Complex Litigation / Medical Malpractice Discovery Paralegal

McKean Smith LLC•Vancouver, WA

11d•Hybrid

About The Position

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.

Requirements

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.

Nice To Haves

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).

Responsibilities

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).
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.
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.
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.
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.
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.