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Draft motions/pleadings as requested (Motions for Extension of Time, Motion for Leave to Depose, Motion to Dismiss, Motions for Summary Judgment, Notices of Depositions, etc.) (Billing dependent on client guidelines)
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Draft Non-Party Subpoenas and Request for Production of Documents and medical authorizations
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Draft FOIA/APRA Requests
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Communicate/Follow up with facilities RE Subpoenas/FOIA/APRA requests
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Review responsive records that come in in response to Subpoenas/FOIA/APRA Requests to ensure compliance.
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Draft Discovery requests (Interrogatories, Requests for Production of Documents, Requests for Admissions)
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Draft initial objections to discovery requests that are served on our clients
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Trial Preparation (example, Exhibits binders, verifying medical special summaries, etc.)
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Special projects as requested.
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Legal research as requested.