English Tutor Litigation Paralegal

Robin M. Johnson

*** ***** ****** ******

Unit **5

Los Angeles, California 90015

March 13, 2023

VIA DIRECT UPLOAD:

Warner Bros. Discovery

ATTN: Human Resources Department

Burbank, California

RE: Sr. Paralegal Position, RE000065339

To Whom It May Concern,

Attached for your review and consideration is my resume. As indicated in my resume I have worked as a paralegal in the state of California and the state of Nebraska. In California, my legal background is in civil arbitration and litigation on both the state and federal levels. I was involved at the onset of the case through arbitration and litigation. Each matter on which I worked required attention to detail, analytical ability and methods of organization that portrayed the facts and conjectures in a chronological format to portray the full breadth of the story. File organization also included maintaining client documents and locating key documents to build a digital folder of evidence to substantiate facts and conjectures. I often communicated with the client verbally and via e-mail to communicate information as directed by the attorney and to request explanation of documents provided by the client that were pertinent to the case. Once depositions were taken in the case, I often had the responsibility of summarizing the depositions in table form which was arranged in chronological format with citations to evidence and cross references to other depositions. The legal research assigned to me included locating cases similar to the present case in terms of fact and legal theories. Further the research included locating applicable state and federal laws pertinent to arbitrating or litigating the present matter. Research also included investigating the parties in the case through Accurint, TLOxp and Lexis Nexis to discover assets and affiliations. Most of the writing completed included complaints for damages, answers to complaints, discovery requests and responses, expert witness disclosures, protective orders, various declarations, motions and proposed orders subpoenas and succinct case summaries. With each of the matters that I worked on I had the dutiful and ethical responsibility to assist in the representation of the client’s interests to the best of my ability. It was a privilege to serve each attorney at these California law firms. 1

A majority of the time spent as a paralegal in Nebraska was at the Mutual of Omaha Companies

“Company” or “Companies”)where I was responsible for a subsection of lawsuits filed by Companies and individuals against the Companies. I was responsible for receiving these lawsuits and commencing the opening process by opening a file in the computer system and Page 2 of 2

meeting with the departments which appeared to be affected by the allegations of the complaint. During this meeting a discussion was had to retrieve all forms of storage of those documents that may be relevant to the plaintiff(s) allegations of the lawsuit. At the direction of in-house counsel I would proceed to locate candidates for local and outside counsel. After local counsel was interviewed and hired, I functioned as a liaison between local counsel, in-house counsel, individuals from the 1 A number of these lawsuits were class actions and consolidations. Companies and third parties. I also functioned as the paralegal to outside counsel working on discovery responses, subpoenas, affidavits, fact sections of briefs and motions, chronologies, matrices, charts and inventories of documents. I attended depositions and trials associated with these cases. I conducted interviews of Company witnesses and provided their statements to outside counsel. As each case proceeded to and through trial, mediation and appeal, I assisted outside counsel by preparing witness and exhibit lists, trial exhibits and other projects as they were assigned. During the pendency of these lawsuits, I received, reviewed, gathered documents and drafted responses to third party subpoenas served on the Companies. Additionally, I received, reviewed and researched answers to legal questions posed by departments within the Companies as a legal review. Various departments would submit requests for assistance with respect to major projects they were working on. When Mutual of Omaha planned to exit the major medical insurance industry, I was asked to assist with making certain that the protocol required for each state was followed. I assisted the agency department with revising the agent and general manager contracts. I assisted the mergers and acquisitions department with the due diligence process undertaken before the contracts were signed to merge or acquire. The law division had departments dedicated to employment, government, lobbying, real estate and regulatory. I assisted these departments as requested. I attended committee meetings on behalf of the litigation department and other departments as requested. The general counsel and director of the litigation department represented the executive floor in legal matters. Because I was their paralegal, I had the privilege of assisting the CEO and CFO with delicate matters and special projects. I also had the privilege of working with and for affiliate companies such as broker dealer KFS-BD and on environmental concerns such as oil jobbers. It was a privilege to work on a wide array of matters and projects with these companies. Additionally, I was assigned a subsection of the Company’s subrogation matters. I assisted counsel with negotiation of matters over $30,000 and personally negotiated subrogation matters under $30,000. I drafted the release and settlement agreements for these subrogation matters. I preformed surveys of certain laws questioned by specific departments by tracking the language of that law state by state and creating a matrix of these laws for easy review and comparison. My responsibilities also included receiving, reviewing and analyzing billing statements from outside counsel. I prepared draft outside counsel billing guidelines and tracked budgets for lawsuits and compared the expenditures to these budgets.

