Library of Pennsylvania Personal Injury Forms

Transcription

1 Brochure More information from Library of Pennsylvania Personal Injury Forms Description: 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... Contents: 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 Alternative Initial Client Letter - Enclosing Packet HIPAA-Compliant Medical Authorization 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 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 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 Form 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 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 Proof of Representation 3.16 Letter to Medicare Enclosing Executed Proof of Representation Form 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

3 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 Pre-Complaint Discovery 5.2 Praecipe for Writ of Summons in Aid of Preparing Complaint 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 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 Philadelphia County Civil Cover Sheet Montgomery County Civil Cover Sheet Delaware County Civil Cover Sheet Allegheny County Civil Cover Sheet Chester County Civil Cover Sheet Luzerne County Civil Cover Sheet Bucks County Civil Cover Sheet Westmoreland County Civil Cover Sheet York County Civil Cover Sheet 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 Philadelphia County Sheriff's Service Form Montgomery County Sheriff's Service Form Delaware County Sheriff's Service Form Allegheny County Sheriff's Service Form Chester County Sheriff's Service Form Luzerne County Sheriff's Service Form Bucks County Sheriff's Service Form Westmoreland County Sheriff's Service Form York County Sheriff's Service Form 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 Acknowledgment of Service

4 5.21 Letter to Defendant Serving Complaint via Certified and Regular Mail 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 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 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 Philadelphia County Motion Cover Sheet Montgomery County Motion Cover Sheet Delaware County Motion Cover Sheet Allegheny County Motion Cover Sheet Chester County Motion Cover Sheet Luzerne County Motion Cover Sheet - No Cover Sheet Bucks County Motion Cover Sheet Westmoreland County Motion Cover Sheet York County Motion Cover Sheet - No Cover Sheet 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 Notice of Intent to File for Default 7.6 Motion to Consolidate 7.7 Motion for Extraordinary Relief 7.8 Motion to Compel Discovery

5 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 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 Abortions/OBGYN History Alcohol Abuse Alcohol Use Alcohol/Drug/Tobacco Use Chlamydia Citizenship Conviction/Incarceration Cumulative/Unqualified Expert Diabetes Domestic, Sexual Abuse DUI Hearsay Hepatitis Late Expert Identification Prior Abuse and Psychiatric History

6 Response in Opposition to Motion in Limine Seatbelt Use Supplemental Defense Expert Report Irrelevant Testimony Response re Contradictory Reports 9.12 Letter to Defense Expert Physician - Document Subpoena for Trial Subpoena Ad Testicandum and Duces Tecum for Trial 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 Letter to Healthcare Requesting Compromise Letter to Court Advising That Case Has Settled Letter to Defense Insurance Company Confirming Settlement Letter Forwarding Release and Settlement Documents to Client Statement of Settlement and Distribution Affidavit of No Child Support Lien Practice Pointer - Child Support Obligations Letter to Opposing Counsel Enclosing Signed Release Letter to Medicare Confirming Lien and Transmitting Payment Letter Forwarding Payment to Healthcare Provider 10.2 Petition to Approve Settlement and Distribution of Wrongful Death and Survival Actions Order to Settle, Discontinue and End Letter Forwarding Settlement Check to Client 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

7 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 Ordering: Order Online - Order by Fax - using the form below Order by Post - print the order form below and send to Research and Markets, Guinness Centre, Taylors Lane, Dublin 8, Ireland.

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