What are the responsibilities and job description for the Complex Litigation / Medical Malpractice Discovery Paralegal position at McKean Smith LLC?
Position Summary
We’re seeking a seasoned plaintiff-side Complex Litigation / Medical Malpractice Discovery Paralegal to own high-volume discovery from intake through trial. This role is built for someone who can turn chaotic records into clean litigation narratives—medical chronologies, damages proof, airtight productions, and deposition-ready exhibit sets—while staying ahead of Washington and Oregon deadlines and court requirements.
Key Responsibilities
Plaintiff-Side Discovery Leadership (Core)
- Draft, prepare, and finalize discovery requests and responses (interrogatories, RFPs, RFAs), including exhibits and verifications for attorney review.
- Drive the discovery workflow end-to-end: document/ESI intake, tracking, meet-and-confer support, deficiency follow-up, and motion-to-compel support.
- Maintain discovery trackers (requests/responses, rolling productions, deadlines, objections) and ensure nothing slips.
- Prepare and maintain Bates-labeled productions, production logs, and privilege/confidentiality handling consistent with protective orders.
- Coordinate ESI processes with attorneys and vendors when needed (collection, processing, review workflows, production specs).
Medical Records & Case Narrative (Med-Mal Focus)
- Obtain and manage medical records and related materials: hospital/clinic records, EMS, imaging, labs, billing, pharmacy, prior providers, and therapy records.
- Prepare medical chronologies, treatment timelines, issue-based summaries, and record highlights for attorney and expert use.
- Track and organize causation/damages evidence: pre-existing conditions, comparative fault themes, future care, and life impact documentation.
- Maintain a clean, litigation-ready medical records system with consistent naming conventions and indexing.
Damages, Liens & Loss Documentation (Plaintiff-Focused)
- Build and maintain the damages file: medical specials, out-of-pocket costs, wage loss documentation, employer records, and supporting declarations.
- Track liens/subrogation (health insurers, ERISA plans, Medicaid/Medicare, PIP/MedPay where applicable) and coordinate requests, notices, and documentation for attorney review.
- Support settlement demand packages with organized exhibits, summaries, and supporting documentation.
Depositions, Experts, and Litigation Support
- Coordinate depositions (providers, experts, corporate reps): scheduling, notices, subpoenas, records delivery, exhibit prep, and deposition kits.
- Support expert workflow: records delivery, disclosure tracking, organizing expert materials, and deposition/trial preparation support.
- Assist with motions and briefing support: cite-checking record references, compiling exhibits/decls, formatting, and e-filing coordination.
Court Rules, Filing & Deadline Management (OR/WA)
- Maintain master calendaring for discovery deadlines, scheduling orders, trial deadlines, service deadlines, and internal review cutoffs.
- Prepare filing-ready documents (formatting, exhibits, service lists) and coordinate e-filing and service in Oregon and Washington venues as assigned.
- Ensure files are audit-ready: consistent version control, confidentiality protections, and secure handling of protected health information.
Client & Third-Party Coordination
- Communicate professionally with clients regarding records, authorizations, and discovery needs—often with empathy in high-stress situations.
- Coordinate with court reporters, videographers, investigators, record vendors, experts, and opposing counsel on discovery logistics.
Required Qualifications
- 3 years as a litigation paralegal with substantial discovery ownership; plaintiff-side PI/med-mal strongly preferred.
- Demonstrated experience managing high-volume medical records and building usable litigation timelines/chronologies.
- Strong working knowledge of civil discovery practice (requests, responses, meet-and-confer, subpoena workflow, protective orders).
- Excellent writing, proofreading, and document formatting skills (Word/Outlook; strong Excel a plus).
- High discretion and comfort handling confidential medical information and sensitive client matters.
Preferred Qualifications
- Complex litigation or med-mal experience in Oregon and/or Washington courts.
- eDiscovery familiarity (Relativity, Everlaw, Logikcull, Casepoint, TrialDirector, etc.) and production specs (PDF/TIFF, load files, Bates, redactions).
- Trial support experience (exhibit lists, trial notebooks, war room).
- Paralegal certificate and/or AA/BA/BS (or equivalent experience).
Core Competencies (What “Great” Looks Like)
- You anticipate problems, don’t just report them.
- You can take a 5,000-page chart and produce a clear, credible story.
- You’re deadline-driven, calm under pressure, and relentless about follow-through.
- You understand plaintiff-side needs: building damages, proving causation, and preparing cases for trial or strong resolution.
Work Environment / Expectations
- Hybrid/in-office as needed for hearings, depositions, trial prep, and secure records handling.
- Occasional overtime around court deadlines and trial.
- Occasional travel in Oregon/Washington for depositions or trial support (if applicable).
Salary : $30 - $45