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COMMONWEALTH OF PENNSYLVANIA

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PA Bulletin, Doc. No. 04-1358b

[34 Pa.B. 3884]

[Continued from previous Web Page]

ACTIONS FOR WRONGFUL DEATH

Rule 2205. Notice to Persons Entitled to Damages.

   (a)  The notice prescribed in Pa. R.C.P. 2005 shall name the decedent and state the court, term and number of the action. If the person to whom it is addressed objects to the authority of the plaintiff to maintain the action, such person may petition the court to remove the plaintiff and to substitute as a new plaintiff any person entitled by law to recover damages in the action or the personal representative of the decedent.

   (b)  An affidavit of service by registered mail of such notice shall be filed in the office of the Clerk of Judicial Records within five (5) days after service or as soon thereafter as the registered return receipt, signed by the person to whom it is addressed, is returned to the plaintiff.

JOINDER AND SUBSTITUTION OF PARTIES

Rule 2227. Compulsory Joinder.

   Application under Pa. R.C.P. 2227(b) to join an unwilling co-owner of a solely joint cause of action as a defendant or an involuntary plaintiff in an action shall be by petition and rule to show cause; the petition shall set forth the substantive grounds for such joinder.

Rule 2232. Defective Joinder. Change of Parties.

   (a)  In any case in which the defendant is required by Pa. R.C.P. 2232(a) to give notice of the pendency of an action to recover damages for any injury, not resulting in death, inflicted upon the person of a husband or wife or a minor, such notice shall be given by registered mail within twenty (20) days after service upon the defendant of the complaint.

   (b)  The notice shall state the court, term, and number of the action, the parties thereto, and its nature, and that the person to whom it is addressed is required to join therein within twenty (20) days after the receipt of such notice or his or her cause of action will be barred and the action will proceed without him or her.

   (c)  Application under Pa. R.C.P. 2232(b) to drop from the record a party who has been misjoined or against whom no claim for relief is asserted in the action shall be by petition and rule to show cause directed to all other parties. Alternatively, a defendant in an action against whom no claim for relief is asserted may seek dismissal of the action as it pertains to him by demurrer.

   (d)  An application under Pa. R.C.P. 2232(c) to join as a party any other person who could have joined or have been joined as such in the action shall be by petition and rule to show cause.

Rule 2253. Extension of Time Limits to Join Additional Defendants.

   Application to the court for an extension of time in which to file a praecipe or compliant to join an additional defendant shall be by motion, duly verified, if facts not appearing of record are averred. The court, if it so chooses, may act upon said motion immediately upon its presentation.

Rule 2352. Praecipe for Rule for Substitution of Successor.

   The praecipe filed with the Clerk of Judicial Records pursuant to Pa. R.C.P. 2352(b) to show cause why the successor should not be substituted as a party shall set forth the last known address of the successor. Said address shall then be set forth in the rule.

Rule 2353. Service by Publication of Rule Concerning Substitution of Parties.

   Service by publication of the rule to show cause why the successor should not be substituted as a party shall be made by publishing said rule, together with a notation of the nature and number of the action in which the rule is issued and the relief demanded, and that, if said successor does not appear in this court within twenty (20) days after the last publication, said rule may be made absolute in his absence. Said publication shall be made as prescribed by Lacka. Co. R.C.P. 440(c).

EXECUTION AND ENFORCEMENT OF JUDGMENTS

Rule 2959. Return Day for Rules Pertaining to Judgment by Confession.

   The return day for a rule to show cause why relief from a judgment by confession should not be granted shall be determined in accordance with Lacka. Co. R.C.P. 206 unless the court directs a different return day at the time the petition is presented.

Rule 3128. Notice of Resale of Personal Property by Sheriff.

   No resale shall be scheduled without first giving notice to all bidders who appeared at the originally scheduled sale. The resale date cannot be sooner than seventy-two (72) hours from the original sale date.

Rule 3129.1. Notice of Sale. Real Property.

