I am a graduate of law school and have been a paralegal for over 35 years in the areas of catastrophic personal injury (including mesothelioma), elder abuse, criminal law (both federal and state), civil litigation, administrative law, real estate, construction defects, product liability, banking law, insurance defense, professional malpractice, workers compensation, and family law. A large part of my legal career has been in transactional related litigation. I have been on the defense side of SEC litigation and FDIC review. I have developed and negotiated agreements involving proprietary rights, real property, intellectual property, licensing rights and service contracts. I have written several criminal appellate briefs both state and federal. I have also written a Writ of Mandate predicated on a criminal matter filed with and decided by the United States Supreme Court.
Throughout my career, I have maintained the highest professional standards and have developed excellent communication and writing skills. I have significant experience in negotiating settlements and handling cases from client intake to resolution. I also have extensive experience in drafting various contracts, agreements, releases, motions (both offensive and defensive), propounding discovery, preparing discovery responses, settlement negotiations, and client contact. I must point out that due to my lengthy experience I have a wide breadth of knowledge in many areas of law and business, and as a result, have the aptitude to quickly learn either new areas or broaden my understanding in any particular field.
Currently, I am seeking a position with a law firm that can benefit from my skills, outstanding work ethic, and commitment to the legal profession. Attached hereto for your review is my resume. I would welcome the opportunity to meet or or speak with you to discuss my qualifications in further detail. Thank you for your time and consideration.
12/1987 New York Law School, New York
Juris Doctorate Degree
05/1983 University of Southern California, Los Angeles
Bachelor's Degree Economics
Law Offices of Francis R. Henriquez,
Personal Injury Manager - Demand Writer 10/16 to Present
South Gate, CA
• Manager of the personal injury department; demand writer; negotiated all settlements with counsel, adverse carrier and medical liens.
UAV Systems Association, Legal Director 06/15 to 10/16
Beverly Hills, CA 90211
• UAVSA is a subsidiary of The Tesla Foundation and the leading national association formed for the primary purpose of serving the growing sUAS/drone community. I was the legal director of the company where I interfaced directly with the FAA on behalf of drone operators acquiring Exemptions, COA's and N-Numbers to operate commercially. Drafted and submitted all legal documents to FAA for review and approval. Became familiar with all codes and statutes regulating commercial drone operation.
• Became knowledgeable of all relevant FAA rules and regulations.
• Managed and maintained large database of national registry clients and related drone operations. Developed and maintained internal filing system to store and track client affairs.
• Developed and spoke before national client base about regulatory issues concerning drone operation.
• Generated reports and article content for inclusion on UAVSA.org website.
BANAFSHEH, DANESH & JAVID, PC, Paralegal (Demand Writer) 02/14 to 06/15
Beverly Hills, CA 90012
• Catastrophic personal injury firm. Lead demand writer for claims involving all motor vehicle collisions, including semi-trucks; pedestrian and bicycle collisions; slip and fall in
commercial as well as residential settings; and prepared mediation briefs. Primary focus was on disputed liability cases.
• Required to research and brief applicable statutes/regulations effecting claims; Ensured hospital compliance with HIPPA requirements. Reviewed and summarized thousands of medical records and lab reports. Understanding of medical procedures and adverse reactions to administered medications and administration errors. Actively consulted with
medical staff including physicians and RN's re: client medical status and pharmacological related issues.
• I recovered 1.5 million dollars in one case and responsible for over 4 million dollars in recovery during my year and half employ.
FUTTER-WELLS, PC, Paralegal 05/13 to 02/14
Santa Monica, California
• Business and financial consulting firm specializing in representing companies and high net worth individuals and investors with their business planning, implementation, financing, merger and acquisition, and dissolution or wind down activities. Jurisdictions involved New York and California. Reviewed and summarized corporate documents, limited partnership agreements, operating agreements, lease agreements, loan and escrow documents and property development agreements. Provided research support on various issues including but not limited to alter ego implications and mortgagee/mortgagor rights.
