over a year.

• Created and maintained filing system for Fort Worth legal department including completed litigation, current litigation, potential litigation, acquisitions, leases and agreements, seismic operations, subcontractors, and attorney reference.

• Created and maintained electronic filing system for Fort Worth legal department as a means for attorneys to create, store and locate documents by litigation, landowner, county, acquisition, etc.

• Created and maintained a current litigation status and schedule for Fort Worth Division for twenty or more cases at a time, including: contact information for outside counsel, internal client information, county and district court information, upcoming litigation deadlines and status of depositions, mediations, and settlements.

• Worked with litigation paralegal at headquarters in Houston and land division managers to gather and review internal documents in response to subpoenas and discovery requests. LITIGATION PARALEGAL Apr 2005 - Dec 2007

SCHEEF & STONE, LLP Dallas, TX

• Due diligence/document analysis of documents seized at fraudulent investment company offices: identified and located over 150 investors and eighty brokers.

• Created detailed reports for bank accounts associated with fraudulent company including bank statement analysis, opening, and closing documents, copies of investor checks/wire transfers and confirmation of deposits of these funds into fraudulent company's bank accounts.

• Managed phone calls and correspondence with investors, brokers, and banks regarding updates to status of receivership, settlement offers and discovery requests and responses.

• Drafted pleadings including receivership fee requests, receivership status reports, abstracts of judgment, writs of execution, notices of settlement and motions for default judgment.

• Drafted subpoenas and deposition notices and worked with process servers to serve evasive individuals with multiple akas.

• Managed proof of claim process for investors: managed and reviewed incoming investor claim forms for complete investment information with back-up documents and collaborated with forensic accountant regarding any discrepancies between the investor's submitted proof of claim and the forensic accounting.

• Westlaw and Lexis research: past and pending actions against individuals and entities, current location of evasive individuals with multiple akas, and cases on point to relevant legal issues.

• Researched and established most time efficient and least costly method for selling receivership assets.

• Traveled to relevant locations/venues to market sale of receivership assets.

• Case file search in clerk's offices of federal and state courts.

• Strategize with Oil and Gas Title Expert Attorney and Receiver to establish the most equitable way to distribute receivership funds to investors according to the legitimacy of the overriding royalty interest sold, the amount of interest sold and the production success of well in assignment.Conducted document analysis to identify fraudulent royalty interests in oil and gas wells, ensuring comprehensive due diligence and accurate reporting. Reviewed legality of royalty interest assignments, verifying ownership, transaction dates, and overselling issues to ensure compliance.

Acted as primary liaison with Title Expert Attorney, facilitating legal review and ensuring the legitimacy of assignments. Identified and reported on investors' transactions, providing clear insights into the financial impact and legitimacy of their investments.

Analyzed seized documents to uncover fraudulent oil and gas well sales, ensuring detailed accuracy in reports for legal action. Identified investor transactions and assessed legitimacy of interest sales, safeguarding investor rights and enhancing legal strategy.

• Collaborated with outside counsel's paralegal to complete and submit tariff filings to the Texas Railroad Commission.Implemented and managed comprehensive filing systems, enhancing document retrieval efficiency and supporting legal operations.

Coordinated with headquarters and external counsel to streamline subpoena responses, improving compliance and reducing turnaround time.

Maintained up-to-date litigation schedules and case statuses, ensuring timely legal actions and strategic case management. Developed electronic filing systems for seamless document access, significantly improving workflow and document management.

Analyzed internal documentation for legal cases, assisting in thorough preparation and effective litigation strategies. Maintained precise litigation schedules, ensuring adherence to deadlines and effective case management, supporting strategic legal outcomes.

EDUCATION

BA IN ENGLISH LITERATURE/CREATIVE WRITING Dec 1997 Columbia University New York, NY

SKILLS

MS Windows (Expert), Mac OS X (Experienced), MS Office(Expert), IManage (Experienced), Clio (Experienced), Coyote (Experienced), DISCO (Experienced), Westlaw (Experienced), Lexus (Experienced), ProLaw, Practice Panther (Experienced), Communication (Expert), Organizational (Expert), People skills, File Management (Expert), Litigation Strategy (Expert), Summarization (Expert), Critical Thinking (Expert), Team Leadership (Experienced), Risk Assessment, Legal Compliance, Research Skills (Experienced), Legal Analysis (Experienced), Client Relations (Expert), Team Collaboration (Expert), Trial Advocacy (Expert), Deposition Preparation (Expert), Discovery Management (Expert), Case Presentation (Experienced), Legal Research Tools, Litigation Support (Expert), Legal Research (Experienced), Evidence Gathering (Expert), Document Management (Experienced).

• Testified as witness for the Texas State Securities Board in action brought against a broker in a Ponzi scheme, which helped to result in his conviction of a first- and second-degree felony after a trial by jury.Conducted comprehensive due diligence, identifying over 150 investors and 80 brokers in fraudulent investment schemes. Managed investor communications, ensuring timely updates on receivership status, settlements, and discovery requests. Drafted and filed legal documents including subpoenas, deposition notices, and motions, ensuring adherence to legal standards.

Coordinated with forensic accountants to resolve discrepancies in investor claims, ensuring accurate records and settlements. Testified for the Texas State Securities Board, contributing to the conviction of a Ponzi scheme broker on felony charges. Conducted detailed due diligence, identifying over 150 investors and 80 brokers in fraudulent investment schemes.

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