   (a)  Whenever a sale of real property is governed by Pa. R.C.P. 3129.1, all handbills, written notices, and publications shall include, as part of the location of the property, a street address.

   (b)  Street address is defined as the street number and street name where a number exists. Where no street number exists, the street address is defined as the land and/or portion of land between the nearest two street numbers and/or intersecting streets which do exist and the street name.

Rule 3130. Notice of Sale of Securities.

   When notice to a defendant of the sale of securities is required by Pa. R.C.P. 3130, such notice may be given by the sheriff by ordinary mail, first class postage prepaid, addressed to the defendant at his or her last known residence and by the posting of handbills in the sheriff's office, which mailing and which handbills shall contain a description of the securities to be sold, the name and place of the business of the broker through whom such sale will be made, and the date when the securities will be offered for sale.

Rule 4000. Motion Practice for Discovery and Scheduling Matters.

   (a)  Any court order regarding discovery, including orders involving sanctions and pre-trial deadlines for the completion of discovery, the exchange of expert reports, the filing of case dispositive motions, and other scheduling matters prior to the filing of a Certificate of Readiness, which a party seeks pursuant to any provisions of Pa. R. Civ. P. 4001 through 4020 or any provisions of the Rules of Civil Procedure of the court of common pleas of Lackawanna County pertaining to discovery or scheduling orders shall be sought by the presentation of a motion in compliance with the provisions of Lacka. Co.R.C.P. 206.1, 4000.1 and 4019.

Rule 4000.1. Motion for Presentation before a Special Trial Master.

   (a)  Presentation to the court of a motion pursuant to Lacka. Co. R.C.P. 4000 shall in all circumstances be initially presented to and decided by a Special Trial Master appointed by the Court who shall follow the same procedures set forth in Lacka. Co. R.C.P. 4000.

   (b)  An order of the Special Trial Master may be appealed de novo by presentation of an appeal motion to the court, together with proof of payment of the Clerk of Judicial Records of an appeal cost of an amount to be set by the court from time to time. The appeal motion shall be filed within ten days of the order of the Special Trial Master and shall be considered by the court pursuant to Lacka. Co. R.C.P. 4000.

   (c)  Motions practice before the Special Trial Master shall be conducted in compliance with Lacka. Co. R.C.P. 206.1 and the Master shall hear motions in the Lackawanna County courthouse on Monday and Thursday at 9:30 a.m., unless otherwise agreed by counsel and the Master or by order of the Master.

   (d)  Presentation of a motion in any case in which the Special Trial Master is involved shall be presented to the court rather than through the procedure set forth in this Rule.

Rule 4007.1. Objections During Oral Depositions; Speaking Objections

   (a)  Counsel making an objection during an oral deposition shall state the word, ''objection,'' and briefly state the legal basis for the objection without argument.

   (b)  If there is to be any discussion, amplification or argument on the objection, the witness shall be excused from the room at the request of any party. Such discussion, amplification or argument shall be made on the record unless all parties agree otherwise.

   (c)  An instruction by counsel to a witness that the witness shall not answer a question shall be sufficient basis for other counsel to suspend the deposition and present the question for resolution under Lacka. Co. R.C.P. 4012. Every reasonable effort shall be made to resolve the matter under Lacka. Co. R.C.P. 4012 during the deposition.

Rule 4012. Protective Orders.

   (a)  If a deposition is being taken within the Lackawanna County courthouse and demand is made for its suspension, a motion for a protective order under Pa. R.C.P. 4012(b) shall be made immediately to the Special Trial Master for Discovery, if available, in which event the motion may be oral and heard. If the Special Trial Master for Discovery is not available, the motion for a protective order may be oral and shall be presented to the Special Trial Master for Discovery within forty-eight (48) hours of the suspension of the taking of the deposition. Otherwise, the objecting party or deponent will be deemed to have waived the objection and the taking of the deposition shall be immediately resumed on notice to all interested parties and the deponent.

