By Kevin L. Connors, Esquire
Faced with a slip and fall personal injury claim, property owners and their insurers need to analyze several key elements in the course of evaluating and defending these highly fact-sensitive claims.
With Pennsylvania Trial and Appellate Courts applying principles set forth in the Restatement (Second) of Torts, the considerations that surface in the course of analyzing and evaluating premises liability claims include:
• Status of the individual making the claim, be it a trespasser, licensee, or invitee;
• Factual cause of the accident and resulting injury, compelling consideration of what condition on the property allegedly caused the accident and resulting injury;
• Status of the party against whom the personal injury claim is being made, requiring consideration of whether the party is an owner in or out of possession, as well as whether the party is a lessor or lessee, requiring consideration of contractual lease terms as to maintenance, repair, inspections, utilities, third-party contractors, and, to sweeten the plot, contractual indemnification issues;
• Nature and cause of the condition being claimed to be the factual cause of the accident and resulting injury, be it transient, as in recent snow or ice, versus neglect, disrepair, or new construction and renovations;
• Notice to the property owner, either actual or constructive, roping in consideration of prior claims, prior complaints, length present, inspection practices and schedules, and third-party contractual considerations;
• The ennui associated with comparative negligence principles, begging the question of whether the individual making the claim has any duty of care for observation, self-awareness, independent self-preservation, or simply the mouse in the maze that cannot find the treat at the backdoor;
• Open and obvious conditions that beg the fact-finder to ask “are you kidding me?”, begging the question of whether the individual making the claim was aware of and appreciated the risk of injury, and nevertheless chose its injurious embrace; and,
• Whether an alternative choice of ways presented itself to the individual making the claim, with that individual unwisely choosing fallacious convenience over less subtle safety.
That is a lot of things to think about, but think about this, that aside from an intentionally violent act, like military invasions, or natural catastrophes, like earthquakes, volcanic eruptions, tsunamis, hurricanes, and other natural disasters, that the most common cause of human injury, whether in the ancient or modern world, are the claims of “I came, I fell, and it must be your fault”.
Before the philanthropic wealth redistribution era of juries and insurance, the fallen, absent death or worse, simply picked themselves up and moved on, without attorney involvement or incident reports.
Those halcyon days are long gone, ushering in an era of nuance and nit-picking.
So what principles are we seeking to perpetuate, in the seesaw world of responsibility for action and inaction?
Let us begin with a very general principle, being the assumption that a property owner, whether commercial or otherwise, will have a vested interest in maintaining, at a minimum, the owned or leased property, in the same state or condition as when initially assuming responsibility for it, in order to preserve the property’s commercial or residential value, as well as to maximize its intended use.
In legalese enforced by juries and courts, this translates into the property owner generally being required to keep the property safe from injury to anyone allowed to enter and be on the property.
In short, ownership and possession means just that, that you are responsible for “taking care”.
Viewed objectively, premises liability legal principles, wherever the Restatement is the controlling playbook, tip the scales of responsibilities against the property owners’ nascent awareness of the condition of the property, over the blind unfamiliarity of a third-party, whether first time or frequent visitors.
You know, they don’t.
You can act, they do not have to.
Enough, it is time to mop the floor, shovel the sidewalk, put out wet floor signs, and otherwise attempt to act like we know what we are talking about.
I. THIRD-PARTY STATUS:
As indicated earlier, there are three distinct classes of third-parties that might make premises liability injury claims, to include:
• A trespasser, who by virtue of having no right to be on the property, is, therefore, owed the lowest duty of care;
• A licensee, entering with permission, requiring protection from an unreasonable risk of harm when it is expected that the licensee will not realize or discover the potential danger of being lost in space; and,
• An invitee, who is someone or anyone that you have invited to your property either by an implicit invitation that you are open for business, or by an express invitation for a backyard barbecue, a game of pickup basketball, or a monthly book club meeting.
If you are Walmart or Target, the chances of the third-party being a trespasser are infinitesimally small, with almost everyone in your store, at whatever hour, being an invitee.
