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The Library of Pennsylvania Personal Injury Forms - Special Rate

Joel Feldman , Michael L. Barbiero , Amber Racine

$219.00 $179.00
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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.

 

"The Library of Pennsylvania Personal Injury Forms is a concise, thorough and easy-to-find forms book; a must for every plaintiff's Personal Injury practitioner.

  Theodore A. Schawartz

Locks Law Firm, Philadelphia

 

"The Library of Pennsylvania Personal Injury Forms is a thoroughgoing compendium of forms for the practicing Pennsylvania trial lawyer. It takes you from pre-complaint discovery through pleadings, discovery, motions practice, trial practice and beyond. And with a CD that includes writable forms, I feel like a local lawyer no matter what county I'm venued in. It's the one book that stays on my desk and never gets back to the bookshelf."

David L. Kwass

Saltz Mongeluzzi Barrett & Bendesky PC, Philadelphia

 

 

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...

 

Includes a CD-ROM with writable forms

 

 

Order today and save! 

Just $179 - Retail $219


 

If you have any questions call us at

800-722-7670 x2453

 

  • Availability: Available
  • Brand: The Legal Intelligencer
  • Product Type: Books
  • Edition: 4
  • ISBN: 1-57786-339-9
  • Pub#/SKU#: LPIF14
  • Pub Date: 11/30/2013

Author Image
  • Joel Feldman

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.


Also by Joel Feldman :
The Library of Pennsylvania Personal Injury Forms
Library of Pennsylvania Personal Injury Forms - Fourth Edition
Pennsylvania Causes of Action 3rd Edition
PA Causes of Action 3rd Edition


Author Image
  • 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

 


Also by Michael L. Barbiero :
The Library of Pennsylvania Personal Injury Forms
Library of Pennsylvania Personal Injury Forms - Fourth Edition


Author Image
  • 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.
Also by Amber Racine:
The Library of Pennsylvania Personal Injury Forms
Library of Pennsylvania Personal Injury Forms - Fourth Edition

