Description:

Job Description:
Position Summary:
The QME Deposition Associate represents the firm's clients by preparing for and personally conducting Qualified Medical Evaluator (QME) depositions in workers' compensation cases. This role is responsible for reviewing case files ahead of scheduled depositions to identify opportunities for resolution prior to deposition, preparing deposition strategy and questions, and appearing at and conducting QME depositions — both applicant-set and defense-set — to develop the record and advance the client's position. The ideal candidate is detail-oriented, organized, and comfortable working independently under deadline pressure in a fast-paced workers' compensation litigation environment.

Key Responsibilities:
Pre-Deposition Case Review
  • Review assigned case files in advance of each scheduled QME deposition to assess case status, medical-legal issues, and litigation posture.
  • Evaluate whether resolution (settlement, stipulation) is achievable prior to the deposition date, and discuss viable cases with the adjuster or client.
  • Communicate with attorneys, adjusters, and opposing counsel to explore early resolution options and confirm whether a deposition can be avoided, continued, or must proceed.
  • Document case review findings and resolution recommendations in the case management system.

Deposition Preparation

  • Review the case file in depth prior to the QME deposition, including claim history, prior medical treatment records, and the QME/AME report(s), to identify key factual and medical issues.
  • Analyze the QME report(s) for internal inconsistencies, gaps, causation issues, apportionment concerns, or areas that need clarification through testimony.
  • Identify disputed issues (e.g., AOE/COE, body parts, permanent disability, need for further treatment, apportionment) and determine what the deposition needs to establish or challenge.
  • Contact the client as needed to get an updated sense of their current medical status, ongoing symptoms, treatment, and how their case is progressing, to make sure the questions and strategy reflect where things stand.

Deposition Attendance
  • Appear at and conduct QME depositions — both applicant-set and defense-set — in person or remotely, questioning the QME and making appropriate objections on the record.
  • Take detailed notes during depositions, tracking key testimony, exhibits marked, and outstanding issues.
  • Manage exhibits and make real-time strategic decisions on the scope and direction of questioning during the deposition.
  • Coordinate post-deposition follow-up tasks.

Administrative & Case Management

  • Maintain accurate and up-to-date case files, deposition logs, and status reports.
  • Communicate proactively with internal team members regarding case status, resolution opportunities, and deposition outcomes.
  • Perform other litigation duties as assigned.

Qualifications:
  • Juris Doctor (J.D.) degree and active license to practice law in California (active member of the State Bar of California) required.
  • 1+ years of experience litigating workers' compensation cases, including taking QME/AME depositions, strongly preferred.
  • Working knowledge of California workers' compensation procedures, QME processes, and deposition practice (or willingness to learn quickly).
  • Prior experience as an associate attorney in a workers' compensation defense or applicant firm is a plus.