Xiomara Martinez
Summary
Senior Trial / Litigation Paralegal with 15+ years of experience in Florida personal injury and PIP litigation. Extensive background supporting attorneys through discovery, motion practice, settlement, and trial preparation while managing high-volume litigation caseloads (80–140 files). Proven strengths in medical records, lien negotiation, pleadings, trial exhibits, and client communication. Highly organized, deadline-driven, and fluent in English and Spanish.
Overview
13
13
years of professional experience
Work History
Trial /Litigation Paralegal
Morgan & Morgan Law Firm
08.2020 - Current
- Serve as trial-level litigation paralegal supporting attorneys in active personal injury cases from litigation through trial
- Manage approximately 80–140 active litigation files at various stages including discovery, motion practice, mediation, and trial preparation
- Draft, file, and manage pleadings, motions, and discovery in compliance with Florida Rules of Civil Procedure
- Prepare and respond to discovery, including Requests for Production, Interrogatories, and supplemental responses
- Request, review, summarize, and organize medical records, bills, and liens
- Coordinate and negotiate balances with medical providers and lienholders
- Prepare settlement documentation and closing statements
- Organize and prepare trial exhibits, witness materials, and trial notebooks
- Assist attorneys with trial preparation, exhibit management, filings, and pre-trial coordination
- Maintain consistent communication with clients regarding treatment, case status, and attorney meetings
PIP Litigation Paralegal
Pardy & Rodriguez, P.A.
02.2019 - 08.2020
- Filed lawsuits on behalf of medical providers seeking unpaid PIP benefits
- Drafted and filed pleadings throughout the life of the case through settlement
- Scheduled hearings, mediations, depositions, and court appearances
- Maintained detailed monthly reports of open, newly filed, settled, and dismissed cases
- Worked extensively with Prevail case-management software
Legal Secretary
Critton, Luttier & Coleman, LLP
10.2017 - 10.2018
- Supported paralegal and investigator on personal injury cases
- Reviewed and processed legal correspondence, mail, and filings
- Prepared affidavits, settlement documentation, and case correspondence
- Managed client scheduling, including medical appointments and transportation
- Maintained organized electronic and physical case files
- Worked with NetDocs document-management system
Paralegal
Scher and Meltzer, P.A.
02.2016 - 03.2017
- Managed 100+ active personal injury files across pre-suit and litigation stages
- Prepared demand packages and settlement documentation
- Drafted and e-filed complaints, summonses, subpoenas, motions, and discovery
- Coordinated hearings, mediations, and depositions
- Maintained detailed monthly case tracking reports
- Worked with Aderant / Client Profiles
Legal Assistant
Murray & Guari
09.2013 - 02.2016
- Supported attorneys in pre-litigation and litigation personal injury matters
- Prepared demands, affidavits, and legal correspondence
- Assisted with transcription, dictation, and file opening
- Managed document production and case tracking
- Worked with TrialWorks
Paralegal
Law Firm of Gary Bruce
08.2012 - 09.2013
- Drafted pleadings, affidavits, and settlement documentation
- Managed discovery and court filings
- Maintained detailed case status spreadsheets
- Worked with Aderant / Client Profiles
Education
Associate of Arts - Psychology
Palm Beach State College
Lake Worth, FLGraduate Certificate - Police Academy (Criminal Justice)
Palm Beach State College
Lake Worth, FLGraduate Certificate -
Medvance Institute
Atlantis, FLSkills
- Florida Civil Litigation
- Personal Injury & PIP
- Trial Preparation & Exhibits
- Discovery & Pleadings
- Medical Records & Liens
- Settlement & Closing Statements
- Case Management Software (Litify, Prevail, TrialWorks, NetDocs, Aderant)
- Client Communication
- Legal Drafting & Research
- Bilingual: English / Spanish
Timeline
Trial /Litigation Paralegal
Morgan & Morgan Law Firm
08.2020 - Current
PIP Litigation Paralegal
Pardy & Rodriguez, P.A.
02.2019 - 08.2020
Legal Secretary
Critton, Luttier & Coleman, LLP
10.2017 - 10.2018
Paralegal
Scher and Meltzer, P.A.
02.2016 - 03.2017
Legal Assistant
Murray & Guari
09.2013 - 02.2016
Paralegal
Law Firm of Gary Bruce
08.2012 - 09.2013
Associate of Arts - Psychology
Palm Beach State College
Graduate Certificate - Police Academy (Criminal Justice)
Palm Beach State College
Graduate Certificate -
Medvance Institute