Patricia M. Cayo

2900 Thomas Avenue South
Suite 2120
Minneapolis, MN 55416

E-mail: [email protected]
Tel: 612-338-3872

Patti Cayo joined James Ryan’s law practice in December 1989. She has 17 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 Equal Employment Opportunity Commission (EEOC) charges. She represented employers in 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 nondispositive) 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, and special verdict forms and creating summary exhibits to be used at trial.

    Investigation

    Ms. Cayo’s investigation experience includes asset searches, Uniform Commercial Code (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 the Family and Medical Leave Act (FMLA), defamation, and other common-law claims that 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 that includes:

    • Proofing drafts of briefs
    • Proofing and verifying citations to cases and rules cited in briefs
    • Assembling appendices 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
      Oct. 27, 2005

      Lorman Educational Services
      Hilton Minneapolis Airport Hotel
      Oct. 26, 2006

      • “Ethics for Paralegals”: Author of and sole presenter at this 90-minute, nationwide teleconference seminar presented to attorneys, paralegals and legal assistants

      Lorman Educational Services
      Oct. 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 90-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