Mock Trial Jurors Needed for Regional Competition To Be Held in Monroe County on March 5, 2024

The PBA/YLD Mock Trial High School REGIONAL FINALS Competition is scheduled for Tuesday, March 5, 2024 live and in-person at the Monroe County Courthouse.

Come see the new portions of the Monroe County Courthouse at this event.

Jurors are needed. If you are available to help, please reach out to Lori@monroebar.org.

Competition will begin promptly at 6:00 PM, with juror arrival requested to be no later than 5:45 PM. Dinner will be available for volunteers at 5:15 PM.

Thank you in advance for your time and continued support for this great program!

Commonwealth Court Allows Pro Se Prisoner's Slip and Fall Claim To Go Forward

In the case of Pritchard v. Meintell, No. 49 C.D. 2022 (Pa. Cmwlth. Jan. 10, 2024 Jubelirer, P.J., Cannon, J., and Ceisler, J.) (Op. by Jubelirer, P.J.), the Pennsylvania Commonwealth Court reversed in part and affirmed in part a lower court’s decision sustaining a Defendant’s demurrer to a prisoner pro se Plaintiff’s slip and fall action on the basis of sovereign immunity.

According to the Opinion, the appellate court found that the trial court erred in finding that the real estate exception did not apply. The trial court was also found to have erred in ruling that sovereign immunity barred the pro se prisoner’s action for his slip and fall injuries.

The court noted that, in alleging that the Defendants failed to maintain the slip/resistant surface on which he slipped, the inmate had adequately alleged an injury that was caused by a dangerous condition of Commonwealth real estate.

The court otherwise found that the inmate’s other negligence claim that were not connected to the negligent maintenance claim were barred under Pennsylvania law.

Anyone wishing to review a copy of this decision may click this LINK.


Source: “Digest of Recent Opinions.” Pennsylvania Law Weekly (Jan. 30, 2024).

Mock Trial Jurors Needed for Finals on Wednesday

 

Motor Vehicle Accident Case Dismissed for Lack of Timely Service of Process

In the case of Irizzary v. Henry, No. 2230-CV-2022 (C.P. Monroe Co. Jan. 31, 2024 Zulick, J.), Judge Arthur L. Zulick of the Monroe County Court of Common Pleas granted a Defendant’s Preliminary Objections in a motor vehicle accident case alleging that the Plaintiff had failed to timely complete service of process in good faith.

According to the Opinion, the Plaintiff immediately attempted to serve the Writ on the Defendant after the lawsuit was filed. T he lawsuit was filed five (5) days before the day the statute of limitations expired.

The Sheriff’s Return of Service indicated that there were no trespassing signs on the Defendant’s property such that the Sheriff’s Deputy would not enter the premises without a court Order authorizing entry onto the property.

At that point, seven (7) months passed without any docket activity.

The Plaintiff then filed a Motion for Special Service seeking to serve the Defendant by publication.

The court did not grant that request to serve the Defendant by publication but instead issued an Order authorizing the Sheriff to go on to the Defendant’s property to serve the Writ. In the Court Order, it was indicated that, if this additional effort of service was unsuccessful, the Plaintiff was then ordered to file a Motion for Service by Publication.

According to the docket, the Sheriff did not take action upon the Order alone. The court noted that it was incumbent upon the Plaintiff at that point to seek the issuance of the Writ and to request service of the Writ in accordance with the Order.

The record showed that the Plaintiff took no action.

Thereafter, the court nevertheless issued a Case Management Order scheduling the case for trial and directing the parties to complete discovery.  Eventually, the defense counsel entered his appearance and filed a Rule to File Complaint, all of which could be accomplished without waiving the arguments about lack of timely service.  The Plaintiff took no further action of record until he thereafter filed a Complaint, which amounted to another lengthy delay without service being completed.

After reviewing the current status of the law regarding the requirements that a plaintiff make timely and good faith efforts to complete service of process, the court noted that the delays found in other cases in which the court had dismissed the cases were much shorter than the period of delay presented in this case.  In this case, the delay in service of process amounted to seventeen (17) months of delay between the filing of the original Writ and the service of the Complaint, with the Writ never having been reissued along the way.

Accordingly, the court found that the Plaintiff had not met his burden of showing a good faith effort to complete service of original process. As such, the court granted the Defendant’s Preliminary Objections in this regard and dismissed the case.