   (b)  In all other cases, the motion must be in writing and presented to the Special Trial Master for Discovery as provided in Lacka. Co. R.C.P. 4000 herein except that, upon failure to present such motion within fifteen (15) days of the suspension of the taking of the deposition, the objecting party or deponent will be deemed to have waived the objection whereupon the taking of the deposition shall be resumed on reasonable notice to all interested parties and the deponent.

Rule 4013. Stay of Proceedings by Discovery.

   (a)  If a party seeks a stay of discovery pending disposition of a motion for a protective order, the basis for such a request shall be stated with particularity in the motion and shall be called to the attention of the Special Trial Master for Discovery at the time of presentation of the motion.

   (b)  If during the pendency of an action a party desires a general stay of the proceedings for purposes of deposition and discovery, the court upon motion and for cause shown may enter an appropriate order staying the proceedings.

Rule 4017.1. Objections During Videotape Depositions.

   (a)  Counsel making an objection during a videotape deposition shall simply state ''objection'' upon which the video operator shall stop the videotape. Further argument or discussion shall be made off camera but on the written transcript.

   (b)  During any discussion or argument, the witness shall be excused from the room at the request of any party.

   (c)  An instruction by counsel to a witness that the witness shall not answer a question shall be sufficient basis for other counsel to suspend the deposition and present the question for resolution under Lacka. Co. R.C.P. 4012. Every reasonable effort shall be made to resolve the matter under Lacka. Co. R.C.P. 4012 during the deposition.

Rule 4019. Petitions for Sanctions before a Special Trial Master.

   (a)  Any party seeking sanctions pursuant to Pa. R.C.P. 4019 for violation of an order of the Special Trial Master pursuant to Lacka. Co. R.C.P., of an order of the court pursuant to Lacka. Co. R.C.P. 4000, or otherwise pursuant to Pa. R.C.P. 4019 shall, in all circumstances, initially do so by motion to the Special Trial Master pursuant to Lacka. Co. R.C.P. 4000.1.

   (b)  Any order of the Special Trial Master granting or denying a sanction may be appealed de novo by presentation of an appeal motion to the court, together with proof of payment to the clerk of Judicial Records of an appeal cost of an amount to be set by the court from time to time, and said appeal motion shall be considered by the court pursuant to Lacka. Co. R.C.P. 4000.

Rule 4020. Use of Deposition at Trial.

   (a)  If all or part of a deposition is offered in evidence as substantive evidence of its contents because of the unavailability of the witness, whether or not a party, the counsel offering said deposition shall first submit to the court such evidence as will enable the court to find that the appropriate facts under Pa. R.C.P. 4020(a)(3) exist.

   (b)  An application to the court to use all or part of a deposition of a witness, whether or not a party, as substantive evidence pursuant to Pa. R.C.P. 4020(a)(3) shall be made upon reasonable notice to all parties.

Rule 4021. Assignment of Judge for Discovery Proceedings.

   In an appropriate case, the court upon its own motion or upon motion of any party may elect to designate one judge to direct all discovery proceedings in that case and to hear and rule upon all motions and petitions relating to discovery. Such designation shall be made by the President Judge.

FORM 1

Court of Common Pleas of Lackawanna CountyFOR CLERK OF JUDICIAL RECORDS USE
ONLY
               Civil Cover SheetDocket Number:
 
PLAINTIFF'S NAMEDEFENDANT'S NAME
PLAINTIFF'S ADDRESSDEFENDANT'S ADDRESS
PLAINTIFF'S NAME DEFENDANT'S NAME
PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS
PLAINTIFF'S NAME DEFENDANT'S ADDRESS
PLAINTIFF'S ADDRESS DEFENDANT'S ADDRESS
TOTAL NUMBER OF PLAINTIFFS TOTAL NO. OF DEFENDANTS COMMENCEMENT OF ACTION
Complaint      Petition Action      Notice of Appeal
Writ of Summons      Transfer from other jurisdictions
AMOUNT IN CONTROVERSY In Excess of Jurisdictional Amount?
Yes       No
COURT PROGRAMS
Arbitration      Jury      Non-Jury      Petition      Minor Court Appeal
Statutory Appeals       Other:
CASE TYPE AND CODE (SEE INSTRUCTIONS)
STATUTORY BASIS FOR CAUSE OF ACTION (SEE INSTRUCTIONS)
REMARKS:
TO THE CLERK OF JUDICIAL RECORDS:
Please enter my appearance on behalf of Plaintiff;
Papers may be served at the address set forth below:
NAME OF PLAINTIFF'S ATTORNEY OR PRO SE
PLAINTIFF
ADDRESS
PHONE NUMBER FAX NUMBER
SUPREME COURT IDENTIFICATION NO. E-MAIL ADDRESS
SIGNATURE DATE