In reviewing this letter and resume, I hope that Warner Bros. Discovery will find that I fulfill the requirements expected for the position of senior paralegal. Should the office need to reach me, I Page 3 of 3

may be reached by mobile telephone at 818-***-**** and/or *****.***.*******@*****.***. I look forward to hearing from Warner Bros. Discovery.

Sincerely,

/s/Robin M. Johnson

Robin M. Johnson

Attachments: Resume

RESUME

950 SOUTH FLOWER STREET, ROBIN UNIT M. JOHNSON 415, LOS ANGELES, CA 90015 MOBILE 818-***-****

S U M M A R Y OF Q U A L I F I C A T I O N S

Paralegal with over twenty years experience in arbitration and litigation. Areas of experience include: acquisitions

(due diligence/pre-planning); airplane manufacturer defects; antitrust; banking; bond and surety contract broker- dealer; class actions; consumer and compliance issues; employment disputes; document retention and destruction; environmental matters; food service and production (ConAgra); insurance: disability, health, life, property and casualty and workers compensation insurance defense; grand jury Investigation; health care and hospital liability; intellectual property; information management; internal audit investigations; NASD/FINRA, SEC, and FBI inquiries; product liability and manufacturer defects; professional malpractice including attorneys and healthcare practitioners; regulatory matters; trademark and patent disputes; wage and employment matters; work product privilege disputes.

P R O F E S S I O N A L L E G A L E X P E R I E N C E HINSHAW & CULBERTSON, LLP - Los Angeles, CA, USA – PARALEGAL- May 2022 to September 2022 o Pre-planning: Assist with cost estimation/litigation plans; o Pre-discovery: (Federal and/or State) Assist in case assessment, fact development, review of documents to create timelines/chronologies, locate key documents; and other case administration as required; o Pre-Trial Pleadings (Federal and State): Draft and prepare interpleaders with exhibits; draft and prepare responsive pleadings (answers and demurrers); prepare proposed orders; draft and prepare affidavits and declarations; draft motions of various types;

o Pre-Trial Discovery: (Federal and/or State) Draft and prepare initial disclosures; form and special interrogatories; requests for production and admission; draft deposition subpoenas for personal appearance and for documents with associated document requests; selection of and preparation of documents for use at deposition; preparation of expert witness disclosures; prepare draft protective orders; prepare summaries of depositions; assist with discovery plans and deposition outlines; o Dispositive Motions: Preparation of exhibits, declarations, separate statements and proposed orders; o Hearings and Trial (State): Attend court calls, ex parte hearings and trial hearings on behalf of counsel; appear in small claims court on behalf of the client; o Arbitration and Trial: Prepare exhibits, prepare exhibit and witness lists; prepare witness folders, trial subpoenas and on call agreements and effect service of same; o Post-Trial: Prepare memos of cost and initiate document destruction per protective orders; o Appellate: Preparation of appellate filings including notices, appendices and exhibits; o Other Review and analysis; background research on companies, opposing parties, opposing counsel, judicial assignments and witnesses through investigative, legal, legislative, and corporate research as applicable; o Other Assistance: communications with clients on behalf of counsel; factual, investigative and legal research and summarization of same; assist with training law clerks on preparation of deposition summaries, exhibit summaries, preparation of motions and pleadings, assist with billing of same; and assist attorneys with file management;

o Billing: Review and approve billing invoices from vendors and assist with pre-bills to clients. GASCOU HOPKINS, LLP – Culver City, CA, USA – PARALEGAL- February 2022 to May 2022 o Case Initiation: (State) Prepare collection demand letters followed by carefully drafted complaints against defendants and all activities associated with same; o Discovery: (State) Prepare form and special interrogatories, requests for admission and requests for production;

o Case Conclusion: (State) Prepare necessary conclusion documents including dismissals and judgments; o Other: Prepare charts analyzing active case inventory categorized by client; prepare charts indicating and categorized opposing counsel, the legal areas in which those counsels operated; document file management; secretarial and technical (hardware/software) support; and general office services. HINSHAW & CULBERTSON, LLP - Los Angeles, CA, USA – PARALEGAL- October 2014 to February 2022 o Pre-planning: Assist with cost estimation/litigation plans; o Pre-discovery: (Federal and/or State) Assist in case assessment, fact development, review of documents to create timelines/chronologies, locate key documents; and other case administration as required; o Pre-Trial Pleadings (Federal and State): Draft and prepare interpleaders with exhibits; draft and prepare responsive pleadings (answers and demurrers); prepare proposed orders; draft and prepare affidavits and declarations; draft motions of various types;

