Litigation paralegal service assisting attorney research draft complaint opposition demurrer answer ex parte discovery motion enforce settlement divorce judgment QDRO

A Paralegals Job Duties

A Paralegals Job Duties

Paralegals use their legal education and specialized skill set to organize documents into a usable format for attorneys. The details involve setting up and maintaining files organized by litigation sub-categories labeled: 1. Pleadings (Complaint, Demurrer, Answer), 2. Discovery, 3. Legal Research, 4. Correspondence, and maybe for complex litigation: 5. Motions. Scanning and photocopying documents and organizing into digital files requires a good litigation vocabulary. Faxing, emailing, U.S. Postal Service and overnight FedEx mailing is integral to a law firm’s practice.

Propounding and responding to discovery involves factual findings, database interface and client liaison for effective special interrogatories, requests for production of documents and requests for admissions. Drafting clear, concise correspondence from an experienced paralegals perspective views every letter or document created as a possible motion exhibit. Depositions involve handling expert witnesses, exhibits and law firm calendaring. Find and retain expert witnesses and assist with drafting doctor, forensic accountants and engineer declarations. Drafting motions requires online and law library legal research, pulling relevant documents as exhibits and drafting law and motion by applying legal authority to facts in order to persuade the court. Filing pleadings at court and serving the opposing parties. A paralegal is a law firm’s ground level legal advocate. Act as liaison between internal departments. Trial preparation, presentations, voir dire and jury instructions. Sit at the counsel table and take notes on witness testimony and jury reactions. Paralegals are professional problem solvers who gain valuable real-life working legal experience by working hard alongside experienced attorneys during all phases of litigation practice and procedure from pre-trial, post-trial and the appellate process. The main tool of paralegals is the laptop computer as a portal to the world of fast-paced information gathering, processing and management. Paralegals are self-motivated life-long learners who thrive on change and challenge. Great paralegals learn how to think and act like great attorneys. Information is power and a paralegals job duty number one is to apply statutes, codes and case law to evidence to create compelling persuassion.

Contract Paralegal

Contract Paralegal

Retaining a freelance independent contract litigation paralegal for discovery, motions and trial preparation is an economical way to staff the digital law firm of today. The LA to Palm Springs paralegal market offers both contract paralegals and paralegals looking for regular permanent positions. Using a legal placement agency to evaluate a contract paralegal is a good way to evaluate permanent paralegals and litigation secretaries to hire for your law firm. You can direct hire qualified litigation paralegals on a permanent basis by contracting with a legal placement agency.

If you are only going to trial once every three years you don’t need an expensive trial exhibit software program or a big-budget animation from a digital production house. You need a seasoned trial paralegal who can give your closing the human touch by putting your exhibits on the courtroom overhead projector. Juries want to be treated warmly, not bored to death with PowerPoint bullets & needless exhibits that do nothing to emotionally engage your jurors with facts and law.

How do you know if you will really like that new paralegal you want to hire? How do you know if your new hire is going to be the right person for your office or just another big hit to your unemployment insurance or next year’s disability claim? Will your new hire be able to learn new procedures, technology and facts on the spot without caving in?

Use Contract Paralegals in Consideration of Your Law Firm Staff

Litigation is difficult for the hardiest of litigation support staff even under normal conditions. What will happen when that case you thought was going to settle unexpectedly goes out to trial? Who will step in to take on the extra work of joint exhibit lists and jury instructions?

I have just finished working on a federal trial with a celebrity attorney from the O.J. Simpson murder trial who let proposed jury instructions on employee safe harbor go to the very last day of trial. The entire courtroom gets irritated if counsel is slow with procedure.

I have sat at the counsel table for a Los Angeles Superior Court trial in Santa Monica and two U.S. District Court Trials, one in Riverside and a Medicare Fraud trial at the Roybal Center in Downtown LA.

Divorce Paralegal QDRO’s

Divorce Paralegal QDRO’s

What is one of the last components of your divorce that will hopefully bring you years of joy and satisfaction? Sharing your grandchildren’s custody with your ex-spouse before the kids turn into teenagers?  No . . . your ex-spouses 401(k) retirement and pension plan accounts that are half yours! 

Attorneys usually refer clients to contract paralegals to prepare post judgment qualified domestic relations orders. The QDRO is the legal mechanism that tells the plan administrator to disburse retirement funds to that plan member’s ex-spouse. A QDRO requires mandatory family law court forms and a qualified domestic relations order in pleading format.


Divorce Paralegal Tools

What does some Internet divorce paralegal downloading free QDRO forms off of the Internet have that you don’t have? The paralegal has Adobe Acrobat or some other paid pdf program that can save and store completed court forms. You cannot save court forms to memory with free Adobe Reader. The paralegal also has years of experience and in the legal profession your worth is measured in years of experience. I have over thirty years of legal experience as  a legal secretary and litigation paralegal.  

LDA’s cannot select court forms for a non-attorney. LDA’s cannot give legal advice or represent a client at a civil, probate or criminal hearing. The non-attorney divorce client must learn about divorce law on the Internet and then inform the LDA which court forms are required pursuant to the Family Law form FL-182. If you need a fast and easy divorce use FL-182 to educate yourself on which forms you want your divorce paralegal to prepare. 

Divorce paralegals should be really good with client contact and turning around an unhappy customer. One question many sales managers will ask on a job interview is how you turned about an unsatisfied customer. 

Divorce is a good time to take inventory of your life. Can you financially afford to divorce the business partner known as your spouse? If you have minor children you need to seriously evaluate the emotional as well as financial impact your divorce will have. Will divorcing your spouse really be the end of all your problems?

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  • Ex Parte Paralegal
Ex Parte Paralegal LA

Ex Parte Paralegal









Ex Parte Paralegal


The ex parte paralegal gives notice of the ex parte application for order shortening time for notice of motion and motion to continue trial dates and discovery and discovery motion cut off dates. Ex parte emergency procedures should not be used to make up for poor case management. Ex parte relief is only appropriate if a party is in immediate danger or irreparable harm or injury. 


Ex Parte Paralegal Package


The ex parte declaration re: notice of ex parte hearing is the ex parte paralegal’s job. I use that caption as my template for the rest of the pleadings. The notice of ex parte application and application would be next in the sequence. The the memorandum of points and authorities in support thereof. The attorney’s declaration in support of ex parte application is very important because it states the legal and factual reasons that the court should consider in weighing the ex parte. 

I always base my motions upon the declaration. The declaration is my factual framework for my law and motion. Litigation economy means preparing pleadings in an efficient ex parte paralegal work flow system. Being efficient is what the years of experience teach a litigation paralegal. This afternoon I was ready for a difficult client to make our 5:00 p.m. filing deadline difficult. A certain breed of American real estate tycoon can make a living by having attorneys sue other real estate developers. This client is a real litigation animal. He had me do what many clients do: I created the framework for our opposition to demurrer and he filled a lot of it in. Not a really good idea. The file is filled with correspondence from real litigation attorneys to this client telling him to back of and let the lawyers do the lawyering. 


Ex Parte Paralegal Abuse of Process


Don’t over use your ex parte paralegal just because you have one. The ex parte procedure is only appropriate in limited circumstances. I have written on them extensively on this website and elsewhere on the Internet. If  you need an ex parte paralegal please email me or call me and send me a retainer. I am an expert in California ex parte law and can get your papers filed in Los Angeles Superior Court in just a few hours. 

Dean McAdams is a litigation paralegal with over thirty years experience. He has a BA in Film from CSUN and a Litigation Paralegal Certificate from UCLA Extension. Dean is not an attorney and does not provide legal advice.