Pennsylvania Superior Court Upholds “Two Schools of Thought Doctrine”

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In the case Sensenich v. Morcos, the plaintiff filed a medical malpractice lawsuit against the defendant, alleging that unnecessary stenting procedures were performed on him. In addition, the plaintiff further alleged that the defendant, as well as other physicians from Westmoreland County Cardiology (WCC), had established a pattern of excessive and unnecessary stenting with other patients.

A Westmoreland County judge instructed the jury on the “two schools of thought doctrine,” which the plaintiff alleged was improper, because it was not applicable to the claims in the case.

Despite this flawed instruction, the Pennsylvania Superior Court upheld the Westmoreland County jury’s verdict that ruled in favor of the defendant.

Two Schools of Thought Doctrine

Depending on a patient’s specific medical condition, there may be multiple treatment options, all of which are considered effective by experienced medical professionals. It is up to the physician to determine which treatment approach makes the most sense for the patient.

The “two schools of thought doctrine” states that when the chosen treatment option does not accomplish its goal, or compromises the patient’s health in any way, the fact that the physician chose one healthcare approach over the other does not make the decision negligent. In addition, juries should not be expected to determine which of the two acceptable treatment options should have been performed by the physician.

The jury found that the defendant obtained consent from the plaintiff to perform the stent procedure, that there was no battery, and the treatment was not performed negligently. In addition, the jury found that there was no corporate negligence involving Excela Health or civil conspiracy among the defendants.

Superior Court Findings

The Superior Court ruled that although the Westmoreland County judge’s “two schools of thought doctrine” instruction was flawed, it ultimately did not sway the jury, who ruled in favor of the defendant. The Pennsylvania Superior Court, made up of a three-judge panel, upheld the Westmoreland County jury’s verdict.

According to a judge from the three-judge Superior Court panel, the defendants succeeded in shifting the focus to the way that the stenting was performed, rather than whether the arteries should have been stented at all. The two schools of thought involved healthy-to-healthy stenting versus spot stenting. The trial judge recognized that the two methods of stenting did not impact the defendant’s decision to place a stent in a vessel that was insufficiently occluded to warrant that intervention.

The Superior Court further found that the only claims upon which the jury reached a verdict were for the unnecessary stenting claims, for which the “two schools of thought doctrine” were not applicable, and the Trial Court specifically instructed the jury to not apply the doctrine to those claims.

The plaintiff’s lawyers may file a petition for reargument.

Philadelphia Malpractice Lawyers at Sidkoff, Pincus & Green P.C. Seek Justice for Victims of Medical Errors

If you or a loved one have been injured while under the care of a healthcare professional, you are urged to contact the Philadelphia malpractice lawyers at Sidkoff, Pincus & Green P.C. We will help you navigate the claims process and ensure that your legal rights are protected at all times. Our experienced team will seek the maximum financial compensation you deserve. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices of conveniently located in Philadelphia, where we serve clients across southeastern Pennsylvania, South Jersey and New Jersey.

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How Job Changes Impact Employees with Disabilities

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If you have ever shopped at Walmart, it is likely that you were greeted by a Walmart employee whose job it is to welcome you to the store. Since the job of a greeter is not particularly strenuous, nor is it difficult to learn, it is a good fit for employees who have certain disabilities.

Unfortunately, Walmart recently announced that it would be replacing the “greeter” job with a “customer host,” which has more responsibilities, including lifting, cleaning, and long periods of standing. For disabled workers who cannot carry out these responsibilities, this means that they are going to lose their job.

According to the Americans with Disabilities Act (ADA), in the event of a job change, employers must provide reasonable accommodations that will allow the employee to do their job.

Examples of Reasonable Accommodations

Employers can work with disabled employees to come up with possible accommodations that will allow the employee to continue doing their job.

The following are examples of accommodations that can be made:

  • Modifying existing facilities so that disabled employees can use them. This includes adjusting the height of equipment for employees who are wheelchair-bound, installing screen magnifiers for workers who are visually impaired, and installing telecommunications for hearing-impaired workers.
  • Adjusting the work-week to a ten-hour/four-day work week, which will allow workers to attend weekly appointments for treatment or physical therapy.
  • Allowing disabled employees to take oral exams instead of written.
  • Transferring an employee to a different location so that they can do that same job, but with better medical care.

