CLE: September 16, 2026 – Begin with the End in Mind: A Paralegal’s Playbook for Summary Judgment Success

Join the Pittsburgh Paralegal Association for a CLE
September 16, 2026 at 12:00 p.m.
Begin with the End in Mind: A Paralegal’s Playbook for Summary Judgment Success
via Zoom
presented by Lisa M. Siefert | Shareholder, GRB Law

This one-hour educational program examines the role of litigation paralegals in developing and maintaining the evidentiary record necessary to support or oppose a motion for summary judgment, with particular emphasis on practice in Pennsylvania state courts and the United States District Court for the Western District of Pennsylvania. The presentation will review the applicable summary judgment framework and explain how the requirements for dispositive relief should inform case management from the inception of litigation through discovery and motion practice. Participants will also gain insight into what litigation attorneys need and expect from paralegals at each stage of a case, including how paralegals can anticipate counsel’s needs, identify potential strengths and weaknesses in the developing record, and provide strategic support rather than simply responding to individual assignments. Participants will learn practical methods for organizing case files around the elements of claims and defenses; identifying, preserving, and tracking material evidence; managing discovery responses and deposition testimony; creating citation-ready exhibit and transcript systems; identifying evidentiary gaps and authentication issues; and assisting counsel in preparing statements of material fact, affidavits, declarations, exhibits, and other components of the summary judgment record. The program will also address procedural distinctions between Pennsylvania state and federal practice, including federal and Western District requirements concerning record citations and statements of material fact, as well as common technical deficiencies that can undermine dispositive motion practice. Through practical examples and hypothetical case studies, the program will demonstrate how strategic case organization, careful record development, and effective attorney-paralegal collaboration throughout the life of a case enable paralegals to become more proactive and valuable members of the litigation team when seeking or opposing summary judgment.

KEY LESSONS AND TAKEAWAYS

1. Begin with the End in Mind. Attendees will understand why preparation for summary judgment begins at case inception and how early decisions concerning file organization, issue identification, preservation, and evidence management can directly affect the ability to obtain or defeat dispositive relief.
2. Organize the Case Around Legal Issues, Not Just Documents. Attendees will learn practical methods for connecting documents, discovery responses, deposition testimony, and other evidence to the elements of claims and defenses so that the record can be efficiently evaluated and used in dispositive motion practice.
3. Develop “Motion-Ready” Evidence Throughout Discovery. Attendees will learn to identify and maintain evidence with admissibility, authentication, and future citation requirements in mind, including the use of pinpoint deposition citations, organized exhibits, evidence matrices, and early identification of gaps or inconsistencies in the record.
4. Understand What Attorneys Need from Paralegals at the Dispositive-Motion Stage. Attendees will gain a practical understanding of the paralegal’s role in preparing a complete and technically sound summary judgment record, including statements of material fact, supporting exhibits, affidavits and declarations, record citations, and quality-control review, with attention to Pennsylvania state practice and the requirements applicable in the Western District of Pennsylvania.