Briefly turning back to that trespasser, being under the Restatement, “a person who enters or remains upon land in the possession of another without the privilege to do so created by the possessors’ consent or otherwise”; that person, sans permission, can still recover for personal injury, but only if those injuries are caused by the property owner being liable for willful or wanton misconduct and neglect, as defined by the Pennsylvania Superior Court in Ott v. Unclaimed Freight Company, 577 A.2d 894 (Pa. Super. 1990);
“Willful conduct means the act or desire to bring about the result in harm, or was at least aware that it was substantially certain to ensue; means that willful conduct requires actual prior knowledge of the trespassers’ peril…
Misconduct, by contrast, means that an actor has intentionally done an act of an unreasonable character, in disregard of a risk known to him or so obvious that they must be taken to have been aware of it, and so great as to make it highly probable that harm would follow. They are usually accompanied by a conscious indifference to the consequences, and no desire to bring about them; as such, actual prior knowledge of the particular injured person’s peril is not required. It is enough that the actor realizes, or at least has knowledge of sufficient facts that would cause a reasonable person to realize, that a period exists, for sufficient time beforehand, to give the actor a reasonable opportunity to take means to avoid the injured person’s accident; the actor is wanton for recklessly disregarding the danger presented…”
Keep in mind that under the Restatement (Second) of Torts §329, the question of whether a person who enters or remains on land is a trespasser, is not dependent upon whether the injury had been intentional, negligent or purely accidental, except to the extent that the injury might bear on the privilege to enter.
A. TRESPASSERS (THINK BAD GUYS STORMING NAKATOMI PLAZA IN DIEHARD I):
A trespasser is defined, under the Restatement (Second) of Torts as “a person who enters or remains upon land in the possession of another without the privilege to do so created by the possessor’s consent or otherwise.” Updyke v. BP Oil Co., 717 A.2d 549 (Pa. Super. 1998).
B. LICENSEES (WHO ARE YOU GOING TO CALL: GHOSTBUSTERS):
Moving on, the Restatement (Second) of Torts §330 identifies a licensee as “a person who is privileged to enter or remain on land by virtue of a possessors’ consent”, also in reliance upon Updyke.
So if you are the New York Public Library infested with unnatural demons possessed by poor posture and bad manners, a classic example of a licensee would be Bill Murray, posing as a Ghostbuster, wreaking havoc on your original collection of Tolstoy works, in the course of eradicating evil, although Mayor Giuliani beware, that if you knew about the defective elevator, and further knew that Bill might be injured by the elevator doors closing too quickly, that you could well be liable to Bill for his personal injuries, since no one would expect Bill to know that the elevator doors might close too quickly, even though Bill’s accumulated late fees for book withdrawals exceeded the gross national product of most third world all-inclusive destinations.
The point being that Rudy should have had the elevator fixed before allowing a Law Abiding Citizen to run amuck among the tomes.
Not exactly along the lines of the Von Trapp family fleeing Nazi-infested Austria, or Peter Pan being invited by Tinkerbell to Neverland, but the principle is simple enough, being that an invitee is “a person who is invited to enter or remain on land for a purpose directly or indirectly connected with the possessor’s business dealings or property”, in reliance upon Restatement (Second) of Torts §332.
Generally, as well as statistically speaking, you will, more often than not, be dealing with personal injury claims involving invitees, with it being extremely rare that your claims will involve those of trespassers or licensees, understanding that invitees are absolutely owed the highest duty of care. Swift v. Northeastern Hospital of Pennsylvania, 690 A.2d 719 (Pa. Super. 1997).
And who imposed this highest duty of care?
It is imposed under Section 343 of the Restatement (Second) of Torts, with the Restatement being an attempt to compress evolving common law principles into well-recognized declarations allowing both sides, Plaintiffs and Defendants, to understand what duties control, and what needs to be proven or disproven in the course of litigating particular claims for remedial correction.
Section 343 of the Restatement, in its infinite wisdom, imposes liability upon a property owner for physical injuries to invitee when:
a) The property owner knows, or by the exercise of reasonable care would discover a condition, that might involve unreasonable risk of harm to an invitee, and;
b) Should expect that the invitee will not discover or realize the danger, or that the invitee might fail to protect themselves against it, and;
c) The property owner fails to exercise reasonable care, by action or inaction, to protect the invitee against the danger. Kiehner v. School District of Philadelphia, 712 A.2d 830 (Pa. Cmwlth. 1998).
Two caveats to being an invitee, the first being that the invitee must “enter the premises on invitation, and the entry must be ‘for a purpose for which the land is open to the public’”. Updyke; Palange v. Philadelphia Law Dept., 640 A.2d 1305, 433 (Pa. Super. 1994).
