Patricia M. Cayo

820 IDS Center
80 South Eighth Street
Minneapolis, MN 55402
E-mail: cayo@ryanlawfirm.com
Tel: (612) 338-3872
Fax: (612) 338-3874

Patti Cayo joined James Ryan's law practice in December 1989. She has seventeen years of experience as a paralegal in the areas of employment law, personal injury, medical malpractice, general civil litigation, and family law. Prior to working as a paralegal, she had eight years of human resource experience which included responding to unemployment claims, workers' compensation claims, and Minnesota Human Rights and EEOC charges, and representing the employer at unemployment and workers' compensation hearings.

LITIGATION SUPPORT

Ms. Cayo is actively involved in all aspects of litigation support, including drafting pleadings and correspondence, attending document reviews, investigation, legal research, and dealing with clients, attorneys, experts, court personnel, and administrative agencies. She also regularly attends depositions, motion hearings, trials, and appellate oral arguments.  The kinds of pleadings Ms. Cayo has drafted include:

• Administrative Proceedings:

  • Minnesota Human Rights Charges and Questionnaires
  • EEOC Charges and Questionnaires

• Litigation:

  • Complaints
  • Answers
  • Discovery (requests and responses)

    • Interrogatories
    • Request for Production of Documents
    • Request for Statements
    • Request for Admissions
    • Notice of Deposition (including duces tecum requests)

MOTION AND TRIAL PREPARATION

Ms. Cayo assists Mr. Ryan with motion (dispositive and non-dispositive) preparation in both state and federal court. In addition to proofing drafts of memoranda, and proofing and verifying citations for the cases and rules cited in memoranda, she drafts supporting affidavits, including those of clients and witnesses. She is involved in every aspect of trial preparation including drafting of witness and exhibits lists, jury instructions, special verdict forms, and creating summary exhibits to be used at trial.

INVESTIGATION

Ms. Cayo's investigation experience includes asset searches, UCC filing searches, locating witnesses, attending inspections of employer facilities, inspecting and photographing the scene of personal-injury accidents, and searching for and obtaining relevant public records. She has conducted more than 300 witness interviews in employment cases involving claims of sexual harassment, other discrimination (age, race, national origin, disability, and gender), assault and battery, violations of FMLA, defamation, and other common-law claims which typically arise in employment cases. Defendant employers have included state agencies, local police departments and city governments, and for-profit corporations. Witnesses she has interviewed have included current and former employees, including former managerial personnel. She has drafted and obtained signed affidavits from hundreds of witnesses she has interviewed.

APPELLATE SUPPORT

Mr. Ryan's practice has always involved extensive appellate work. In addition to lending litigation and trial support, Ms. Cayo has participated in the production of numerous appellate briefs and appendices, work which includes:

• Proofing drafts of briefs
• Proofing and verifying citations to cases and rules cited in briefs
• Assembling the Appendix to appellate briefs
• Preparing drafts of:

  • Notices of Appeal
  • Statements of the Case
  • Certificates as to Transcript
  • Tables of Authorities
  • Tables of Contents

In addition to her association with Mr. Ryan, she was employed part-time from 1998 to 2000 as a paralegal for a litigation attorney whose sole practice is in the area of family law.

Professional Experience:

James G. Ryan (1989 - Present)
Richard D. Goff & Associates (1998 - 2000 [part-time])

Seminars Taught:

• "Discovery Skills for Legal Staff in Minnesota":   Author of and sole presenter at this full-day seminar -- offered twice -- attended by attorneys, paralegals, and legal assistants

Lorman Educational Services
Sheraton Bloomington Hotel Minneapolis South
October 27, 2005

Lorman Educational Services
Hilton Minneapolis Airport Hotel
October 26, 2006

• "Ethics for Paralegals":  Author of and sole presenter at this ninety-minute, nationwide teleconference seminar presented to attorneys, paralegals, and legal assistants

Lorman Educational Services
October 17, 2006

• "Litigation Skills for Legal Staff":  Author of and sole presenter at this full-day seminar attended by attorneys, paralegals, and legal assistants

  Lorman Educational Services
  Sheraton Bloomington Hotel Minneapolis South
  March 28, 2007

• "Winning at Trial:  Essential Trial Preparation Techniques": Author of and sole presenter at this ninety-minute, nationwide teleconference seminar presented to attorneys, paralegals, and legal assistants

  Lorman Educational Services
  April 3, 2007

Education:

A.A., University of Minnesota - Twin Cities Campus, 1976

Professional Associations:

Member, Minnesota State Bar Association
Member, Minnesota Trial Lawyers Association

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