A significant part of Serena’s work involves subpoena preparation and records development. She has prepared and managed subpoenas across Pennsylvania, New York, New Jersey, Delaware, and other jurisdictions as needed, including researching jurisdiction-specific procedures and handling subpoena domestication. She also works through complex records-procurement issues by identifying the appropriate custodians, resolving deficiencies, and following up to obtain responsive materials. These capabilities support efficient discovery and give legal teams access to the information needed for case evaluation and strategy.
Serena brings particular strength to litigation involving medical evidence. She reviews medical records, develops treatment chronologies, identifies significant diagnoses and prior injuries, and determines when additional records may be necessary. She also facilitates inspections and independent medical examinations by coordinating among attorneys, engineering experts, medical experts, vendors, and opposing counsel.
Her broader litigation experience includes preparing attorney-directed pleadings, motions, discovery requests and responses, subpoenas, correspondence, and filings for state and federal courts, as well as matters involving the EEOC, NLRB, and OSHA. Serena has managed discovery from document collection through production, including document organization, Bates labeling, privilege logs, and discovery responses. She has also supported depositions, hearings, and trial preparation by assembling exhibits, binders, and other litigation materials. Earlier public-records research experience further developed her ability to analyze court records, prepare accurate reports, protect confidential information, and contribute to fact development.
