Litigation Paralegal - Complex Real Estate & Property Litigation (Pensacola)

Litigation Paralegal – Complex Real Estate & Property Litigation

Property Management Law Solutions, PLLC is seeking a highly experienced Litigation Paralegal to join our litigation team. This position is intended for a seasoned litigation professional who is capable of independently managing sophisticated state and federal court matters and working closely with attorneys on case strategy, substantive drafting, discovery, dispositive motions, hearings, and trial preparation.

This is not an entry-level or primarily administrative paralegal position. The successful candidate must have substantial hands-on experience managing complex litigation from initial filing through trial.

Minimum Qualifications

Applicants must have:

• At least eight (8) years of substantial litigation paralegal experience, with significant responsibility in complex civil litigation;
• Extensive experience in both Florida state court and federal court litigation;
• Extensive experience involving real estate, property, landlord-tenant, possession actions, partition, foreclosure, liability, property management business, housing, title, or other property-related litigation;
• Strong knowledge of litigation procedure, court rules, deadlines, discovery practice, motion practice, and trial preparation;
• Advanced proficiency using case management software, electronic filing systems, document management systems, and modern legal technology;
• Exceptional organizational, analytical, writing, and case-management skills;
• A keen attention to details and multi-tasking capacity; and
• The ability to independently manage a substantial litigation workload with limited supervision.

Key Responsibilities

The Litigation Paralegal will work directly with litigation attorneys and will be expected to take an active role in the management and development of cases, including:

Case Management

• Independently manage litigation files from inception through resolution or trial;
• Maintain complete and organized electronic case files;
• Review incoming pleadings, correspondence, discovery, notices, and court orders and identify required action;
• Calendar and monitor all litigation deadlines, hearings, discovery obligations, pretrial deadlines, and trial dates;
• Create, maintain, and follow case-specific task plans and litigation timelines;
• Identify upcoming deadlines and issues before they become emergencies;
• Be knowledgeable with local rules of state and federal courts; and
• Ensure that attorneys are timely informed of matters requiring substantive attention.

Substantive Legal Drafting

Prepare substantive first drafts of litigation documents, including:

• Complaints and amended complaints;
• Answers and affirmative defenses;
• Motions and responses;
• Discovery requests and responses;
• Subpoenas;
• Notices;
• Affidavits and declarations;
• Proposed orders;
• Pretrial statements;
• Trial-related filings;
• Correspondence concerning substantive litigation matters; and
• Other pleadings and litigation documents appropriate for paralegal preparation and attorney review.

The successful candidate must be capable of producing a strong substantive first draft rather than simply formatting attorney-prepared content.

Legal Research & Case Analysis

• Conduct legal and factual research using Lexis, court databases, statutes, rules, and other authoritative sources;
• Locate and summarize relevant statutes, procedural rules, cases, local rules, and court requirements;
• Prepare research summaries and litigation memoranda for attorney review;
• Assist attorneys in identifying legal issues and strengths and weaknesses in the facts, evidence, and strategies;
• Analyze pleadings, discovery, documents, and factual records to assist in developing the theory and strategy of the case.

Discovery Management

• Draft and manage interrogatories, requests for production, requests for admission, and subpoenas;
• Organize and analyze large document productions;
• Coordinate document collection with clients;
• Maintain discovery indexes and production logs;
• Assist with privilege review and privilege logs;
• Track discovery deadlines and deficiencies;
• Prepare discovery deficiency correspondence;
• Assist attorneys with motions to compel, protective orders, and discovery disputes;
• Prepare deposition exhibits, chronologies, witness materials, and supporting documents.

Motion Practice & Hearings

• Assist attorneys in preparing motions, responses, replies, affidavits, exhibits, and supporting authorities;
• Assemble and organize hearing materials;
• Prepare hearing notebooks and electronic hearing files;
• Coordinate witnesses and exhibits;
• Assist attorneys in preparing factual chronologies and argument outlines.

Trial Preparation

The Senior Litigation Paralegal must have meaningful trial preparation experience, including:

• Preparing comprehensive trial notebooks;
• Organizing exhibits and demonstrative evidence;
• Preparing exhibit and witness lists;
• Preparing subpoenas and coordinating witnesses;
• Maintaining deposition designation materials;
• Preparing evidentiary materials;
• Assisting with motions in limine;
• Preparing jury instruction and verdict-form materials under attorney supervision;
• Organizing trial exhibits and electronic trial presentations;
• Assisting attorneys before and during trial; and
• Managing logistical and administrative trial requirements.

Technology Expectations

Our firm utilizes technology extensively to manage cases efficiently. Applicants must be comfortable working in a technology-driven environment and should have strong proficiency with:

• Legal case management software (experience with Smokeball is strongly preferred);
• Microsoft Word, Outlook, Excel, and Adobe Acrobat;
• Electronic filing in Florida state courts and federal courts;
• Document management and electronic discovery;
• Legal research platforms;
• PDF editing and document preparation;
• Electronic calendaring and task management; and
• AI-assisted legal technology and other modern litigation tools.

What We Are Looking For

The ideal candidate is someone who:

• Thinks several steps ahead in a litigation matter;
• Understands how litigation actually progresses rather than simply completing assigned tasks;
• Takes ownership of assigned cases;
• Can review a file and identify what needs to happen next;
• Understands the relationship between pleadings, discovery, evidence, motion practice, and trial strategy;
• Produces accurate and professional work with minimal supervision;
• Is comfortable working directly with experienced litigation attorneys;
• Can manage multiple complex cases and competing deadlines;
• Communicates problems and potential issues before deadlines are jeopardized;
• Is highly organized and detail-oriented;
• Exercises sound professional judgment;
• Works efficiently and understands the importance of productivity and accurate timekeeping;
• Consistently and contemporaneously keeps track of work and time performed on tasks; and
• Takes pride in producing substantive, high-quality litigation work.

Preferred Experience

Strong preference will be given to candidates with experience involving:

• Real estate litigation;
• Commercial property disputes;
• Landlord-tenant litigation;
• Title and ownership disputes;
• Quiet title actions;
• Partition actions;
• Boundary and easement disputes;
• Foreclosure litigation;
• Premises liability litigation;
• Complex discovery;
• Federal and state court practice;
• Evidentiary hearings;
• Summary judgment proceedings; and
• Jury or non-jury trials.

Position Expectations

This position requires someone who can function as a substantive member of the litigation team, not merely provide clerical support. The successful candidate will be expected to contribute meaningfully to case preparation, litigation strategy, organization, attorney efficiency, and the overall management of the firm's litigation docket.

Applicants whose experience has primarily consisted of scheduling, filing documents, answering phones, formatting pleadings, or providing general administrative support without significant substantive litigation responsibility are unlikely to be a good fit for this position.

Compensation

$65,000 - $80,000, depending on experience and qualifications

To Apply

Please submit a résumé describing your litigation experience, including your experience in state and federal court, substantive pleading and discovery preparation, legal research, complex case management, and trial preparation. Applicants are encouraged to specifically identify the types of complex liti]]> <