As the banking area expands, the paralegal may be involved in bank holding
company formation, merger and acquisition work, new banking law, as well as the
Prepare and organize files and subfiles for all transactions.
Review documents received from bank and organization of same.
Prepare letters for signature by both attorneys and legal assistants to clients,
other counsel and various regulators.
Have telephone communications with client and regulator.
Maintain transition checklist or other system to keep attorney advised of
status of the transaction.
Attend team meetings to keep informed on new issues and laws in the
Prepare closing memorandum for transaction.
Clean-up and close file.
Responsibilities of a Senior Paralegal may also include the following.
Coordinate subpoena’s and summons served on bank.
Research legal issues and questions to insure the bank’s compliance with
Analyze reports for suspected fraudulent activity.
A legal assistant in the bankruptcy area can perform a variety of tasks. They can
work with the federal courts, draft and file pleadings and have extensive phone
contact with the public. The duties of a legal assistant working in the bankruptcy
area can include:
Provide client with previously created lists of documents required for filing
Collect personal financial information regarding the bankruptcy and prepare
list of assets.
Maintain tickler/calendar system including status sheet.
Compile initial bankruptcy schedules.
Survey court records of lawsuits and judgments against the bankrupt.
Obtain Uniform Commercial Code (UCC) and real property searches as well
as appraisals, where necessary.
Collect and organize data.
File wage-earner plan schedule and fee with bankruptcy court (Chapter 13
Inventory, organize and index pleadings.
Attend and assist at document productions.
Serve subpoenas/pleadings documents.
Check creditor documentation to ensure proper perfection of security
Attend court hearings with attorney and client.
Responsibilities of a Senior Paralegal may also include the following:
Conduct initial interview of client in a Chapter 7 case.
Familiarize client with general procedures at bankruptcy court hearings,
meetings and motions;
Analyze and summarize factual information.
Meet with client to review and sign schedules.
Draft and file bankruptcy petition and schedules.
Draft and file proof of claim regarding bankruptcy.
Process letters to creditors with copy of stay order.
Attend first meeting of creditors and prepare summary.
Collect data for creditor's proof of claim regarding bankruptcy.
Serve and file debtor's monthly financial statements in Chapter 11 cases.
Compile initial schedules for bankrupt wage-earner plan.
Compile data and prepare proof of claim for wage-earner plan.
Perform legal, financial and statistical research.
Assist with preparation of Table of Contents and Table of Authorities.
Cite check statutes and cases.
Draft reaffirmation agreements - contact creditors and complete necessary
forms related thereto.
Draft various motions including Fee Applications and Retention of
Handle routine telephone calls and correspondence to creditors, creditor's
committee chairperson, attorney and trustee;
Serve and file complaints in adversary proceedings; and
Draft and file attorney's fee applications with the bankruptcy court. Assist
with all calculations for fee applications.
Assist with service of process of complaints;
Communicate with U.S. Bankruptcy Courts throughout the country to obtain
pleadings and status reports.
Prepare Final Reports in Chapter 11 cases.
Prepare semi-annual reports to U.S. Trustee Office.
Assist with distribution of estate funds to all creditors including preparation
of W-2 forms.
As a quot;Creditor's Rightsquot; Paralegal, other duties include:
Obtaining, evaluating and reporting essential facts.
Review security and mortgage documents, etc. to determine what can be
claimed as collateral to secure payment for indebtedness.
Involvement with replevin cases.
Work on collection suits with deficiency balances.
The duties of a legal assistant working in the area of collection and reimbursement
may include the following:
Obtain pertinent information about the debtor, such as:
Date of birth
Social security number
Employer and employer's address
Debtor's address and phone number
Usual line of work
Professional or non-professional memberships
Determine how the debt was incurred.
Determine past payment history.
Determine location of debtor.
Conduct initial review of documents provided by client.
Maintain judgment account worksheet in order to record payments, collection
costs and court costs.
Attend hearing with attorney for initial claim of plaintiff.
Appear in court with attorney conducting the citation examination.
Register foreign judgment in local court.
Obtain certified copy of judgment transcript.
Become familiar with Fair Debt Collection Practices Act.
Become familiar with those provisions of bankruptcy code affecting
Determine the amount of time, effort and money to be spent by the client in
order to find and prosecute the debtor.
Determine how the client wishes matter collected, such as:
Strong demand letter, then suit
Demand letter with follow-up, if necessary
Partial payment or payment plan
Payment in full
Prepare summons and complaint.
Do investigative work, such as:
Prepare documents which may include subpoena duces tecum
Request production of documents from employers and banks
Petition for order in garnishment
Work out payment plan with the debtor.
Determine balance due on wage and non-wage garnishments,- i.e., payments
made, including filing, service and attorney's fees, if applicable,, to set-up
Conduct asset investigation.
Draft motions for opposing summary judgment.
Draft memoranda and affidavits in support of summary judgment.
Draft judgment, cost bill and other supporting pleadings.
Draft notice of demand to pay.
Draft, file and serve documents for judgment debtor examination.
Draft, have issued and served the writ of garnishment, the order to release
garnishment, the order of examination, and writ of execution.
File request for dismissal form.
Arrange for indemnity bond for sheriff.
Arrange for posting of notice of sale or publication of notice of sale.
Maintain communication with sheriff regarding levy on personal property.
Prepare bid and attend sheriff's sale on real property.
Transfer judgment transcript to a different court.
Obtain exemplified copy of foreign judgment.
Prepare affidavit for transfer of a foreign judgment.
Register judgment in a different state.
Prepare and file satisfaction of judgment.
Handle collection matters once debtor files bankruptcy.
COMPUTER LITIGATION SUPPORT
Discuss case-specific needs and use of software program(s) with attorney(s)
Determine which software suits case needs, considering programs that link
document indices, images, and testimony.
Develop case-specific database(s) to facilitate the retrieval of documents and
testimony and in preparation for trial.
Work with outside vendors (or in-house personnel) to identify documents
uniformly through use of Bates labels or other means.
Review documents and prepare summaries (also referred to as abstracts or
coding sheets) for software conversion.
Work with outside vendors (or in-house personnel) to have documents
scanned (OCR'd) for full-text transfer and review within software program
and/or imaged for review within software environment.