o Pre-Trial Discovery: (Federal and/or State) Draft and prepare initial disclosures; form and special interrogatories; requests for production and admission; draft deposition subpoenas for personal appearance and for documents with associated document requests; selection of and preparation of documents for use at deposition; preparation of expert witness disclosures; prepare draft protective orders; prepare summaries of depositions; assist with discovery plans and deposition outlines; o Dispositive Motions: Preparation of exhibits, declarations, separate statements and proposed orders; o Hearings and Trial (State): Attend court calls, ex parte hearings and trial hearings on behalf of counsel; appear in small claims court on behalf of the client; o Arbitration and Trial: Prepare exhibits, prepare exhibit and witness lists; prepare witness folders, trial subpoenas and on call agreements and effect service of same; o Post-Trial: Prepare memos of cost and initiate document destruction per protective orders; o Appellate: Preparation of appellate filings including notices, appendices and exhibits; o Other Review and analysis; background research on companies, opposing parties, opposing counsel, judicial assignments and witnesses through investigative, legal, legislative, and corporate research as applicable; o Other Assistance: Managed teams of contract attorneys and individuals to review documents in regard to a class action; assist with continuing legal education for attorneys; locate and interview expert witnesses; attend IME’s of witnesses on behalf of counsel; coordinate with private investigators for sub rosa and other services; other requested factual, investigative and legal research and summarization of same; assist with review of resumes in regard to hiring law clerks; assist with training law clerks on preparation of exhibits, motions pleadings and billing of same; and document file management; o Billing: Review and approve billing invoices from vendors and assist with pre-bills to clients. BARGER & WOLEN, LLP – Los Angeles, CA, USA – PARALEGAL- November 2010 to October 2014 o Please refer to the above information at Hinshaw & Culberson LLP. SWERDLOW, FLORENCE, SANCHEZ, SWERDLOW & WIMMER- Beverly Hills, CA,USA – TEMPORARY LITIGTION PARALEGAL – October 2010 to November 2010

o Pre-Trial: Responsible for reviewing and compiling information from payroll, timekeeping, and tax information in regard to wage and hour class action of major fast food chain that included undocumented immigrants. BARGER & WOLEN, LLP – Los Angeles, CA, USA – TEMPORARY LITIGATION PARALEGAL- August 2010 to November 2010

o Fact development: Responsible for the review of core electronic and paper files produced in connection with repetitive litigation in order to provide a road map and succinct overview of the electronic population centralized into one document repository;

o Discovery process: Conducted legal research and prepared deposition summaries; locate and interview expert witnesses.

CALDWELL, LESLIE & PROCTOR, PC, Los Angeles, CA, USA – TEMPORARY LITIGATION PARALEGAL - March 2010 to May 2010

o Fact development: Reviewed large populations of paper and electronic files in connection with ongoing banking litigation for the preparation of indices, motions, briefs, settlements, and closing; o Pre-trial preparation: Provided assistance in the preparation of pre-trial motions and briefs through legal and factual research including assembly of documents and exhibits. HELTON LAW GROUP, LLP – Long Beach, CA, USA – TEMPORARY LITIGATION PARALEGAL - December 2009 to January 2010

o Pre-trial and trial: Prepared pleadings and electronic discovery under the Ca.Code.Civ.Proc. in both litigation and arbitration matters at various stages of development that involved contractual disputes regarding employment, hospital liability, and matters concerning employment discrimination and sexual harassment. BARGER & WOLEN, LLP – Los Angeles, CA, USA – CONTRACT LITIGATION PARALEGAL- December 2007 to May 2008 o Case building: Reviewed, categorized, and indexed populations of paper and electronic files; created tracking

“charts” to record data on a series of related matters with like issues and witnesses for use by counsel on local, intranet, and internet based applications on behalf of the client; o Pre-trial preparation: Assisted in discovery and trial preparation for arbitration and litigation; conducted legal research; interviewed potential expert witnesses; prepared deposition summaries. KFS-BD, Inc. - Omaha, NE, USA - CONTRACT LITIGATION PARALEGAL – September 2007 to November 2007 o Discovery: In regard to documents collected as a result of the response to FINRA and SEC subpoenas - organized an extensive population of documents pertaining to broker dealers, brokerage firms, and district sales offices; assisted in preparation of discovery responses for State Department of Banking and Finance investigation and the related civil matters; assisted local counsel in Colorado as necessary regard to prosecution of brokers and broker dealers.

