The paralegal is often responsible for drafting all the discovery documents and also managing and maintaining all the depositions, exhibits and testimony in both hard copy and electronically. In large cases, it is essential for the paralegal to be competent in using litigation software, such as document imaging. It is important that the paralegal communicates effectively with outside counsel and staff, judicial and court personnel, and the vendors who are providing support services for the case. Attorney strategies for trial preparation differ. Some attorneys utilize their paralegals to help them with their opening statement and closing arguments.
Paralegals often accompany and assist attorneys at trial.
Paralegals need to be able to prepare the exhibits and trial books and to draft voir dire questions. Nancy Cihak, CLA, who is employed by John T. Cook, P.A., emphasizes how important organization is in litigation. She monitors the flow of the file so that the next step is appropriately taken and the process doesn't bog down. After the defense attorney files an answer, Nancy customarily sends out interrogatories and requests to produce. At that same time, she will set the defendant for deposition within 40 to 50 days.