Develop and maintain information retrieval systems, including computerized
resource materials for various specialty practice areas to be accessed and
used by in-house personnel. Resource materials include:
Documents prepared by in-house personnel, such as commonly used legal
and general forms, research memoranda, briefs, motions, and jury
Documents obtained from outside sources that contain general information
related to specific practice areas, such as agency regulations and local court
Formation of Corporate Entities
Check name availability and reserve or register corporate name.
Draft and file articles or certificate of incorporation.
Draft notices of organizational meetings and resolutions to be adopted.
Draft minutes of organizational meeting of incorporator(s), stockholders or
board of directors, or written consents in lieu of meeting.
Assemble and maintain corporate minute book.
Order corporate seal.
Draft documents necessary to issue stock certificates including subscription
agreements, receipts, stock certificates, restrictive legends, and stock and
Assist with the establishment of a bank account; prepare banking
Prepare and file application for federal employer identification number.
Prepare and file appropriate state tax registrations.
Prepare and file election by a small business corporation.
Prepare and file assumed name certificates.
Prepare and file appropriate applications for professional or special purpose
Draft employment agreements and confidentiality agreements for corporate
officers and key employees.
Maintenance of Corporate Entities
Maintain corporate minute book and stockholder records.
Draft amendments to articles or certificate of incorporation and draft
resolutions for board of directors and stockholder approval, as necessary
Draft amendments to bylaws and draft resolutions for board of directors and
stockholders approval, as necessary and appropriate.
Draft amendments to stockholders agreement.
Prepare documents necessary to issue and transfer stock certificates
including subscription agreements, receipts, stock certificates, restrictive
legends, and stock and stockholder registers.
Prepare notices, proxy materials, ballots, affidavits of mailing, and agendas
for annual and special meetings of stockholders.
Draft oaths and reports of judges/inspectors of election for stockholder
Draft resolutions to be considered by board of directors and stockholders.
Prepare minutes of meetings of the board of directors and stockholders or
written consents in lieu of meeting.
Prepare minutes of committee meetings.
Draft documents necessary to qualify corporations as foreign corporations in
Draft and file annual reports, notices of changes of officers, directors, and
related corporate information in jurisdiction of incorporation and in foreign
jurisdictions in which corporation is qualified to transact business.
Draft various applications and reports required by jurisdiction of
incorporation and/or in foreign jurisdictions in which corporation is qualified
to transact business.
Collect internal information and assist in responding to auditors' requests for
Conduct UCC, tax lien, judgment, pending suit and bankruptcy searches with
appropriate state and local agencies.
Draft UCC financing statements and subsequent amendments, assignments,
or terminations with appropriate state and local agencies.
Draft amendments to agreements and draft necessary documents to affect
Order certified copies of charter documents and certificates of good standing
from Secretary of State offices.
Formation and Maintenance of Partnership and
Limited Liability Companies
Check name availability and reserve or register partnership or limited liability
Draft certificates of limited partnerships or articles or organization.
Prepare and file application for federal employer identification number.
Prepare and file assumed name certificates.
Draft partnership and limited liability company annual reports and other state
Maintain partnership and limited liability company records in a manner
appropriate for the operation of the entity.
Maintain lists of partners or members.
Prepare minutes of meetings of partners or members or written consents in
lieu of meeting.
Draft subsequent amendments to partnership and operating agreements.
Draft documents necessary to qualify partnership or limited liability company
in foreign jurisdictions.
Draft documents for closing and assist in closing for stock purchase, asset
purchase and merger transactions.
The responsibilities of the corporate paralegal are extensive and diversified. Within
the corporate area, a paralegal may be specialized in many areas. The following is
an overview of the duties a corporate paralegal may be responsible for:
CORPORATE DEPARTMENT -- GENERAL
Maintenance of corporate information data sheets.
Organization and maintenance of state, federal and special forms, and
revisions per changing law.
Maintenance of active and inactive corporate lists.
Maintenance of minute books, stock ledgers and corporate seals.
Research inquiries from attorneys, clients, accountants, business managers,
Review bulletins for new corporate and tax law.
Maintenance of fiscal year end and annual meeting monthly tickler system.
Close-out inactive corporations from department system.
Maintenance, preparation and filing of annual corporate and franchise tax
Incorporate standard corporations.
Consult with attorney, client and accountant.
Reserve name by verbal communication or certificate.
Draft all incorporation, government and tax documents, such as:
Annual reports to Secretary of State for
foreign and domestic corporations
Assumed name application and filing
Pre-incorporation subscription agreement
Calculate fees for various government filings.
Draft correspondence to client, accountant, government offices and business
Review documents with attorney or client.
Prepare data sheet on all current corporate information.
Incorporate professional non-profit corporations, foundations and charitable
Draft all incorporation documents;
Prepare state and federal exemption applications.
Prepare budgets and correspondence.
Prepare documentation regarding annual meetings of shareholders and
directors, such as:
Draft monthly memo to attorneys
Verify changes -- data sheet, correspondence
from client, stock book changes
Draft correspondence to client and accountant
Prepare documentation regarding special meetings, such as:
Change of agent or principal address
Open/close bank account(s)
Resignations, additions or changes to
officers, directors or shareholders
Maintain corporate data sheets.
Draft stock certificates, either new issuance, cancellation or transfer.
Draft assignment separate from certificate.
Draft Certificate of Amendment of Articles of Incorporation.
Draft resolutions for election of officers, directors, and special actions.
Prepare documentation-regarding fiscal year end resolutions, such as:
Draft monthly memo to attorneys
Draft questionnaire to accountant or client
Draft correspondence to client or accountant
and follow-up regarding return of executed
Prepare consents regarding salary, dividends,
leases, loans, etc.
Prepare additional documentation regarding special meetings, such as:
Special agreements regarding leases, licenses,
productions, loans, etc.
Notice of meetings, proxies, scripts, ballots, etc.
Written consents without a meeting
Draft Amendments to By-laws and resolutions
Securities trading accounts
Draft notice of transaction or issuance with Department of Corporations.
Draft employment agreements and extensions.
Draft foreign qualifications.
Draft loan-out agreements.
Draft stock options and Stock Purchase Agreements.
Draft notice of availability of annual return (NonProfit).
Preparation of documents, such as:
Consent by directors
Certificate of Election to-wind-up and dissolve
Assumption of liability
Assignment, sale or other transfer of assets
Consent to adoption of plan of dissolution
Certificate of Dissolution
Certified copy of Board of Directors
Internal Revenue Service (IRS) forms
Individual or corporate assumption of tax liability
and tax clearance certificate from Franchise Tax Board
Review letter from client/accountant regarding information requested.
