Heller v. Makoul

35 Pa. D. & C.3d 271, 1985 Pa. Dist. & Cnty. Dec. LEXIS 397
CourtPennsylvania Court of Common Pleas, Lehigh County
DecidedMarch 14, 1985
Docketno. 81-C-2508
StatusPublished

This text of 35 Pa. D. & C.3d 271 (Heller v. Makoul) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lehigh County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heller v. Makoul, 35 Pa. D. & C.3d 271, 1985 Pa. Dist. & Cnty. Dec. LEXIS 397 (Pa. Super. Ct. 1985).

Opinion

DAVISON, J.,

The sole issue involved in this, defendant’s second motion for summary judgment, is the degree to which an attorney’s absolute privilege for defamatory communications [272]*272extends to communications preliminary to proposed litigation. We hold on the authority of Smith v. Griffiths, 327 Pa. Super. 418, 476 A. 2d 22 (1984) and Post v. Mendel, No. 6957 (Pa. Superior Ct. December 12, 1984) January 10, 1984, LEXIS, States Library, Pa. File) that the privilege encompasses a letter written prior to the commencement of litigation and sent from claimant’s counsel to the responsible party’s insurance adjustor.

The pertinent facts are summarized in the opinion accompanying our order entered November 7, 1983:

“The plaintiff, Adam Heller, resident manager of the Allentown branch of Toensmeier Adjustment Service, Inc. (Toensmeier) an independent claims adjustment agency, was retained to investigate a claim made by Ernest MacDonald against his landlords, John and Freda Mudrick, for personal injuries allegedly sustained in an incident in the MacDonald apartment. The Mudricks’ insurer, Home Mutual Insurance Company of Pennsylvania (Home Mutual) engaged Toensmeier in connection with MacDonald’s claim.”

In a letter dated July 9, 1980, Richard J. Makoul, Esq., MacDonald’s attorney and the defendant here, notified Home Mutual of the nature of the claim and his client’s resultant injuries and also stated:

“I am aware that this case is assigned to Toensmeier Adjustment Service, Inc., represented by Adam W. Heller, Claim Representative.

As a result of past professional experience with Heller, and based on his reputation in the legal community, it is my opinion that he is either incapable of or unwilling to engage in good faith negotiations, no matter how legitimate the claim. It is generally believed that his sole interest is to exploit the carrier [273]*273for as much of a fee as he can extract, with little interest in negotiating a fair settlement.

I have neither the time nor the inclination to engage in what I know will be pointless settlement discussions with Heller, while he runs up the meter. Unless this case is assigned to another adjustor the matter will proceed without any further notice to litigation.”

Both Home Mutual’s claims manager, Robert R. Witwer, and Toensmeier’s president, John M. Lang, were sent copies of Makoul’s letter. In responding to Makoul, Witwer and Lang defended Heller’s integrity and ability as an adjustor and refused to assign the matter to another adjustor. MacDonald subsequently filed suit against his landlords.

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Bluebook (online)
35 Pa. D. & C.3d 271, 1985 Pa. Dist. & Cnty. Dec. LEXIS 397, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heller-v-makoul-pactcompllehigh-1985.