1. INTRODUCTION
1.1 Ten County Selection Process 1
2. INITIAL CORRESPONDENCE/FORMS
2.1 Welcome Letter to Client 3
2.2 Welcome Letter to Client - Medical Malpractice Case 4
2.3 Initial Client Letter Enclosing HIPAA and CFA 5
2.3.1 Alternative Initial Client Letter - Enclosing Packet 6
2.3.1.1 HIPAA-Compliant Medical Authorization 7
2.3.1.2 Contingent Fee Agreement 9
Practice Pointer - Contingent Fee Agreement 11
2.4 New Client Reminders 12
2.5 Thank You Letter to Referring Attorney 13
2.6 Letter Requesting Medical Records 14
Practice Pointer - Medical Records Fees 15
Practice Pointer - Electronic Ordering of Medical Records 16
2.7 Letter to Client Confirming Medical Records Ordered 17
2.8 Client Status Letter - Medical Malpractice Case 18
2.9 Client Status Letter - Construction Accident Case 19
2.1 Client Status Letter - Product Liability Case 20
2.11 Client Status Letter - Dram Shop 21
2.12 Client Status Letter - Tractor Trailer Accident Case 22
2.13 Client Status Letter - Unsafe Drug Case 23
2.14 Client Status Letter - Medical Device Case 24
2.15 Letter to Referral Attorney - Status 25
2.16 Letter to Medical Provider Requesting Disability Statement 26
2.17 Letter to Physician/Medical Provider Requesting Comprehensive Report - General 27
2.18 Letter to Physician/Medical Provider Requesting Comprehensive Report - Detailed 28
2.19 Letter to Employer Requesting Wage Loss Confirmation 29
2.2 Letter to Client Verifying Wage Loss Accuracy 31
2.21 Request for Preservation of Video/Digital Recordings 32
2.22 Letter Requesting News Videos, 911 Transcripts/Recordings, EMS Reports, Police Reports 33
Practice Pointer - Ordering News Videos - Time Limits 34
Practice Pointer - 911 Recordings - Time Limits/Subpoenas 34
2.23 Letter Requesting Ambulance/Emergency Responder Report 35
2.24 Spoliation Letter - Preservation of Evidence - Tractor Trailer Accident 36
2.25 Notice Letter to Governmental Unit 38
Practice Pointer - Form 95 39
2.25.1 Form 95 40
2.26 Notice Letter to Commonwealth of Pennsylvania 42
2.27 Notice Letter to Defendant - Motor Vehicle Case 43
2.28 Notice Letter to Defendant - Premises Liability Case 44
2.29 Letter to Liability Insurer to Verify Coverage - Premises Liability 45
2.3 Letter to OSHA Requesting Investigative Report - Freedom Of Information (FOIA) Request 46
2.31 Letter to FMSCA - Freedom of Information (FOIA) Request 47
2.32 Letter Requesting Weather Report 48
2.33 Letter to Investigator - Motor Vehicle Case 49
2.34 Letter to Investigator - Premises Liability Case 50
2.35 Letter to Investigator - Dram Shop Case 51
2.36 Rejection Letter - Client 52
2.37 Rejection Letter - Client - Referral Attorney 53
2.38 Rejection Letter - Referral Attorney 54
3. PRE-LITIGATION
3.1 Letter to Client Enclosing Unsafe Drug Questionnaire 55
3.1.1 Questionnaire for Unsafe Drug Claim 56
3.2 Letter to Expert Requesting Certificate of Merit 60
3.3 Letter to Treating Physician Requesting Expert Report 61
3.4 Letter to Expert (Physician Specialty) Requesting Expert Report - Medical Malpractice 62
3.5 Letter to Expert (Engineer) Requesting Expert Report - Product Liability 63
3.6 Letter to Expert (Toxicologist) Requesting Expert Report - Dram Shop 64
3.7 Letter to Expert (Bar Practices) Requesting Expert Report - Dram Shop 66
3.8 Letter to Expert (Economist) Requesting Expert Report 68
3.9 Letter Requesting Private Health Insurance Lien 69
3.1 ERISA Letter to Health Insurance Carrier 70
Practice Pointer - ERISA Status 71
3.11 Letter Requesting Workers' Compensation Records 72
3.12 Letter Requesting Workers' Compensation Lien 73
3.13 Letter Requesting Department of Public Welfare Lien 74
Practice Pointer - Medicare Liens 75
3.14 Letter to Medicare Requesting Lien Information 76
3.15 Letter to Client Enclosing Medicare Proof of Representation Form 77
3.15.1 Proof of Representation 78
3.16 Letter to Medicare Enclosing Executed Proof of Representation Form 79
3.16.1 Letter to Medicare Enclosing Engagement Letter 80
3.17 Notification Letter to Medicare Coordination of Benefits - Request Lien 81
3.18 Letter to Client - Enclosing Complaint for Verification 82