Draft and circulate memorandum to attorneys regarding pending litigation.
Review responses and discuss with attorneys.
Communicate with client and accountant.
Draft response and revise per attorneys' suggestions.
Complete limited partnership filings.
Draft promissory notes.
Draft Incumbency Certificate.
Draft Power of Attorney.
Direct miscellaneous inquiries to government offices, such as:
Agent for service of process
List of current officers and directors
Assumed name search -- county clerk
Good Standing -- state and tax status
Name availability and reservation.
Review master calendar regarding pending action.
Review new client list regarding conflict of interest.
Draft shareholders agreements.
Obtain certificate of inactivity from Franchise Tax Board.
Draft index, assemble documents and supervise binding of closing binder.
Draft license agreements.
Draft Purchase and Sale of Assets agreement.
Obtain Uniform Commercial Code (UCC) searches and prepare financing
Draft documentation for mergers, acquisitions and reorganizations, such as:
Draft checklist or memoranda
Prepare written consent by directors
Draft agreement of merger
Draft certificate of approval of agreement of merger
Prepare certified copy of Board of Directors resolutions
Obtain consent of shareholders
Draft short-form merger (subsidiary)
Prepare closing documents officers' and encumbancy certificates.
Obtain good standing certificates and certified charter documents from
Secretary of State.
Prepare tax election and arrange for appropriate filings.
Draft recording certificates and handle recordation thereof.
Draft financing statement, handle filing, obtain UCC judgment and tax lien
Attend closing with attorneys and maintain document control.
Review and organize closing documents.
Complete 1934 Exchange Act documents - 10-K, 10-Q, 9-K, 8-K, Rule 144
Prepare filings for security registration and draft responses to comments.
Prepare applications for brokers-dealer and investment advisor licenses.
Assist in due diligence analysis.
Draft and monitor legal newspaper publications.
Draft and file election by small business corporation and subsequent
shareholders' consents to such election.
Draft and file application for proper licensing when forming professional or
special purpose corporation.
Draft notices, proxy materials, ballots, affidavits of mailing and agenda for
annual and special meetings.
A paralegal in the criminal law field can function in two possible roles:
organizational or investigative. The organizational role may include document and
file control as well as assistance at criminal court hearings, trials and sentencing
process. The investigative role may include conducting-the initial client interview
plus gathering and analyzing facts relating to an alleged crime.
The following is a summary of the assignments a paralegal may perform:
Review personnel and medical records.
Prepare and have served subpoenas for document production.
Initiate and respond to correspondence.
Document telephone conferences, personal meetings, etc. for the file.
Assist in writing of reports to state and federal prosecutors to halt an
Summarize and annotate lower court transcripts for appeal.
Coordinate appeal procedures with court reporter in securing transcript for
Participate in document productions to and from government agencies.
Supervise witness and evidence files.
Analyze bank records and preparation of check spreads.
Coordinate documents with testimony at hearings, trial and depositions.
Review corporate records, including minutes and financial data.
Review and analyze tax records along with supporting documentations.
Do legal research, assist in appellate briefs and analyze responses thereto.
In the investigative role of criminal law the paralegal may:
Review fingerprints, handwriting and polygraph results.
Obtain information regarding blood, hair samples and other physical
Obtain and analyze coroner and autopsy reports.
Obtain and analyze driving records.
Prepare memorandum or summary of investigative interviews.
Locate and work with accident reconstruction and other experts pertinent to
Measure and photograph alleged crime scene.
Prepare factual chronologies.
Have knowledge of criminal charges.
Assist in surrendering defendant to authorities for processing.
Review arresting information and indictments, search warrants and consents
to search, assist at search location and prepare inventory of items seized.
Interview client while in custody under special circumstances.
Obtain and review police reports, photographs, and statements to
prosecutors from witnesses.
Locate and analyze statements, interviews, depositions, etc. of witnesses
conducted by third parties;
Trace property ownerships.
Conduct or participate in client, witness, character and expert witness
Prepare questions for and attend depositions, other interviews and polygraph
Prepare character sketch of client, witnesses and victims.
Interview and analyze community to help determine the need for a change of
Conduct survey of community standards and availability of sexually explicit
material in relation to First Amendment cases.
At criminal court hearings and trials a paralegal may:
Assist with preparation of trial brief.
Assist with jury selection.
Log exhibits offered and admitted.
Log objections sustained and overruled.
Monitor jury's reactions during trial.
Assist with preparation of opening and closing arguments.
Prepare outline of prosecution and defense cases.
Coordinate specific documents with witness during testimony.
Verify that all depositions have been filed.
Prepare visual aids, charts, diagrams, etc. for use at trial.
Coordinate telephone contact with office and witnesses.
Assist in planning and strategy.
Take notes and monitor related hearings and trials'.
Assist in preparation of witness for testimony in trial or deposition.
Investigate background information on potential jurors, including areas of
residence, political affiliations, etc.
Draft jury instructions;
Assist with analysis of voir dire.
Prepare complete notes of witness testimony.
Assist with interviewing jury following verdict.
The paralegal can also be helpful in the sentencing process by:
Assist client in meetings with probation officer.
Make bail arrangements.
Obtain discovery (police reports, search warrant, affidavit, etc.).
Draft motion compelling discovery.
Conduct legal research.
Subpoena and interview witnesses.
Examine physical evidence and tangible objects.
Examine and photograph scene of alleged crime.
Coordinate and arrange for outside investigators and experts.
Prepare trial notebook.
Draft supplemental memorandum of law.
Draft motions in arrest of judgment, for new trial, for release pending new
Draft petition for leniency/probation.
Draft notice of appeal.
Assist with preparation of pre-sentence report and investigate methods of
Assist client in effectuating restitutions.
Assist with change of plea matters, including drafting petition to enter a plea
Investigate facts for decision to prosecute or prepare defense.
Interview client with attorney.
Gather information for plea bargaining and prepare charges or plea for
Prepare for preliminary hearing or Grand Jury presentation.
Draft testimony of defendant.
Analyze case based on discovery.
Draft motion for change of venue.
Draft motions to set aside indictment, to suppress, to controvert, for civil
compromise, for diverson, in limine, for return of property, to postpone trial,
to disqualify judge and, to withdraw as attorney of record, etc.
Draft and respond to interrogatories.
Draft deposition questions and summarize depositions.
