Personal Injury Attorney ( 3-5 years experience in personal injury requried)

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<p><strong>RESPONSIBILITIES</strong></p><p><strong> Case Management & Discovery</strong></p><ul><li>Independently manage a caseload of personal injury litigation matters from post-intake through resolution or trial</li><li>Draft and respond, supervise, to discovery demands, bills of particulars, and discovery motions under the CPLR</li><li>Coordinate and manage expert disclosure</li><li>Prepare and serve demands pursuant to CPLR Article 31; prosecute motions to compel where necessary</li></ul><p>Depositions</p><ul><li>Defend and conduct plaintiff and defendant depositions in motor vehicle, premises, and Labor Law matters</li><li>Prepare clients for EBTs; depose adverse parties, witnesses, and corporate representatives</li><li>Identify and use deposition testimony in motion practice and trial preparation</li></ul><p>Motion Practice</p><ul><li>Draft summary judgment motions and oppositions on liability and serious injury threshold under Insurance Law § 5102(d)</li><li>Prepare and oppose motions in limine, CPLR § 3212 motions, and Frye/Daubert challenges</li><li>Research and draft legal arguments on CPLR procedure, comparative fault, and damages</li></ul><p>Trial Preparation & Trial</p><ul><li>Prepare trial binders, witness lists, exhibit lists, and jury charges</li><li>Draft voir dire questions and opening/closing outlines</li><li>Attend and participate in trial proceedings; second-chair or first-chair as caseload warrants</li><li>Work toward independent first-chair trial responsibility</li></ul><p> </p><p><strong>REQUIRED QUALIFICATIONS </strong></p><p><strong>  </strong></p><ul><li>New York Bar admission — active and in good standing; no exceptions</li><li>3–5 years of plaintiff-side personal injury litigation experience in New York</li><li>Demonstrated hands-on experience with CPLR Article 31 discovery practice (demands, responses, motions to compel, PCOs)</li><li>Working knowledge of New York Insurance Law § 5102(d) serious injury threshold — categories, Adverse Physical Exam dynamic, and motion practice</li><li>Familiarity with no-fault/PIP framework in New York motor vehicle matters</li><li>Experience with NYS Supreme Court practice in at least one of the five boroughs; knowledge of court-specific part rules</li><li>Experience defending and/or conducting examinations before trial (EBTs)</li><li>Ability to independently manage a caseload without daily supervision</li></ul><p> </p><p><strong>PREFERRED QUALIFICATIONS</strong></p><p><br></p><ul><li><strong> </strong>Experience in multi-defendant litigation and cross-claims practice</li><li>Ability to read and analyze medical records independently (radiology, orthopedic, neurological)</li><li>Prior experience working with damages experts (life care planners, economists, accident reconstructionists)</li><li>Experience to premises liability matters (slip/trip and fall, building code violations, negligent security)</li><li>Exposure to Medical Malpractice matters</li><li>Experience in Labor Law §§ 240 and 241 (construction accident) matters</li><li>Prior first- or second-chair trial experience in NYS Supreme Court</li><li>Familiarity with no-fault arbitration proceedings</li><li>Able to use adobe, Ms. Word, and law related AI etc.</li></ul><p><br></p>

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