3.19 Referring Attorney Status Letter - Quarterly Report - Medical Malpractice 83
3.2 Referring Attorney Status Letter - Quarterly Report - Construction Accident 84
3.21 Referring Attorney Status Letter - Quarterly Report - Dram Shop 85
3.22 Referring Attorney Status Letter - Quarterly Report - Unsafe Drug 86
3.23 Referring Attorney Status Letter - Quarterly Report - Medical Device 87
4. PIP - PERSONAL INJURY PROTECTION
4.1 Letter of Representation to Client's Insurance Carrier 89
4.2 Request for Driver/Vehicle Information 90
4.3 Letter of Representation to Defendant's Insurance Carrier 94
4.4 Letter to Client Enclosing Insurance Application for Benefits 95
4.5 Letter to Medical Provider Providing PIP Carrier Information 96
4.6 Letter Forwarding Completed PIP Application to Insurance Carrier 97
4.7 Affidavit of No-Insurance 98
4.8 Letter Requesting PIP Carrier to Reimburse Private Health Insurer 99
4.9 Letter to Insurance Company Requesting Copies of Waivers 100
4.1 Letter to Client's Carrier Requesting PIP Payout Log 101
4.11 Letter to Insurance Company Requesting Exhaustion Letter 102
4.12 Letter to Client Enclosing Copy of Exhaustion Letter 103
4.13 Complaint for First Party Benefits and Bad Faith 104
5. COMPLAINTS/INITIAL FILINGS & SERVICE
5.1 Praecipe for Writ of Summons 109
Practice Pointer - Rule 4003.8 - Pre-Complaint Discovery 110
5.2 Praecipe for Writ of Summons in Aid of Preparing Complaint 111
5.2.1 Notice of Deposition in Aid of Preparing Complaint 112
5.3 Product Liability Complaint - Defective Design 114
5.4 Product Liability Complaint - Crashworthiness 127
5.5 Medical Malpractice Complaint 138
5.5.1 Certificate of Merit - Medical/Professional Malpractice 153
5.6 Unsafe Drug Complaint 156
5.7 Unsafe Medical Device Complaint 166
Practice Pointer - Unsafe Medical Device Complaint 171
5.8 Motor Vehicle Accident Complaint - Intersectional Collision 172
5.9 Motor Vehicle Accident Complaint - Arbitration - Rear End Collision 178
5.1 Tractor Trailer Accident Complaint 185
5.11 Premises Liability Complaint - Defective Sidewalk 192
5.12 Premises Liability Complaint - Snow and Ice 196
5.13 Construction Accident Complaint 201
5.14 Dram Shop Complaint 218
5.15 Complaint Specific Forms 229
5.15.1 Philadelphia County Civil Cover Sheet 230
5.15.2 Montgomery County Civil Cover Sheet 234
5.15.3 Delaware County Civil Cover Sheet 235
5.15.4 Allegheny County Civil Cover Sheet 237
5.15.5 Chester County Civil Cover Sheet 241
5.15.6 Luzerne County Civil Cover Sheet 243
5.15.7 Bucks County Civil Cover Sheet 244
5.15.8 Westmoreland County Civil Cover Sheet 246
5.15.9 York County Civil Cover Sheet 248
5.15.10 Berks County Civil Cover Sheet 249
5.16 Notice to Defend - Philadelphia County (English/Spanish) 250
Practice Pointer - Notice to Defend 251
5.17 Letter to Court Enclosing Complaint for Filing 252
5.18 Letter to Sheriff Enclosing Complaint for Service 253
Practice Pointer - Original Service Forms 254
5.18.1 Philadelphia County Sheriff's Service Form 255
5.18.2 Montgomery County Sheriff's Service Form 256
5.18.3 Delaware County Sheriff's Service Form 257
5.18.4 Allegheny County Sheriff's Service Form 260
5.18.5 Chester County Sheriff's Service Form 264
5.18.6 Luzerne County Sheriff's Service Form 267
5.18.7 Bucks County Sheriff's Service Form 270
5.18.8 Westmoreland County Sheriff's Service Form 271
5.18.9 York County Sheriff's Service Form 274
5.18.10 Berks County Sheriff's Service Form 276
5.19 Letter to Process Server Enclosing Complaint for Service 277
5.2 Letter to Counsel Enclosing Complaint for Service with Acknowledgment of Service 278
5.20.1 Acknowledgment of Service 279
5.21 Letter to Defendant Serving Complaint via Certified and Regular Mail 280
5.21.1 Affidavit of Service 281
5.22 Letter to Court Enclosing Affidavit for Filing 282
5.23 Stipulation to Dismiss Party 283
5.24 Plaintiff's Memorandum of Law in Response to Defendant's Petition to Transfer Venue 285
5.25 Preservation/Spoliation - Truck Case 294
6. DISCOVERY
6.1 Philadelphia County Standard Plaintiff's Interrogatories - Motor Vehicle 295