LAW OFFICES OF GARY DORDICK, Paralegal 02/13 to 05/13:
Beverly Hills, California
• Plaintiff's firm involved in catastrophic personal injury. Head of discovery department. Managed and supervised other paralegals in preparing offensive and defensive discovery. Extensive client contact. Prepared oppositions to demurrers and motions in limine.
KELLER, FISHBACK & JACKSON, Paralegal 11/2011 to 02/13:
• Plaintiff's firm worked only on mesothelioma claims (and other asbestos related injuries). Involved in all facets of case preparation: intake, development of discoveryplan, propounded and responded to discovery, retrieval of medical, employment and other related records and data based management. Extensive client contact. Draft correspondence and memoranda. Prepared deposition summaries. Prepared mandatory settlement conference briefs, trial binders and all trial related documents.
LAW OFFICES OF RONALD G. WHITEMAN, Paralegal 01/2011 to 11/2011:
Los Angeles, California
• Sole practitioner. I was primarily involved in a large misappropriation of trade secret litigation. Drafted First Amended Complaint expanding applicable causes of action and parties, drafted opposition to pretrial motions, prepared and developed discovery plan, prepared responses to extensive discovery, responded to meet and confer letters, prepared case for trial. Prepared and drafted all correspondence to opposing counsel.
• Counsel's practice centered around family law. Prepared and drafted stipulated judgments and all related judicial counsel forms. Prepared and responded to discovery. Prepared high profile case for trial (Date of separation was primary issue); including extensive exhibit list.
LAW OFFICES OF MARK ALBERT, Paralegal 07/2009 to 12/2010:
Los Angeles, California
• Drafted appellate briefs for The California Appellate Project: Drafted discovery requests; Reviewed, summarized and cataloged documents in large SEC filing.
WATERS KRAUS & PAUL, Paralegal 10/2008 to 06/2009:
El Segundo, California
• Plaintiff's Firm worked only on mesothelioma claims (and other asbestos related claims). Worked in the Discovery Department responsible for responding to
Defendant's Discovery requests which included General Order Standard Interrogatories, Special Interrogatories, Form Interrogatories, Request for Production and Request for Admissions. Worked extensively with proprietary full text database systems similar to Summation. Also worked with Visionary software similar to Concordance.
SANDS & ASSOCIATES, Paralegal 12/2003 to 08/2008:
Beverly Hills, California
• Involved in all facets of civil litigation and catastrophic personal injury claims including medical malpractice, elder abuse and wrongful death from client intake to resolution; med-mal cases involved wrongful death, pressure ulcers and improper drug administration. Extensive client contact from intake to resolution; negotiated extensively with insurance adjusters as well as counsel. Developed and managed a significant working relationship with a chain of licensed medical facilities to manage the costs of third party medical services; also worked with a series of auto-body repair shops to facilitate negotiating property damage claims. Attended several IME's, obtained medical reports and billing, reviewed and summarized medical reports. Have negotiated medical liens, pharmaceutical costs and other related costs and fees. After
review of discovery responses I have researched and drafted meet and confer letters and discovery motions in addition to demurrers/motions to strike and oppositions thereto; formulated discovery plans and prepared responses to discovery; drafted motions and oppositions, attack on the pleadings and motions in limine; Prepared mediation briefs and assisted in trial preparation including exhibit books and witness lists. Summarized deposition and court transcripts.
• Involved in two year litigation against the City of Glendale in Inverse Condemnation suit; argued Imminent Domain taking due to overly restrictive use of property guidelines.
• Worked directly with Mr. Sands on recovery of Residual Interest Wrap Notes, negotiable debt instruments evidencing partnership interests in HUD owned properties worth 5-10 million dollars; prepared and filed UCC-1 financing statements and worked with USPTO.
• Primary negotiator over the construction, design and placement of a Technicolor high-rise structure on the Sunset Gower Studio lot. Firm represented owner of studio immediately abutting proposed construction lot.
