Here is a LINK to my article entitled "PLEADING FOR CLARITY: Appellate Guidance Needed To Settle The Issue Of The Proper Pleading of Recklessness In Personal Injury Matters" which was just published in the January 2022 edition of The Pennsylvania Bar Association Quarterly.
Note that the article contains a detailed Scorecard of decisions handed down by the various county courts of common pleas all across the Commonwealth of Pennsylvania in recent years, which may prove helpful for your research on this issue, depending upon which county you are litigating the issue.
I send thanks to Professor Robert Rains, the Editor of the PBA Quarterly for his excellent editing of the article into a better article and for selecting this piece for publication.
Also thanking Phyllis Pilla for her editorial assistance with the article as well.
Anyone desiring a copy of any of the cases referenced in the article may contact me at dancummins@CumminsLaw.net.
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