Litigation Specialties:
• Complex Commercial Litigation
• Concordance
• Electronic Data Discovery (EDD)
• Electronic Discovery (ESI)
• Employment Law Litigation
• Intellectual Property Patent Litigation
• Investigation
• Legal Project Management
• Legal Recruiting
• PowerPoint presentations
• Sanction II
• Summation
• Trial Director 6
• Trial Technician “Hot Seat” Experience
• Trial Consulting, Preparation & Presentation
This is just a sampling of services we can provide:
Case Administration and Legal Project Management:
- Docketing and deadline control
- Regular communication with client to update him on file status and provide copies of all written communication and court filings
- Review of Local Court Rules, State Rules of Civil Procedure, Federal Rules of Civil Procedure and Local Patent Rules
- Organize and build digital files for easy access of all file documents
- Monitor work product and privileged communication
- Legal Project Management
- Coordination of legal team and collaboration of multiple attorneys including local counsel
- Develop checklists and forms to fit your personal style and preference
- Develop pleading and document indexes for ease in locating documents
Initial Investigation and Research:
- Initial telephone interview of potential clients received by referral
- Interviews with client(s) and witnesses to document relevant facts
- Develop overall case chronology as well as topic chronologies for key areas
- Internet research and investigation to obtain background information and verify identity of parties
- Attend client office conferences via speakerphone or in person to assist in documenting file
- Obtain third party, non-party and other documents by subpoena
Filing of Petition/Complaint:
- Preparing the initial draft of the Petition/Complaint for your review using your form files and allowing you to finalize and sign
- Prepare appropriate cover sheets and electronic filing of case documents to commence case in proper jurisdiction
- Locate process server and obtain service of process on Defendant(s) or serve complaints locally
- Determine and docket answer dates
Filing of Answer/Counterclaim:
- Obtain service documents from client
- Check court docket and obtain copies of all documents not received with citation/summons
- Verify service date and determine answer date
Discovery:
- Confer with you to develop offensive and defensive discovery strategies
- Draft interrogatories, requests for production of documents, requests for admission and requests for inspection
- Determine and docket discovery response dates
- Contact opposing counsel to schedule depositions by agreement
- Coordinate schedule with witnesses and court reporter
- Preparation of client and witnesses for deposition
- Transmit deposition transcript, signature and errata pages to client, if required
- Determine and docket deadline for return of signature and errata pages to court reporter and opposing counsel
- Review discovery received from opposition, docket deadlines and forward to client
- Confer with client to obtain answers and documents responsive to discovery requests
- Prepare initial drafts of discovery responses
- Prepare documents for production, bates numbering, scan to electronic format
- Coordinate document inspections and delivery of document productions to opposing counsel
- Maintain privilege logs
- Make privilege redaction's per your instructions
- Communicate with opposing counsel concerning unanswered discovery and draft motion to compel if necessary
- Prepare deposition summaries for ease in locating key witness testimony
- Review all discovery documents to continue development of witness and exhibit lists
- Coordinate client signatures to discovery documents
Motions, Hearings, and Pre-Trial:
- Initial drafts of motions and orders
- Proofreading, editing and cite checking all briefs
- Preparation of exhibit attachments
- Prepare client affidavits and coordinate execution
- Coordinate electronic and physical filings
- Obtain hearing dates from Court and notify opposing counsel
- Monitor pleading requirements per local court rules
- Organize hearing notebooks
- Determine pre-trial order requirements per local court rules, docket deadlines
- Initial draft of pre-trial order, communicate with opposing counsel to receive information for pre-trial order, finalize order prior to hearing
- Obtain pre-trial hearing, docket and notify all parties
Settlement, Mediation, and Arbitration:
- Coordinate with client and opposing counsel to schedule settlement conferences, select mediator or arbitrator
- Confirmation notice to all parties
- Review mediation statement requirements
- Prepare initial draft of mediation statement and organize attachments
- Organization settlement/mediation/arbitration notebooks
- Prepare initial draft of all settlement documents
Trial Preparation:
- Obtain trial setting and file motion requesting trial setting, if required
- Notify opposing counsel and client of trial settings and deadlines
- Review Scheduling Order and court rules to determine all trial related deadlines, docket and monitor all deadlines
- Develop trial notebook
- Coordinate preparation of trial exhibits, delivery to court and opposing counsel
- Prepare pattern jury instructions and questions
- Prepare motions in limine and obtain hearing date prior to beginning of trial
- Issue subpoenas and obtain service on trial witnesses
- Coordinate trial schedule with expert witnesses
- Coordinate arrangements for electronic equipment and exhibit enlargements
- Participate in the hot seat at trial utilizing electronic trial presentation software
Judgment and Appeal:
- Draft judgment
- Determine and docket appeal deadlines
- Perfect judgment lien and begin post-judgment discovery
- Assist with appeal process as necessary

1717 McKinney Avenue
Suite 700
Dallas, Texas 75202
Phone: (214) 263-1463
E-mail: kslyter@litigationparalegals.net
This web site, Litigation Paralegals, LLC, is designed for informational purposes only and the information and opinions are not to be interpreted, construed and/or used as rendering legal advice or legal services or accepting fees for legal advice or legal services. The laws of the State of Texas will apply to all transactions resulting from this site. Texas law prohibits paralegals from offering legal services directly to the public and such practice may be considered The Unauthorized Practice of Law. Litigation Paralegals, LLC cannot render legal services, give you legal advice, tell you what your legal rights or remedies are, represent you in court; or tell you how to testify in court and reserves the right to deny services to anyone without cause.