6.2 Philadelphia County Standard Plaintiff's Interrogatories - Premises Liability 309
Practice Pointer - Objections to Standard Form Discovery 318
6.3 Plaintiff's Interrogatories - Premises Liability/Ice and Snow 320
6.4 Plaintiff's Interrogatories - Unsafe Drug 329
6.5 Plaintiff's Interrogatories - Unsafe Medical Device 340
6.6 Plaintiff's Interrogatories - Medical Malpractice - Physician 352
6.7 Plaintiff's Interrogatories - Medical Malpractice - Hospital 369
6.7.1 Plaintiff's Cooper Interrogatories to Defense Expert 383
6.8 Philadelphia County Standard Defendant's Request for Production of Documents 388
6.9 Philadelphia County Standard Plaintiff's Request for Production of Documents 392
6.1 Request for Production of Documents - Unsafe Drug 396
6.11 Request for Production of Documents - Unsafe Medical Device 412
6.12 Request for Production of Documents - Medical Malpractice 430
6.13 Request for Production of Documents - Product Liability 433
6.14 Request for Admissions 437
6.14.1 Request for Admissions - Premises Liability - Snow and Ice 441
6.15 Letter to Client Enclosing Defense Counsel Interrogatories 446
6.16 Letter to Client Enclosing Draft Response to Interrogatories 447
6.17 Letter Serving Discovery Requests 448
6.18 Letter to Opposing Counsel Regarding Overdue Answers to Discovery 449
6.19 Letter to Opposing Counsel Requesting More Specific Answer to Discovery 450
6.2 Letter to Client Regarding Scheduled Defense Medical Examination 451
6.21 Letter to Client Confirming Deposition Date/Time 452
6.22 Deposition Notice - Defendant 453
6.23 Deposition Notice - Corporate Designee 455
6.24 Deposition Notice - Physician/Expert Witness for Trial 457
6.25 Deposition Notice - Videotaped Deposition 459
6.26 Letter Serving Deposition Notice 461
6.27 Letter to Client Regarding Additional Documents Requested During Deposition 462
7. MOTIONS
7.1 Letter to Court Enclosing Motion for Filing 463
Practice Pointer - Motion Court Cover Sheets 464
7.1.1 Philadelphia County Motion Cover Sheet 465
7.1.2 Montgomery County Motion Cover Sheet 467
7.1.3 Delaware County Motion Cover Sheet 468
7.1.4 Allegheny County Motion Cover Sheet 472
7.1.5 Chester County Motion Cover Sheet 476
7.1.6 Luzerne County Motion Cover Sheet - No Cover Sheet
7.1.7 Bucks County Motion Cover Sheet 485
7.1.8 Westmoreland County Motion Cover Sheet 487
7.1.9 York County Motion Cover Sheet - No Cover Sheet
7.1.10 Berks County Motion Cover Sheet 491
7.2 Motion to Amend Complaint 495
7.3 Response to Motion to Dismiss 507
7.4 Motion to Remand - Citizenship 513
Practice Pointer - Motion to Remand 516
7.5 Letter to Defendant Advising of Intent to File Motion for Default Judgment 517
7.5.1 Notice of Intent to File for Default 518
7.6 Motion to Consolidate 519
7.7 Motion for Extraordinary Relief 527
7.8 Motion to Compel Discovery 531
7.9 Motion to Compel More Specific Answers to Discovery 538
7.1 Motion to Strike Objections and Compel Answers 546
7.11 Motion to Compel Deposition 553
7.12 Motion to Compel Expert Report 560
7.13 Motion to Compel Inspection 567
7.14 Motion to Award Delay Damages 574
7.16 Motion to Withdraw as Counsel 582
Practice Pointer - Motion to Withdraw as Counsel 587
7.17 Response to Motion for Summary Judgment 588
7.18 Motion to Enforce Settlement 596
8. MEDIATION/ARBITRATION
8.1 Letter to Counsel to Appoint Defense Arbitrator 599
8.2 Letter to Selected Plaintiff's Arbitrator 600
8.3 Letter to Proposed Single Arbitrator 601
8.4 Letter to Defense Counsel to Appoint Neutral Arbitrator 602
8.5 Letter to Client Confirming Arbitration Hearing 603
8.6 Arbitration Memorandum 604
8.7 Itemization of Medical Treatment 606
8.8 Letter to Defense Counsel Enclosing Arbitration Package 607
8.9 Letter to Counsel Regarding Agreements Made 608
8.1 Letter to Client Regarding Binding High-Low Arbitration and Trial 609
8.11 Letter to Client Enclosing Arbitration Decision 610
8.12 Letter to Client Regarding Arbitration Appeal Process 611
8.12.1 Notice of Appeal from Award of Board of Arbitrators 612
8.13 Letter to Court Enclosing Appeal from Arbitration Award 613
8.14 Motion to Remove Case from Arbitration 614
