Discovery & Writer Paralegal

Overview

The Discovery Paralegal is a centralized, firm-wide resource supporting all litigation attorneys across every pod. This role owns the firm's written discovery function end to end — from propounding initial discovery through drafting responses, tracking deadlines, & coordinating production — so that pod paralegals & handling attorneys can focus on case strategy, client communication, & trial preparation.

This is the highest-leverage support hire in the firm’s current structure. The person in this role works across four litigation teams simultaneously, manages competing priorities from multiple attorneys, & produces consistent, deadline-compliant work product without requiring hand-holding from any individual attorney.

It demands exceptional organizational discipline, strong legal writing ability, & the interpersonal maturity to work across different attorney styles & preferences without friction. This is not a pod-support role. It is a firm-wide function.

My Why

Our clients have been through devastating, life-altering events — fires, hurricanes, disasters. They hired us to make them whole. Discovery is one of the most powerful tools we have to do that: it compels the insurance company to produce what it knows, reveal what it paid, &expose where it fell short.

What This Role Is and Is Not

This Role IS

This role IS

• The firm-wide owner of all written discovery on litigation files across all four litigation attorney pods
• Responsible for propounding, responding, tracking, & producing discovery & legal drafting across all four pods — functioning as each pod’s Writer Paralegal until dedicated pod-level Writers are hired
• A cross-pod deadline enforcement &drafting production function — this role exists to ensure that no discovery deadline is missed &that all litigation attorneys have timely, quality work product
• A cross-pod coordination role with active, ongoing working relationships with all four litigation attorneys & their dedicated Logistics Paralegals
• A quality control point for all discovery & drafted work product: formatting, local rule compliance, completeness, & consistency with firm standards across all pods

This role IS NOT

• A case manager or file owner
• The primary client contact — that responsibility stays with the pod paralegal
• Responsible for trial prep, mediation materials, or post-settlement work
• A supervisor of pod paralegals — this is a peer coordination role, not a management role
• A catch-all for general paralegal tasks outside discovery & litigation drafting. Trial prep, mediation materials, post-settlement processing, & client logistics remain with each pod’s dedicated Logistics Paralegal.

Key ResponsibilitiesA. Propounding Discovery (All Pods)

• Propound written discovery on all litigation files within 14 days of the defendant's answer being filed (state court) or following the Rule 26 conference (federal court).
• Use Litify merge packets to generate discovery requests & ensure all propounded discovery is entered as Discovery Objects in Litify upon sending.
• Calendar response deadlines in Litify immediately upon propounding.
• Coordinate with the handling attorney & pod paralegal to ensure discovery requests are case-specific & not generic — this role is not a template-only function.
• Prepare & send supplemental discovery as directed by the handling attorney at the 120-day discovery plan stage.
• Prepare subpoenas to third parties (SDTs) as directed by the handling attorney's Discovery Plan.

B. Responding to Discovery Propounded by Opposing Counsel (All Pods)

• Upon receipt of defendant's discovery, send to client immediately (within 24-48 hours).
• Give client 7 days to respond; follow up every 2 days if no response received.
• Schedule a client review call with the handling attorney within 14 days of receiving discovery.
• Prepare initial draft responses with objections using Eve within the firm's approved discovery response prompts.
• Coordinate attorney review of assembled document production — responses must be sent within 30 days of receipt.
• Prepare Rule 37 / 10.1 meet-and-confer communications when opposing counsel fails to timely respond to our discovery.
• Prepare motions to compel at the handling attorney's direction when meet-and-confer efforts are unsuccessful.

C. Deadline Tracking & Litify Management (All Pods)

• Maintain a firm-wide discovery deadline tracker across all active litigation files, updated in real time.
• Monitor the 31st day after propounding & check in with the handling attorney if responses have not been received.
• Ensure all discovery deadlines are entered & current in Litify for every assigned litigation file.
• Flag any deadline at risk immediately to the handling attorney & manager — do not wait to be asked.
• Confirm receipt of defendant's discovery responses & notify pod paralegal & attorney when production is complete & ready for review.