Anyone wishing to review a copy of this decision may click this LINK.

Summary Judgment Denied In Supermarket Slip and Fall That Occurred in Checkout Aisle

In the case of Scillia v. The Golub Corporation, No. 3772-CV-2022 (C.P. Monroe Co. Jan. 18, 2024 Williamson, J.), the court denied a Motion for Summary Judgment in a supermarket slip and fall case.

According to the Opinion, the Plaintiff’s incident occurred in a narrow pathway between checkout registers where the Plaintiff allegedly slipped and fell as a result of a liquid on the floor.

The Defendants filed a Motion for Summary Judgment arguing that the Plaintiffs failed to meet their burden of proving negligence in terms of actual or constructive notice of the condition, and/or under an argument that the doctrine of an open and obvious condition defeated the Plaintiff’s case.

The court denied the Motion for Summary Judgment after finding that issues of fact existed with respect to both arguments presented by the defense.

The court emphasized that the incident occurred directly in a check-out aisle that was being manned at all times by a cashier. The court distinguished this case from other grocery store slip and fall cases in other parts of of supermarket stores based upon, in part, upon the fact that the incident occurred in a narrow area where customers are required to walk and which area was directly in front of a cashier employee.

The court also noted that there were sets of cart tires on the floor in the area of the liquid puddle, which would tend to possibly show that the puddle was there for a longer period of time such that a jury could find that the puddle arguably could have been noticed by store employees before the Plaintiff encountered it.

With regards to the arguments made by the defense under the open and obvious doctrine, the court again found that there were also issues of fact on that question that should be left to be decided by a jury.

Anyone wishing to review a copy of this decision may click this LINK.

Source of image:  Photo by Shvets on www.pexels.com.

Mock Trial Jurors Needed for Semi-Finals On Wednesday

 

Based on Bankruptcy Court Stay of the Matter, Appellate Court Overturns Administrative Dismissal of Case by Trial Court

In the case of Tyson v. City of Philadelphia, No. 519 C.D. 2022 (Pa. Cmwlth. Jan. 16, 2024 McCullough, J., Wojcik, J. and Hannah Leavitt, S.J.) (Op. by McCullough, J.), the Pennsylvania Commonwealth Court vacated a Philadelphia County trial court’s denial of a Petition to Open an Administratively Dismissed Action.

This case involved a trip and fall along a sidewalk in Philadelphia. The Plaintiff sued the City of Philadelphia, Sears Holdings Corp. d/b/a Kmart and other Defendants.

The one (1) Defendant, Sears Holdings Corp. and its affiliates had provided the trial court with a notice that a voluntary bankruptcy proceeding was pending which necessitated a stay of this action.

However, this personal injury litigation was administratively terminated by the trial court due to a lack of docket activity. The injured party Plaintiff’s Petition to Open was denied. That party asserted that he was not aware of the administrative dismissal paperwork.

In part, the Plaintiff asserted that the administrative dismissal was improper as no action should have been taken in the matter due to the pending bankruptcy of Sears Holding and the automatic stay issued by the bankruptcy court.

On appeal, the Commonwealth Court found that the trial court had erred in administratively dismissing the action for failure to prosecute given that one of the Defendants in the case had filed a voluntary bankruptcy proceeding and given that a bankruptcy stay had to be construed to apply to the dismissals.

The lower court’s decision was vacated and the case was remanded for further proceedings.

Anyone wishing to review a copy of this decision may click this LINK.


Source: “Digest of Recent Opinions.” Pennsylvania Law Weekly (Jan. 30, 2024).

Mock Trial Jurors Needed for Semi-Finals Set for Next Wednesday

 

Superior Court "Constrained" To Reverse Trial Court's Decision Transferring Venue Out of Philadelphia

In the case of James v. Walmart Distribution Center, No. 856 EDA 2023 (Pa. Super. Feb. 2, 2024 Dubow, J., McLaughlin, J., and King, J.) (Op. by Dubow, J.), the Pennsylvania Superior Court noted that it was constrained to reverse a trial Court Order transferring venue of this slip and fall case from Philadelphia to Lehigh County based upon the doctrine of forum non conveniens, as provided in Pa. R.C.P. 1006(d).

This matter involves a slip and all incident that occurred in Bethlehem, Lehigh County, Pennsylvania. The Plaintiff received her medical care in Lehigh County after the incident.

