Career

Position Title: Litigation Paralegal – Discovery Review and Case Analysis
Department: Litigation
Reports To: Managing Attorney / Assigned Attorney
Position Type: Full-Time

Salary $45,000.00 to $60,000.00 depending on the right candidate

Position Summary

McHughes Law Firm, PLLC is seeking an experienced, highly organized, and analytical Litigation Paralegal capable of independently reviewing discovery responses, evaluating the evidence and procedural status of litigation matters, identifying deficiencies, and recommending the appropriate next steps in each case.

The ideal candidate must possess the ability to think critically, exercise sound judgment, and move litigation matters forward without requiring constant direction from the supervising attorney.

A primary responsibility of this position is to review discovery, determine what action should be recommended next, and prepare a comprehensive written memorandum to the assigned attorney documenting the findings, analysis, and recommended course of action.

The paralegal is expected to take ownership of assigned files, recognize issues requiring attorney attention, and ensure that cases do not remain inactive due to a lack of review or follow-up.

Essential Duties and Responsibilities

1. Discovery Review and Analysis

• Independently review interrogatories, requests for production, requests for admission, and all corresponding responses.
• Evaluate whether discovery responses are complete, responsive, and consistent with the allegations and defenses.
• Identify incomplete answers, improper objections, missing documents, contradictory statements, and other discovery deficiencies.
• Review pleadings, motions, court orders, correspondence, and supporting documentation to understand the procedural and factual history of each case.
• Compare discovery responses against pleadings and other evidence to identify admissions, disputed facts, and potential evidentiary issues.
• Identify unanswered requests for admission and promptly alert the attorney to any potential consequences or applicable deadlines.
• Determine whether additional discovery, supplemental responses, or further investigation should be recommended.

2. Case Evaluation and Recommended Next Steps

Following review of discovery, the paralegal shall evaluate the case and recommend the appropriate procedural action for attorney consideration.

Recommendations may include:

• Preparing correspondence concerning deficient discovery responses.
• Drafting a motion to compel discovery.
• Preparing additional interrogatories, requests for production, or requests for admission.
• Recommending depositions or additional investigation.
• Evaluating whether the discovery supports a motion for summary judgment.
• Identifying whether admissions or undisputed facts support dispositive relief.
• Recommending settlement discussions or other methods of resolution.
• Identifying matters requiring additional evidence before proceeding.
• Recommending preparation for trial or other court proceedings.
• Identifying deadlines, procedural requirements, and immediate action items.

The paralegal must be able to explain why a particular course of action is recommended, rather than simply identifying that discovery has been received or reviewed.

All legal recommendations and decisions concerning litigation strategy remain subject to attorney review and approval.

3. Preparation of Written Case Analysis Memorandum

Upon completion of the discovery review, the paralegal shall prepare a written memorandum addressed to the assigned attorney and maintained in the electronic case file.

Each memorandum should include:

1. Case Identification: Case name, case number, assigned attorney, and date of review.
2. Procedural History: Brief summary of the pleadings, motions, court orders, and current status of litigation.
3. Discovery Reviewed: Identification of the discovery requests, responses, documents, and other evidence examined.
4. Summary of Findings: Material admissions, disputed facts, relevant evidence, and information obtained through discovery.
5. Discovery Deficiencies: Identification of incomplete responses, missing documents, objections, inconsistencies, and outstanding discovery.
6. Legal and Procedural Issues: Identification of issues that may affect the case, including applicable deadlines and matters requiring attorney evaluation.
7. Recommended Next Steps: Specific proposed actions, supported by an explanation of the factual and procedural basis for each recommendation.
8. Priority and Deadlines: Identification of time-sensitive matters and proposed completion dates.
9. Attorney Action Required: A clear statement of decisions, approvals, or instructions needed from the supervising attorney.

The memorandum must provide the attorney with sufficient information to understand the status of the case, the significance of the discovery, and the recommended next course of action without having to independently reconstruct the entire file.

4. Case Management and Follow-Up

• Maintain accurate and complete electronic case files.
• Ensure all discovery responses and supporting documents are properly identified, organized, and saved.
• Maintain a system for tracking discovery deadlines, court deadlines, and outstanding tasks.
• Monitor assigned cases to prevent unnecessary inactivity or delay.
• Follow up on outstanding discovery and other matters requiring action.
• Prepare drafts of correspondence, pleadings, motions, and other litigation documents for attorney review.
• Document all substantive file reviews and recommended actions in the case management system.
• Promptly bring urgent matters, approaching deadlines, and significant legal issues to the attorney’s attention.
• Implement approved litigation strategies and monitor completion of assigned tasks.

Required Qualifications

• Prior experience as a litigation paralegal, preferably involving civil litigation, creditor’s rights, commercial litigation, or collection matters.
• Demonstrated experience reviewing and analyzing written discovery.
• Strong understanding of civil litigation procedures, discovery practices, and court deadlines.
• Ability to identify significant factual and procedural issues and recommend appropriate action.
• Excellent legal writing, analytical, organizational, and communication skills.
• Ability to prepare clear, concise, and substantive memoranda for attorney review.
• Ability to manage multiple litigation files and competing deadlines.
• Proficiency with electronic case management systems, Microsoft Word, Adobe Acrobat, and electronic filing systems.
• Ability to work independently, exercise initiative, and recognize when attorney involvement is necessary.
• Strong attention to detail and commitment to accuracy and confidentiality.

Preferred Qualifications

• At least two years of civil litigation paralegal experience.
• Experience with Arkansas state and federal civil procedure.
• Familiarity with Arkansas Rules of Civil Procedure, particularly discovery and motion practice.
• Experience drafting motions to compel, motions for summary judgment, and other litigation pleadings.
• Experience in creditor’s rights, debt collection, judgment enforcement, or commercial litigation.
• Ability to conduct legal research and identify relevant procedural rules for attorney consideration.

Performance Expectations

The successful candidate will be evaluated on the following:

• Quality of Analysis: Ability to identify significant facts, deficiencies, admissions, and procedural issues.
• Independent Initiative: Ability to evaluate assigned matters and recommend action without waiting for detailed attorney instructions.
• Written Communication: Quality, completeness, and usefulness of case analysis memoranda.
• Timeliness: Prompt review of discovery and identification of deadlines.
• Case Progression: Consistent follow-up to ensure litigation matters advance toward resolution.
• Accuracy: Reliability of file reviews, factual summaries, and procedural recommendations.
• Accountability: Ownership of assigned responsibilities and timely completion of attorney-approved actions.

Scope of Authority

The paralegal is expected to exercise independent analytical judgment in reviewing discovery, identifying issues, and developing proposed courses of action. However, the paralegal works under the supervision of a licensed attorney and does not independently provide legal advice, make final legal strategy decisions, or undertake actions reserved to licensed attorneys.

Overall Objective

The objective of this position is not merely to process discovery or maintain litigation files. It is to provide meaningful case analysis that assists the attorney in making informed decisions and moving litigation forward efficiently.

The successful candidate will be a proactive litigation professional who can review a file, understand the issues, recognize what needs to happen next, and communicate a well-reasoned recommendation to the attorney in writing.