Library of Pennsylvania Personal Injury Forms

If you have a personal injury case in Pennsylvania, this book is a "must have"!

Why?

It is the only forms book that concentrates on the 10 most litigious counties in Pennsylvania: Philadelphia, Delaware, Chester, Bucks, York, Montgomery, Allegheny, Luzerne, Westmoreland and Berks.


The book contains hundreds of pages of forms and information you need to prosecute your case from beginning to end.

Topics Include:

- Medical Malpractice

- Workers' Compensation

- Construction Site Accidents

- Dram Shop Cases and more...

Forms Include:

- New client/ Initial intake forms

- Sample motions

- Sample arbitration forms

- Sample trial documents and more...

1. INTRODUCTION
1.1 Ten County Selection Process


2. INITIAL CORRESPONDENCE/FORMS
2.1 Welcome Letter to Client
2.2 Welcome Letter to Client - Medical Malpractice Case
2.3 Initial Client Letter Enclosing HIPAA and CFA
2.3.1 Alternative Initial Client Letter - Enclosing Packet
2.3.1.1 HIPAA-Compliant Medical Authorization
2.3.1.2 Contingent Fee Agreement Practice Pointer - Contingent Fee Agreement
2.4 New Client Reminders
2.5 Thank You Letter to Referring Attorney
2.6 Letter Requesting Medical Records
Practice Pointer - Medical Records Fees
Practice Pointer - Electronic Ordering of Medical Records
2.7 Letter to Client Confirming Medical Records Ordered
2.8 Client Status Letter - Medical Malpractice Case
2.9 Client Status Letter - Construction Accident Case
2.1 Client Status Letter - Product Liability Case
2.11 Client Status Letter - Dram Shop
2.12 Client Status Letter - Tractor Trailer Accident Case
2.13 Client Status Letter - Unsafe Drug Case
2.14 Client Status Letter - Medical Device Case
2.15 Letter to Referral Attorney - Status
2.16 Letter to Medical Provider Requesting Disability Statement
2.17 Letter to Physician/Medical Provider Requesting Comprehensive Report - General
2.18 Letter to Physician/Medical Provider Requesting Comprehensive Report - Detailed
2.19 Letter to Employer Requesting Wage Loss Confirmation
2.2 Letter to Client Verifying Wage Loss Accuracy
2.21 Request for Preservation of Video/Digital Recordings
2.22 Letter Requesting News Videos, 911 Transcripts/Recordings, EMS Reports, Police Reports
Practice Pointer - Ordering News Videos - Time Limits
Practice Pointer - 911 Recordings - Time Limits/Subpoenas
2.23 Letter Requesting Ambulance/Emergency Responder Report
2.24 Spoliation Letter - Preservation of Evidence - Tractor Trailer Accident
2.25 Notice Letter to Governmental Unit
Practice Pointer - Form 95
2.25.1 Form 95
2.26 Notice Letter to Commonwealth of Pennsylvania
2.27 Notice Letter to Defendant - Motor Vehicle Case
2.28 Notice Letter to Defendant - Premises Liability Case
2.29 Letter to Liability Insurer to Verify Coverage - Premises Liability
2.3 Letter to OSHA Requesting Investigative Report - Freedom Of Information (FOIA) Request
2.31 Letter to FMSCA - Freedom of Information (FOIA) Request
2.32 Letter Requesting Weather Report
2.33 Letter to Investigator - Motor Vehicle Case
2.34 Letter to Investigator - Premises Liability Case
2.35 Letter to Investigator - Dram Shop Case
2.36 Rejection Letter - Client
2.37 Rejection Letter - Client - Referral Attorney
2.38 Rejection Letter - Referral Attorney


