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Automobile Law Section

Information for members of PaTLA's Automobile Law Section

The "List"--2 pgs., List of activities used for limited tort clients; Created by Robert J. Mongeluzzi; Originally run in the Philadelphia Trial Lawyers Association's The Verdict ;Submitted by Joanne Fishman of Philadelphia. 8/24/2004; Click here for document

Household Exclusion -- 5 pgs., Memorandum opinion & order from Erie County Common Pleas Judge John A. Bozza setting aside the household exclusion based upon the language in the UIM provisions of the State Farm policy. Posted 8/19/2004. Submitted by Elliot Segal of Erie and Scott Cooper of Harrisburg.

Household Exclusion PT II -- 14 pgs., Opinion and order from Washington County by Aribtrator Stephen McCloskey finding coverage, rejecting the household exclusion defense. This “scholarly” opinion addresses Colbert and all of the other issues that have been handed down both prior and subsequent thereto. Posted 8/20/2004. Submitted by Pat Loughren of Pittsburgh.

Opinion-Damages in wrongful death action -- 14 pgs., Opinion from Judge Turgeon of Dauphin Cty. from Aug. 10, 2004 that includes analysis of damages in a Wrongful Death and Survival Action. Although it was an auto accident case, liability was admitted and the issues addressed in the motion for a new trial [which was granted] are applicable to med mal cases also. Posted 8/12/2004. Submitted by Luther Milspaw of Harrisburg.

Precluding evidence of minor impact defense -- 5 pg.-Motion in limine and 10-pg. Brief in support of Motion to preclude introduction of photographs and evidence regarding minor impact when the expert has not been retained to testify as to those issues; posted 7/21/2004. Prepared by Nina Milovanovich of Lancaster. 

Frye/Daubert Update -- 6 pgs., Within the last two years, there have been a few important appellate cases decided in the the state and federal courts in the Commonwealth of Pennsylvania which have discussed the important Frye and Daubert decisions; posted 7/13/2004. Prepared by Scott B. Cooper of Harrisburg. click here for the article

Motion In Limine to Preclude Defendant's Expert Testomony -- 11 pgs., Motion In Limine and Brief to Exclude Bioengineer in MIST Case; posted 6/24/2004. Submitted by PaTLA member Gerald Spivack of Philadelphia. click here for motion & brief

Exculpatory Release Brief -- 8 pgs., For injuries sustained while horseback riding. Note: Brief is 2-3 years old and would need updating; posted 6/17/2004. Submitted by PaTLA member Joseph J. Liotta III of Franklin. click here for brief

Brief accompanying motion to compel expert discovery -- 33 pgs., copntains detailed analysis of numerous arguments; posted 6/11/2004. Submitted by PaTLA member Nina Milovanovich of Lancaster. click here for brief

Waddell Signs Information -- Contains information about Nonorganic physical signs in low-back pain. Updated 6/8/2023  
Cross for Waddell - Submitted by Joseph DeSimone of Bensalem Cross 
Link to article on Corrected Use of Waddell Signs Article




Residency Brief in UM/UIM Cases -- 12-page brief, posted 5/25/2004. Submitted by PaTLA member Amy Coryer-Host of Harrisburg. click here for brief

Expert discovery opinion --
(1) Lancaster Judge David Ashworth's 7-pg. opinion and order of July 19, 2023 denying defendant's motion for stay in Criswell v. Boll, posted 8/16/2004. Submitted by PaTLA member Nina Milovanovich of Lancaster. Click here for opinion
(2) Lancaster Common Pleas Judge's 22-pg. opinion and order denying doctor's motion for protective order, posted 4/23/2004. Submitted by PaTLA member Nina Milovanovich of Lancaster. Click here for opinion

The Missing Witness: The DME Doctor -- Article by Dale Larrimore of Philadelphia (copyright Philadelphia Trial Lawyers and Dale Larrimore), posted 4/19/2004. What remedies are available of plaintiffs counsel when defense chooses not to call the DME doctor as a witness at trial. click here for article

Brief on Causation Defense -- Brief in support of motion to preclude defense prepared by Joe Nypaver of Altoona. click here for brief 

Forum non conveniens  -- Brief prepared PaTLA member Evan Aidman of Ardmore on plaintiff’s memorandum of law in opposition to defendant’s petition to transfer venue. click here for memo

Household Exclusion -- Brief prepared by PaTLA member Patrick J. Loughren of Pittsburgh on household exclusion in a case pending before Superior Court. The facts are identical to Prudential vs. ColbertClick here for brief

Motion Practice Article -- By PaTLA Member Dale Larrimore of Philadelphia. On Oct. 24, 2003, the Pennsylvania Supreme Court adopted a Per Curiam Order, establishing new requirements for the determination of Preliminary Objections, Motions for Judgment on the Pleadings, Motions for Summary Judgment, Petitions and Motions in the Courts of Common Pleas throughout Pennsylvania... Click here for article

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