LACKAWANNA COUNTY COURT OF COMMON PLEAS CIVIL COVER SHEET INSTRUCTIONS

   An attorney or pro se party filing a document commencing any type of civil action shall file a properly completed Civil Cover sheet. Copies of the Civil Cover Sheet shall be attached to service copies of the document commencing the action.

PARTIES

   Regardless of the type of action, the initiating party or parties shall be designated as Plaintiff or Plaintiffs and the responding party or parties shall be designated as Defendant or Defendants. Names of individuals shall be listed as last name, first name, middle initial. Full names of agencies and corporations shall be provided. Spouses shall be listed as separate parties unless the claim of one spouse is limited to a claim for consortium in which case the designation, et ux. or et vir shall be used. Where there are more than three plaintiffs or defendants, a supplemental form listing the additional parties shall be attached to the Cover Sheet.

   The section labeled ''Remarks'' is for procedural matters only. These may include such matters as related cases where consolidation might be advisable. Matters such as expected difficulty with service of process or the status of settlement discussions do not belong in this section.

CASE TYPE AND CODE DESIGNATION

FAM Family Court
FAM/CUSTCustody
FAM/DIVDivorce
MCT Minor Court Appeal
LAG Local Agency Appeal
LAG/MVSMotor Vehicle Suspension
LAG/ZBZoning Board Appeal
LAG/O Other Agency Appeals
PCP/VALValidation of Tax Title
PCP/TS Tax Sale
PCP/OBJObjection to Tax Sale
PCP/PRIVPetition to set aside private sale
PCP/O Other Proceedings commenced by Petition
CJ Confession of Judgment
CLASS Class Action
CNT Contract cases
DECL Declaratory Judgment
COND/DT Condemnation/Declaration of Taking
TORT/AB Assault & Battery
TORT/LS Libel & Slander
TORT/FR Fraud
TORT/BF Tort Bad Faith
TORT/WCP Wrongful Use of Civil Process
TORT/O Other torts
NGL/MVA Motor Vehicle Accident
NGL/NF No-Fault Benefits
NGL/PI Personal Injury
NGL/PREM Premises Liability
NGL/PROD Product Liability
NGL/TT Toxic Tort
NGL/O Other Negligence Action
MLP/D Dental Malpractice
MLP/L Legal Malpractice
MLP/M Medical Malpractice
MLP/O Other Malpractice
EQ Equity
REPL Replevin
RP Real Property
RP/EJ Ejectment
RP/QT Quiet Title
RP/MF Mortgage Foreclosure
RP/ML Mechanic's Lien
RP/PRT Partition
PP Personal Property Actions

STATUTORY CAUSE OF ACTION

   If the action is commenced pursuant to statutory authority, the specific statute must be identified with full citation.

PENDING CASES

   Previously filed related cases must be identified by caption and docket number whether or not consolidated.

FORM 2

: IN THE COURT OF COMMON PLEAS
: OF LACKAWANNA COUNTY
Plaintiff(s)               
:
:
vs. :
:
:
Defendant(s)               
: NO. ____ -CV- ____

PRAECIPE FOR ASSIGNMENT

TO:   Lackawanna County Court Administrator

   Please be advised that the Plaintiff/Defendant has filed __________(identify motion, petition or preliminary objection)

in the above-captioned case.