If, however, a specific accommodation would impose an undue hardship, the employer would not be required to make that change. The employer will be responsible for providing proof that the requested accommodation is an undue hardship, which can be difficult to do.

The courts will look at everything from tax credits and other sources of money as well as whether the disabled employee has expressed a willingness to pay for part of the costs.

How to Request an Accommodation

You will need to notify your employer, either in writing or face-to-face, that you require an accommodation as a result of your disability. It is highly recommended that you put the request in writing, so that you have a paper trail in case your employer disputes the request.

Your employer may not ignore your request. Once the request has been made, your employer should respond as quickly as possible. If your employer fails to respond in a timely manner, it could result in a violation from the ADA.

It is unclear if Walmart has been or will be providing reasonable accommodations for the greeters with disabilities who will be using their jobs. Several greeters who have already lost their jobs due to Walmart’s new requirements have filed law suits.

Philadelphia Employment Lawyers at Sidkoff, Pincus & Green, P.C. Protect the Rights of Employees with Disabilities

If your job was changed, and your employer did not make reasonable accommodations for you, contact the Philadelphia employment lawyers at Sidkoff, Pincus & Green, P.C. We will secure the financial compensation that you are entitled to receive. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are located in Philadelphia, where we serve clients in Pennsylvania, South Jersey, and across New Jersey.

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Pennsylvania Proposes Restrictions on Non-Compete Agreements

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Pennsylvania is proposing to become one of several states where the use of non-compete agreements will be restricted.

After Massachusetts, New York City, and New Jersey introduced bills designed to protect workers from the dangers of non-compete agreements, New Hampshire, Vermont, and Pennsylvania have continued this trend by introducing proposals that will limit the use of these agreements.

If passed, the Pennsylvania and Vermont bills will ban all non-compete agreements in ordinary employee relationships. The New Hampshire bill was defeated in March 2018.

Prohibiting Non-Compete Agreements

The Vermont bill and the Pennsylvania bill both will prohibit all non-compete agreements, with the exception of those having to do with the sale of a business or dissolution of a business partnership. In the Vermont bill, the description of the prohibited agreement does not clarify whether both non-solicitation agreements and non-compete agreements are prohibited, or just non-competes.

The Pennsylvania house bill is similar to the Vermont bill in that it prohibits all “covenants not to compete,” with the exception of those that arise from the sale of a business or the dissolution of a partnership or limited liability company. However, Pennsylvania’s HB 1938 defines the “covenant not to complete” as an agreement between an employer and an employee that discourages the employee from seeking employment elsewhere.

As a result, non-disclosure and non-solicitation agreements are outside the ban. HB 1938 also includes a clause that relates to judicial recourse and choices of law and venue.

If an employee files a lawsuit against their employer, and wins, the bill includes a provision that allows the employee to recover attorney fees and damages, including punitive damages. HB 1938 does not offer any recommendations for the standards that should be used to determine whether damages should be awarded. In addition, it does not offer guidance on the amount of damages the employee should receive if punitive damages are awarded.

Additional Bill Provisions

HB 1938 also requires all non-compete cases that involve a Pennsylvania resident be decided upon in a Pennsylvania court under Pennsylvania law. This means that the parties involved may not negotiate an alternate venue, or a conflicting choice of law.

In addition, parties may not file in federal court, even if the conditions for federal jurisdiction are met. The only other states that have non-compete bans as broad as Vermont and Pennsylvania propose to enact are California, North Dakota, and Oklahoma.

The last action on this bill was referral to the Pennsylvania General Assembly’s Labor and Industry committee, where it has remained for over a year.

Philadelphia Employment Lawyers at the Law Offices of Sidkoff, Pincus & Green P.C. Represent Employees in Non-Compete Cases

If you were required to sign a non-compete agreement, and you have questions about how that impacts your employment, it is in your best interest to contact the Philadelphia employment lawyers at Sidkoff, Pincus & Green P.C. We will address all of your questions and concerns, including the enforceability of a restrictive covenant. Our skilled legal team will protect your rights and secure the maximum financial compensation you deserve. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are conveniently located in Philadelphia, where we serve clients in Pennsylvania, South Jersey, and across New Jersey.

