Senior Litigation Paralegal

P. C. LUDLOW

Harbor City, CA *****

Email: *********.******@*****.***

Telephone: 424-***-****

Mobile Messages: 310-***-****

PROFESSIONAL SUMMARY

JD-educated Senior Litigation Paralegal with 20+ years of high-level litigation experience across California courts, including trial preparation, discovery management, appellate brief drafting, mediation, and complex case development. Certified under California Business & Profession Code

§ 6450 and fully MCLE-compliant through November 2027. Expert in manual authority verification, primary-source research, and risk-mitigation practices required under California’s 2025 citation-verification mandate. Skilled in supervising AI-assisted drafting to prevent hallucination case law, fabricated citations, and procedural errors. Extensive background in family law, personal injury, probate/trust litigation, business and personal disputes, real property, civil harassment, domestic violence, and general civil litigation. Remote- ready, tech-savvy, and trusted by attorneys statewide for accuracy, reliability and litigation judgment. CORE COMPETENCIES

Litigation Skills & Case Management

• Civil Litigation (Family law, PI, probate, trusts, business and personal disputes)

• Discovery management (propounding/responding, motions, meet-and-confer)

• Trial preparation, exhibit organization, counsel-table assistance

• Calendaring (three-system proficiency)

• Mediation & arbitration support

• Client communication, intake, witness preparation

• Accident investigation & factual development

• Appellate brief preparation and case-record review Drafting & Legal Writing

• Complaints, answers (including verified), motions, oppositions

• Ex parte applications, trial briefs, mediation statements

• Specialized discovery (interrogatories, RFPs, RFAs)

• Meet-and-confer letters

• Settlement proposals

• Legal correspondence and client instructions and explanations

• Communications with opposing counsel and court staff

• Editing, proofreading, court-compliant formatting Research and Authority Verification

• Manual primary-source research (20+ years)

• Bluebook citation accuracy

• Authority verification under California’s 2025 rules

• Case-law valuation, statute confirmation, rule-checking

• Avoidance of AI-generated hallucinations and false citations

• Risk-mitigation research practices

Technology & Software

• Microsoft Word, Excel, PowerPoint

• Adobe Acrobat

• WordPerfect

• My Case

• Essential Forms

• E-filing systems

• High-speed typing (75+ WPM)

• Rapid adoption of new legal-tech platforms

AI Oversight & Risk Management

• Verification of AI-generated citations and authorities

• Detection of hallucinated case law and fabricated facts

• Confidentiality and privilege protection of AI workflows

• Human-in-the-loop supervision of AI drafting

• Ensuring compliance with California AI ethics rules

• Identifying procedural, factual, and citation errors in AI output

• Maintaining accuracy, reliability, and professional standards PROFESSIONAL EXPERIENCE

Senior Litigation Paralegal

• The Document Lady, Harbor City, CA 2024–Present

Freelance paralegal providing high-level litigation support to attorneys statewide. Responsibilities include legal research, drafting, discovery, client interviews, trial preparation, and remote case management across family law, probate, trusts, PI, real estate, civil rights, elder abuse, personal and business disputes, and criminal law. Fully compliant with § 6450 and MCLE requirements.

• The Tabo Law, Sacramento, CA (remote) 2024–2025

Drafting, research, and preparation of pleadings, discovery, DVROs, child custody briefs, ex parte applications, motions, mediation preparation, and calendaring. Emergency drafting and rush filings, criminal law support. Northern California remote legal practice. Senior Civil Litigation Paralegal

• Law Offices of Saman Behnam, Long Beach, CA 2013–2024 Extensive trial preparation, drafting complaints/answers, discovery, motions, MSJ oppositions, arbitration support, courtroom assistance, calendaring, research across PI, probate, trusts, personal and business disputes, landlord-tenant, malpractice, real property and employment law.

• Senior Civil Litigation Paralegal (Independent Contractor), Los Angeles, CA 2017–2020 PI Plaintiff – drafting complaints, reviewing medical records, preparing motion/oppositions, discovery, client intake, witness preparation, accident investigations, trial support and client education.

Private Paralegal Practice

• Various California Attorneys and Law Firms 2004–Present Research, drafting, trial preparation, appellate briefs, complaints/answers, discovery, SJ oppositions, probate, labor board matters, insurance defense, and case management across multiple California counties. Primarily remote.

Executive Assistant/Paralegal

• Benjamin R. Katz & Associates, Inc., Los Angeles, CA 2000–2012 Paralegal and executive assistant to CEO Katz, supporting tax preparation, insurance defense, labor/employment matters, Workers’ Compensation, corporate organization, wage disputes, and labor board hearings. The position ended due to the CEO’s passing. SPECIALIZED EXPERIENCE

• Litigation Investigator

Buehler-Thompson Investigations

Offices of Mark Robinson and Melvin Belli 1981–1983

• Conducted in-person witness interviews

• Measured accident scenes, photographed, and created hand-drawn diagrams

• Examined stored, damaged vehicles for evidence analysis

• Prepared investigative reports for senior investigator Gene Buehler

• Supported high-stakes plaintiff investigation teams

• Voluntary Settlement Conference Mediator – Family Law California Court of Appeal, 4 th District, Division 2, Riverside, CA Approx. 1992–1995

• Selected by the Justices to mediate appellate family-law cases

• Conducted mandatory settlement conferences prior to appellate hearings

• Resolved all assigned cases, preventing the need for formal appellate review

• Facilitated negotiations and clarified legal/factual issues for litigants

• Adjunct Instructor – California Community Property California Southern Law School, Riverside, CA Approx. 1977

• Designed full course curriculum

• Delivered in-person lectures to evening law students

• Created midterms, finals, and written assignments

• Evaluated and graded all student work

• Provided instruction on California Community Property doctrine EDUCATION

Juris Doctor (J.D.), with Honors, Western State University, College of Law – Fullerton, CA Bachelor of Arts, with Honors, Political Science and History, University of California – Riverside California Fifth Year Teacher Credential, Elementary and Secondary, California State University

– San Bernardino, CA

CERTIFICATIONS & COMPLIANCE

Certified Paralegal – California Business & Professions Code § 6450 – MCLE-Compliant through November 2027. Completed required ethics, technology, and general courses (November 2025).

REFERENCES & WRITING SAMPLES

Available upon request.

Contact this candidate