   [  ]  All parties have agreed to submit this matter on briefs without the necessity of oral argument.

   [  ]  Please schedule this matter for oral argument.

______________________________________________________
(Attorney for Plaintiff) (Attorney for Defendant)
______________________________________________________
______________________________________________________
______________________________________________________
Address Address
______________________________________________________
Telephone Number Telephone Number
Respectfully submitted:
Date: _________________ By: _________________

FORM 3

PLAINTIFF/DEFENDANT PRE-TRIAL
SETTLEMENT STATEMENT

Case Caption                                                            Court Term & No.

   I.  Facts in brief detail:

   II.  Contentions of the parties as to liability and pertinent legal issues:

   III.  A statement of settlement negotiations to date, including plaintiff's most recent demand and the defendant's most recent offer:

   IV.  Plaintiff's contentions as to injuries and special damages:

   (a)  Injuries sustained:

   (b)  Special damages:

   (1)   Medical:

   (2)  Loss of earnings:

   (3)  Out-of-pocket expenses (type and amount):

   (4)  Other:

   V.  Nature and extent of loss suffered by plaintiff, or the right sought to be enforced (non-personal injury cases):

   VI.  Any other factor which should aid in disposing of the action:

FORM 4

PLAINTIFF/DEFENDANT PRE-TRIAL CONFERENCE STATEMENT

Case Caption                                                            Court Term & No.

   I.  Version of the facts in brief detail:

   II.  Contentions as to liability and/or legal issues pertinent:

   III.  List of requested stipulations of fact or authenticity (admissibility of documents):

   IV.  Estimated trial time:

   V.  A list of all documents or exhibits other than those a party expects to use for impeachment or rebuttal purposes. The list should be specific enough to enable the judge and opposing counsel to identify each document or exhibit. A party may, at his option, produce copies of all documents or exhibits at the pretrial conference in lieu of listing them in the pretrial statement:

   VI.  A list by name and address of all witnesses the party intends to call at trial, except those who may be used for rebuttal or impeachment purposes. If the parties learn the names of any additional witnesses after the pretrial conference, they will promptly exchange names and addresses:

   VII.  A statement of settlement negotiations to date, including the plaintiff's most recent demand and the defendant's most recent offer:

   VIII.  All legal issues or other questions which counsel reasonably anticipate will arise during selection of the jury or during trial:

   IX.  Plaintiff's contentions as to injuries and special damages:

   (a)  The injuries sustained are as follows:

   (b)  The special damages are as follows:

   (1)   Medical--(here set forth names of doctors, hospitals, etc., and amount of bills for same):

   (2)  Loss of earnings--including amount of time lost, occupation and employer rate of pay:

   (3)  Any other out-of-pocket expenses (type and amount):

   (4)  Other:

   (c)  Nature and extent of loss suffered by plaintiff (primary or counterclaim) or the right sought to be enforced (non-personal injury cases):

   X.  Any additional issues you feel should be considered as an aid in disposing of this action:

______________________________________________________
Attorney       Party Represented

FORM 5

Pre-Trial Order

   (1)  Jurisdiction. A statement as to the nature of the action and the authority under which the jurisdiction of the court is invoked.

   (2)  Facts. A comprehensive written stipulation of all uncontested facts in such form that it can be read to the jury as the first evidence at trial.

   (a)   These facts should include all matters capable of ascertainment, such as ownership, agency, dimensions, physical characteristics, weather conditions, road surfaces, etc. Approximations and estimates which are satisfactory to counsel will be accepted by the judge.

   (b)   No facts should be denied unless opposing counsel expects to present contrary evidence on the point at trial, or genuinely challenges the fact on credible grounds.

   (c)  The facts relating to liability and to damages are to be separately stated.

   (d)  The parties shall reach agreement on uncontested facts even though relevancy is disputed; if such facts are ruled admissible, they need not be proved.

   (e)  The parties shall also set forth their respective statements of facts which are in dispute, separating those referring to liability from those referring to damages.