• Reviewed, negotiated and drafted various contracts involving real estate, commodities, proprietary interests and service contracts; Assisted Senior Partner at three week arbitration in breach of contract action involving large residential development.
LAW OFFICES OF MANUEL H. MILLER, Paralegal 04/2001 to 12/2003:
• Worked directly under and supervised by Senior Partner, Manuel H. Miller. Primarily involved in law and motion through all facets of civil litigation including products liability.
• Wrote all pretrial and post-trial criminal motions such as bail motions, motions to suppress evidence and motions setting aside indictment, sentencing memoranda. Successful 1538 Motion.
• Trained incoming Paralegals; Researched and drafted discovery motions, pretrial motions, attack on the pleadings; Propounded discovery. Reviewed deposition and court transcripts.
LAW OFFICES OF ROBERT H. BESWICK, Paralegal 01/1986 to 04/2001:
Beverly Hills/Century City, California
• Involved in the Defense of the largest medical insurance fraud case in the history of the U.S. Central District before Judge Hatter. The story made the cover of Newsweek. "The Impending Russian Mafia." Drafted all of the motions, pre-trial, Sentencing Memoranda, Motions to set aside the Plea and related memoranda for an active primary defendant who was ultimately released based on the issues raised in my Appellate Brief. Frequently met with the Russian and Yugoslavian Defendants at the MDC, federal holding facility, to coordinate defense strategies. Actively worked on two capital cases. Researched, reviewed and drafted all pretrial and post trial criminal motions. Successful 1538 Motion.
• Researched and drafted several criminal appeal briefs both state and federal, two of which went to oral argument in the Ninth Circuit Court of Appeals; Researched and drafted Writ of Mandamus for the Supreme Court of the United States. Provided
defense assistance in the "OJ Simpson" case. Worked on the "Death Row Records" cases as well as the "Rampart" cases writing Habeas
Corpus Petitions in order to get wronged defendants before U.S.D.C. Judge Fees who managed the caseload specifically for these defendants.
• Coordinated directly with the senior partner in business litigation, insurance defense and subrogation practice for large car rental company; I was responsible for thousands of subrogation cases. Supervised seven paralegals in the handling of these cases and managed the discovery calendar; met with Supervising Counsel to review cases and performance of the assigned paralegal to insure completion of case within a specific time frame.
• Responded to and prepared discovery and other pretrial motions; Involved in all facets of civil litigation and personal injury claims from client interview to resolution; Extensive client contact; Developed working relationship with chain of medical facilities; Obtained and negotiated property damage claims; Obtained, reviewed and summarized medical reports and billing. Negotiated settlements with defense carriers and opposing counsel. Negotiated medical liens.
• Researched and drafted meet and confer letters, discovery motions; formulated discovery plan and prepared responses to discovery; drafted pretrial motions, attack on the pleadings and motions in limine; prepared mediation briefs, and assisted in trial preparation including exhibit books.
• Reviewed and wrote contracts, correspondence, negotiated with opposing counsel, advised senior partner of case status, and directly communicated with clients; negotiated fees and costs with clients and adverse parties.
• Developed and implemented legal and management assistance in either marketing new products or creating business framework for future operations with business and corporate clients; visited client sites to determine effectiveness of operations.
• Responsible for preparing and filing all articles of incorporation and domestic stock statements with the secretary of state; maintained corporation books;
• Practice included family law; involved in preparing dissolution papers, discovery, and research on complex community property issues.
• Coordinated directly with the senior partner in entertainment law; formed with Senior Partner Sports America, Inc. and International Speakers Bureau, Inc.
ADDITIONAL INFORMATION: * Literate in Word Perfect, Word, Outlook, Lotus Notes, Legal Solutions, Abacus, Visionary (Concordance style software), Chrome, Lexis Nexis (e-filing and research) and Westlaw; experienced in working with proprietary full text database systems such as Summation. * I have negotiated thousands of settlements with insurance carriers and opposing counsel. * I have been an avid collector of comic books for over 50 years. REFERENCES: Upon Request: Writing Sample Available
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