3. PRE-LITIGATION
3.1 Letter to Client Enclosing Unsafe Drug Questionnaire
3.1.1 Questionnaire for Unsafe Drug Claim
3.2 Letter to Expert Requesting Certificate of Merit
3.3 Letter to Treating Physician Requesting Expert Report
3.4 Letter to Expert (Physician Specialty) Requesting Expert Report - Medical Malpractice
3.5 Letter to Expert (Engineer) Requesting Expert Report - Product Liability
3.6 Letter to Expert (Toxicologist) Requesting Expert Report - Dram Shop
3.7 Letter to Expert (Bar Practices) Requesting Expert Report - Dram Shop
3.8 Letter to Expert (Economist) Requesting Expert Report
3.9 Letter Requesting Private Health Insurance Lien
3.1 ERISA Letter to Health Insurance Carrier
Practice Pointer - ERISA Status
3.11 Letter Requesting Workers' Compensation Records
3.12 Letter Requesting Workers' Compensation Lien
3.13 Letter Requesting Department of Public Welfare Lien
Practice Pointer - Medicare Liens
3.14 Letter to Medicare Requesting Lien Information
3.15 Letter to Client Enclosing Medicare Proof of Representation Form
3.15.1 Proof of Representation
3.16 Letter to Medicare Enclosing Executed Proof of Representation Form
3.16.1 Letter to Medicare Enclosing Engagement Letter
3.17 Notification Letter to Medicare Coordination of Benefits - Request Lien
3.18 Letter to Client - Enclosing Complaint for Verification
3.19 Referring Attorney Status Letter - Quarterly Report - Medical Malpractice
3.2 Referring Attorney Status Letter - Quarterly Report - Construction Accident
3.21 Referring Attorney Status Letter - Quarterly Report - Dram Shop
3.22 Referring Attorney Status Letter - Quarterly Report - Unsafe Drug
3.23 Referring Attorney Status Letter - Quarterly Report - Medical Device


4. PIP - PERSONAL INJURY PROTECTION
4.1 Letter of Representation to Client's Insurance Carrier
4.2 Request for Driver/Vehicle Information
4.3 Letter of Representation to Defendant's Insurance Carrier
4.4 Letter to Client Enclosing Insurance Application for Benefits
4.5 Letter to Medical Provider Providing PIP Carrier Information
4.6 Letter Forwarding Completed PIP Application to Insurance Carrier
4.7 Affidavit of No-Insurance
4.8 Letter Requesting PIP Carrier to Reimburse Private Health Insurer
4.9 Letter to Insurance Company Requesting Copies of Waivers
4.1 Letter to Client's Carrier Requesting PIP Payout Log
4.11 Letter to Insurance Company Requesting Exhaustion Letter
4.12 Letter to Client Enclosing Copy of Exhaustion Letter
4.13 Complaint for First Party Benefits and Bad Faith


5. COMPLAINTS/INITIAL FILINGS & SERVICE
5.1 Praecipe for Writ of Summons
Practice Pointer - Rule 4003.8 - Pre-Complaint Discovery
5.2 Praecipe for Writ of Summons in Aid of Preparing Complaint
5.2.1 Notice of Deposition in Aid of Preparing Complaint
5.3 Product Liability Complaint - Defective Design
5.4 Product Liability Complaint - Crashworthiness
5.5 Medical Malpractice Complaint
5.5.1 Certificate of Merit - Medical/Professional Malpractice
5.6 Unsafe Drug Complaint
5.7 Unsafe Medical Device Complaint
Practice Pointer - Unsafe Medical Device Complaint
5.8 Motor Vehicle Accident Complaint - Intersectional Collision
5.9 Motor Vehicle Accident Complaint - Arbitration - Rear End Collision
5.1 Tractor Trailer Accident Complaint
5.11 Premises Liability Complaint - Defective Sidewalk
5.12 Premises Liability Complaint - Snow and Ice
5.13 Construction Accident Complaint
5.14 Dram Shop Complaint
5.15 Complaint Specific Forms
5.15.1 Philadelphia County Civil Cover Sheet
5.15.2 Montgomery County Civil Cover Sheet
5.15.3 Delaware County Civil Cover Sheet
5.15.4 Allegheny County Civil Cover Sheet
5.15.5 Chester County Civil Cover Sheet
5.15.6 Luzerne County Civil Cover Sheet
5.15.7 Bucks County Civil Cover Sheet
5.15.8 Westmoreland County Civil Cover Sheet
5.15.9 York County Civil Cover Sheet
5.15.10 Berks County Civil Cover Sheet
5.16 Notice to Defend - Philadelphia County (English/Spanish)
Practice Pointer - Notice to Defend
5.17 Letter to Court Enclosing Complaint for Filing
5.18 Letter to Sheriff Enclosing Complaint for Service
Practice Pointer - Original Service Forms
5.18.1 Philadelphia County Sheriff's Service Form
5.18.2 Montgomery County Sheriff's Service Form
5.18.3 Delaware County Sheriff's Service Form
5.18.4 Allegheny County Sheriff's Service Form
5.18.5 Chester County Sheriff's Service Form
5.18.6 Luzerne County Sheriff's Service Form
5.18.7 Bucks County Sheriff's Service Form
5.18.8 Westmoreland County Sheriff's Service Form
5.18.9 York County Sheriff's Service Form
5.18.10 Berks County Sheriff's Service Form
5.19 Letter to Process Server Enclosing Complaint for Service
5.2 Letter to Counsel Enclosing Complaint for Service with Acknowledgment of Service
5.20.1 Acknowledgment of Service
5.21 Letter to Defendant Serving Complaint via Certified and Regular Mail
5.21.1 Affidavit of Service
5.22 Letter to Court Enclosing Affidavit for Filing
5.23 Stipulation to Dismiss Party
5.24 Plaintiff's Memorandum of Law in Response to Defendant's Petition to Transfer Venue
5.25 Preservation/Spoliation - Truck Case