8.15 Letter to Client Explaining Mediation Process 616
8.16 Letter to Mediator Enclosing Plaintiff's Mediation Memo 617
8.17 Mediation Memorandum - Construction Accident 618
8.18 Mediation Memorandum - Dram Shop 629
8.19 Mediation Memorandum - Tractor Trailer Accident 634
8.2 Letter to Client Enclosing Defense Mediation Memo 643
9. TRIAL
9.1 Letter to Client Regarding Trial Date 645
9.2 Letter Enclosing Trial Submissions 646
9.3 Voir Dire - Medical Malpractice 647
9.4 Voir Dire - Product Liability 651
9.5 Pre-Trial Memorandum 655
9.6 Plaintiff's Offer of Deposition Testimony 660
9.7 Stipulation Regarding Medical Bills 661
9.8 Stipulation to Dismiss Party 662
9.9 Plaintiff's Motion for Directed Verdict by Plaintiff 664
9.1 Jury Questions 665
9.11 Motions in Limine/Response to Motions in Limine
9.11.1 Abortions/OBGYN History 668
9.11.2 Alcohol Abuse 673
9.11.3 Alcohol Use 679
9.11.4 Alcohol/Drug/Tobacco Use 684
9.11.5 Chlamydia 689
9.11.6 Citizenship 694
9.11.7 Conviction/Incarceration 699
9.11.8 Cumulative/Unqualified Expert 704
9.11.9 Diabetes 713
9.11.10 Domestic, Sexual Abuse  
9.11.11 DUI 724
9.11.12 Hearsay 730
9.11.13 Hepatitis 735
9.11.14 Late Expert Identification 740
9.11.15 Prior Abuse and Psychiatric History 746
9.11.16 Response in Opposition to Motion in Limine 752
9.11.17 Seatbelt Use 757
9.11.18 Supplemental Defense Expert Report 763
9.11.19 Irrelevant Testimony 769
9.11.20 Response re Contradictory Reports 776
9.12 Letter to Defense Expert Physician - Document Subpoena for Trial 787
9.12.1 Subpoena Ad Testicandum and Duces Tecum for Trial 788
9.12.2 Document Subpoena Addendum 790
9.13 Letter to Plaintiff's Expert Witness for Appearance at Trial 792
9.14 Notice to Attend 793
9.15 Notice to Attend - Doctor 794
10. SETTLEMENT
10.1 Demand Letter - Dog Owner Liability 797
10.2 Demand Letter - Construction Accident Case 800
10.3 Demand Letter - Dram Shop 801
10.4 Letter to Client Confirming Rejection of Settlement Offer 803
10.5 Third-Party Bad Faith Letter 804
10.6 Letter to Court Requesting Settlement Conference 805
10.7 Settlement Memorandum - Medical Malpractice 806
10.8 Settlement Memorandum - Motor Vehicle Accident 812
10.9 General Release 815
10.1 Pro Tanto/Dollar Release 818
Practice Pointer - Releases 820
10.11 Letter to Healthcare Requesting Compromise 821
10.12 Letter to Court Advising That Case Has Settled 822
10.13 Letter to Defense Insurance Company Confirming Settlement 823
10.14 Letter Forwarding Release and Settlement Documents to Client 824
10.15 Statement of Settlement and Distribution 825
10.16 Affidavit of No Child Support Lien 826
Practice Pointer - Child Support Obligations 827
10.17 Letter to Opposing Counsel Enclosing Signed Release 828
10.18 Letter to Medicare Confirming Lien and Transmitting Payment 829
10.19 Letter Forwarding Payment to Healthcare Provider 830
10.2 Petition to Approve Settlement and Distribution of Wrongful Death and Survival Actions 831
10.21 Order to Settle, Discontinue and End 836
10.22 Letter Forwarding Settlement Check to Client 837
10.23 Letter Forwarding Referral Fee to Referral Attorney 838
11. UM/UIM
11.1 Notification of UIM Claim 839
11.2 Letter to UIM Carrier Providing Proof of Claim 840
11.3 Underinsured Motorist Bad Faith Letter 841
11.4 Letter to Insurance Carrier Requesting Appointment of Defense Counsel 842
11.5 Post-Koken Letter to Insurance Company Requesting Arbitration 843
Practice Pointer - Koken 844
11.6 Letter to Client Advising of UM/UIM Hearing Award 845
11.7 Letter to Client Advising of UM/UIM Arbitration Hearing 846
12. WORKER'S COMPENSATION
12.1 Standard Contingent Fee Agreement 847
12.2 Initial Letter to Client Enclosing Fee Agreement and HIPAA 848
12.3 Letter of Representation to Insurance Company 849
12.4 Entry of Appearance 850
12.5 Letter to Employer re Electronic Filing of Claim Petition 851
12.6 Letter to PA Bureau of Worker's Compensation Enclosing Claim Petition for Filing 852
12.7 Letter to PA Bureau of Worker's Compensation Requesting Copy of Bureau File 854
  Practice Pointer - Worker's Compensation Website Information 855
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