Is any distinction drawn between an invitation and implicit permission, being the line in the sand between invitee versus licensee status, with the invitation loosely following the invitee believing that the possessor gestured, however symbolically, for the invitee to enter, with permission generally being found where the licensee believed that the possessor will permit the licensee’s entrance; in the context of the invitation, the question becomes whether the possessor desired or encouraged invitees, as the general public, to enter.
Is the duty of care to an invitee absolute?
No, generally, Pennsylvania Courts have consistently held that a property owner is not a guarantor of the safety of invitees on its premises. Swift v. Northeastern Hospital of Pennsylvania, 690 A.2d 719 (Pa. Super. 1997).
Liability does not necessarily flow from the occurrence of an accident; it flows from the breach of a duty of care to the invitee resulting in personal injury.
The concept of notice, requiring actual knowledge, or, constructively, the “you should have known”, nevertheless is a burden of proof borne by the injured party, as liability for personal injuries caused by a condition on a property requires knowledge not only that a danger exists, but that the danger might cause injury to the insouciant Plaintiff.
Notice falls into two categories, actual or constructive.
Actual notice is just that, “I came, I saw, I forgot.”
Constructive notice is more ethereal, as it often depends upon what the meaning of the word notice is, if you follow our drift.
Constructive notice often trips over itself, such as when time proves or disproves it, meaning how long whatever it was, was or was not present, a factual question that almost always arises in the context of weather-related events, like rain, snow, or ice, as those conditions occur irrespective of ownership, often without regard for status, and, more often than not, without regard for safety.
So how is constructive notice proven, when actual notice actually is not that obvious?
That issue was addressed by the Federal District Court in Craig v. Franklin, 555 F.2d 547 (E.D. Pa. 2008).
In finding that the Plaintiff had failed to establish either actual or constructive notice, with the Plaintiff claiming that they had sustained personal injuries as a result of slipping in, or on, a puddle of soda, while walking through the Franklin Mills Mall, the Court, in granting the Defendant’s Motion for Summary Judgment, reviewed the factors that it would consider necessary to be established to prove constructive notice, including:
• The number of people visiting the Mall;
• Frequency of its use;
• Nature of the alleged defect;
• Location of the defect on the premises;
• Probable cause of how the defect was created;
• What opportunity, if any, the Mall Owner/Manager had to discover the presence of the defect;
• Time that might have elapsed between creation of the defect and the Plaintiff’s accident; and,
• Duration of the existence of the alleged hazard.
Concluding that the alleged hazard only existed for a very brief period of time, before the Plaintiff allegedly fell, the Court, in granting Summary Judgment, determined that the property owner could not, even by the exercise of reasonable care, have discovered the existence of the alleged defect/hazard, and did not, therefore, owe any duty of care to the Plaintiff to remove or warn of the presence of the soda, further concluding that the evidence in the case would have required a jury to speculate, in the absence of circumstantial evidence as to the duration of the spilled soda being present, before a jury could conclude that the Mall Owner/Manager should have had constructive notice that an alleged hazard existed that might result in injury to its invitees.
Since the Plaintiff was unable to prove how long the spill was present, Summary Judgment was granted in favor of the Mall Owner.
In the land of the Emperor with no clothes, there is no prize for wearing the best sneakers.
III. YOUR DEFENSES:
Like we said, a property owner is not a guarantor of safety, as liability is balanced upon the fulcrum of actions taken or not taken by the injured party, with your defenses to premises liability and personal injury claims being:
• That the injured party cannot prove you did or failed to do something when you knew or should have known that the Plaintiff might be injured;
• That the injured party cannot prove the classic negligence intersection of duty, breach, cause, and injury;
• That the injured party cannot overcome proof that the injured party’s comparative negligence was the factual cause of injury, a burden of proof imposed upon the property owner;
• That the evidence establishes that the injured party’s accident and injuries were caused by the injured party’s voluntary assumption of a known risk resulting in injury; and,
• That an alternative choice of way existed for the injured party to avoid encountering being injured, with the injured party’s blind eye to a safer way being the predicate to liability abandonment against the property owner.
A. Comparative Negligence Exists in Every Slip and Fall:
From the moment that we became bi-pedal, comparative negligence became apparent in every slip and fall case since the dawn of time.
