And just like that, week five has come and gone. On Monday, I received a handful of new assignments to complete, some of which were timely research tasks that I immediately got started on. The first one was a procedural question from Rob Blank regarding what is considered sufficient notice for service of a notice of subpoena duces tecum to a non-party. A straight forward question, but I really had to search through the case law for a situation similar to the one I was presented with in order to find a court who had addressed this issue previously. My love for civil procedure definitely shined through and helped me find a few on point opinions.

I wrote in a previous blog post that I have to break assignments down into smaller pieces and then just start chipping away at the various projects, otherwise the “boulder” (that is my to-do list in its entirety) becomes overwhelming. On Tuesday, this was what I focused on doing. I was able to chip away at a few large assignments by getting some of the heavy lifting done in the research department on each. Primarily, I was able to make significant progress on an assignment for Carie Hall pertaining to when a claim for contribution can be asserted. This was another procedural question that I researched with nerdy enthusiasm. Tuesday was also the Multicultural Luncheon which was an awesome and delicious break in the day. Everyone in the office is a wonderful cook!

Wednesday was probably the busiest, and most exciting, day of the week. It started with the submission of a motion to compel response for Tyler Derr. I received the assignment on Monday and had drafted the majority of the motion on Tuesday, so on Wednesday I came into the office with fresh eyes to proofread and then turned it in. Around 8:30 am, I received an email from Abby Roberts, an attorney in the Miami office, who had a deposition via Zoom in the Tampa office that morning. I was able to sit in and help her present the deponent with an exhibit— this was the first deposition I had sat in on, so I was nervous to only be in the physical room with the deponent and the court reporter. It was interesting to see how technology allows attorneys to appear from other cities and locations. Abby was videoconferencing in from Miami, which is about five hours away, and the other attorney had called in from a nearby city. I say that technology is great and wonderful in allowing this option with the caveat of that is when it works of course! The beginning of the deposition was a battle with the technology to get it to cooperate and allow both the Zoom and standard telephone call to go through. Luckily we were able to out-smart it, and the rest was smooth sailing. I watched Abby on the screen and observed how she handled the technology obstacle and her line of questioning with the deponent, both of which were patiently, friendly, and straightforward.

After the deposition, I went back to my office and finished drafting a summary of the scene inspection I had gone to last week with Rob Blank. Once I turned that in, I was about to continue the research I had been working on earlier in the week for Carie when Meredith Fee came and asked me if I wanted to come to the hearing she was about to have. Of course I said yes! The Thirteenth Judicial Circuit Court is downtown, so we decided to walk. We got a little turned around on the way—unintentionally taking the scenic route you could say—so we definitely got our steps in for the day. Nevertheless, we arrived with plenty of time to check-in, cool down, and review the motions. Once we were called back to the hearing room and setting up inside in front of the judge, I watched Meredith sort her documents and notes appropriately and could tell she had spent the requisite time preparing. Opposing counsel had a half-inch binder with him, it was tabbed and likely contained all that was necessary, but I thought it looked very professional and organized that Meredith had, what seemed to me, like any documentation that the judge might ask for ready to go. The hearing was for a motion to compel and to set the case for trial—we were successful on both and Meredith let me draft the proposed Orders for each. By the time we walked back to the office we were both hot and ready to take our heels off. Turns out, the temperature was so high that day that a heat advisory warning was out! That explains it.

On Thursday and Friday, I focused on continuing the work that I had prioritized on Tuesday. The materials for the Direct/Cross Examination workshop also came out late Wednesday afternoon, so I was able to read through that packet and begin strategizing and creating an outline for the line of questioning I anticipated presenting. The deposition was pretty entertaining considering the plaintiff’s demeanor and the frequent unbelievable comments and responses he gave. This will definitely be a fun cross! After returning from the hearing on Wednesday, I also had a chance to meet with Tyler to receive feedback on the motion to compel I had drafted, and also receive two motions for protective orders to draft for him. All of his assignments have been from the same case thus far, so I’ve been able to slowly start piecing together the bigger picture of the case for myself, which I have found helpful, as opposed to merely being filled in and reading through the case file. Also on Friday, I was able to sit in on a telephone conference with Rob and paralegal Susan McClugage to hear the initial expert opinion of the scene inspection that I had attended last with Rob last Wednesday. It was interesting to hear the opinions and perspectives of the experts, and I was grateful that Rob let me come to the inspection with him so that I could visually picture the area in my mind that the experts were referencing.

It’s hard to believe that this week marks the end of June and all that’s left is July! I have had immense exposure to different assignments, various issues, and interesting cases already and this was only week five! Every day is something new, and I’m looking forward to what next week brings.