Litigation Paralegal Medical Malpractice

Timothy Michael O'Brien, RP

**** ***** ****, *************, **

Phone: 484-***-****

e-mail: *******@***.***

EXPERIENCE

**** – Present The Perry Law Firm, L.L.C. Bethlehem, PA LITIGATION PARALEGAL

● Sole paralegal supporting a three litigation attorneys engaged in a medical malpractice defense practice;

● Responsible for direct management of a case load of approximately 50 individual lawsuits.

● Subpoena and acquire all relevant medical and other records for eventual expert review;

● Locate, retain and communicate with all medical and economic expert witnesses from case involvement through trial / settlement;

● Responsible for submission of all materials to expert witnesses for review during each case;

● Preparation of multiple volume binders for trial as directed by counsel. 2001 - 2006 Pachulski, Stang, Ziehl, Young, Jones & Weintraub LLP Wilmington, DE BANKRUPTCY PARALEGAL

● Assist attorneys in large multi-office boutique bankruptcy law firm with all aspects of case preparation in Chapter 11 bankruptcy and bankruptcy litigation matters.

● Responsible for tracking all pleading deadlines and significant dates within multiple assigned cases.

● Prepare agenda letters and pleadings binders for federal bankruptcy court hearings.

● Create and maintain an on line firm wide deadline chart tracking specific deadlines in all bankruptcy matters handled in the firm's four national offices.

● Perform legal research using Westlaw and Lexis applications on an as needed basis. 2001 Murtha, Cullina, Roche, Carens & DeGiacomo, LLP Boston, MA COMMERCIAL LITIGATION PARALEGAL

● Employed specifically in support a team of five attorneys involved in a $500 million dollar commercial property loss litigation;

● Assist attorneys with preparation for depositions. Attend and directly support counsel at deposition;

● Responsible for maintaining the status of all document productions and submission of same for inclusion within a large electronic document database. Organize and maintain file room containing all case related files.

2000 Swartz & Swartz Boston, MA

LITIGATION PARALEGAL

● Responsible for the completion of all pre-trial obligations and trial preparation related to large-scale plaintiff product liability, medical malpractice and wrongful death litigation.

● Create and file complaint packages;

● Preparation of all aspects of pre-trial discovery including interrogatories, answers, requests for production and responses;

● Serve and file summonses and deposition subpoenas;

● Request and compile medical records;

● Summarize deposition transcripts;

● Draft Pre-Trial Conference Memoranda.

1998 - 2000 John Hancock Financial Services, Inc., Boston, MA PARALEGAL / ALTERNATIVE DISPUTE RESOLUTION

● Served with two attorneys on a panel negotiating monetary settlement terms for individual legal claims containing allegations of various misrepresentations made by agents of the insurer;

● Draft detailed summaries of insurance claims submitted as part of a class action lawsuit;

● Responsible for the daily review, preparation and presentation of insurance claims before a panel of attorneys as part of a claim review team within the Alternative Dispute Resolution phase of a class action lawsuit. 1997 -1998 Attorney Frederic C. Harris, Arlington, MA PARALEGAL

Litigation:

● Produce all written client correspondence, create and maintain case files;

● Draft and file Interrogatories, Answer to Interrogatories, Requests for Production of Documents, Response to Requests for Production of Documents.

● Request Medical Records;

● Draft itemized client billings;

● Completed personal financial statements;

pursuant to divorce proceedings.

Probate:

● File Petition for Probate;

● Request Death Certificate, locate and document disposition of decedent's bank accounts and securities, request and complete life insurance claim forms;

● File full range of Probate pleadings including Petition for Probate, Appointment of Temporary Executor, Notice of Probate of Will, Probate of Will and Bond of Executor.

Corporations:

● Draft and file Articles of Organization related to the incorporation of non-profit and general business corporations.

● Complete S-Corporation tax status filing.

EDUCATION:

1990 - 1994 Bachelor of Arts, University of Massachusetts, Amherst, MA Major: History Minors: Criminal Justice

(Certificate); Sociology

Paralegal Certification, Northeastern University, Boston, MA 2004 Registered Paralegal Certification, National Federation of Paralegal Associations (NFPA) LICENSES

Notary Public, Commonwealth of Massachusetts (1996 - 2003) Notary Public, State of Delaware (2001 - 2006)

Courses/Workshops:Securities Regulation and Blue Sky Law; Intellectual Properties. MEMBERSHIPS:Voting Member, Massachusetts and Delaware Paralegal Association. LANGUAGES:Latin (5 years); Spanish (2 years); German (1 year).

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