PRODUCTION OF SECURITY ACCIDENT SCENE VIDEO WITHOUT DELAY
Attached is a Memorandum of Law that I recently submitted in a slip and fall case in an attempt to secure the security video evidence of the fall before my client’s deposition. The defense argued that it should not be produced prior to the plaintiff’s deposition because of its impeachment value. The court focused on the word “solely” in Rule 26 and ordered the production before the plaintiff’s deposition. UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA JAMIE E. MASSUNG, Plaintiff, vs. DOLGENCORP, LLC t/d/b/a DOLLAR GENERAL and DOLLAR GENERAL, Defendants. CASE NO. 2:19-CV-01081-PLD PLAINTIFF’S MEMORANDUM IN SUPPORT OF PRODUCTION OF SECURITY ACCIDENT SCENE VIDEO WITHOUT DELAY Plaintiff
STAIR-RELATED INJURIES
Stairs can be dangerous especially for the very young and senior citizens. The consequences of a fall from the top of the steps to a story lower can be devastating. Even a fall at the bottom of the steps can cause a serious injury. According to the April, 2018 American Journal of Emergency Medicine, over 1 million patients are treated in United States Emergency Rooms for stair-related falls each year. According to the National Safety Council’s Injury Facts, falls are the third leading cause of preventable deaths and the first leading cause of preventable nonfatal injuries in the United States. The noted
PERSONAL UMBRELLA
If you want the maximum protection possible from your automobile insurance policy, consider asking your insurance agent for a quote for a personal umbrella policy. This coverage typically insures you for an additional $1,000,000 in liability, uninsured and underinsured motorist coverage. While many people are not currently in the market for this amount of insurance coverage, it is a fairly inexpensive way to protect your own future earning capacity against accidental loss in a motor vehicle accident. A typical personal umbrella policy requires you to carry $500,000 in liability, uninsured, underinsured, and homeowner’s coverage. For an additional premium per year,
THE VANISHING REMEDY IN CAR ACCIDENTS
If you have been the victim of an automobile accident, you have certain rights which are guaranteed by law. Basically, you have the right to be returned to the same condition that you were in before the accident occurred. ¨ You have the right: To the very best medical care available with no out-of-pocket expense to you. ¨ You have the right: To recover any lost wages or loss of earning capacity which may have resulted from the incident. ¨ You have the right: To be compensated for any pain, suffering and inconvenience from the incident. ¨ You have the right: To an equitable
CAR ACCIDENTS, HEART & LUNG BENEFITS AND SUBROGATION
This office ended the unjust subrogation of Heart and Lung from police officers and other public safety personnel involved in Pennsylvania auto accidents. In 1993, when Workers’ Compensation benefits were again subjected to subrogation in auto accident cases, governments began to claim subrogation rights from Heart & Lung benefits paid to public safety personnel. Heart and Lung Act benefits were created by the Legislature to provide full payment of salary to police officers, firemen and other law enforcement officers who are injured in the performance of their duties and by reason thereof are temporarily incapacitated from performing their duties. These benefits