Complex Litigation / Medical Malpractice Discovery Paralegal

McKean Smith LLC

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).

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Vacancy posted 3 days ago

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