I am proud to be featured on the Freelancers Union site! I speak from the perspective of both a freelance paralegal and writer. To read the full article, access this link:


Five Ways Full-Time Employment Can Hurt You.

This article came across my news feed about three months ago. I must have been out there in the real world too busy “buying and selling services,” (as the writer so succinctly describes in this article) to post it!

Much food for thought here, and the ideas should give every employer and worker pause when they consider their business model and role within the world:

The comments are from people who have completely missed the point of the article. The best security you can ever provide for yourself is a situation where you are offering your services and building relationships with a small group of clients you admire, trust, and respect. Hopefully, the feelings are mutual and everyone prospers. Operating this way ensures that no one person or one group of people can ever determine your income or value. You build a world for yourself where you are virtually unstoppable/unfireable. I can’t think of a situation that would provide more security.

Not everyone wants freedom, and I may not always want it either. Freedom is not easy. Building relationships, performing optimally every single time, and coming through before you say you will — these are not easy things. If you are not prepared to fight nearly every single day, you will lose your footing and crash. I have seen both sides of it. The easiest thing in the world is to have a job. You show up and you are going to get paid.

On your own, you get paid for what you can do. My feeling is that this is absolutely the purest working relationship that two people can ever have with each other. The buyer knows that the seller is dedicated to providing the best product imaginable, because if she doesn’t, the buyer will never come back. The seller retains control over her own ability to generate income and provide the best life for herself. If you are a knowledge worker, you need to be aware that the world has been changing for quite some time now.

To every paralegal and any knowledge worker employee in America, I ask you:  When you wake-up one day, and go to your “good” job, will you ever find yourself called into a conference room and informed that your bonus is gone or your salary is frozen? If this happens, what are you prepared to do? Only you know what you can live with, and most likely your answer will vary as your life stages change. Will you sit quietly and give them a “Thank you, sir. May I have another,” thanking God that you still have a job, or will this news scare the hell out of you and make you enter the world again on your own and fight for your life?

You are not powerless in your situation. You do not actually have to do anything. You might not remember, but you do have free will, choice, and a mind to build a world according to your specifications.

My first day of freedom began February 11, 2014. I have never been leaner, sharper, faster, or stronger than this moment in time.

I will leave you with my Freelancer’s Prayer:

Help me recognize opportunities to be of service to others. Bring people who want what I have to offer into my life, and me into theirs. Let me not waste anything. Keep my spirit strong to keep fighting. Let me leave things and people better than how they came to me. 


How much is Your Time Worth?

In the June 2014 issue of Entrepreneur Magazine, there is an article about the value of an entrepreneur’s time.

To calculate what your time is worth, take your total income from all sources and divide it by 2,000 (the number of hours in a 40-hour week). If your hourly wage is greater than the cost to pay someone else to handle a task, it makes sense to pay someone else to complete the task.


Paralegal Pay Rises.

An Article that all lawyers should read:


Litigation Paralegal Organization.

When I was an in-house litigation trial paralegal, I perfected my case management tools so that I could keep my team running in the most efficient way possible. For every case I was assigned to, I created a working notebook for myself that contained the following sections:

A. General Case Management

This section contains documents that are used constantly throughout the case. Instead of wasting your time printing them multiple times a week, I have found that it is easier to just have them readily available in one place.

1. Complaint, Affidavits of Service, & Answers

These initial case documents are constantly being referred back to.

2. Chart of Outstanding Motions

I use this chart to keep track of all motions that have been filed by every party and note how the Judge ruled upon them. This is a very useful tool that a paralegal can use to remind the attorneys when a motion has been outstanding for two months without the Judge having made a ruling. This is one of the ways that cases get stuck in the system, and you can help get them moving again if you call attention to it.

3. Orders

The name of the tab says it all. If the Judge has issued an Order, you need to understand the substance of it and have it handy to refer back to.

4. Hearing Transcripts

You need to really pay attention to these and make sure you have noted important statements from the Judge, and that you understand the arguments the attorneys are making.

5. Discovery Correspondence

This is an easy way to keep track of the documents that are being produced to us and by us, and will also include discovery dispute letters.

6. Discovery Objection Spreadsheets

I use these to track every response to every discovery request we’ve propounded. I keep a notes section to list whether an additional response is needed or if responsive documents have been produced. The attorneys and I use these spreadsheets to prepare discovery dispute letters to opposing counsel.

B. Document Management

The items listed below are organizational tools that I use when new documents come in.

7. Player’s List

This is a more general version of a witness list. Essentially, this contains the name, contact information, and notes about everyone who may or does have knowledge about the case.