The Mutual of Omaha Companies - Omaha, NE, USA - SENIOR LITIGATION PARALEGAL - May 1995 to July 2005 o Case administration and Discovery: Received and created frame work for new matters, including all activities associated with fact gathering, discovery, and management of multiple active litigations at any one time that included complex and class actions and matters that involved the executive offices and company affiliates through and to the appeals process; legal review requests and associated research; manage vendors, staff and teams of outside counsel associated with projects; o Liaison: Served as paralegal team leader and legal liaison to improve intra-department and inter-department communications; worked directly with and acted as a liaison between in-house counsel, outside counsel, clients, company departments, expert witnesses, fact witnesses, consultants, vendors, staff, and others, including providing assistance in spontaneous matters for affiliate companies and inter-company departments;

o Document review: Created and generated various reports using company, affiliate company and interdepartmental software for administrative use and discovery purposes; o Subrogation: Managed third party subrogation and small claims court matters and negotiated settlement; o Discovery: Responded to company-wide subpoenas, intercompany requests to litigation, and public legal inquiries, including “cold” calls from the public; o Company Assistance: Drafted corporate legal documents, such as, certificates of incorporation, bylaws, mission statements, operating statements, and other documents, such as, releases, settlement agreements, wills and testaments, real estate purchase agreements, and factual sections of legal arguments; o Participation in Committees: Participated in legal division and department meetings and those involving company record destruction and retention;

o Delicate matters: Functioned within a matrix on matters that included a Chinese wall between in-house counsel;

o Contracts: assisted in contract development through various stages including re-drafting and proofreading contract templates for use nationwide; reviewed and compared leases, purchase agreements and various categories of real estate documents, assisted in critiquing and drafting company manuals, including the outside counsel billing guidelines;

o Company evaluation in re purchase and development: Performed due diligence associated with company acquisition and merger; assisted with market and product exit on a legal and regulatory level; o Regulatory Department Assistance: Conducted nationwide legal surveys of State and Federal Law; reviewed legislative history to provide analysis on legislative intent; o Concluded matters: Indexed, recorded and retrieved closed matters and associated content; o Acquisitions: Performed due diligence work in terms of acquiring companies; o Billing: Performed administrative reviews of outside counsel billing invoices with associated documentation to ensure compliance with outside counsel litigation guidelines; o Other Assistance: Performed various administrative functions including the establishment of document retention policies, time billing and keeping, quality improvement processes, and various other forms of information management; Paralegal to numerous outside counsel hired to assist with discovery, litigation and trial; client group coordination and client relation; assist in seeking and interviewing qualified outside counsel. McGrath, North, Mullin & Kratz, P.C. – Omaha, NE, USA – LITIGATION PARALEGAL- May 1992 to May 1995 o Case management: Functioned as part of a team to coordinate all facets of discovery and case management for subsidiaries and affiliates of ConAgra Foods, Inc. including communication with high priority witnesses and expert witnesses; gathered, reviewed, managed, and organized matters with extensive populations and types of documents; performed responsibilities associated with day to day case management including, preparation of indices, chronologies, and timelines involving a constant flow of exhibits, documents, deposition testimony, and expert consultation materials;

o Discovery Trial and Appeal: Assisted in all phases of the discovery, trial and appeal processes. LEGAL EDUCATION:

o College of Saint Mary, Omaha, Nebraska - Bachelor of Arts Degree in Paralegal Studies with a minor in Computer Science – Graduated December 1992, Magna Cum Laude. OFFICE MANAGEMENT AND RESEARCH SOFTWARE:

o Adobe Acrobat Professional; Concordance; CorelDraw; Docs Open; DepoSmart; FileMaker; Harvard Graphics; Hummingbird Law Pack; iOffice Management Products; Lotus and Lotus Suite; Microsoft Office products; Oracle, PeopleSoft, Quattro Pro, Relativity, Summation, Word Perfect products; programming in Cobol I and II, C and R;

o Research: Accurint, Courthouse News, Courtlink, EDGAR, Find Law, Internet, Lexis Advance, Pacer, Rutter Guide, TLOxp and Westlaw.

GAPS IN EMPLOYMENT AND VOLUNTEER EXPERIENCE

YEAR 2022.

Jury duty Superior Court of Los Angeles,

YEAR 2010.