This is even true under Pennsylvania Law, as we require that ambulation be accompanied by observation, necessitating the obvious, that is that we see and observe that which is open and obvious.
If it can be observed, it can be avoided. Lewis v. Duquesne Inclined Plane Co., 28 A.2d 925 (Pa. 1942).
It is, and always will be, Hornbook Law in Pennsylvania that a person must look where they are going.
A classic example is illustrated by the Pennsylvania Supreme Court’s Decision in Carrender v. Fitterer, 456 A.2d 120 (Pa. 1983), incorporating an excellent review and recitation of assumption of risk doctrine principles, in which the Pennsylvania Supreme Court held that if “both the condition and the risk are apparent to and would be recognized by a reasonable man, the position of the visitor, exercising normal perception, intelligence and judgment,” then it can be argued that the injured party assumed the risk of injury.
Open and obvious, means that the condition is “known to exist”, and that means that it is “recognized that it is dangerous, and the probability and gravity of the threat and harm is appreciated.”
Trial Courts apply a “reasonable man” standard, in terms of whether a Plaintiff should have observed an “open and obvious” condition, in the course of which the condition should be avoided, when that is not a question of fact, Summary Judgment becomes appropriate, as in Campisi v. Acme, 915 A.2d 117 (Pa. Super. 2006).
B. Assumption of the Risk:
Another defense to premises liability cases that simply does not garner the same press as either we had no duty to the injured party, or the accident was caused by the injured party and not by the property owner, is the assumption of the risk defense, a tricky defense to perfect, since it requires some subtlety in eliciting admissions from the injured party, and since it requires the injured party to admit that they not only knew that the risk existed, but they then voluntarily chose to risk injury, when the safer course was avoidance.
It continues to be a problematic defense, given the critical heat targeted at it by both judiciary and legal commentaries.
However, under Bullman v. Guintoli, 761 A.2d 566 (Pa. Super. 2000), the assumption of the risk defense is alive and viable in Pennsylvania, and it obviously continues to be an affirmative defense, under Pennsylvania Rule of Civil Procedure No. 1030, a defense borne by the property owner, which remains very difficult to assert in the context of a Motion for Summary Judgment.
There are four types of assumption of the risk under the Restatement (Second) of Torts, as articulated by the Pennsylvania Supreme Court in Howell v. Clyde, 620 A.2d 1107 (Pa. 1993), including:
• The injured party expressly consents to relieve the property owner of any obligation to exercise care, in the course of which the injured party agreed that they know of and choose to encounter the risk, the classic examples of which are almost any extreme sport related activity;
• The injured party voluntarily enters into a relationship with the property owner, that the injured party understands involves risks, and the injured party is regarded as having tacitly agreed to relieve the property owner of responsibility for the injured party agreeing to encounter the risk;
• The injured party is aware that the property owner might have created a potential risk of injury, and the injured party elects a close encounter of a risky kind; and,
• Finally, the injured party voluntarily chooses to encounter a known risk that is unreasonable, from a “reasonable man” standard, with that choice by the injured party constituting contributory negligence, barring the injured party claiming liability against the property owner, as the accident is considered to have been caused by the injured party’s knowing and voluntary choice. Restatement (Second) of Torts, §496 A, under Comment c.
Due to the vagaries of the assumption of the risk defense, particularly in terms of the juries inability to comprehend and apply it in case-dispositive determinations, the Pennsylvania Supreme Court in Howell abolished the assumption of the risk as an affirmative defense to be decided by a jury, holding, instead, that if there is sufficient evidence, being the mere preponderance standard, that the assumption of the risk defense applies, then its application must be determined by the Trial Court, in the course of determining and analyzing the property owner’s duty of care, being none if the defense applies, to the party making the knowing and voluntary choice to assume the risk despite their potential injury.
This doctrine is further codified in Pennsylvania, under the Pennsylvania Skier’s Responsibility Act, 42 Pa. §7102, that applies to downhill skiing, the same having been applied in several Court Decisions involving skier injuries at ski slopes, as skiing is regarded as an activity fraught with danger, although the same Statute does not preclude an injured party from making a personal injury claim against another Tortfeasor, such as another skier, or for an injury not directly connected to downhill skiing, such as in the case of Chepkevich v. Hidden Valley Resort, 911 A.2d 946 (Pa. Super. 2006), where a skier was allowed to claim personal injury against a ski slope for the alleged negligence of its ski lift operator.
