Job Summary:

Provide assistance to Lead Staff Counsel from inception of case through trial. Focus on gathering, analyzing, and organizing information; drafting discovery requests and discovery responses, motions, and other documents under the direction of the attorneys; and preparation of case for trial.

Essential Duties and Responsibilities:

• Draft case specific written discovery requests, specifically Interrogatories, Request for Production and Request for Admissions to be propounded upon the Plaintiff
• Drafts legal objections and factual answers to written discovery served upon the company, specifically responses to Interrogatories, Request for Production, and Request for Admissions.
• Drafts good faith letters to opposing counsel regarding outstanding discovery requests.
• Drafts discovery motions and responses to opposing discovery motions.
• Prepares non-party subpoenas for documents.
• Prepares documents to be produced in response to Request for Production.
• Drafts Privilege Logs by identifying applicable privileges as it relates to claim and other documents.
• Communicate with witnesses including field adjusters, engineers, contractors, insureds, etc. and assist the handling attorney with preparation for depositions and trials.
• Prepare electronic and paper Exhibits for Trial at attorney direction.
• Assist and/or ensure that electronic binders for discovery, depositions and pleadings are prepared for trial.
• Communicate and coordinate witnesses for trial attendance.
• Work with handling Attorney and Legal Assistant to prepare for trial; set up arrangements for equipment at Court house; attendance at trial may be requested when permitted by Court but is not required.
• Communicate with co-workers, management, clients, vendors, and others as needed in a courteous and professional manner.
• Maintain the integrity of the company and products offered by complying with federal and state regulations as well as company policies and procedures; and
• Other tasks as assigned.

Key Competencies

• A thorough understanding of the Florida Rules of Civil Procedure
• A thorough understanding of the Florida Evidence Code.
• A thorough understanding of all Administrative Orders in effect within each jurisdiction that the paralegal handles.
• A thorough understanding of case law governing discovery in Florida.
• Ability to work independently on discovery matters, independently spot issues and be able to target discovery to specific factual issues in order to apply the applicable law to the discovered facts.

Minimum Education and Experience:

• Strongly prefer bachelor’s degree, Associates or Certificate in Paralegal Studies from an ABA-approved program, or a Juris Doctorate.
• At least 2 years of experience working as a paralegal.
• At least 1 year of experience with insurance claims. First party property experience strongly preferred.

General Qualifications Required:

• Strong research skills
• Strong organization skills with the ability to successfully multi-task, prioritize and maintain the daily tasks for the assigned case load.
• Strong communication skills
• Focus and commitment on delivery of high-quality legal work.
• Works collaboratively with team members and others.
• Demonstrates desire to acquire effective trial skills with increased litigation complexity.
• Demonstrates personal commitment to professional development.
• Personal integrity and adherence to a high degree of professionalism and ethical competency.
• Strong decision making and problem-solving abilities.
• Sense of urgency/responsiveness.

General Information:

All employees must pass a pre-employment background check. Other checks may be needed based on position: driving history, credit report, etc.

The preceding job description has been designed to indicate the general nature of work performed; the level of knowledge and skills typically required; and usual working conditions of this position. It is not designed to contain, or be interpreted as, a comprehensive listing of all requirements or responsibilities that may be required by employees in this job. Nothing in this job description restricts management’s right to assign or reassign duties and responsibilities to this job at any time.

Heritage Insurance Holdings, Inc. is an Equal Opportunity, Affirmative Action Employer. We will not discriminate unlawfully against qualified applicants or employees with respect to any term or condition of employment based on race, color, national origin, ancestry, sex, sexual orientation, age, religion, physical or mental disability, marital status, place of birth, military service status, or other basis protected by law.