Pennsylvania Supreme Court Proposal Would Impact How Medical Malpractice Lawsuits Are Filed

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In Pennsylvania, if a patient files a medical malpractice lawsuit it must be filed in the county where the harm or injury allegedly occurred. However, a recent Pennsylvania Supreme Court proposal would allow patients to file a medical malpractice lawsuit in another county, as long as the party being sued – whether it is the doctor or the hospital – conducted business there.

The proposal by the Pennsylvania Supreme Court would eliminate the restriction on where medical liability claims can be filed. It would also allow medical malpractice lawyers to file a claim in a county that is known for awarding higher payoffs, such as Philadelphia County and Allegheny County, a practice known as venue shopping.

The proposal comes at a time when medical malpractice lawsuits in Pennsylvania are down. For example, there were only 224 malpractice cases filed in Allegheny County in 2017, down from an average of 396 cases filed from 2000 to 2002, which is a 43.4 percent decrease. In Philadelphia there were 406 cases filed in 2017, down from an average of 1,204 from 2000 to 2004, which is a decrease of roughly 66 percent.

According to the Supreme Court’s Civil Procedural Rules Committee, the same rules should apply to civil litigation, regardless of the county where the lawsuit is filed. There should not be exceptions for medical malpractice cases.

Philadelphia Medical Malpractice Lawyers at Sidkoff, Pincus & Green P.C. Assist Clients with Malpractices Cases in Pennsylvania

If you have been injured while under the care of a healthcare provider, and you are considering pursuing a medical malpractice lawsuit, you are urged to contact the Philadelphia medical malpractice lawyers at Sidkoff, Pincus & Green P.C. We will address all of your questions and concerns and secure the maximum financial compensation you deserve. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are conveniently located in Philadelphia, where we serve clients across southeastern Pennsylvania, South Jersey and New Jersey.

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Employee Complaints No Longer a Protected Concerted Activity

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Employees who are unhappy with some aspect of their work conditions often share their frustrations with other employees. A National Labor Relations Board (NLRB) decision made during the Obama administration held that these types of complaints were a protected activity, which meant that employers could not discipline an employee based on complaints made to another employee about work conditions.

However, in January of 2019, the NLRB overturned that decision. As a result, employees who share their complaints with co-workers could face disciplinary action and possible termination.

In a case involving an Alstate Maintenance, LLC, a skycap worker at JFK International Airport was terminated after complaining to his supervisor, in front of several coworkers, about having to transport a soccer team’s equipment. According to the skycap worker, he did not receive a tip from the same team the previous year after he helped the group move their luggage.

The NLRB upheld the Administrative Law Judge’s decision that the termination did not violate the National Labor Relations Act. The employee ultimately carried out his job responsibilities after complaining about it. However, he and three other employees were terminated because of the complaints made about the lack of tips from the previous year.

Protected Versus Not-Protected Activity

According to the Labor Board, the employee’s complaints did not constitute a protected activity. If the complaints were made during an employee meeting, or if the issue that the employee was complaining about impacted all of the employees, the Labor Board may have ruled differently. However, because of the circumstances of the complaint, and that they were made in front of colleagues, the employer’s decision to terminate the skycap was not a violation of the National Labor Relations Act.

In the 2011 Worldmark by Wyndham court decision, the judge held that employee complaints having to do with terms and conditions of employment in a group setting are protected and concerted activity. However, the recent ruling in the Alstate Maintenance, LLC case overruled that decision, which means that any statements made in a meeting, or in a group setting where other employees are present, will not be automatically considered a concerted activity.

If a complaint is related to the terms and conditions of employment, a full investigation should take place before any disciplinary action is taken. An experienced Philadelphia employment lawyer should review the case and recommend the best legal course of action.

Philadelphia Employment Lawyers at the Law Offices of Sidkoff, Pincus & Green P.C. Protect the Legal Rights of Employees

If your employment has been terminated, or disciplinary action has been taken against you after making complaints about your work conditions, you are urged to contact the Philadelphia employment lawyers at the Law Offices of Sidkoff, Pincus & Green P.C. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are conveniently located in Philadelphia, where we serve clients throughout South Jersey, Pennsylvania and New Jersey.

