Lead, mentor, and develop foreign paralegal staff. Independently propound and respond to discovery requests. Develop tailored discovery strategies. Prepare precise jury charges. Draft petitions, complaints, and discovery aimed at gathering key evidence. Draft comprehensive petitions, pleadings, and complaints. Review and analyze discovery records and gathered evidence. Draft motions to compel as necessary. Monitor and adhere to all court deadlines and statutes. Assemble trial binders. Draft legal motions.