However, the Plaintiff filed her lawsuit in the Philadelphia Court of Common Pleas against the various Defendants. The Defendants filed Answers to the Complaint.

Thereafter, the Defendants filed a Motion to Transfer Venue based upon the doctrine forum non conveniens. The Defendants argued that the Plaintiff’s choice of forum in Philadelphia was oppressive because the case had no connection to Philadelphia County and because the litigating in Philadelphia would create a hardship for representatives of the Defendant.

The court noted that, while the Defendants provided affidavits to the trial court in support of a contention that the four (4) hour roundtrip commute to Philadelphia from the parties’ home would be oppressive because it would severe affect the individuals’ personal life and ability to perform their jobs, the Superior Court noted that the affidavits provided did not identify the Defendant’s defense and/or the evidence that these affiants would provide that was key to the defense as required by the applicable standard of review.

As noted above, the trial court had entered an Order transferring the case to Lehigh County based upon an application of doctrine of forum non conveniens under Pa. R.C.P. 1006(d)(1). The Superior Court reversed.

The Pennsylvania Superior Court noted that the courts have interpreted Rule 1006(d)(1) to require, as a threshold matter, that the Defendant identify its defense and provide a general statement that identifies the witnesses who will be inconvenience by traveling for trial to the Plaintiff’s chosen forum and the relevancy of those witnesses’ testimony to the Defendant’s defense.

Here, although the trial court noted that it found that the defense had credibly argued and presented supporting facts through affidavits and depositions that the hardship to the witnesses’’ family and work life were no mere inconvenience, this Superior Court noted that the trial court made its hardship analysis without even knowing the Defendant’s defense and whether the witnesses who provided affidavits would even testify at trial.

The Superior Court noted that, while the Defendants had alleged in their Answer and Affirmative Defenses that someone else had caused the spill that caused the Plaintiff to fall and that the Defendants lacked notice of the spill, the court stated that these were mere allegations and noted that the affidavits and depositions on the venue issue did not address the manner in which the testimony of the witnesses at issue supported these defenses. Rather, the information provided by the Defendant’s affidavits merely address the hardship associated with the travel to testify in Philadelphia.

The Superior Court noted that the trial court had erred in assuming that the witnesses were key witnesses as there was no evidence to support such a finding. As such, the Superior Court found that the trial court had abused its discretion by failing to hold the Defendants to the proper burden of proof relative to the doctrine forum non conveniens. As such the Superior Court found that the trial court erred in overriding the deference which it was obligated to provide to the Plaintiff’s choice of forum. As such, the trial court ordered transferring venue based upon a doctrine of forum non conveniens was reversed.

Anyone wishing to review a copy of this decision may click this LINK.


I send thanks to Attorney Dale Larrimore of the Philadelphia law firm of Larrimore & Farnish, LLP for bringing this case to my attention.

Source of image:  Photo by Trev Adams on www.pexels.com.

Superior Court Addresses Law of Liability for Ambulance Crew Members

In the case of Lamarr-Murphy v. Del. Co. Mem. Hosp., No. 1846 EDA 2021 (Pa. Super. Dec. 20, 2023 McCaffery, J., Lazarus, J., and Murray, J.) (Op. by McCaffery, J.), the court affirmed the trial court’s denial of post-trial motions in a case involving emergency medical services rendered to the Plaintiff's decedent.

The decedent, who was only 39 at the time of his death, had a history of gout, blood clots, and deep vein thrombosis.  On the day in question, he passed out at home and an ambulance was summoned.  The Plaintiffs alleged negligence with respect to how the ambulance crew handled their interaction with the decedent at his home and during the transport to the hospital.  In addition to having issues with the medical treatment provided to the decedent by the EMS crew, the Plaintiffs also asserted that the ambulance crew was negligent for taking a different route to the hospital that the family would have taken and for stoping at red lights and stop signs.

Along the way to the hospital, the Plaintiff's deceded went into cardiac arrest and the ambulance was stopped so that the crew could administer CPR and provide other treatment measures.

Overall, 39-40 minutes had passed between the time the ambulance left the decedent's home and the time it arrived at the hospital.  The decedent was pronounced dead on arrival.