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Two Emergency Services Employees File Lawsuit Against Delaware County for Hostile Work Environment

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A federal civil lawsuit has been filed against Delaware County by two former employees with the Delaware County Department of Emergency Services. Both individuals were longtime employees with exemplary records. One of the women worked as an information systems coordinator and the other worked as a 911 coordinator.

The lawsuit alleges that they were sexually harassed by their co-workers, and that there was an abusive and hostile work environment.

Both women were accused of having pornographic images on their computers at work, which resulted in their termination.

Allegations of a Hostile Work Environment

In the lawsuit, which was filed in late November, the women alleged that they were passed over for pay raises and promotions on multiple occasions. In addition, they claimed that a number of female workers were not given permission to use company-owned cars and electronics, or access to reserved parking spots while men were able to take advantage of these perks.

Men were also given more vacation days and were allowed to roll over vacation and sick days, but women had to use these days by a certain date or lose them. Women were also penalized for showing up to work late or leaving early, whereas these rules were not strictly enforced with the men.

The women also alleged that they were humiliated and disrespected at work when male employees left trash on their workspaces and were told that they had to attend meetings with the office manager twice a day for no apparent reason. Both women claimed that the treatment was an act of retaliation in response to them speaking out about the hostile work environment, in addition to waste and fraud.

According to the suit, when one of the women got sick at work she could not leave until she obtained written permission to depart. According to the lawsuit, men could leave without similar permission.

The Firing of the Employees

Prior to termination, police showed up at one women’s home and the other’s office asking them about pornographic images that were found on their work computers. The former employees denied ever seeing these images on their computers.

According to the attorney representing the women, the fact that it was on their computer is another example of the hostile and abusive treatment in the workplace. The attorney representing the county and its employees declined to comment.

The women have filed a complaint with the Equal Employment Opportunity Commission (EEOC) and are seeking damages for lost wages as a result of their termination.

Philadelphia Employment Lawyers at Sidkoff, Pincus & Green P.C. Represent Victims of Workplace Harassment

If your employee rights have been violated due to a hostile work environment, you are urged to contact the Philadelphia employment lawyers at the  Law Office of Sidkoff, Pincus & Green P.C. We handle a wide range of legal matters related to workplace harassment, including sexual harassment and wrongful termination. We will protect your rights and obtain the maximum financial compensation you deserve. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are conveniently located in Philadelphia, where we serve clients throughout southeastern Pennsylvania, South Jersey and New Jersey.

UPS Settles Religious Discrimination Case for $4.9 Million

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In the largest class religious discrimination settlement in the history of the Equal Employment Opportunity Commission (EEOC), the United Parcel Service (UPS) has agreed to pay the EEOC $4.9 million to resolve a lawsuit claiming that the company was biased against current and prospective employees who wear beards and long hair for religious reasons.

The lawsuit alleged that the company’s uniform and appearance guidelines that employees are required to follow are biased against certain religious groups.

In addition to refusing to hire individuals who had beards and long hair, UPS failed to provide these employees with the same opportunities as other employees. For example, UPS only allowed employees with religious-related beards and long hair to work in nonsupervisory jobs that did not involve any customer contact. In addition, they were not considered for promotions and were not provided with faith-based work accommodations, according to the EEOC.

The U.S. District Court for the Eastern District of New York ruled that UPS had to establish a $4.4 million claims fund for the workers who brought the case to the EEOC, as well as a class of other claimants that the EEOC has identified.

With the remaining $500,000 of the $4.9 million settlement, a reserve fund must be established for claimants who have not yet been identified by either party. UPS must also revisit its application forms and religious accommodations processes, and make the appropriate changes.

Religious Charges Have Doubled Over the Past Two Decades

According to the executive director for the American Association for Access, Equity, and Diversity, since 1997 the number of religious charges filed with the EEOC has doubled. As a result, she said, their organization will be offering a wide range of training programs that will address racial and ethnic intolerance.

Religious freedom is one of the fundamental rights afforded to all citizens of this country, and it must be protected, a judicial analyst for the religious freedom advocacy group Focus on the Family pointed out.

Employers have a responsibility to make religious accommodations that ensure reasonable accommodations for employees, while making sure that it does not impose an unreasonable hardship on the business, according to a Senior Vice President for the Center for Workplace Compliance.