8. Index of Docs Produced

Your master spreadsheet of every document that has been produced by every party in the action. This is broken up by party, and then the date the documents were produced. It contains a short description of the document with the bates-label.

9. Exhibit List

The exhibit list is a culled down version of your Index of Docs Produced. You know not every document that is produced to you or by you, will be used at trial. It is helpful to create an exhibit list of important documents as they are produced so you don’t find yourself trying to piece the case together when you get noticed for trial.

10. Non-Party RPD Tracking Chart

When parties serve requests for documents upon non-parties, I create a simple chart that lists out who propounded the request and when, what day we objected to it or sent a no object letter, and what day we received the response.

11. List of Docs Sent To / From Experts

Another simple chart that is created in the beginning and will really make your entire team’s life a whole lot easier. What materials are you sending to the experts and what are they sending you? When did it happen? Are you producing it to the other side?

12. Chronology

I love updating this spreadsheet as documents come in. This is an absolutely priceless method of keeping track of what happened and what document source evidences it.

In addition to my own work book, every case also has separate deposition notebooks, discovery response notebooks, and documents produced notebooks. I have found these tools to be the best way to keep myself and my team on top of the case.


A Note About Expert Files and Research 

As a paralegal, you may be utilized in locating an expert to support the firm’s case theory, participate in preparing for the expert’s deposition, and preparing exhibits for trial. Undoubtedly, one of the most important aspects of your job will be to manage the communications between your office and your expert’s office. You will be responsible for tracking the documents that you send out to the expert for review, and also tracking the materials that are sent in to your attorneys. Another aspect of your job will also involve researching the opposing party’s experts. This article discusses some tips for you to use. When communicating with your expert in writing, keep in mind that everything you send is discoverable. Most lawyers prefer you to send basic cover letters when enclosing documents, and refrain from listing out any details or instructions (other than to call the attorney when the document review is completed). Of course, keep your internal tracking spreadsheet updated for every item you transmit to an expert.

When preparing your expert files for deposition and trial, you should have the following documents without fail: CVs, billing records, documents you have sent to the expert for review, expert notes, and all of the documents that the expert has sent your office. If you are going to trial, you will want to be sure to have several hard copies of the expert’s deposition with marked exhibits.

When researching the experts that your opposing party has selected, the internet will be your best friend for performing research. See if you can obtain copies of prior depositions disclosed on the expert’s testimony list. If your firm does not have a subscription service, you will have to request copies by emailing or calling one of the friendly lawyers listed in the prior case. Some additional research sources you may be able to utilize for researching the opposing party’s expert are listed below:

Paid services:

IDEX through Lexis Nexis; and
Free services:

Court websites;
American Medical Association;
American Board of Medical Specialties;
American College of Physicians;
American College of Emergency Physicians;
PubMed (free to view abstracts of articles);
Google and social media sites;
Medical schools and universities;
Client websites; and
Local (local for your expert) newspapers.
Stay on top of the documents that are going out of your office in care of your experts, and the documents that are coming to you from your experts, and you will be in excellent shape when it comes to assisting your attorneys prepare for and attend depositions and trials.


Ten Practical Tips for Trial Paralegals 

During the heat of preparing for trial, something is bound to be forgotten. Here are a few common things that have the potential to slip through the cracks. When reading this, bear in mind that the reason you are being warned is because a paralegal who went before you let it slide. Some things are just best learning from other people aren’t they? Here is your cheat sheet to ensure you have what you need for your lawyers when you show up for trial.

Ten Practical Tips to Remember:


1. Check on travel arrangements. Are you responsible for arranging hotel rooms, airfare, or car service for experts, the clients, and your attorneys? If you aren’t sure, ask your lead attorney. Remember, paranoia keeps you safe and ignorance is no excuse. It is typically a wise idea to have a car service on speed dial so you can move witnesses and experts in and out of the courtroom quickly.

Court Room Set-up:

2. Do you need a court order to install equipment or bring in demonstrative exhibits? Find out a month before trial and take the proper steps to get an order if you need one.

3. Will there be a room just for your witnesses and trial team? Where will you keep your trial exhibits and extra supplies? Talk to your lead attorney and agree on the day and time for transporting exhibits to the courthouse.

4. Get to know the court reporter and the courtroom staff.

Snacks and Supplies:

5. Keep a stash of bottled water and premium snacks on hand, but always know where the vending machines in the building are. Further, it is helpful to identify a deli that will deliver daily to your courtroom.

6. Make sure your trial box is stocked with every office supply that you use. This is your traveling supply closet, and if you can think of it, it needs to be packed up and carried to court with you. Don’t forget the pain reliever and extra legal pads!


