Complex Litigation / Medical Malpractice Discovery Paralegal
7 days ago
Vancouver
Job Description 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., • 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., • 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., • 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., • 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., • Communicate professionally with clients regarding records, authorizations, and discovery needs—often with empathy in high-stress situations., • 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)., • 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)., • 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., • 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).