Arrange for diversion to rehabilitation or other programs.
Arrange civil compromise; Arrange work release.
Draft trial memorandum.
Attend conference with prosecutor.
Attend pretrial conference with judge and attorney.
Draft jury instructions; Attend and assist at trial.
Attend conference with client and attorney regarding pre-sentence report.
Prepare sentencing information and work with probation officers.
Research law regarding appealable issues.
Draft assignments of error and arguments.
Draft and design qualified plan documents and trust agreements, including
amendments and restatements, to comply with law and regulations or client
Develop and review summary plan descriptions.
Draft welfare benefit plans, including cafeteria plans, medical reimbursement
plans and dependent care assistance plans.
Draft affiliate adoption statement.
Draft administrative documents, including notification of participation,
election to participate, beneficiary designation, qualified joint and survivor
annuity and qualified pre-retirement survivor annuity waivers and application
for benefits, and election to contribute.
Draft summary annual report.
Draft loan request forms, including consents, if appropriate, and purpose of
loan verification for participant loans.
Draft board of directors resolutions for plan adoption, adoption of
amendments, contribution amounts, and other actions required to be taken
by the board.
Draft and file application for IRS determination letter.
Assist client in preparing and filing annual report (5500 series and related
Monitor progress of new plans and amendments to verify required actions
occur on schedule.
Review and interpret regulations issued by government agencies to
determine their application and relevance to client plans.
Assist in preparing and coordinate general notice mailings to clients about
potential impact of new legal developments upon plans.
Monitor IRS reporting and disclosure deadlines.
Draft responses to questions raised by the IRS.
Draft required Pension Benefit Guaranty Corporation (PBGC) filings (i.e.,
PBGC- Is and notices of intent to terminate).
Draft or review qualified domestic relations orders.
The environmental law practice is varied and could require the paralegal to become
active in several areas. These areas can include litigation, legal analysis of
administrative regulations and adjudications, application for permits and Superfund
The functions of a paralegal in environmental law may include:
Summarize deposition and hearing transcripts.
Arrange and index documents, exhibit lists and files.
Attend meetings and hearings held by federal and state agencies.
Contact with federal and state agency representatives to obtain information
Familiarity with environmental acts and their applications, including:
Comprehensive Environmental Response
Compensation and Liability Act (Superfund)
Resource Conservation and Recovery Act
Toxic Substances Control Act
Clean Air Act
Clean Water Act
Participate in workshops and seminars on environmental law and allied
Assist in marketing for your respective affiliation through authoring
Draft pleadings which include motions, responses and interrogatories.
Prepare permit applications through data review and organization.
Participate in environmental audit of facilities and provide observations on
compliance issues to the attorney and/or client.
Update files on the standards governing the generation, transportation,
treatment, storage and disposal of solid and hazardous wastes.
Assist in compilation of allocation costs.
Assist in analyzing siting requirements for landfills, waste treatment plans
Prepare allocation/waste-in tables for Superfund-like sites.
Administrate PRP cleanup activities at a site.
ESTATES AND TRUSTS
A legal assistant working in the areas of estates and trusts will perform a variety of
tasks which may include:
Assist with estate planning and investment analysis.
Maintain will and trust form files.
Prepare documents to probate will and administer the estate.
Assist with claims including social security, veteran's benefits, and health-
and life insurance.
Assist in transfer and distribution of estate assets to beneficiaries.
Assist elderly clients with financial management including nursing home
placement, health insurance, Title XIX and veteran benefits.
Draft wills and trusts.
Arrange and attend lockbox inventories and prepare probate and non-probate
Attend client meetings and maintain monthly client contact for estate, trust
administration and accounting purposes.
Prepare estate and inheritance tax projections.
Conduct tax research for clients and probate department.
Perform estate asset liquidations, transfers and banking functions.
Prepare estate inventory, accounting and inheritance, gift, individual, estate
and trust income tax returns.
Prepare documents such as real estate transfers, claims and litigation
involving an estate or trust.
Prepare documents to close estate.
The primary function of a paralegal in family law (domestic relations) is to assist the
attorney in helping qualified clients obtain a dissolution of marriage.
Responsibilities of the paralegal may include:
Attend initial interview with attorney and client.
Collect background information on client including marriage certificates,
sources of support, residence, assets, number of children, etc.
Complete domestic relations questionnaire form.
Do legal research.
Draft notice to produce.
Serve notice on opposing counsel.
Arrange for service of documents.
Conduct follow-up by filing petitions and checking service.
Conduct timely briefings of client concerning status of the case.
Set trial dates and prepare necessary notification to all parties.
Assist client in preparation of monthly income and expense sheet.
Arrange for appraisal of real property and personal property.
Schedule expert witness interviews and availability for trial.
Close cases and clean-up file.
Research tax aspects of child support/maintenance.
Determine protection and places available in domestic violence incidents.
Draft Petition for Name Change.
Prepare forms necessary to transfer property (automobile titles, stock
transfers, quit claim deeds).
Inform or notify insurance companies of any items in the marital settlement
agreement which may have an effect on coverage or ownership of policies.
Ascertain whether property has been delivered to the rightful owner.
Keep track of dates by which monetary property settlement payments must
be made, and, if necessary, file the legal documents to enforce the judgment.
Identify non-legal problems that can be referred to other entities.
Participate in discussion of other remedies including counseling, separation,
reconciliation, mediation, etc.
Draft Petition for Dissolution or Response
Draft temporary motions, affidavits and orders.
Draft property settlement agreement.
Determine support needs.
Draft Decree of Dissolution and accompanying motions and affidavits.
Draft motion and affidavit for modification.
Communicate with any opposing counsel or client as issues and concerns
Maintain contact with client and handle calls when legal advice is not needed.
Obtain information for discovery, organize, categorize and determine
completeness of discovery.
Draft proposed stipulations.
Confer with client prior to court date on issues relevant to hearing.
Draft Petition for Adoption and Consent for Adoption plus Decree of
Draft post-decree pleadings necessary to enforce/modify the judgment.
The responsibilities of a legal assistant working in the foreclosure area are
diversified as well as extensive. They can be working with the State Courts as well
as the Federal Courts. Their responsibilities can vary from drafting pleadings to
filing pleadings. The duties of a legal assistant working in the foreclosure area may
Draft trustee's notice of sale and arrange for publication.