General assistance: Dream Center Disciples and Angelus Temple, Los Angeles, CA, USA; Assisted Andrew Posner, Director, BACUP Life Center, Los Angeles, CA, USA, writing and proofreading; Assisted Desiree Singleton, Director, Young Life Hollywood, Hollywood, CA, fundraising and office organization; Prepared legal contracts and memos, merchandising, marketing, advertising, new business, and volunteer opportunity plans for Harwood Hamilton, Boxervate® Los Angeles, CA, USA; and Marketing: Marketed and promoted ThomasLift artwork both nationally and internationally. YEAR 2009.

Identifying areas of need: methods and practices in the following areas: clean water; availability of access to nutrition, clothing, toilets and hygienic items; prevalence of homelessness, human trafficking, and child labor; fertile soil/farming; sustainable plumbing/plumbing; garbage and refuse disposal; recycling; housing; electricity and sanitation; solar power; and availability of emotional outlets, including, suicide hotlines, rehabilitation and recovery facilities, in one or all of the following: Manama, Bahrain; Cotonou and Porto Novo, Benin; Francistown and Gaborone, Botswana; Beijing, PR, China; Hong Kong SAR, China; Macau, China; Brazzaville, Republic of Congo; Mumbai, India; Maputo and Pemba, Mozambique; Islamabad, Pakistan; Doha, Qatar; Johannesburg, South Africa; Manzini and Mbabane, Swaziland; Osaka, Shin-Osaka, and Tokyo, Japan; Dubai, United Arab Emirates; Los Angeles, California, USA; and Sana’a, Yemen; Children’s Ministry: Diepsloot, Gauteng, South Africa; English Instructor and Tutor: Saha Café, Huilongguan, Beijing, PR, China; “On the Street Evangelism and Prayer,” Mui Wo, Lantau, Hong Kong, SAR China; Shinjuku- ku, Tokyo, Japan; and Taipa, Macau;

Child Care: International China Concern, Cheung Chau Island, Hong Kong, SAR China; English Tutor, proofreader, Northern China Si Ping Martial Arts Academy,Ye He, PR, China; Other Assistance: Legal research, advertising, marketing, word processing, and general assistance, The Nine MMA, Los Angeles, CA, USA; Fundraising through “bridge building,” Pics, LLC, Los Angeles, CA, USA; Legal writing, drafting and proof reading assistance; preparation of merchandising, marketing, advertising, new businesses, and volunteer opportunity plans for Boxervate®, Los Angeles, CA, USA; and marketing and promoting Thomas Lift prophetic artwork both nationally and internationally. YEAR 2008.

Volunteering: Street ministry, Mui Wo, Hong Kong, SAR, China, and Beijing, PR, China; English Instructor, contributing editor/proofreader - Institute of Microelectronics Chinese Academy of Sciences, and Academy of Opto-Electronics - Beijing, PR, China; reviewed and revised research papers published in the United States on behalf the Institute of Microelectronics, Chinese Academy of Science: “Oxygen Effects on He/O2 Plasma Jet at Atmospheric Pressure, Surface Cleaning of Flat Panel Display Substrates by a Uniform Area Cold Plasma Tunnel at Atmospheric Pressure,” and “Surface Modification of Polytetrafluoroethyleneuerine by Dielectric Barrier Discharge Using Ar/Acrylic Acid” by Professor Shouguo Wang, Jun Wan, et al; English Instructor and Tutor, Beijing Yan Yuan Jing Hua Foreign Language Training Institute, Beijing University Science Park, and Saha Café, Huilongguan, Beijing, PR, China; English Tutor, proofreader, worship and intercession, Northern China Si Ping Martial Arts Academy -Ye He, PR, China; and Marketing and promoting Thomas Lift prophetic artwork. YEAR 2007.

Volunteering: International House of Prayer, Council Bluffs, Iowa; Information Coordinator, organizing missions department data, prayer requests, and small group data, Glad Tidings Church, Omaha, Nebraska; General Assistance, sound booth, van driver, and related tasks – First Nations Ministry, Native American Assembly, Teen Challenge, and the North East Urban Indian Health Coalition, Omaha, NE; and Volunteer - English Instructor and Tutor- Beijing Yan Yuan Jing Hua Foreign Language Training Institute – Qinhuangdao, PR, China.

YEARS 2005-2006

Volunteering: Church planting, children’s ministry, community outreach and street evangelism, Crouch End and Forest Hill, London, England, UK, and outreaches into various areas in the United Kingdom.

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