M.O. v. Lavco, LLC

CourtSuperior Court of Pennsylvania
DecidedDecember 30, 2025
Docket422 EDA 2025
StatusUnpublished

This text of M.O. v. Lavco, LLC (M.O. v. Lavco, LLC) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
M.O. v. Lavco, LLC, (Pa. Ct. App. 2025).

Opinion

J-S38029-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

M.O., (A MINOR AT ALL REVELANT : IN THE SUPERIOR COURT OF TIMES), BY TANIA ORENSTEIN AND : PENNSYLVANIA JEREMY ORENSTEIN H/W AS : PARENTS AND NATURAL GUARDIANS : : Appellant : : : v. : No. 422 EDA 2025 : : LAVCO, LLC D/B/A CAMP LAVI, AND : JOHN DOES (1-99) :

Appeal from the Order Entered January 17, 2025 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 240800817

BEFORE: McLAUGHLIN, J., KING, J., and BENDER, P.J.E.

MEMORANDUM BY KING, J.: FILED DECEMBER 30, 2025

Appellant, M.O., (a minor at all relevant times), by Tania Orenstein and

Jeremy Orenstein H/W as parents and natural guardians, appeals from the

order entered in the Philadelphia County Court of Common Pleas, which

sustained the preliminary objection of Lavco, LLC D/B/A Camp Lavi,

(“Appellee” or “Camp Lavi”), and transferred this case to Wayne County. 1 We

affirm.

____________________________________________

1 This appeal is properly before us as an interlocutory order as of right under

Rule of Appellate Procedure 311. See Pa.R.A.P. 311(c) (permitting interlocutory appeal as of right from order changing venue of civil action); Winner v. Progressive Advanced Ins. Co., ___ A.3d. ___, 2025 WL 2716494 (Pa.Super. filed Sept. 24, 2025) (stating: “Under the rule, an appeal may be taken as of right from an order in a civil action or proceeding changing venue or transferring the matter to another court of coordinate jurisdiction”). J-S38029-25

The relevant facts and procedural history of this case are as follows.

This matter arises out of incident which occurred on August 9, 2022, at Camp

Lavi in Lakewood, Pennsylvania. M.O, who was attending Camp Lavi at the

time, was injured when struck in the chest with a baseball while playing a

game at the camp. M.O. is a resident of Great Neck, New York. The

defendants are Appellee and John Does.2 Appellee is a Pennsylvania limited

liability company with a principal business address in Lakewood, Wayne

County, Pennsylvania.

On August 6, 2024, Appellant filed a complaint in the Philadelphia

County Court of Common Pleas against Appellee. Appellee filed preliminary

objections to the complaint on September 17, 2024, pursuant to Rule of Civil

Procedure 1028(a)(1), arguing in part that Philadelphia County was an

improper venue for the case. The trial court issued a rule to show cause why

the preliminary objections should not be sustained. On November 8, 2024,

Appellee submitted a supplemental affidavit by Sean Steinmetz in support of

its preliminary objections. In his affidavit, Mr. Steinmetz, the director of Camp

Lavi, stated that the camp had no connection with Philadelphia.

On January 16, 2025, after the parties conducted additional discovery

and submitted supplemental briefs to the court, the trial court sustained

2 Appellant designated John Does (1-99) as defendants added to this action

where their actual names/identity are unknown despite a reasonable and diligent search. Appellant reserved the right to amend the complaint and name defendants pursuant to Rules of Civil Procedure 2005 and 1033.

-2- J-S38029-25

Appellee’s preliminary objections to venue and transferred this case to Wayne

County. On February 11, 2025, Appellant filed a timely notice of appeal.

Pursuant to the court’s order, Appellant filed a concise statement of errors

complained of on appeal on March 11, 2025.

Appellant raises the following issues on appeal:

1. Did the trial court abuse its discretion when it determined that [Appellee] had sustained its burden of proof to support transfer of this case when the proofs submitted regarding its business activities in [Appellant’s] chosen venue were nothing more than legal conclusions accompanied by a copy of the complaint and the docket sheet?

2. Did the trial court abuse its discretion when it determined that [Appellee] had sustained its burden of proof to support transfer of this case when the proofs submitted regarding its business activities in [Appellant’s] chosen venue were contradictory?

(Appellant’s Brief at 4).

In his first issue, Appellant argues that the trial court erred in sustaining

Appellee’s preliminary objections based solely on the affidavit of Mr.

Steinmetz. Appellant contends that the affidavit and attached exhibits

submitted by Appellee were insufficient to meet its burden of proving that it

did not regularly conduct business in Philadelphia. Appellant claims that in

Stern v. Prudential Securities Inc., 836 A.2d 953 (Pa.Super. 2003), this

Court held that the Nanty-Glo3 rule barring summary judgment based solely

3 Nanty–Glo Borough v. American Surety Co., 309 Pa. 236, 163 A. 523

(1932).

-3- J-S38029-25

on oral testimony, applies to preliminary objections as well. Appellant insists

that similar to the requirement that parties moving for summary judgment

may not rely exclusively upon oral testimony, preliminary objections must also

be supported by non-testamentary evidence. Appellant concludes that the

trial court erred by sustaining Appellee’s preliminary objections without

adequate supporting evidence, and this Court must grant relief. We disagree.

This Court has explained our standard of review as follows:

A trial court has discretion to determine the lack of need for further discovery on the issue of venue, and we review its decision in that regard for abuse of discretion. See Fritz v. Glen Mills Sch., 840 A.2d 1021 (Pa.Super. 2003). “[T]he court abuses its discretion if, in resolving the issue for decision, it misapplies the law, exercises its discretion in a manner lacking reason, or does not follow legal procedure.” Continental Cas. Co. v. Pro Machine, 916 A.2d 1111, 1115–16 (Pa.Super. 2007).

Deyarmin v. Consol. Rail Corp., 931 A.2d 1, 7 (Pa.Super. 2007), appeal

denied, 597 Pa. 706, 948 A.2d 805 (2008).

Further:

The moving party has the burden of supporting its objections to the court’s jurisdiction.[4] Once the plaintiff has produced some evidence to support jurisdiction, the defendant must come forward with some evidence of his own to dispel or rebut the plaintiff’s evidence. The moving party may not sit back and, by the bare allegations as set forth in the preliminary objections, place the burden upon the plaintiff to negate those allegations. It is only when the ____________________________________________

4 The Deyarmin Court explained that “for procedural purposes, objections to

venue are treated as raising a question of jurisdiction.” Deyarmin, supra at 9 (quoting County Constr. Co. v. Livengood Constr. Corp., 393 Pa. 39, 44, 142 A.2d 9, 13 (1958)).

-4- J-S38029-25

moving party properly raises the jurisdictional issue that the burden of proving jurisdiction is upon the party asserting it. If an issue of fact is raised, the court shall take evidence by deposition or otherwise.

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