Prepare and serve trustee's notice of sale on grantors and subsequent lien
Record all proofs of service, affidavits of mailing and publication prior to
Check for federal tax liens 30 days prior to sale.
Review published foreclosure notices.
Draft any necessary notification letters to the IRS.
Attend foreclosure sale.
Obtain execution of documents and record deed under power of sale.
Assist attorney at closing.
Order foreclosure report (minutes of foreclosure) and analyze same.
Review foreclosure report with respect to priority of lienholders and
determine parties to be served.
Draft foreclosure complaint.
Draft motion and supporting documents for summary judgment.
Draft motion and order for default.
Draft decree of foreclosure.
Draft and serve notice of non-judicial sale on Internal Revenue Service (IRS),
Draft bid sheet for sale.
Draft notice of sale under power and 10-day attorneys' fee demand letter.
Draft deed under power of sale and foreclosure affidavits.
Draft documents for deed in lieu of foreclosure transactions including
affidavits, closing statements, settlement agreement and releases.
Review existing collateral and analyze documentation with respect to an
account of a distressed borrower.
Suggest curative work to lenders and draft modification to existing loan
papers relating thereto.
Coordinate matters prior to closing with local counsel, real estate brokers,
clients and opposing counsel, matters.
Review management agreements and service contracts.
Prepare checklist of documents and items to be accomplished at closing.
Coordinate post-closing follow-up recording documents, wiring funds,
obtaining necessary cancellation documents, organizing and indexing files
plus overseeing preparation of closing document binders.
Draft post-sale documents including motion for writ of assistance.
Draft and record trustee's deed after sale.
Draft correspondence to occupants giving 30 days to vacate.
Take possession, satisfy and transmit original promissory note and trust
deed to trustee.
(Land Use/Public Finance)
Maintain repository of all City of Chicago Planned Developments, Tax
Increment Financing District and Redevelopment Agreements.
Review Federal, State and City websites for RFP (Request for Proposals).
Prepare Zoning, Planned Development and boundary maps in preparation for
Obtain necessary information to complete business and liquor licenses.
Complete information regarding MBE and WBE certification for clients.
Obtain tax exempt status information from Cook County.
Complete documentation for City of Chicago, Cook County and State of
Illinois regarding ethics compliance.
Obtain UCC financing statements.
Obtain necessary corporate, partnership or limited liability company
documentation and resolutions in connection with loan transaction.
Organize Closing documents for closing.
Obtain certificates from State agencies (e.g., Articles of Incorporation, Good
Standing of Company).
Compile closing Transcript, prepare Index, and organize closing binders.
GUARDIANSHIP AND ADOPTIONS
A legal assistant working in the area of guardianship and adoption will perform a
variety of tasks which may include:
Prepare court documents, unusual petitions and periodic accountings.
Develop and maintain manual or computerized accounting procedures for
production of financial records for estate and guardianship planning and
Develop and maintain manual or computerized client data base to be used in
preparation of estate calendar, financial and informational reports.
Develop and maintain tax, probate and other manuals including computer
manuals to document procedures and provide form and letter files.
Research and compile information pertaining to due diligence aspects of
mergers, acquisitions and other transactions.
Prepare reports on IP matters for attorneys and clients.
Maintain docket system of due dates for actions, including responses,
renewals, oppositions, Section 8 and 15 affidavits, use affidavits, Patent
Cooperation Treaty requirements, and payments of patent annuities in
foreign countries. (Docket Person)
Assist in intellectual property-related litigation.
Assist in oppositions, interferences and cancellations; locate and draft
documents necessary for use in these inter parties proceedings.
Perform on-line searches of Patent and Trademark Office (PTO) records,
industry databases and general legal research.
Conduct searches for information regarding trademarks.
Draft and file applications, statements of use, renewal applications, affidavits
of use, and assignments.
Draft responses to PTO actions.
Police client's trademarks to guard against potential infringements.
Coordinate international filings with foreign law offices and/or other foreign
Maintain foreign trademarks, which includes corresponding directly with
foreign associates and instructing them to search trademarks and to file
applications, renewals, affidavits of use and oppositions.
Correspond with clients regarding applications and registrations.
Obtain legalizations and certifications for filing foreign trademarks.
Perform on-line searches of Patent and Trademark Office (PTO) records,
industry databases and general legal research.
Conduct searches for information regarding patents.
Draft and file formal paper, (i.e., Combined Declarations and Power of
Attorney; Assignments and transmittal forms regarding patent application
Coordinate international filings with foreign law offices and/or other foreign
Maintain foreign patents, which includes corresponding with clients and
outside services regarding patent maintenance.
Correspond with clients regarding applications and issued Patents.
Obtain legalizations and certifications for filing foreign patents.
Draft and file applications.
Draft and file renewal applications.
Check availability of domain names.
Register domain names.
Attend to transfer of ownership.
Search databases to determine ownership of domain names.
Note- Some of the information contained in the Litigation section of this publication
also includes work performed in the Intellectual Property specialty area.
A labor law paralegal's duties closely resemble those of a litigation legal assistant.
There are, however, several tasks unique to labor that do not present themselves in
traditional litigation. Initial resolution of a dispute in labor law takes place at the
administrative level. In-house grievance boards, arbitrators and local state and
federal agencies investigate and/or hear and rule on the issues before the case
proceeds into litigation. When the available administrative relief available has been
exhausted, an individual may elect to pursue redress. through the courts. Title VII,
Section 1981, ADEA lawsuits dominate the caseload, thereby placing the majority of
trials under the jurisdiction of the federal courts.
As you can see from the following list, a labor law paralegal's duties are extensive.
A primary function of a labor 1aw paralegal's position involves assisting the
attorney in obtaining a favorable determination at the administrative level. The
organization and inventory of all case materials, as well as file maintenance as the
case progresses through the various phases of resolution, play an important role in
the ultimate success of the case. Assignments are often issued in terms of goals,
with the procedural aspects left to the paralegal's discretion.
A labor law legal assistant may perform the responsibilities of:
Being a liaison with:
Equal Employment Opportunity Commission
State Civil Rights Commission
State Department of Labor
U.S. Department of Labor
State Education Labor Relations Board
National Labor Relations Board (NLRB)
Secretary of State
Federal and state courts
National and local unions
This includes all communications, document recordings and retrieval of
information from each agency, such as:
Perform general case investigation.
Prepare deposition summaries, general abstracts and detail issue analysis.
Attend depositions and arbitration hearings.
