New A.3d Cite for Richner v. McCance Case

The new Atlantic Third citation for the recent case in which the Pennsylvania Superior Court skirted the consolidation verses severance issue in post-Koken cases is, as follows:


Richner v. McCance, 13 A.3d 950 (Pa. Super. 2011) (Insurance company’s Preliminary Objections objecting to the joinder of a Plaintiff’s third party tort claim with a count for declaratory judgment against the insurance company sustained; however, the Superior Court “emphasize[d] that [it was] not here deciding the propriety of the joinder of third party liability claims with post-Koken UIM benefit claims).