6. DISCOVERY
6.1 Philadelphia County Standard Plaintiff's Interrogatories - Motor Vehicle
6.2 Philadelphia County Standard Plaintiff's Interrogatories - Premises Liability
Practice Pointer - Objections to Standard Form Discovery
6.3 Plaintiff's Interrogatories - Premises Liability/Ice and Snow
6.4 Plaintiff's Interrogatories - Unsafe Drug
6.5 Plaintiff's Interrogatories - Unsafe Medical Device
6.6 Plaintiff's Interrogatories - Medical Malpractice - Physician
6.7 Plaintiff's Interrogatories - Medical Malpractice - Hospital
6.7.1 Plaintiff's Cooper Interrogatories to Defense Expert
6.8 Philadelphia County Standard Defendant's Request for Production of Documents
6.9 Philadelphia County Standard Plaintiff's Request for Production of Documents
6.1 Request for Production of Documents - Unsafe Drug
6.11 Request for Production of Documents - Unsafe Medical Device
6.12 Request for Production of Documents - Medical Malpractice
6.13 Request for Production of Documents - Product Liability
6.14 Request for Admissions
6.14.1 Request for Admissions - Premises Liability - Snow and Ice
6.15 Letter to Client Enclosing Defense Counsel Interrogatories
6.16 Letter to Client Enclosing Draft Response to Interrogatories
6.17 Letter Serving Discovery Requests
6.18 Letter to Opposing Counsel Regarding Overdue Answers to Discovery
6.19 Letter to Opposing Counsel Requesting More Specific Answer to Discovery
6.2 Letter to Client Regarding Scheduled Defense Medical Examination
6.21 Letter to Client Confirming Deposition Date/Time
6.22 Deposition Notice - Defendant
6.23 Deposition Notice - Corporate Designee
6.24 Deposition Notice - Physician/Expert Witness for Trial
6.25 Deposition Notice - Videotaped Deposition
6.26 Letter Serving Deposition Notice
6.27 Letter to Client Regarding Additional Documents Requested During Deposition


7. MOTIONS
7.1 Letter to Court Enclosing Motion for Filing
Practice Pointer - Motion Court Cover Sheets
7.1.1 Philadelphia County Motion Cover Sheet
7.1.2 Montgomery County Motion Cover Sheet
7.1.3 Delaware County Motion Cover Sheet
7.1.4 Allegheny County Motion Cover Sheet
7.1.5 Chester County Motion Cover Sheet
7.1.6 Luzerne County Motion Cover Sheet - No Cover Sheet
7.1.7 Bucks County Motion Cover Sheet
7.1.8 Westmoreland County Motion Cover Sheet
7.1.9 York County Motion Cover Sheet - No Cover Sheet
7.1.10 Berks County Motion Cover Sheet
7.2 Motion to Amend Complaint
7.3 Response to Motion to Dismiss
7.4 Motion to Remand - Citizenship
Practice Pointer - Motion to Remand
7.5 Letter to Defendant Advising of Intent to File Motion for Default Judgment
7.5.1 Notice of Intent to File for Default
7.6 Motion to Consolidate
7.7 Motion for Extraordinary Relief
7.8 Motion to Compel Discovery
7.9 Motion to Compel More Specific Answers to Discovery
7.1 Motion to Strike Objections and Compel Answers
7.11 Motion to Compel Deposition
7.12 Motion to Compel Expert Report
7.13 Motion to Compel Inspection
7.14 Motion to Award Delay Damages
7.16 Motion to Withdraw as Counsel
Practice Pointer - Motion to Withdraw as Counsel
7.17 Response to Motion for Summary Judgment
7.18 Motion to Enforce Settlement