Review and purge client's documents for document production.
Gather documents from various agencies and opposing counsel.
Prepare trial notebooks.
Maintain in-house library of previous briefs and memoranda of law.
Review publications for recent developments.
Use Lexis and Westlaw.
Shepardize case law.
Draft witness lists and deposition outlines.
Create statement of facts.
Responsibilities generally associated with litigation may be initiated pursuant to
arbitration, federal and state discrimination charges, Workers' Compensation and
Unemployment Compensation proceedings, and National Labor Relations Board or
state education relations board charges. The labor law paralegal should be familiar
with the procedures of these various forums and be able to assist the attorney
using many of the same skills necessary in litigation (See the Litigation section for
In addition, quite apart from any litigation-related duties, a labor law paralegal must
be familiar with standard personnel policies and procedures, Consumer Price Index
(CPI) and wage-related data, affirmative action requirements and availability data,
standard union contract language and other general employee relations matters.
Commencement of Case
Attend initial interview with client; obtain background information.
Prepare party/contact list.
Obtain, review, organize, and analyze preliminary documentation and
information supporting client's claim.
Investigate corporate background to determine proper party(ies) to sue,
statutory agent, and officers.
Initiation of Action
Work with attorney(s) to develop defenses, theory of case, and trial strategy.
Compile information, facts, etc. for use in preparing answer to complaint and
other defensive pleadings.
Conduct or coordinate factual investigation, including interview of witnesses;
retain outside investigator, if necessary.
Draft interrogatories, requests for admissions, requests for production, etc.;
review responses to same for completeness. Draft responses to discovery
Meet with client; coordinate the review & collection of client files; compile,
organize, summarize and analyze factual data collected.
Examine and, if necessary, obtain public records relevant to facts of lawsuit.
Conduct research to locate, interview, and retain expert witnesses.
Obtain written reports/analyses of physical evidence, injuries, issues, and
financial evaluations from expert witnesses.
Prepare statistical and/or factual memoranda; prepare market surveys and
gather industry statistics.
Prepare factual/event chronologies from deposition testimony, documents,
and other factual records.
Supervise personnel, such as document clerks and junior paralegals
assigned to specific projects for pending litigation; monitor progress of
Organize procedures for obtaining documents; coordinate production
schedules with adverse parties.
Review and obtain relevant documents in client's possession; work with
attorney to determine/identify relevant and privileged materials
Perform, supervise, or coordinate objective/subjective coding of case
documents. Consult in-house or outside sources to develop document
databases for relevant case documents from document production. (See
Computer Litigation Support section, supra, for more detailed information.)
Review, index, organize, analyze, and summarize documents produced by
other parties. As necessary and appropriate, prepare additional discovery
requests; follow up on outstanding discovery requests to ensure response
by opposing party.
Update discovery, responses as additional information is collected.
Coordinate deposition schedule with client, attorneys, and opposing counsel.
Draft & arrange for service of record & deposition subpoenas
Draft outline of questions for examining of witnesses at depositions.
Review and assemble documents for use in deposition.
Prepare witnesses for deposition.
Attend deposition and assist attorney through note taking and organization
of exhibits identified during depositions.
Index and summarize deposition testimony and exhibits.
Draft list of documents and testimony to use in impeaching opposition
witnesses and/or identifying inconsistent information.
Assist in preparing motions for summary judgment, motion to dismiss, or
Conduct computer-assisted legal and factual research using on-line services
such as WESTLAW, LEXIS or Dialog.
Assist in preparing discovery, pre-trial, and trial motions (i.e., motions to
oppose expedited discovery, to compel discovery, for protective order, to
extend time limit, to preclude evidence from being admitted at trial, to admit
out-of-state attorney to appear pro hac vice, for reconsideration of court's
decision or responses to same.
Research and draft motions in limine.
Draft affidavits and assemble exhibits in support of briefs and petitions.
Communicate with court and opposing counsel regarding hearing dates,
filings, etc., including arranging for extensions of time to respond.
Review briefs for accuracy of actual information and quotes as well as
citations to the record.
Proof briefs for spelling, syntax, consistency, and textual integrity; ensure
accuracy of table of contents and table of authorities.
Review and assemble exhibits to be included in the appendix to brief.
Draft pretrial statements and settlement conference memoranda.
Attend pretrial conference with judge and attorneys.
Prepare and index key pleadings notebook, including cited authorities.
Prepare trial notebooks of key documents and witness files.
Work directly with experts, consultants, and witnesses concerning case and
assist to prepare them for trial.
Coordinate arrangements with local vendors regarding technical courtroom
equipment, space, and other requirements. If trial will be held in a distant city
or state, set up quot;trial office.quot;
Develop outlines for direct and cross-examination of witnesses.
Coordinate lay and expert witnesses' attendance at trial. Draft trial
subpoenas for non-party witnesses.
Review discovery documents for relevance & use as trial exhibits, identify
potential trial exhibits, and confer with attorney regarding use at trial in
conjunction with witness testimony.
Organize, mark and index triad exhibits.
Coordinate design and preparation of graphic exhibits, video and/or
computer presentations and other demonstrative evidence materials for use
Monitor and coordinate exchange of trial exhibits with other parties.
Draft summary of documents and testimony to use in revealing
inconsistencies and/or impeaching opposition witnesses.
Manage physical and demonstrative evidence at trial.
Obtain jury list and biographical information on potential jurors.
Draft jury instructions and voir dire questions.
Attend jury selection and record information obtained from voir dire
questioning of potential jurors.
Develop chart of jury chosen with information gathered during the jury
Attend and assist attorney at trial by maintaining list of exhibits as identified,
offered into evidence, admitted, or objected to (including judicial disposition),
and noting developments of case, reactions of jurors, witnesses, and
opposing counsel during trial.
Obtain daily electronic data, audio, and/or videotape transcripts from
proceedings in electronic courtrooms.
Order hearing transcripts and prepare index or outline of transcripts, or
arrange for input on full-text research database.
Paralegals in this specialty must be familiar with a wide variety of laws, rules,
procedures and common practices in the medical as well as the legal field. The laws
include federal, state and local laws dealing with health, insurance and malpractice
In addition to the normal paralegal functions such as identifying legal issues,
drafting pleadings such as complaints, interrogatories, production of documents,
statement of facts and rebuttals, a paralegal in this specialty may
also do the following:
Obtain medical authorizations.
Determine what medical records are needed and request same.
