One of the first things a paralegal should do is assist with the pre-claim investigation. This process includes finding witnesses and interviewing them. They also begin to gather documents and evidence and sort the facts chronologically. The next process is pleadings. The plaintiff's paralegal can help draft the pleadings. The defendant's paralegal can help investigate claims and draft responses. The discovery process is where the paralegal will spend much of their time. This is where paralegals help attorneys draft interrogatories, prepare deposition summaries, create and maintain discovery indexes, and summarize and analyze items such as medical records and other documents. Paralegals also help conduct legal research. Once this research is completed, paralegals can create legal research memos. In addition to legal research, paralegals also conduct factual research. This information can come from many different types of sources, as long as it is relevant to the case. Before the trial begins, the paralegal is responsible for ensuring that everything is in order. They also serve as a liaison between the trial team and witnesses, clients, experts and other members of the courtroom. During the trial, the paralegal will assist the attorneys in any way necessary. Their responsibilities include setting up exhibits, collecting materials and preparing the