Harry Stump, Attorney At Law

1380 Old Freeport Road
Suite 3B
Pittsburgh, PA 15238

Phone: 412-281-5325
Email: hs@hstumpesq.com
Directions to our office

Premises Liability

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

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