Arrange for independent medical exams.
Draft submissions to the medical review panel board.
Schedule appointments and meetings with clients, attorneys, adjusters and
Attend meetings of attorneys and doctors and prepare memoranda of same.
Handle routine correspondence such as updating clients, memoranda to the
file and responses to inquiries.
Review all case files on a periodic basis and follow-up on status.
Review medical and forensic publications.
Conduct client interviews.
Review medical records and medical reports (index and summarize records).
Extract data from medical reports and annotate them.
Ascertain amounts and categories of damages for settlement.
Obtain medical expert opinions.
Prepare submissions to various funds or the Department of Insurance.
Prepare all pleadings necessary to open estates in the case of wrongful death
Research and review general areas of the law in a case.
Research and review medical topics.
Design and prepare graphs, transparencies, charts and trial aids.
MUNICIPAL BOND FINANCINGS
There are various types of municipal financings which include but are not limited
to: General authority; Hospital; Industrial; Pollution control; General obligation;
General revenue; Housing; and Water and sewerage The practice of municipal bond
law is highly specialized and the level of responsibility assumed at any given time
will vary with experience. The functions performed by the municipal bond financing
legal assistant may include the following:
Prepare transaction checklist or memorandum.
Communicate with clients and prepare file memoranda and notes for same.
Maintain client and closing document files.
Participate in final structuring sessions.
Assist in drafting, proofreading and redlining documents.
Preparation and Review of Documents
Draft, revise and finalize documents including exhibits, comprising of the
transcripts of official proceedings for a financing; and Review documents
prepared by other parties to a financing.
Research in preparation for drafting documents and in response to specific
attorney requests (generally, to respond to procedural questions rather than
to draw conclusions on points of law); and
Review advance sheets and other library resource materials on a regular
basis in order to keep abreast of changes and proposed changes in the laws.
Miscellaneous Financing Responsibilities
The legal assistant often coordinates the printing of bonds, the scheduling of
various required actions (such as a validation proceeding), the acquisition of
certificates of good standing, the filing or recording of financing statements an
security instruments, and the filings of requisite forms with the Internal Revenue
Service or other governmental offices.
Prepare financing statements and file with the Secretary of State.
Obtain Uniform Commercial Code (UCC) searches.
Prepare follow-up letters to clients.
Assist at bond closings including document coordination and management.
Transmit closing documents to bond purchasers and other parties.
Attend board meetings of issuers of bonds and prepare minutes.
Coordinate and schedule board meetings.
Redline and distribute bond financing and closing documents.
Contact all parties to the bond financing in order to obtain factual information
for each financing.
Draft Forms 3, 4, 8-K, 10-K and 10-Q.
Draft Form 144 and related documentation.
Draft security agreements (deed, guaranty, mortgages, etc.).
Review bond purchase agreement or underwriting agreement.
Draft summaries of documents for use in preparing preliminary official
statement and official statement.
Coordinate the accuracy of the statements with underwriter.
Finalize basic documents and distribute for execution.
Draft necessary resolutions authorizing the issuance of the bonds.
Send bond form to printer.
Proof first galley of the bonds and check manufacturing schedule, coupon
Check bonds at time of closing and read bond numbered 1.
Draft company authorizing resolutions and officers' certificates;
Draft recording certificate.
Obtain certificates from state agencies with respect to good standing of
company and certified corporate documents.
Compile the closing transcript, prepare index and organize closing binders.
Draft loan agreements, trust indentures and security agreements (guaranty,
deed and mortgages).
Draft miscellaneous bond closing documents.
Coordinate preparation of bond closings including scheduling and
preparation for closing agenda.
Prepare preliminary and final closing reports.
Prepare applications to the Economic Development Commission.
Draft forms of documents for use in bond financings.
Draft registration statement and prospectus.
Organize filing the registration statement.
Draft 1934 Act Reports.
Draft questionnaire for officers, directors and principal shareholders.
Draft promissory notes.
Draft bond purchase or underwriting agreements.
Draft bond purchase agreements.
Draft Blue Sky memoranda and Blue Sky registration.
Review status of Blue Sky application.
Draft Legal Investment Survey.
Notify State Securities Administrators of SEC effectiveness.
Draft and file dealer or salesman registration documents.
Perfect securities or dealer exemptions.
Prepare memoranda on the availability of exemptions.
Draft and file documents for registering broker/dealers or salesman with
federal and state securities commissions.
Draft and file documents for renewing or withdrawing the registration of
broker/dealers with salesmen.
Qualify dealer corporations where applicable.
Draft lease agreement, loan agreement, agreement of sale, facilities financing
agreement ordinance or contracts.
Draft closing papers for issuer including authorizing resolutions,
authentication order to trustee, incumbency certificate, nonarbitrage
Prepare tax election, if applicable, and arrange for appropriate filing.
Attend closing, checking all certificates and opinions, insurance policies and
Duties of the public benefits legal assistant dealing with Social Security as well as
Medicare and Medicaid may include the following:
Research appropriate Social Security law.
Assist with Medicare waivers and Medicare appeals.
Assist with Medicaid claims.
Assist with Social Security overpayment waivers.
Locate medical information.
Review Social Security file and obtain documentation;
Assist with consumer fraud complaints and forward to Consumer Protection
Obtain documentation for unemployment claim.
Represent claimants at Supplementary Security Income (SSI) hearings.
Represent claimants at Social Security Disability (SSD) hearings.
Negotiate with landlord and tenant to resolve problems.
Coordinate with other parties (buyer, seller, title company, opposing counsel,
Arrange for execution of purchase agreement.
Review purchase agreement for critical dates and contingencies and
Prepare closing checklist.
Due Diligence Responsibilities
Matters of Title
Conduct or arrange for title search and request abstract of title. Order title
commitment and/or preliminary title report.
Negotiate title insurance coverage.
Review legal description of the property and track against map, if available.
Review exceptions (standard exceptions regarding survey, taxes and
assessments, etc.) and encumbrances of record.
Arrange for discharge/satisfaction of deed trust/mortgage (existing
mortgages of record on the property) and obtain payoff figures.
Review easements and if necessary, plot against legal description.
Draft escrow instructions.
Arrange for issuance of title policy.
Existent Contracts/Lease Declarations
Review contracts and leases for assignment, due on sale and due on
encumbrance provisions; prepare abstracts regarding same.
Draft requisite assignment, amendment or extension documentation.