8. MEDIATION/ARBITRATION
8.1 Letter to Counsel to Appoint Defense Arbitrator
8.2 Letter to Selected Plaintiff's Arbitrator
8.3 Letter to Proposed Single Arbitrator
8.4 Letter to Defense Counsel to Appoint Neutral Arbitrator
8.5 Letter to Client Confirming Arbitration Hearing
8.6 Arbitration Memorandum
8.7 Itemization of Medical Treatment
8.8 Letter to Defense Counsel Enclosing Arbitration Package
8.9 Letter to Counsel Regarding Agreements Made
8.1 Letter to Client Regarding Binding High-Low Arbitration and Trial
8.11 Letter to Client Enclosing Arbitration Decision
8.12 Letter to Client Regarding Arbitration Appeal Process
8.12.1 Notice of Appeal from Award of Board of Arbitrators
8.13 Letter to Court Enclosing Appeal from Arbitration Award
8.14 Motion to Remove Case from Arbitration
8.15 Letter to Client Explaining Mediation Process
8.16 Letter to Mediator Enclosing Plaintiff's Mediation Memo
8.17 Mediation Memorandum - Construction Accident
8.18 Mediation Memorandum - Dram Shop
8.19 Mediation Memorandum - Tractor Trailer Accident
8.2 Letter to Client Enclosing Defense Mediation Memo


9. TRIAL
9.1 Letter to Client Regarding Trial Date
9.2 Letter Enclosing Trial Submissions
9.3 Voir Dire - Medical Malpractice
9.4 Voir Dire - Product Liability
9.5 Pre-Trial Memorandum
9.6 Plaintiff's Offer of Deposition Testimony
9.7 Stipulation Regarding Medical Bills
9.8 Stipulation to Dismiss Party
9.9 Plaintiff's Motion for Directed Verdict by Plaintiff
9.1 Jury Questions
9.11 Motions in Limine/Response to Motions in Limine
9.11.1 Abortions/OBGYN History
9.11.2 Alcohol Abuse
9.11.3 Alcohol Use
9.11.4 Alcohol/Drug/Tobacco Use
9.11.5 Chlamydia
9.11.6 Citizenship
9.11.7 Conviction/Incarceration
9.11.8 Cumulative/Unqualified Expert
9.11.9 Diabetes
9.11.10 Domestic, Sexual Abuse
9.11.11 DUI
9.11.12 Hearsay
9.11.13 Hepatitis
9.11.14 Late Expert Identification
9.11.15 Prior Abuse and Psychiatric History
9.11.16 Response in Opposition to Motion in Limine
9.11.17 Seatbelt Use
9.11.18 Supplemental Defense Expert Report
9.11.19 Irrelevant Testimony
9.11.20 Response re Contradictory Reports
9.12 Letter to Defense Expert Physician - Document Subpoena for Trial
9.12.1 Subpoena Ad Testicandum and Duces Tecum for Trial
9.12.2 Document Subpoena Addendum
9.13 Letter to Plaintiff's Expert Witness for Appearance at Trial
9.14 Notice to Attend
9.15 Notice to Attend - Doctor


10. SETTLEMENT
10.1 Demand Letter - Dog Owner Liability
10.2 Demand Letter - Construction Accident Case
10.3 Demand Letter - Dram Shop
10.4 Letter to Client Confirming Rejection of Settlement Offer
10.5 Third-Party Bad Faith Letter
10.6 Letter to Court Requesting Settlement Conference
10.7 Settlement Memorandum - Medical Malpractice
10.8 Settlement Memorandum - Motor Vehicle Accident
10.9 General Release
10.1 Pro Tanto/Dollar Release
Practice Pointer - Releases
10.11 Letter to Healthcare Requesting Compromise
10.12 Letter to Court Advising That Case Has Settled
10.13 Letter to Defense Insurance Company Confirming Settlement
10.14 Letter Forwarding Release and Settlement Documents to Client
10.15 Statement of Settlement and Distribution
10.16 Affidavit of No Child Support Lien
Practice Pointer - Child Support Obligations
10.17 Letter to Opposing Counsel Enclosing Signed Release
10.18 Letter to Medicare Confirming Lien and Transmitting Payment
10.19 Letter Forwarding Payment to Healthcare Provider
10.2 Petition to Approve Settlement and Distribution of Wrongful Death and Survival Actions
10.21 Order to Settle, Discontinue and End
10.22 Letter Forwarding Settlement Check to Client
10.23 Letter Forwarding Referral Fee to Referral Attorney


