Complex Litigation / Medical Malpractice Discovery Paralegal

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).