Review condominium declaration/resale certificate for due on sale
provisions/rights of first refusal.
If necessary, obtain corporate organizational documents, including
authorization of the applicable parties to purchase and/or sell, for all parties.
Review corporate documents for prohibitions against borrowings, power of
decision making bodies, and so forth.
If necessary, obtain certificates of good standing/certificates of existence.
Conduct public records search of the parties, including judgments, tax liens,
and UCC filings.
If residential, provide purchasers with information about homeowner's
Coordinate with lender and purchaser to ascertain lender insurance
Obtain and review required evidence of insurance from purchase or
Prorate real and personal property taxes and utilities, and adjust for closing
Obtain closing figures from bank and prorate all closing costs.
Exchange all figures with other parties.
Review figures with client.
Purchase Money Loan
Perform financial calculations (amortization, net present value, discounting,
annual percentage rate).
Draft promissory note and deed of trust/mortgage.
Obtain and/or draft necessary corporate, partnership, or limited liability
company documentation and resolutions in connection with loan transaction.
(See Business/Corporate Section, supra, for more detailed information.)
As necessary, draft any leases and/or assignments, extensions or
modifications to lease.
If necessary, draft Uniform Commercial Code (UCC) financing statements,
amendments, extensions, and/or terminations.
Finalize closing checklist.
Organize closing folders.
Attend closing and assist attorney in activities regarding execution of closing
Educate signatories with respect to the documents being executed.
If appropriate, notarize documents upon execution.
Coordinate recording of real estate documents and filing of UCC financing
Obtain documents to be executed post-closing.
Coordinate with all parties concerning post-closing questions and, if
necessary, provide documents.
Follow-up on recorded/filed documents.
Prepare closing binders.
Obtain solicitation form from seller, if applicable, and prepare and file Form
Assemble tax bills and payments.
Obtain and analyze property information and current valuation.
Draft complaint on real property assessment.
Coordinate formal property appraisal and report.
If appropriate, prepare notice of appeal on valuation of property.
Obtain terms of lease from attorney notes or interview.
Prepare initial draft of lease.
If necessary, revise lease.
Conduct due diligence to the extent necessary.
Arrange for any existent contract modifications.
If necessary, prepare memorandum of lease.
Facilitate execution of lease and memorandum of lease.
If necessary, record memorandum of lease.
Review or draft estoppel certificates and/or subordinates, non-disturbance
and attachment agreements.
Prepare subdivision, condominium, and timeshare registrations for in-state
and out-of-state registrations.
Assist with probate and trust transfers and property investigations.
Draft notice of mechanic's lien: determine validity of existing mechanic's
liens; prepare releases or waivers of rights and assist with foreclosing
The following is a summary of the responsibilities of a Blue Sky legal assistant:
Do Blue Sky research.
Prepare Blue Sky memoranda.
Prepare and file application for registration of securities and general
reporting requirements under state securities laws.
Perfect private placement exemption under state Blue Sky laws.
Prepare and file application for registration as a broker-dealer with the
Security Exchange Commission (SEC) and with various states.
Prepare and file application for membership in National Association of
Security Dealers (NASD).
Prepare and file application for membership in the securities and
commodities exchanges and in clearing organizations.
Prepare and file application for registration with Commodity Future Trading
Prepare and file application for registration as an investment advisor with the
SEC and with various states.
The responsibilities of a tax legal assistant may incorporate many different areas of
the law. Depending upon the degree of specialization, a tax paralegal can perform
functions which include probate, accounting, corporate and litigation matters.
Generally, a tax paralegal would possess a strong background in accounting and
business related skills.
The functions of a tax paralegal may include the following activities:
Income Tax Matters
Prepare federal and state individual income tax returns.
Prepare federal and state corporate income tax returns, including related
Prepare federal and state partnership income tax returns.
Prepare federal and state fiduciary income tax returns.
Prepare federal and state quarterly and annual payroll tax reports, including
preparation of unemployment tax returns.
Do research in connection with current tax law.
Prepare documentation to substantiate returns as filed.
Be familiar with some form of computerized tax service for processing of
Prepare income tax projections to assist client in current year tax planning.
Prepare amended income tax returns in connection with proposed
adjustments to taxpayer's returns as originally filed.
Determine adjustments required by governmental agency in connection with
income tax returns and preparation of appropriate response stating position
of taxpayer in connection with proposed adjustments.
Prepare documentation in support of taxpayer's position, including
preparation of exhibits to petitions and response pleadings.
Prepare financial statements and all accompanying workpapers in
connection with individual, corporate, partnership and trust claims. This
responsibility would also include preparation of adjusting journal entries,
calculation of capital gains and losses, determination of security valuation
and all other related accounting functions.
The litigation responsibility of a tax legal assistant may include many of the same
duties as described in the Litigation Section of this booklet. The litigation duties of
a tax paralegal working for the Internal Revenue Service (IRS), might include the
Prepare Subchapter S tax court cases (deficiencies of less than $10,000),
including preparation of all documentation and necessary pleadings to be
filed with the court.
Assist the attorneys with processing of criminal matters.
Assist the attorneys assigned to tax shelter cases.
Maintain records and draft returns for following taxes: corporate income,
franchise, individual income, partnership income, estate, estate income and
Draft supporting documents for refunds.
Gather information for audits and reviews.
Coordinate civil summons matters, working with revenue officers and the
United States Attorney's Office.
Duties of the workers' compensation legal assistant may include the following:
Obtain copy of accident repor.
Prepare LS-203 form, LS 18 form and transmit to Department of Labor.
Draft request for hearing or response.
Draft application to schedule date or reply.
Draft motion to postpone or response.
Draft demand for documents.
Draft trial brief.
Organize medical reports.
Schedule doctor appointments.
Schedule meetings and interview doctors.
Request employer medical mileage reimbursement.
Obtain authorization forms.
Prepare narrative case evaluation.
Supervise compliance with demand for documents.
Prepare exhibit list.
Check average weekly wage calculations.
Assist attorney at Workers' Compensation Board (WCB) hearings.
Draft affidavit regarding attorney's fees.
Evaluate disability utilizing WCB rules and guidelines.
Compute special damage and wage loss.
Research claim options.
Assist in negotiation of settlement.
Draft petition for review at WCB hearing.
Draft appellate brief.
Draft petition for judicial review; Draft statement of case.
Draft issue and fact section of appellate brief.
Draft motion for reconsideration.