During the course of this litigation, the ambulance company defendants asserted that it was immune from liability under the Good Samaritan Act.  The trial court ruled that the Act applied and that, therefore, at trial, the Plaintiffs would have to prove gross negligence to prevail on the claims presented.  A mixed verdict resulted at trial and this appeal followed.   

The Superior Court noted that the exclusion in the emergency responder statute for “hospital emergency facilities” was meant to exclude on-site emergency rooms, not hospital ambulance services, from liability.  The appellate court otherwise noted that an emergency provider is granted immunity under the statute unless that individual’s actions amount to intentional harm or gross negligence with respect to the injured party.

The Superior Court also held that the choice of route or the use of sirens by an ambulance crew does not rise to the level of gross negligence.

The court otherwise noted that an ambulance driver’s compliance with traffic laws also does not amount to a breach of duty to a healthy passenger that could serve to support the passenger’s claim for negligent infliction of emotional distress based upon an injury to a relative located within the ambulance.

Anyone wishing to review a copy of this decision may click this LINK.


I send thanks to Attorney James M. Beck of the Reed Smith law firm in Philadelphia for bringing this case to my attention.

Source of image:  Photo by Erik McLean on www.unsplash.com.

You're in Luck: Summary Judgment Denied in PetSmart Store Slip and Fall Case

In the case of Dominiak v. PetSmart, Inc., No. 23-4 (E.D. Pa. Dec. 20, 2023 Perez, J.), the court denied a motion for summary judgment in a slip and fall case.

This matter involved a slip and fall on  a yellowish liquid on the floor in a PetSmart store that was presumed to be urine left by a dog.  Neither the Plaintiff nor the store representatives could say how the liquid came to be on the floor or how long it was there before the Plaintiff encountered it.  However, evidence was produced by the store to show that dogs routinely urinate on the store's floor several times a day, every day.  Because dog urination occurred so frequently in the stores, the store had regular inspections schedule and several "oops stations" throughout the store for clean up purposes.    

The court found that the Plaintiff had presented disputed facts as to the issues of both actual and constructive notice on the part of the Defendant. The court noted that issues of fact were presented with regards to actual notice by virtue of the frequency that the particular type of hazard had allegedly recurred, and with respect to constructive notice possibly being able to be found by the jury due to the central location within the store where the fall occurred.

Anyone wishing to review a copy of this decision may click this LINK.  The Court's companion Order can be viewed HERE


I send thanks to Attorney James M. Beck of the Reed Smith law firm in Philadelphia for bringing this case to my attention.

Source of image:  Photo by Hannah Lim on www.unsplash.com.

Plaintiff's Trip and Fall Over Pallet of Products in Store Barred By Open and Obvious Doctrine

In the case of Ziadeh v. Wal-Mart, Inc., No. 1:22-CV-00094 (M.D. Pa. Jan. 2, 2024 Wilson, J.), the Middle District Court granted summary judgment to a store in a trip and fall case.

According to the Opinion, the Plaintiff allegedly tripped over a pallet with supplies on it that was located within an aisle of the store.    

The court ruled that the object that the Plaintiff tripped over was sufficiently large and visible as to be considered to be open and obvious. As such, the court found that the Defendant did not owe the Plaintiff any duty under the open and obvious doctrine.

The court also found that the Plaintiff’s speculation about another similar object possibly being involved in the incident, the presence of which was not supported by any evidence, was insufficient to prevent the entry of summary judgment.

The court ruled that the question of whether a condition is open and obvious is an objective analysis, and one that does not require any subjective apprehension of danger by the Plaintiff.

In this case, the court found that the Defendant was entitled to rely upon the assumption that a Plaintiff would employ ordinary care to protect herself from obvious harm.

Anyone wishing to review a copy of this decision may click this LINK.


I send thanks to Attorney James M. Beck of the Reed Smith law firm in Philadelphia for bringing this case to my attention.

Source of image:  Photo by Justus Menke on www.unsplash.com.

Judge Nealon of Lackawanna County Orders a Plaintiff To Produce Various Items of Discovery in a Medical Malpractice Action

In the case of Healey v. Scranton Hospital Company, LLC, No. 23-CV-1793 (C.P. Lacka. Co. Jan. 12, 2024 Nealon, J.), Judge Terrence R. Nealon of the Lackawanna County Court of Common Pleas granted a medical malpractice Defendant’s Moton to Compel a Plaintiff to provide various items in discovery.

