Joanne LaVita

**** *. ***** ******

Apt. ***

Daytona Beach, FL 32114

aduvik@r.postjobfree.com

772-***-****

EDUCATION:

****-**** ******* ******** **********, Boca Raton, Florida Bachelor of Arts in Criminal Justice

EMPLOYMENT:

August 2022- Paralegal/Legal Assistant, Pozo Diaz & Pozo December 2022 Miami, Florida

Work remotely for a small boutique firm based in Miami. Work with one attorney handling premises liability cases as well as bodily injury cases and had caseload of approximately 27 cases. Managed attorney’s calendar, ensured deadlines and jurisdictional rules and procedures were adhered to. Familiarity with filing pleadings through the state E-filing Portal as well as Federal filings. Propounded and responded to discovery, drafted pleadings, and correspondence. Coordinated depositions, mediations, inspections, medical examinations of Plaintiff with opposing counsel as well as mediators and retained experts. Reviewed and processed all invoices though AIM for accounting to pay. Breakdown and review of claim file and obtain information on collateral source providers to prepare Notice of Production from Non-Parties and Subpoenas to obtain medical records of Plaintiff. Prepared case summaries and summarized discovery responses oof Plaintiff. Trial preparation consisted of preparing exhibits for exhibit exchange, preparing any demonstratives, making any travel accommodations for witnesses, preparing subpoenas for trial, and drafting witness and exhibit lists. Other duties as assigned

October 2021-

May 2022 Legal Assistant/Paralegal. The Rock Law Group Maitland, Florida

Work with attorney handling first party property cases as well as Bodily injury cases. Propound and respond to discovery, draft motions and other pleadings; investigate compile and submit obtained information to adjuster to assist in the furtherance of defense of the matter. Set up property inspections, communicate and retain medical experts as well as engineering experts. Manage attorney’s calendar, set depositions, hearings, mediations. Prepare exhibit lists, witness lists, releases, etc. Other duties as assigned. April 2020-

June 2021 Litigation Paralegal, Hassell Legal, P. A. Daytona Beach, Florida

Litigation paralegal in insurance defense firm handling first party property matters as well as automobile accidents and skip and falls. Responsible for propounding and responding to discovery, drafting motions, pleadings. Summarizing medical records, drafting Notices of Production from Non-Parties and subpoenas. Bates indexing, Entered billing, communication with adjusters, mediators, experts, and medical providers. Trial preparation consisted of preparing exhibits for exhibit exchange, drafting witness and exhibit lists. Coordinated inspections and Compulsory Medical Examinations. Other duties as assigned.

July 2019-

April 2020 Legal Assistant, Mateer Harbert, P.A.

Orlando, Florida

Worked for Shareholder and Partner in the areas of Plaintiff Malpractice and Insurance Defense. Manage calendars, calendar deadlines, coordinate and set depositions and mediations. Draft correspondence and pleadings, enter billing, assist medical paralegal in obtaining medical records, screen potential new clients, handle travel arrangements, trial preparation. Other duties as assigned. August 2017-

November 2018 Legal Assistant/Paralegal, Lydecker Diaz Orlando, Florida

Worked for a partner and associate handling third party/bodily injury liability, wrongful death, general liability, government liability, first-party defense. Draft simple discovery and other pleadings, maintain attorneys’ calendars, schedule hearings, mediation, deposition, CMEs, process check requests, pre-bills, attorney expenses, records review, E-filing. Research rules and effect service on out-of-state witnesses. Filing, opening/closing of files. Communicate with adjusters and provide them with status updates, medical records review, Notices of Production Non Party, prepare subpoenas/medical records requests for both pre litigation and litigation files. Assigned projects from Shareholder located in Miami from time to time.

April 2015-

August 2017 Legal Assistant, Groelle & Salmon, PA

Maitland and Vero Beach, Florida

Worked for a Partner and associate attorney in an insurance defense firm that handled first party property, bodily injury, and premises liability claims. Duties included draft pleadings, scheduling of hearings, mediations, depositions, inspections; maintain communication with client and provide status updates; file documents with the court via E-filing. Research rules for other states when deponent resided out of Florida jurisdiction; docket entries in case management system (Time Matters); compile documents for and prepare hearing binders, deposition binders; ensure all “to-dos” entered in Time Matters and closed as completed. Upload documents to carriers’ website as required; send and monitor responses to subpoenas/records requests; assist in preparing budgets and submit to carriers; manage attorneys’ calendar; assist in training of new legal assistance; cover reception as needed; close files, prepare settlement documents, receive, verify and send settlement checks. Prepare weekly expense reports and monthly firm credit card report and send to accounting. Make travel arrangements. Assisted other offices at times when the workload was heavy.

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