   (3)  Damages or Other Relief. A statement of damages claimed or relief sought.

   (a)  A party seeking damages shall list each item claimed under a separate descriptive heading (personal injury, wrongful death, loss of profits, survival, loss of wages, deprivation of civil rights, punitive damages, false imprisonment, libel, slander, property damage, pain, suffering, past and future medical expense, balance due under contract, performance due under a contract, interest, etc.) shall provide a detailed description of each item, and state the amount of damages claimed.

   (b)  A party seeking relief other than damages shall list under separate paragraphs the exact form of relief sought with precise designations of the persons, parties, places, and things expected to be included in any order providing relief.

   (4)  Legal Issues. Under separate paragraphs, each legal issue that must be decided and the principal constitutional, statutory, regulator, and decisional authorities relied upon.

   (5)  Witnesses. Under separate headings, and under separate headings for liability and damages, the names and addresses of all witnesses whom the plaintiff, defendant, and third-parties actually intend to call at trial.

   (a)  Witnesses shall be listed in the order they will be called. Each witness shall be identified and there shall be a brief statement of the evidence which the witness will give.

   (b)  A detailed summary of the qualifications of each expert witness shall be submitted. This summary shall be in such form that it can be read to the jury when the expert takes the stand to testify.

   (c)  Only those witnesses listed will be permitted to testify at trial, except to prevent manifest injustice.

   (d)  Failure to call at trial any listed witness shall not be a proper subject of jury argument unless justified by the record of the case exclusive of pre-trial conference statements or the pre-trial order.

   (e)  Whenever practicable, a hypothetical question to be propounded to any expert witness shall be prepared in advance for submission to the court and parties in sufficient time as not to delay the trial. If impracticable at this stage, counsel shall arrange for its submission at a later time during trial.

   (6)  Exhibits. A schedule of all exhibits to be offered in evidence at trial, together with a statement of those agreed to be admissible and the grounds for objection to any not so agreed upon.

   (a)  The exhibits shall be serially numbered without any designation as to whether they are being offered by plaintiff or defendant. The exhibits shall be physically marked before trial in accordance with the schedule.

   (b)  Where testimony is expected to be offered as to geographical location, building, structure, waterway, highway, road, walkway, or parcel of real estate, plaintiff shall furnish an exhibit in such form that it can be used in the courtroom as an aid to oral testimony.

   (i)  Except in those cases where the issues require the use of exact scale, the exhibit may be a simple single-line, hand-drawn sketch.

   (ii)  In most instances, it will not be necessary that the exhibit be to scale or contain other than reasonably accurate features of the geographical characteristics involved.

   (iii)  If of adequate size and clarity, this exhibit may be an existing drawing, plan, or blueprint.

   (c)  Except for unusual circumstances, it is expected that the authenticity or genuineness of all exhibits, including non-documentary items, documents, photographs, and data from business records from sources other than parties to the litigation will routinely be stipulated to and will be received in evidence if relevant. Counsel likewise are expected to agree upon the use of accurate extracts from or summaries of such records. Life expectancy tables, actuary tables, and other similar statistical tabular data routinely and regularly used in litigation in the Commonwealth's courts should also normally be stipulated to.

   (d)  At trial, counsel shall furnish a copy of each exhibit to the judge.

   (7)  Legal Issues and Pleadings. Special comments regarding the legal issues or any amendments to the pleadings not otherwise set forth.

   (8)  Trial Time. An estimate of the number of trial days required, separately stated for liability and damages.

   (9)  Discovery Evidence and Trial Depositions. Each discovery items and trial deposition to be offered into evidence.

   (a)  Where the videotape or deposition of a witness is to be offered in evidence, counsel shall review it so that there can be eliminated irrelevancies, side comments, resolved objections, and other matters not necessary for consideration by the trier of fact. Counsel shall designate by page the specific portions of deposition testimony and by number the interrogatories which shall be offered in evidence at the trial. To serve this end all videotape depositions will be accompanied by a typewritten deposition of the same testimony.