Another caveat to the assumption of the risk doctrine defense, is that a Trial Judge may only apply this defense, as a bar to a personal injury claim, in the course of analyzing the property owner’s potential duty of care to the injured party, if “the Court may determine that no duty exists only if reasonable minds could not disagree that the Plaintiff deliberately and with the awareness of a specific risk inherent in the activity nonetheless engaged in the activity that produced his injury. Wallis v. SEPTA, 723 A.2d 270 (Pa. Cmwlth. 1999).
While the application of the assumption of the risk doctrine defense requires proof that the injured party was subjectively aware of the inherent risk in a particular activity, and nevertheless chose to engage it, there is precedent for that knowledge and understanding being proven through circumstantial evidence, with the operative fact being proof of the Plaintiff’s voluntary and knowing choice to encounter the risk. Frey v. Harley Davidson, 734 A.2d 1 (Pa. Super. 1999).
The assumption of the risk defense incorporates a public policy concern that one who chooses to take a particular risk cannot later complain that they were injured because of that risk. Zachardy v. Geneva College, 733 A.2d 648 (Pa. Super. 1999).
Yes, we are clearly suggesting that the assumption of the risk doctrine in defense is one embodied in a no duty analysis, as it is not an analysis of fault, it is an analysis of cognition and choice.
That being said, this defense will only bar a personal injury recovery “where it is beyond question that (the injured party) voluntarily and knowingly proceeded in the face of an obvious and dangerous condition…”, Struble v. Valley Forge Military Academy, 665 A.2d 4 (Pa. Super. 1995).
C. Choice of Ways:
The choice is yours.
For a choice of ways defense to be applied, again an affirmative defense under a comparative negligence analysis, it requires that there be a safer course, in contrast to the course chosen, with there being sufficient facts present to evidence that a reasonable person would recognize the potential danger inherent in the less safe choice of ways.
As obvious as that might seem, a jury cannot be charged with that defense when the injured party is confronted with a choice of equally safe or equally dangerous paths, nor can it be applied when someone cannot distinguish as which choice is safer.
This doctrine is almost always a jury question.
IV. INVESTIGATING AND DEFENDING SLIP AND FALLS:
Who you gonna call?
There is simply no other way to say this, other than that the investigation of a slip and fall claim should begin as soon as it is reported or witnessed, as only then can the conditions present be captured and recorded, in any manner of available mediums, to include:
• Photographs, yes, we all have smartphones with camera apps, and there is no reason why that spilt soda in the Franklin Mills Mall could not be captured in photographs, so that later, when the injured party files suit, we know what the puddle looked like, we know its dimensions, we know its color, and, most importantly, we know what the injured party might have seen, if the injured party had looked, and its description, whether soda, or some other liquid spill, or snow, or black ice, is then not left to the injured party’s after-the-fact description, as injured parties almost always testify that they only became aware of what caused their fall and accident, after they have fallen; the implication being that whatever caused the fall was invisible to and undiscoverable by the injured party, although, for reasons of proving notice to the property owner, it was not only present long enough for the property owner to have known that it was there, although the property owner through negligence or neglect failed to act, implying by virtue of the property owner’s alleged ignorant neglect, that the property owner should be found responsible for its creation and resulting injury;
• No less true, incident reports and statements that capture the injured party’s description of how, why, when, and what, are critical to locking down “the story of the event”, as memory is not Proustian, meaning simply that it is almost always suspect in terms of recording actual real detail as “the story” takes on a colorful life of its own, either through embellishment or erosion, making re-creation almost always fictional;
• Eyewitness statements, presuming lack of bias or interest, can influence the truth of the event, clarifying, verifying, or eviscerating the injured party’s account, validating or invalidating the claim of both injury and liability;
• Surveillance video, assuming that it is neither lost through spoliation, nor altered, accidentally or intentionally, as the “film speaks for itself”;
• Weather reports, always necessary in cases where weather is the issue;
• Social media accessible through multiple websites capturing photographs, posts, that might be relevant both to the event and the injury;
• Public media, to include newspaper and television reports, all of which are now internet-accessible;
• Activity log, detailing and recording staffing and inspection schedules, and event reporting;
• Contracts, in cases involving multiple defending parties, often the case with commercial properties, and always the case in construction accident cases, requiring analysis of contractual obligations as to property ownership, property management, contractual scope of work issues, and the incessant hold harmless clauses imbedded in contractual insurance and indemnification clauses, that, in some cases, require the assumption of liability regardless of activity or fault;
