Description

RESPONSIBILITIES

Case Management & Discovery

Independently manage a caseload of personal injury litigation matters from post-intake through resolution or trial
Draft and respond, supervise, to discovery demands, bills of particulars, and discovery motions under the CPLR
Coordinate and manage expert disclosure
Prepare and serve demands pursuant to CPLR Article 31; prosecute motions to compel where necessary
Depositions

Defend and conduct plaintiff and defendant depositions in motor vehicle, premises, and Labor Law matters
Prepare clients for EBTs; depose adverse parties, witnesses, and corporate representatives
Identify and use deposition testimony in motion practice and trial preparation
Motion Practice

Draft summary judgment motions and oppositions on liability and serious injury threshold under Insurance Law § 5102(d)
Prepare and oppose motions in limine, CPLR § 3212 motions, and Frye/Daubert challenges
Research and draft legal arguments on CPLR procedure, comparative fault, and damages
Trial Preparation & Trial

Prepare trial binders, witness lists, exhibit lists, and jury charges
Draft voir dire questions and opening/closing outlines
Attend and participate in trial proceedings; second-chair or first-chair as caseload warrants
Work toward independent first-chair trial responsibility

Requirements

New York Bar admission — active and in good standing; no exceptions
3–5 years of plaintiff-side personal injury litigation experience in New York
Demonstrated hands-on experience with CPLR Article 31 discovery practice (demands, responses, motions to compel, PCOs)
Working knowledge of New York Insurance Law § 5102(d) serious injury threshold — categories, Adverse Physical Exam dynamic, and motion practice
Familiarity with no-fault/PIP framework in New York motor vehicle matters
Experience with NYS Supreme Court practice in at least one of the five boroughs; knowledge of court-specific part rules
Experience defending and/or conducting examinations before trial (EBTs)
Ability to independently manage a caseload without daily supervision
 

PREFERRED QUALIFICATIONS 
Experience in multi-defendant litigation and cross-claims practice
Ability to read and analyze medical records independently (radiology, orthopedic, neurological)
Prior experience working with damages experts (life care planners, economists, accident reconstructionists)
Experience to premises liability matters (slip/trip and fall, building code violations, negligent security)
Exposure to Medical Malpractice matters
Experience in Labor Law §§ 240 and 241 (construction accident) matters
Prior first- or second-chair trial experience in NYS Supreme Court
Familiarity with no-fault arbitration proceedings
Able to use adobe, Ms. Word, and law related AI etc.