Patricia M. Cayo Brought Years of Experience as a Controller to Her Job as a Paralegal
by Kenneth Davis
Patricia M. Cayo, Paralegal, MN
"When I attended the University of Minnesota in the early-mid 1970s, they had a paralegal certificate program. No paralegal degree programs existed at the time," she said. "I enrolled in a number of classes, but due to lack of student interest, the certificate program was eliminated. I do recall [that] at the time, there was fear among law students that paralegals would take over many of the legal support responsibilities typically assigned to law clerks and young associates. There wasn't much support in the legal community for the development of paralegal careers."
Since the paralegal program was no longer an option, Cayo obtained an A.A. in General Studies with a focus on business.
After graduation, she worked in the corporate offices of a Minnesota corporation that owned and operated several temporary help services placing industrial, clerical, para-technical, medical, and law services personnel. Cayo's official title was Controller. As Controller, she was responsible for billing, credit, and collections, accounts payable (everything financial), monitoring employee unemployment and workers’ compensation claims, and the administration and monitoring of employee benefits, such as insurances and retirement accounts.
"Most people do not realize that employers are assessed an employment tax on their overall payroll," she said. "Employers are assigned an experience rating based on the amount of money paid by the state for unemployment claims that are generated by an employer's terminating or laying off of employees."
After working as a controller for eight years, Cayo joined attorney James G. Ryan's Minneapolis-based law practice, Ryan Law Firm, in December of 1989 as a paralegal. At the firm, she 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.
Additionally, she assists Ryan with dispositive and non-dispositive motion preparation in both state and federal courts. And in addition to proofing drafts of memoranda and proofing and verifying citations for cases and rules cited in memoranda, Cayo 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, as well as creating summary exhibits to be used at trial.
Cayo's investigation experience has involved asset searches, UCC filing searches, locating witnesses, attending inspections of employer facilities, inspecting and photographing the scenes of personal-injury accidents, and searching for and obtaining relevant public records.
Cayo is also a member of the Minnesota State Bar Association and the paralegal section of the Minnesota Trial Lawyers Association.
"I believe membership in any legal association is important, especially an association that has a paralegal section," she said. "I like having a support group of individuals who walk in my shoes. I learn a great deal from other paralegals. We share ideas and educate each other [about] areas of law we don't commonly practice."
She said the most dramatic change she has seen in the legal industry since becoming a paralegal has been "the community's recognition of paralegals as 'para-professionals.'"
Cayo listed some highlights of her career as a paralegal:
"Attending a Rule 12 motion hearing in federal court and having the judge pick up a key argument from the affidavit I drafted for a witness that I interviewed," she said. "Going to oral argument before the Minnesota Court of Appeals and having an appellate judge point out the accuracy of our brief's citations to the record (I proof and verify all case and record citations to every pleading and appellate brief); investigating a high-profile law enforcement case that received a lot of media (television and newspaper) coverage and having excerpts of witness affidavits I drafted quoted in the newspaper and on air; attending a summary judgment hearing in federal court and having the judge remember the facts of a case I investigated ten years earlier; regularly attending depositions, motion hearings, trials, and appellate oral arguments; being complimented by a federal magistrate judge during a settlement conference for the organization of our submissions; and being asked to author and present at three continuing legal education seminars."
She said she considers one of the most important issues facing the legal community today to be ethics violations.
"Recently, among other violations, lawyers and firms around the country have been charged with stock options backdating, giving kickbacks to people to take part in shareholder lawsuits, and misappropriation of client funds," she noted.
When asked whether she would do anything differently if she could do it all over again, Cayo answered that she wouldn't change a thing.
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