Lead, mentor, and develop foreign paralegal staff. Independently propound and respond to discovery requests from scratch. Develop tailored discovery strategies. Prepare precise jury charges. Draft petitions, complaints, and targeted discovery. Draft petitions, pleadings, and complaints for state and federal courts. Review and analyze discovery records and gathered evidence. Draft motions to compel. Monitor and adhere to court deadlines and statutes. Assemble trial binders. Draft legal motions.