7. Whatever you have on paper, make sure you also have it either on a portable hard drive or a flash drive on your person, and that your tech team has it too.


8. Label the backs of every trial board with a number, and keep a coded list of what everything is. This will help you find the correct board quickly, and will keep you from fumbling in front of the jury.

Call List:

9. Keep everyone involved in the trial coded into your phone, and keep a hard copy list on your person. This means your vendors, your trial team, court personnel, and all fact witnesses and experts.

Contact Back in the Office:

10. You need one dedicated person back in the office to run back-up tasks for you. Never involve the entire office staff, though, or you will confuse things.


Everything I Need to Know About Business I Learned From My Lawyers.

I have noticed some universal truths over the years about lawyers. They do some funny things sometimes that will infuriate you as a paralegal, but they will also provide you with invaluable life lessons along the way if you are paying attention. Everything I need to know about business I learned from working for lawyers, and here are a few of the highlights:

Always lead with your most important question

This may be the only one that will ever get answered. This applies to questions propounded over emails or in person. This rule is applicable to everyone you communicate with. Everyone is busy and it is very easy to get bogged down in details. The best practice is to develop in your field so that you are not even having to ask too many questions – period.

How to control conversations and questioning

If the opposition is questioning you too much, answer a question with a question, and if that is not possible, be as vague as possible. There is a fine art to avoiding subject matters you are not ready to discuss and being evasive in a way that people can tell you are avoiding them. For instance, if someone asks you how that draft is coming along, just respond by asking them something about themselves and engaging them in a different subject. Then excuse yourself soon after. If someone asks you something that you feel is too personal, learn to respond with a careful and respectful “Why do you want to know?”

Avoid making promises

This is the old (but still true) adage about over-delivery and under-promising to constantly wow people. A lot of times you really can’t extend a promise anyway. You can communicate what you hope to accomplish, and how you propose to go about ensuring you achieve the goal, but it is dangerous territory indeed to promise results.

Don’t interrogate your family members or friends if you want to keep them

Litigators are naturally curious people. In the beginning, it can be hard to turn off the questioning instinct. Treat your friends and family members as though you are cross-examining them, and you will soon find yourself very lonely.

How to work with difficult people or terminate toxic relationships

Litigation is one of the most stressful work environments that exist. You have to work with demanding clients, other co-workers who are under just as much stress as you are, and satisfy lawyers who are under more stress than anyone. If you remain positive and keep a “How would you like me to go about achieving _____?” attitude, it will be clear that you are trying your best to help. No matter how difficult someone is to work with, if they understand that your goal is to help them, they should calm down and stop attacking you. If the abuse continues, walk. This person does not deserve your good work. A graceful exit is another skill that you must master.

How to read the fine print / pay attention to the details

When you first start out in litigation, you won’t understand how important the details are. But you will after you accidentally delete a clause that changes everything in a contract, or after you mistakenly discard a document because you thought it was a duplicate. Pay attention!

Trust no one

Always assume that something will go wrong and allow yourself enough time to fix things when they fall apart. Few people want to mess you up on purpose. Still, they will fail you, or your equipment will fail you. Your vendor will have a problem on their end, and you won’t have your exhibits on time. Or your court reporter won’t show up. The day your response brief is due with twenty exhibits that must be copied and marked will be the day your copier breaks down. Anticipate these things happening and have a plan to manage the risks. Set yourself a calendar reminder a few days before your deadline to check in with your vendors and make sure they aren’t operating on the eleventh hour. Get your exhibits copied and assembled the day before your response brief is due. If that is not possible, have a contingency plan in effect so you can run to a copy store or a friendly law firm around the corner and take care of your deadline.

Be proactive and plan

Take the initiative and get tasks done early. This will ensure that you have enough time to meet your firm’s deadlines. There are some last minute things that will occur in litigation and in general business operations. But if you remain diligent in organizing your documents and managing your tasks, there really shouldn’t be much that you find yourself unprepared to handle.


Attorneys are notoriously bad communicators. Everything that you come across you must evaluate yourself and pose the question: “Who else needs to know about this?” THEN TELL THEM!

Doing things out of an abundance of caution

This is the one that will infuriate you, and as a paralegal, you will come to refer to this practice as Throwing Everything Against the Wall to See What Sticks. For instance, if your lawyer needs to send an important piece of communication pursuant to the Overnight Statutory Delivery requirement (Read: Fed-ex), why stop there? Go ahead and send it via fax, electronic mail, and regular mail. Why do a task one way, when clearly you can do it five different ways? Just know that the reason why they do this is to protect the interests of their clients in every possible way, and not to drive you to the brink of insanity. I think.