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

RESPONSIBILITIES Case Management & DiscoveryIndependently manage a caseload of personal injury litigation matters from post-intake through resolution or trialDraft and respond, supervise, to discovery demands, bills of particulars, and discovery motions under the CPLRCoordinate and manage expert disclosurePrepare and serve demands pursuant to CPLR Article 31; prosecute motions to compel where necessaryDepositionsDefend and conduct plaintiff and defendant depositions in motor vehicle, premises, and Labor Law mattersPrepare clients for EBTs; depose adverse parties, witnesses, and corporate representativesIdentify and use deposition testimony in motion practice and trial preparationMotion PracticeDraft summary judgment motions and oppositions on liability and serious injury threshold under Insurance Law § 5102(d)Prepare and oppose motions in limine, CPLR § 3212 motions, and Frye/Daubert challengesResearch and draft legal arguments on CPLR procedure, comparative fault, and damagesTrial Preparation & TrialPrepare trial binders, witness lists, exhibit lists, and jury chargesDraft voir dire questions and opening/closing outlinesAttend and participate in trial proceedings; second-chair or first-chair as caseload warrantsWork toward independent first-chair trial responsibility REQUIRED QUALIFICATIONS   New York Bar admission — active and in good standing; no exceptions3–5 years of plaintiff-side personal injury litigation experience in New YorkDemonstrated hands-on experience with CPLR Article 31 discovery practice (demands, responses, motions to compel, PCOs)Working knowledge of New York Insurance Law § 5102(d) serious injury threshold — categories, Adverse Physical Exam dynamic, and motion practiceFamiliarity with no-fault/PIP framework in New York motor vehicle mattersExperience with NYS Supreme Court practice in at least one of the five boroughs; knowledge of court-specific part rulesExperience defending and/or conducting examinations before trial (EBTs)Ability to independently manage a caseload without daily supervision PREFERRED QUALIFICATIONS Experience in multi-defendant litigation and cross-claims practiceAbility to read and analyze medical records independently (radiology, orthopedic, neurological)Prior experience working with damages experts (life care planners, economists, accident reconstructionists)Experience to premises liability matters (slip/trip and fall, building code violations, negligent security)Exposure to Medical Malpractice mattersExperience in Labor Law §§ 240 and 241 (construction accident) mattersPrior first- or second-chair trial experience in NYS Supreme CourtFamiliarity with no-fault arbitration proceedingsAble to use adobe, Ms. Word, and law related AI etc.