According to the Opinion, this matter involved a medical malpractice action against a hospitalist, his employer, and a local hospital and involved allegations of the improper administration of opioid medication in the emergency room to the Plaintiff which allegedly caused the Plaintiff to suffer hypoxemic respiratory failure and cardiac arrest allegedly due to the Plaintiff’s documented history of obstructive sleep apnea.

With the Motion to Compel filed by the Defendants, the Defendants asserted that they had served discovery on the Plaintiffs seeking information and documents concerning potential witnesses and regarding Plaintiff’s past medical expenses, work history, medical treatment, health and disability insurance, income tax filings, Social Security Disability documents, documentation and information regarding Plaintiff’s past and future wage loss claims, and with respect to projected future medical expenses.

The Plaintiff responded to these inquiries by stating “to be supplied” or that the requested information and documentation would be provided “at the completion of discovery.” Certain Defendants filed a Motion to Compel more timely and complete responses from the Plaintiff.

Judge Nealon granted this motion noting that, during pre-trial discovery, litigants are obligated to provide to their adversaries relevant information and documentation that currently exist or are readily available. As such, the court ordered the Plaintiff to produce certain items of discovery at issue.

Judge Terrence R. Nealon
Lackawanna County 

However, Judge Nealon also noted that that evidence which requires expert review and formulation need not be produced until later in the discovery process and as required by Pa. R.C.P. 4003.5. Accordingly, the court ruled that, since the Plaintiff’s past loss of income, future loss of earning potential, and the projected medical expenses required expert analysis and calculations in medical malpractice actions, the Plaintiff was allowed to “seasonably provide” that information when he produced his expert witness reports in accordance with the court’s scheduling deadlines.

On a related discovery issue relative to the Defendants’ efforts to secure the Plaintiff’s Social Security Disability documentation, it was noted that an additional authorization was required from the Plaintiff to produce that information. Although the Plaintiff had previously responded in written discovery responses that he would sign the necessary authorization and that he had no objections to the Defendants securing this information, the Plaintiff refused to produce the executed authorization.

The court ordered the Plaintiff to produce an executed authorization to secure the Social Security Disability records given that the Plaintiff had previously indicated that this would be done and given that the Defendants were not seeking to obtain information privately from the Plaintiff’s treating physicians in violation of Pa. R.C.P. 4003.6.

Anyone wishing to review a copy of this decision may click this LINK.

Carrier Held Liable in Bad Faith Claim

In the case of Devincenzo-Gambone v. Erie Insurance Exchange, No. 2017-CV-09856 (C.P. Montg. Co. Oct. 12, 2022 Rogers, J.), the court entered a ruling against the carrier in a bad faith after finding that the carrier had recklessly disregarded a reasonable basis to pursue its petition following an Arbitration of a UIM case.

The court found fault with the carrier’s handling of issues regarding a binding Arbitration on the issues of stacking and damages.

The court found that the Plaintiff had presented clear and convincing evidence that the carrier did not act reasonably in investigating, evaluating, and arbitrating the Plaintiffs’ claims and that the carrier lacked a reasonable basis to hold a portion of the Arbitrator’s Award and to file a Petition to Modify or Correct the Award.

Anyone wishing to review a copy of this decision may click this LINK.

I send thanks to Attorney David B. Pizzica of the Philadelphia law firm of the Pansini Law Group/Pansini & Pizzica for bringing this case to my attention.

Mock Trial Jurors Needed For Thursday

 

Eastern Federal District Court Gives Lessons in Alternative Service of Process in Federal Court

In the case of Allstate Vehicle and Property Ins. Co. v. Top Line Builders, LLC, No. 2:23-CV-03974-TJS (E.D. Pa. Dec. 20, 2023 Savage, J.), the Federal District Court for the Eastern District of Pennsylvania ruled, in a property damage action pursued by a Plaintiff insurance company, that the Plaintiff’s request to serve a Defendant in an alternative manner by posting a copy of the Summons and the Complaint at its business premises would be denied.

The court noted that, under F.R.C.P. 4(h)(1)(B), a corporation must be served “by delivering a copy of the Summons and of the Complaint to an officer, manager, or general agent, or any other agent authorized by appointment or by law to receive service of process and-if the agent is one authorized by statute and the statute so requires-by also mailing a copy of each to the defendant....”