• Retaining and utilizing experts, often requiring the utilization of professional engineers to evaluate and analyze the conditions that can be proven to have existed, as well as to evaluate the respective duties of care of the involved party;
1. Investigating a slip and fall before suit is filed:
The Complaint is filed, the injured party alleges premises liability negligence against you, your insured, or someone that you have been telling underwriting for years should not be insured, and given the very limited timelines within which a response to the Complaint must be filed with the Court, several things might seem obvious, but we will review them anyway, to include:
Requesting the courtesy of an extension to file a response to the Complaint, routinely accompanied by the proviso that the extension is limited to a formal Answer to the Complaint, that the extensions are never granted for the filing of Preliminary Objections;
Notification to the people and parties that need to be notified;
Evaluation of coverage issues, confirming that the named party is an insured, that the policy was in force and in effect, that exclusions do not limit coverage, that the allegations in the Complaint do or do not warrant coverage being reserved, and that the insurer is clear as to the separate duties, under the insurance policy, to defend and indemnify the insured and/or insurer for the claim being asserted to include an analysis of the application of endorsements for additional insured status, as well as issues of contractual indemnification;
Contact with the injured party’s counsel to secure courtesy copies of counsel’s investigation of the claim, to include requesting, and permitting, the statement, written or recorded from the injured party, any witness statements or admissions that counsel has secured my witnesses or the insured, any photographs, by whomever, that counsel can provide, as well as the reports and conclusions of any investigators or experts retained by the injured party’s counsel, as well as to requesting copies of the injured party’s medical records, as those records may or may not contain descriptions of the event and injury by the injured party that might be consistent or inconsistent with the theory of liability being asserted by the injured party’s counsel;
Contacting and securing any documentation or investigation that the insured might have concerning the event, to include incident reports, statements, photographs, relevant contracts, etc.;
Communications necessary to effectuate defense strategy with other involved insurers; and,
The obvious one, referral to approved entrusted counsel, if the claim cannot be resolved, necessitating that it be litigated through discovery, trial preparation, and case disposition through settlement negotiations, ADR, arbitration, and/or Trial.
b) IN SUIT:
1. Defending the slip and fall after suit is filed:
Evaluate jurisdictional considerations, necessary to determine if jurisdiction and venue are proper and reality-based.
Almost all litigation guidelines require consensus between insurer and defense counsel as to an action plan for case resolution, balancing perceived liabilities against projected expenses and reserves;
Define scope and expense of what needs to be done;
Determine who needs to be pushed, and why;
Address who needs to be deposed and why;
Address what experts need to be considered and why;
Evaluate respective risks of all involved parties, to determine end game strategies;
Eliminate all loose ends associated with potential liens;
Require formal Trial Report, evaluating all Trial issues;
Consider propriety of case-dispositive Motions, to include Preliminary Objections, Motions for Consolidation, Motions for Venue Transfer, Motions for Judgment on the Pleadings, Motions for Summary Judgment, requiring that there be “no genuine issue of material fact”, and Motions in Limine to limit or preclude evidence at Trial.
From event inception through claim resolution, under whatever context, there are no straight lines, although there are lots of compelling overlooks and scenic vistas which may or may not point to a general direction or course of action.
If there is any truth inherent in this discourse, it is that perspective and perception are the pillars upon which event objectivity is built.
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Defending liability-based lawsuits throughout Pennsylvania, on behalf of insurance carriers, third-party administrators, and self-insured businesses and corporations, our 100+ years of cumulative experience defending our clients against negligence and occurrence-based liabilities, empowers our Casualty Practice Trial Group attorneys to be entrusted to create the factual and legal leverage to expeditiously resolve lawsuits and claims, in the course of limiting/reducing/extinguishing our clients’ potential liabilities under Pennsylvania’s common law, trial practices, and rules of civil procedure.
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Questions concerning tort and/or contract liability that might arise in the context of casualty claims can be directed to Kevin L. Connors at firstname.lastname@example.org (Phone: 610-524-2100 Ext. 112).