Trial Paralegal

Job Description Job Description Onyx Law Firm is seeking a seasoned Senior Trial Paralegal with a minimum of seven years of substantive litigation experience and direct, hands‑on experience handling first-party insurance breach-of-contract and bad-faith litigation against insurance companies . Our firm represents policyholders in complex disputes arising from the denial, delay, underpayment, and mishandling of first-party property insurance claims. These cases commonly involve claims for: Breach of the insurance contract; Breach of the implied covenant of good faith and fair dealing; Unreasonable claim delay or denial; Failure to conduct a full, fair, and thorough investigation; Improper reliance on exclusions or unsupported causation opinions; Additional living expenses and loss-of-use benefits; Dwelling, personal-property, code-upgrade, and repair-scope damages; Consequential and emotional-distress damages; Brandt attorney-fee damages; and Punitive damages based on managing-agent authorization, participation, or ratification. This is not an entry‑level position, a general litigation position, or a role for someone seeking to learn first-party insurance law on the job . Applicants must already understand how a first-party insurance case is developed from the policy and claim file through written discovery, depositions, expert discovery, motions for summary judgment or summary adjudication, motions in limine, jury instructions, special verdict forms, exhibits, and trial. The Type of Person We Are Seeking We are not looking for someone who merely waits for assignments, enters dates on a calendar, or organizes documents after being given step‑by‑step instructions. We are looking for the trial attorney’s trusted litigation partner and operational second-in-command -someone who: Anticipates what the case will require before being asked; Recognizes a missing exhibit, evidentiary gap, conflicting deadline, or unsupported expert assumption before it becomes a problem; Understands why a particular adjuster note, denial-letter statement, vendor assignment, estimate discrepancy, omitted inspection, or change in coverage position matters; Can transform a large and disorganized insurance claim file into a coherent evidentiary record; Remains calm, precise, and professional when discovery, dispositive‑motion, expert, and trial deadlines converge; and Takes genuine ownership of the quality, organization, and readiness of the case. The successful candidate must understand that first-party insurance litigation exists at the intersection of contract interpretation, claim-handling conduct, construction science, causation, damages, discovery, and trial evidence . First‑Party Insurance Claim‑File Analysis The candidate must be capable of reviewing and understanding the insurance claim file as evidence—not simply as a collection of documents. The role includes: Review insurance policies, declarations pages, endorsements, coverage forms, exclusions, conditions, and duties‑after‑loss provisions; Analyze claim diaries, activity logs, adjuster notes, correspondence, coverage letters, reservation‑of‑rights letters, denial letters, payment records, estimates, photographs, videos, recorded statements, proofs of loss, examinations under oath, and insurer‑vendor reports; Create a detailed claim chronology showing what the insurer knew, when it knew it, what it did, what it failed to do, and how its coverage position changed; Build issue matrices connecting each policy provision and legal theory to the supporting witness, document, deposition testimony, exhibit, and motion evidence; Identify inconsistent claim notes, unexplained delays, missing inspections, uninvestigated coverage theories, unsupported conclusions, and evidence favorable to coverage that may have been disregarded; Compare insurer estimates with contractor, restoration, engineering, public‑adjuster, and insured estimates; Track all payments by coverage category, including dwelling, contents, additional living expenses, debris removal, code upgrades, mitigation, environmental testing, and other benefits; Assist with the preparation of damages summaries and demonstrative timelines; Identify documents necessary to establish the reasonableness or unreasonableness of the insurer’s investigation; Track the chain of custody for failed plumbing components, building materials, testing samples, photographs, video, and other physical evidence; and Maintain a clean, searchable, OCR‑enabled, and properly Bates‑numbered document database. Written Discovery and Discovery Motion Practice The Senior Trial Paralegal must have substantial experience with California civil discovery and be able to prepare sophisticated attorney‑directed drafts. Responsibilities include: Draft and organize form interrogatories, special interrogatories, requests for production, requests for admission, supplemental discovery, and corresponding responses; Assist with substantive objections, verifications, document identification, and production responses under attorney supervision; Prepare deposition notices, requests for production at deposition, notices of person‑most‑qualified depositions, and detailed PMQ topics; Prepare and coordinate third‑party subpoenas to contractors, plumbers, engineers, mitigation companies, alarm companies, environmental consultants, public adjusters, mortgage companies, prior insurers, and other relevant witnesses; Manage subpoena service, objections, consumer notices, production dates, deposition officer issues, and follow‑up communications; Prepare privilege logs and track withheld or redacted documents; Organize electronic discovery productions, metadata, native files, email collections, photographs, videos, spreadsheets, and claim‑management‑system exports; Review productions for completeness and identify missing document categories; Prepare discovery deficiency charts and meet‑and‑confer correspondence; Assist with motions to compel further responses, motions to compel compliance, protective orders, sanctions motions, and related separate statements; Maintain a discovery‑status matrix for every discovery request, response, supplemental response, production, meet‑and‑confer effort, and motion deadline; Prepare deposition exhibit sets and witness‑specific document collections; Summarize deposition testimony with accurate page‑and‑line citations; Create impeachment indexes identifying inconsistent testimony, claim‑file entries, correspondence, and prior statements; and Preserve a clear record of discovery misconduct, delayed production, evasive responses, and prejudice to the insured. Motions for Summary Judgment and Summary Adjudication Substantial MSJ/MSA experience is required. The candidate must understand that summary judgment work is not simply formatting a motion. It requires building an admissible evidentiary record in which every material factual assertion is supported by competent evidence. Responsibilities include: Assist in developing the factual chronology and theory of the motion or opposition; Prepare and maintain evidence matrices linking each material fact to declarations, deposition testimony, discovery responses, claim‑file documents, expert opinions, and exhibits; Draft and revise separate statements of undisputed and additional material facts under attorney supervision; Verify every record citation and pinpoint reference; Organize declarations, exhibits, deposition excerpts, discovery responses, policies, correspondence, expert reports, and other supporting evidence; Prepare evidentiary objections and responses to objections; Assemble exhibit compendiums, appendices, requests for judicial notice, and supporting declarations; Check citations, quotations, defined terms, exhibit references, numbering, and cross‑references throughout all motion papers; Prepare tables of contents and authorities using proper Microsoft Word functionality; Confirm compliance with page limitations, formatting rules, filing requirements, service requirements, and department procedures; Assist with opposition and reply strategy by identifying evidentiary gaps, disputed facts, inconsistent declarations, expert‑foundation problems, and improper burden shifting; Maintain a live chart showing every element, defense, exclusion, burden, supporting fact, and evidentiary source; and Prepare hearing binders and concise argument‑support materials for counsel. Other Law‑and‑Motion Responsibilities The Senior Trial Paralegal will also assist with: Motions to compel; Motions for protective orders; Motions for sanctions; Motions to strike; Motions in limine and oppositions; Evidentiary objections; Trial briefs; Ex parte applications; Motions concerning expert testimony; Motions concerning authentication, hearsay, business records, subsequent evidence, and claim‑file materials; Motions involving punitive‑damages evidence and managing‑agent discovery; Posttrial motions where required; and Attorney‑directed legal and factual research using Westlaw, Lexis, or comparable research platforms #J-18808-Ljbffr