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Complex Litigation / Medical Malpractice Discovery Paralegal 

McKean Smith LLC
Full-time
Remote friendly (Vancouver, Washington, United States)
United States

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).