The court additionally noted that, under F.R.C.P. 4(h)(1)(A), a corporation may be served “in the manner prescribed by Rule 4(e)(1) for serving an individual.” 

In federal court, an individual may be served by either delivering copies of the Summons and the Complaint personally to the Defendant, leaving copies with someone of suitable age who resides at the individual's dwelling or usual place abode, or by delivering copies of the Defendant’s authorized agent. F.R.C.P. 4(e)(2)(A)-(C).

The federal court noted that there is no federal civil rule providing for alternative service. However, under Rule 4(e)(1), any method of service allowed by the state in which the judicial district is located is permitted.

The court noted that, under Pennsylvania State Rule of Civil Procedure 430, alternative service is allowed if the Plaintiff makes a Motion to the Court and secures a special Order allowing for alternative method of service.

The federal court noted that Rule 430 does not explicitly identify the prerequisites for obtaining an Order for alternative service. However, it was noted that the Rule requires the Plaintiff to submit “an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made.” The federal court noted that, “implicit in this requirement is that the Plaintiff has an obligation to make a good faith effort to locate the Defendant and a practical effort to serve the Defendant.”

In this case, the court found that Allstate failed to meet its burden to demonstrate that it made a practical effort to complete service on the Defendant.

More specifically, the court noted that Allstate had not shown that personal service upon the Defendants could not be made.

According to the Opinion, Allstate searched the Pennsylvania Department of State’s Business Entity database and the Pennsylvania Office of the Attorney’s General Licensed Contractor search mechanism. Allstate additionally conducted internet searches and, through these various searches, located a street address for the particular Defendant at issue.

Allstate then attempted service at that street address but could not confirm that the particular Defendant or its primary agent was located at that address.

According to the Opinion, the process servicer retained by Allstate made three (3) attempts to serve the Defendant, all on the same day of the week in different weeks.   It was additionally noted that two (2) of the attempts were made at the same time of day, between the hours of 5 and 8 p.m. The court found that these efforts failed to demonstrate that personal service could not be made.

The court otherwise denied Allstate’s Motion to Serve the Defendant by the Alternative Method of posting a copy of the Summons and the Complaint at the business street address.

The court concluded that the Plaintiff had failed to demonstrate that it had made sufficient practical efforts to serve the Defendant in person. The court noted that the Plaintiff’s efforts to actually locate an address for the Defendant were sufficient, but that the Plaintiff's effort to complete service could have been better given that the Plaintiff had a duty to show that it made practical efforts to complete that service after identifying a location for service.

The federal court stated that, generally, this requires a showing of multiple attempts to effectuate personal service. The court stated that the timing and the days on which the attempts to complete service are made are important factors in determination of whether the attempts at service will be considered to be sufficient.

As noted above, the court found that the Plaintiff’s efforts were insufficient and the Motion for Alternative Service was, therefore, denied.

At the conclusion of its Opinion, the court did not otherwise offer any advice or indication as to how service should be completed.

Anyone wishing to review a copy of this decision may click this LINK.  The Court's companion Order can be viewed HERE.


Source: “Digest of Recent Opinions.” Pennsylvania Law Weekly (Jan. 15, 2024).

Source of image:  Photo by Arturo D on www.pexels.com.

Philadelphia County Court Finds Venue Lacking in Case Where Accident Occurred in New Jersey

In the case of Davis v. Arbor Material Handling, Inc., No. 230402106 (C.P. Phila. Co. Aug. 30, 2023 Anders, J.), the trial court granted a Defendant’s Preliminary Objections with regards to venue in a negligence case in which the Plaintiff alleged that a defective forklift resulted in injury to the Plaintiff.

In granting the Preliminary Objections, the trial court noted that, despite being afforded the opportunity to conduct discovery on the issue of venue, the Plaintiff did not do so. The court ultimately noted that the Plaintiff failed to meet the burden of demonstrating that Philadelphia County was a proper venue.

In contrast, the Defendant at issue presented evidence to show that Philadelphia County was an improper venue.

More specifically, the record before the court indicated that the Defendants’ registered offices were not located in Philadelphia County. In addition, the Defendants did not regularly conduct business in Philadelphia County. Moreover, the cause of action itself arose in New Jersey.

Anyone wishing to review a copy of this decision may click this LINK.


Source: “Digest of Recent Opinions.” Pennsylvania Law Weekly (Jan. 11, 2024).