11. UM/UIM
11.1 Notification of UIM Claim
11.2 Letter to UIM Carrier Providing Proof of Claim
11.3 Underinsured Motorist Bad Faith Letter
11.4 Letter to Insurance Carrier Requesting Appointment of Defense Counsel
11.5 Post-Koken Letter to Insurance Company Requesting Arbitration
Practice Pointer - Koken
11.6 Letter to Client Advising of UM/UIM Hearing Award
11.7 Letter to Client Advising of UM/UIM Arbitration Hearing


12. WORKER'S COMPENSATION
12.1 Standard Contingent Fee Agreement
12.2 Initial Letter to Client Enclosing Fee Agreement and HIPAA
12.3 Letter of Representation to Insurance Company
12.4 Entry of Appearance
12.5 Letter to Employer re Electronic Filing of Claim Petition
12.6 Letter to PA Bureau of Worker's Compensation Enclosing Claim Petition for Filing
12.7 Letter to PA Bureau of Worker's Compensation Requesting Copy of Bureau File
Practice Pointer - Worker's Compensation Website Information


13. APPENDIX - FORMS BY COUNTY (see companion cd-rom for county forms)
13.1 Philadelphia County
13.2 Montgomery County
13.3 Delaware County
13.4 Allegheny County
13.5 Chester County
13.6 Luzerne County
13.7 Bucks County
13.8 Westmoreland County
13.9 York County
13.1 Berks County

Joel Feldman, Managing Partner of Anapol Schwartz

Joel Feldman is the Managing Partner of Anapol Schwartz, Weiss, Cohan, Feldman & Smalley, as well as an active trial attorney. He is proud to have participated in the firm's successes in the past and to have helped the firm earn its reputation for excellence. His clients are unanimous in their appreciation for his hard work, as well as his compassion and concern for their interests.

He has represented a number of individuals in a wide variety of personal injury actions, as well as securities litigation and stockbroker claims. His personal injury practice includes cases arising from dangerous products and construction site accidents, nursing home neglect, dangerous conditions on properties, automobile and truck accidents, medical and dental malpractice, and alcohol-related accidents. He received his Bachelor's degree from University of Vermont in 1976 and his law degree from Villanova University School of Law in 1981.


Michael L. Barbiero

Michael L. Barbiero joined Ostroff Law in 2011. He concentrates his practice in personal injury, wrongful death and catastrophic injuries. He also serves as a Certified Arbitrator for the Philadelphia Court of Common Pleas Compulsory Arbitration Program. He is licensed to practice law in Pennsylvania and New Jersey.

Mr. Barbiero was named a Pennsylvania "Rising Star Super Lawyer" in the December 2008 edition of Philadelphia magazine which recognizes the top 2.5 percent of attorneys 40 years old or younger in the state of Pennsylvania.

Prior to returning to school for his law degree, Michael worked for several years with troubled teens throughout Philadelphia and the surrounding counties. Following a post law school clerkship with the esteemed Hon. Alex Bonavitacola, Michael spent several years as an attorney defending businesses and insurance companies. This experience directly benefits the accident victims he now represents, because he has been on "both sides of the fence" and understands how insurance companies and their attorneys review and handle personal injury cases. Michael then spent eight years focusing on the representation of catastrophically injured victims while employed at the renowned "Anapol, Schwartz" personal injury law firm in Philadelphia, PA


Amber Racine

Amber Racine joined the firm as an associate in September 2008 and concentrates her practice on consumer class actions, consumer fraud litigation, pharmaceutical litigation and other civil and commercial litigation. Prior to becoming an Associate, Ms. Racine worked at Anapol as a paralegal from 2002-2008.

Ms. Racine received her Bachelor's degree in History & Politics from Drexel University where she was an A.J. Drexel Scholar. Ms. Racine entered Temple University's James E. Beasley School of Law in 2004 and attended classes in the evening while continuing her paralegal work at the firm. In 2008 she received her law degree and was awarded Distinguished Classroom Performance and Outstanding Oral Advocacy Awards.

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