D. Local Rule & Jurisdiction Compliance (All Pods)

• Maintain working knowledge of discovery rules, formatting requirements, & procedural deadlines across all jurisdictions in which the firm actively litigates — including Louisiana state, Louisiana federal, & all active out-of-state jurisdictions.
• Ensure all propounded & responsive discovery complies with the applicable court's local rules on formatting, spacing, font, & service.
• Consult with the pod logistics paralegal on filing & service logistics when electronic or physical filing is required.
• Flag jurisdictional issues or unfamiliar local rules to the handling attorney immediately upon assignment.

E. Cross-Pod Legal Drafting (Writer Function)

• Serve as the firm’s interim Writer Paralegal across all four litigation pods, producing template-driven & Eve-assisted legal work product fed by each pod’s Logistics Paralegal deadline calendar.
• Draft pleadings, motions, discovery requests & responses, mediation position papers, & other litigation documents using firm templates & Eve prompts, as directed by the handling attorney & fed by the pod Logistics Paralegal’s calendar.
• Maintain an active drafting queue across all four pods, prioritizing based on deadline urgency & attorney direction. Communicate daily on competing priorities when multiple pods have simultaneous deadlines.
• Escalate discovery disputes, drafting bottlenecks, missed response deadlines, or production deficiencies to the handling attorney promptly with a recommended course of action. Never allow a deadline to pass without escalating first.
• Coordinate with each pod’s Logistics Paralegal to ensure discovery responses & drafted work product are properly filed, labeled, & linked to exhibits in Litify. Ensure the handling attorney has reviewed & approved all substantive filings before submission.

F. Cross-Pod Coordination Protocol

• Work directly with the Logistics Paralegal in each pod to receive the active deadline calendar, upcoming drafting needs, & case-specific context required to produce accurate, tailored work product. Do not draft discovery or litigation documents without adequate case context from the pod.
• Maintain a unified drafting queue across all four litigation pods. When competing deadlines arise simultaneously, communicate priority conflicts to Dominique immediately for resolution. Never silently deprioritize one pod’s deadline to serve another.
• Participate in weekly litigation team meetings to report on discovery status, drafting output, & any open items across all pods.
• Adapt to the working style & communication preferences of each litigation attorney. This role serves four attorneys with different case loads, case types, & expectations. Flexibility & cross-team professionalism are non-negotiable.
• Proactively flag to Dominique when overall cross-pod volume is approaching the ceiling of what one person can manage without deadline risk. This role requires self-awareness about capacity limits a& nd the professional confidence to raise that flag before a deadline is missed, not after.

Critical Role Competencies

• Deadline-obsessive across multiple teams — treats every discovery deadline on every pod as non-negotiable & self-manages a unified queue without being reminded by individual attorneys.
• Process-disciplined — follows firm protocols consistently & completely; does not improvise on deadline-critical workflows.
• Proactive communicator — flags problems, delays, & risks before they become crises; does not wait to be asked for updates.
• Jurisdiction-aware — understands that local rules vary & actively researches the applicable rules for every new case jurisdiction.
• Systems fluent — maintains accurate, real-time data in Litify; understands that a deadline not entered is a deadline that will be missed.
• High-volume capable — manages discovery across a full docket of litigation files simultaneously without losing track of any individual file's status.
• Cross-team collaborative without being dependent — builds effective working relationships with four different attorneys & their Logistics Paralegals, adapts to different working styles, & executes core responsibilities without hand-holding from any individual pod.
• Professionally accountable — takes ownership of errors, corrects them immediately, & reports them to the handling attorney without prompting.

Technical Skills & Requirements

• Fluent in Litify — specifically in discovery object creation, deadline calendaring, merge packet generation, & case note documentation.
• Proficient in Eve — specifically the firm's discovery drafting & response prompts.
• Comfortable with MS Office 365, RingCentral, & Slack.
• Able to read & apply court local rules independently for formatting, filing, & service requirements.
• Experience with both state & federal court discovery procedures required.
• Familiarity with out-of-state insurance defense litigation preferred but not required — willingness to learn jurisdiction-specific rules is required.