Other Responsibilities— Specific Areas: In certain cases, preparation of stipulation extending period in which to answer or otherwise respond to complaint; Preparation of initial draft of answer or other responsive pleadings; Obtain and index/organize all documents provided by the client relative to the litigation, including chronology of documents; Preparation of initial draft of interrogatories, requests for admissions and requests for production of documents; If necessary, schedule appointment with expert witness(es), prepare draft letter to expert, forwarding materials for his/her review; Preparation of initial draft notices of depositions, scheduling of reporter and conference room, preparation of subpoena, when necessary; In certain cases, review of deposition transcript and preparation of outline of same; Extensive preparation and organization of client's documents for production, in certain cases by e-discovery; Extensive organization of documents produced, in certain cases by e-discovery; Scheduling of witness interview, informing witness of trial dates; in certain cases, the paralegal may be asked to conduct an initial interview; Preparation of motions as requested by assigning attorney, for example, motions to compel, motions to show cause, motion in contempt; Schedule court reporter and arrange for location for deposition; The litigation paralegal may be requested to do limited legal research, jury verdict research, expert witness research, obtaining case law, sherardizing and cite checking in cases from briefs; (the litigation paralegal should have a good working knowledge of Westlaw); Preparation and selection of and marking exhibits for depositions and/or trial; Pre-trial check of jury questionnaires and jury lists; If necessary, work with attorneys on arbitration/trial exhibits and potential testimony using litigation support software; In certain cases, the paralegal will be asked to attend arbitration/trial with the attorney; In cases which are settled, preparation on an initial draft of release and dismissal entry; In cases to be appealed, preparation of Notice of Appeal, precise and docketing statements as well as preparation of outline of trial transcript; In certain cases, preparation of post-judgment documents, including principes for certificates of judgment; non-wage garnishments and wage garnishments; The litigation paralegal should follow-up various details in specific cases as requested the assigning attorney; Closing files: work on organizing all files, with detailed index for easy retrieval in the future, in . Project and case management skills including a strong aptitude for managing and prioritizing multiple projects and deadlines .