   (b)  Depositions and interrogatories to be used for cross-examination or impeachment need not be listed or purged.

FORM NO. 6

REQUEST FOR MEDIATION

PLAINTIFF(S): __________

DEFENDANT(S): __________

INSURER(S): __________
 
__________

PLAINTIFF'S ATTORNEY: __________
 
 
__________
 
 
__________

DEFENDANT'S ATTORNEY: __________
 
 
__________
 
 
__________

ASSIGNED JUDGE: __________

TYPE OF CASE: __________

STATUS OF CASE: __________

THE REASON THE PARTIES REQUESTING MEDIATION BELIEVE THIS CASE IS APPROPRIATE FOR MEDIA- TION: __________
 
 
__________
 
 
__________
 
 
__________

Respectfully submitted,
__________
Counsel for __________

FORM 7

Court of Common Pleas
County of Lackawanna
CERTIFICATE OF READINESS
CIVIL TRIAL LISTING ACTION
NUMBER
 
ACTION

ALL CIVIL CASES SHALL BE ASSIGNED TO A JUDGE FOR TRIAL BY THE COURT ADMINISTRATOR
UPON THE FILING OF A CERTIFICATE OF READINESS IN THE FOLLOWING FORM:

TYPE OF TRIAL REQUESTED
 
[  ]  Jury     [  ]  Non-Jury     [  ]Arbitration
ESTIMATED TIME
 
_____ DAYS
DATE PREPARED
 
_________________
PLAINTIFF(S)
 
DEFENDANT(S)
 
ADDITIONAL DEFENDANTS(S)
 
   I CERTIFY THAT ALL DISCOVERY IN THE CASE HAS BEEN COMPLETED; ALL NECESSARY PARTIES AND WITNESSES WILL BE AVAILABLE; SERIOUS SETTLEMENT NEGOTIATIONS HAVE BEEN CONDUCTED; ALL DEPOSITIONS FOR USE AT TRIAL HAVE BEEN COMPLETED OR SCHEDULED; NO CASE DISPOSITIVE MOTIONS ARE PENDING NOR DOES ANY PARTY CONTEMPLATE THE FILING OF SAME; NO CERTIFICATE OF READINESS HAS BEEN FILED WITHIN THE PAST 24 HOURS BY ANY PARTY OR LAWYER OF RECORD IN THIS CASE; THE CASE IS READY IN ALL RESPECTS FOR TRIAL; THAT A COPY OF THIS CERTIFICATE OF READINESS HAS BEEN SERVED ON ALL COUNSEL HAVING AN INTEREST IN THE CASE NO LESS THAN 15 DAYS PRIOR TO THE FILING; NO PARTY OR COUNSEL OBJECTS TO THE FILING OF THIS CERTIFICATE OF READINESS.
_________________      ___________________________
DATE SERVED                                SIGNATURE OF TRIAL COUNSEL
COUNSEL WHO WILL ACTUALLY TRY THE CASE
FOR THE PLAINTIFF(S)
ADDRESS
TEL. NUMBER
FOR THE DEFENDANT(S)
ADDRESS
TEL. NUMBER
FOR THE ADDITIONAL
DEFENDANT(S)
TEL. NUMBER
IDENTIFY ANY JUDGE WHO HAS DECIDED A CASE DISPOSITIVE MOTION IN THIS CASE PURSUANT TO LACKA. CO. R.C.P. 1028, 1034 OR 1035.2: ___________________________
 
CASE ASSIGNED TO JUDGE _________________
STATUS CONFERENCE SCHEDULED FOR _________________ AT ______ .M.
IMPORTANT NOTICE: FILE CERTIFICATE WITH THE CLERK OF 
JUDICIAL RECORDS, LACKAWANNA 
COUNTY COURTHOUSE, SCRANTON, PA 
CJR-CV-2
[Pa.B. Doc. No. 04-1358. Filed for public inspection July 23, 2004, 9:00 a.m.]



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