Onyx Law Firm is seeking a seasoned Senior Trial Paralegal with a minimum of seven years of substantive litigation experience and direct, hands-on experience handling first-party insurance breach-of-contract and bad-faith litigation against insurance companies.

Our firm represents policyholders in complex disputes arising from the denial, delay, underpayment, and mishandling of first-party property insurance claims. These cases commonly involve claims for:

• Breach of the insurance contract;
• Breach of the implied covenant of good faith and fair dealing;
• Unreasonable claim delay or denial;
• Failure to conduct a full, fair, and thorough investigation;
• Improper reliance on exclusions or unsupported causation opinions;
• Additional living expenses and loss-of-use benefits;
• Dwelling, personal-property, code-upgrade, and repair-scope damages;
• Consequential and emotional-distress damages;
• Brandt attorney-fee damages; and
• Punitive damages based on managing-agent authorization, participation, or ratification.

This is not an entry-level position, a general litigation position, or a role for someone seeking to learn first-party insurance law on the job. Applicants must already understand how a first-party insurance case is developed from the policy and claim file through written discovery, depositions, expert discovery, motions for summary judgment or summary adjudication, motions in limine, jury instructions, special verdict forms, exhibits, and trial.

The Type of Person We Are Seeking

We are not looking for someone who merely waits for assignments, enters dates on a calendar, or organizes documents after being given step-by-step instructions.

We are looking for the trial attorney’s trusted litigation partner and operational second-in-command—someone who:

• Anticipates what the case will require before being asked;
• Recognizes a missing exhibit, evidentiary gap, conflicting deadline, or unsupported expert assumption before it becomes a problem;
• Understands why a particular adjuster note, denial-letter statement, vendor assignment, estimate discrepancy, omitted inspection, or change in coverage position matters;
• Can transform a large and disorganized insurance claim file into a coherent evidentiary record;
• Remains calm, precise, and professional when discovery, dispositive-motion, expert, and trial deadlines converge; and
• Takes genuine ownership of the quality, organization, and readiness of the case.

The successful candidate must understand that first-party insurance litigation exists at the intersection of contract interpretation, claim-handling conduct, construction science, causation, damages, discovery, and trial evidence.

First-Party Insurance Claim-File Analysis

The candidate must be capable of reviewing and understanding the insurance claim file as evidence—not simply as a collection of documents.

The role includes:

• Review insurance policies, declarations pages, endorsements, coverage forms, exclusions, conditions, and duties-after-loss provisions;
• Analyze claim diaries, activity logs, adjuster notes, correspondence, coverage letters, reservation-of-rights letters, denial letters, payment records, estimates, photographs, videos, recorded statements, proofs of loss, examinations under oath, and insurer-vendor reports;
• Create a detailed claim chronology showing what the insurer knew, when it knew it, what it did, what it failed to do, and how its coverage position changed;
• Build issue matrices connecting each policy provision and legal theory to the supporting witness, document, deposition testimony, exhibit, and motion evidence;
• Identify inconsistent claim notes, unexplained delays, missing inspections, uninvestigated coverage theories, unsupported conclusions, and evidence favorable to coverage that may have been disregarded;
• Compare insurer estimates with contractor, restoration, engineering, public-adjuster, and insured estimates;
• Track all payments by coverage category, including dwelling, contents, additional living expenses, debris removal, code upgrades, mitigation, environmental testing, and other benefits;
• Assist with the preparation of damages summaries and demonstrative timelines;
• Identify documents necessary to establish the reasonableness or unreasonableness of the insurer’s investigation;
• Track the chain of custody for failed plumbing components, building materials, testing samples, photographs, video, and other physical evidence; and
• Maintain a clean, searchable, OCR-enabled, and properly B