Plaintiff personal injury law firm needs an experienced aggressive litigation associate. Job duties and responsibilities include but are not limited too: propounding written discovery, and responding to written discovery. defending depositions, and taking depositions, preparing pre litigation demand for settlement letters and packages of materials. Court appearances for CMC's, Status conferences, FSC's, preparation of trial documents, summarizing medical records and discovery, . Must have experience in fast paced busy plaintiff firm. Must have exceptional writing and communicating skills. Must be able to manage a case load of 50-75 files. Must be extremely efficient, organized and hard working.