If wearing a beard or long hair presents a safety issue, it could jeopardize the safety of the worker and pose an undue hardship on the employer. For example, if the business involves the use of machinery that poses a constant risk of a caught-in/between accident.

It is important that employers understand that the EEOC will continue to closely examine decisions related to religious discrimination.

Philadelphia Employment Lawyers at The Law Office of Sidkoff, Pincus & Green P.C. Represent Employees in Discrimination Cases

If your religious rights have been violated, contact the Philadelphia employment lawyers at the Law Office of Sidkoff, Pincus & Green P.C. We will protect your rights and secure the maximum financial compensation you deserve. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are conveniently located in Philadelphia, where we serve clients throughout South Jersey, Pennsylvania and New Jersey.

Third Circuit Reverses NLRB’s Determination In Favor of Union Workers

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The Third Circuit Court of Appeals recently ruled that an employer’s threat and subsequent call to the police regarding union organizers on both public and company property did not violate 29 U.S.C. § 157 Section 8(a)(1). National Labor Relations Board v. ImageFirst Uniform Rental Service., No. 17-3680, 2018 WL 6614237 (3d Cir. December 18, 2018). The case arose from an incident in which ImageFirst, a health care laundry service provider, called the police on union members who were distributing pro-union literature on and near their Columbia, PA facility. The manager called the police and requested the union workers be removed from company property and a grassy area which abutted the road. The union ultimately filed a complaint and alleged that ImageFirst unlawfully interfered with union activities under 29 U.S.C. § 157 Section 8(a)(1). An administrative judge decided the trespassing was too insignificant to warrant a removal of the union members. The NLRB affirmed the decision.

In reversing, the Third Circuit Court found that substantial evidence did not support the finding by the NLRB that ImageFirst’s threat to call the police and the company’s call to the police were motivated solely by a desire to remove the union representatives from the public right-of-way. Rather, the Court concluded that “no reasonable fact finder could have failed to find that ImageFirst’s conduct was motivated by broader concerns over its property interests, implicated by the union representative’s repeated and ongoing forays onto its private property.” Therefore, the company’s concern was reasonable and the Court denied enforcement of the NLRB findings.

At the Law Offices of Sidkoff, Pincus & Green, our experienced Pennsylvania and New Jersey attorneys handle many types of legal matters. If you are interested in having a consultation with one of our attorneys, please call us at 215-574-0600 or contact us online.

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Termination One Month After Requesting FMLA Leave Creates Sufficient Casual Link

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In Ha Long v. Spalding Auto. Inc., the Eastern District Court of Pennsylvania—ruling on a motion to dismiss—determined that the plaintiff may proceed on his FMLA retaliation claim against his former employer because there were sufficient facts to establish a prima facie case for FMLA retaliation. No. CV 17-4865, 2018 WL 6244755, at *4 (E.D. Pa. Nov. 29, 2018). In Ha Long, the plaintiff sued his former employer alleging employment discrimination and retaliation. Plaintiff began his employment with Defendant in 2013 and was diagnosed with thoracic disease and disc disease in September 2015. Throughout his employment, Plaintiff periodically needed to request time off and needed accommodations due to his health conditions. Later, in March 2016, Plaintiff requested FMLA leave to attend to his daughter’s needs, as she was undergoing surgery. Initially, the FMLA request was not approved; however, the employer approved the FMLA leave after Plaintiff contacted his union representative, who contacted the chief operating officer. Then in June 2016, Plaintiff again had to request FMLA leave due to the pain he was experiencing as a result of his medical condition. On July 1, 2016, Defendant approved this request, conditioned upon Plaintiff sending appropriate FMLA documents within fifteen (15) days. Plaintiff allegedly complied with this request, but on August 1, 2016, Defendant terminated Plaintiff claiming the documentation was never received and citing attendance issues.

In order to state a viable claim for FMLA retaliation, the plaintiff here must be able to show that: (1) he engaged in protected employee activity; (2) he suffered an adverse employment action; and (3) the adverse action was causally related to the protected activity. Based on the facts at hand, the Court found that the plaintiff has alleged sufficient facts in order to defeat a motion to dismiss his FMLA retaliation claim. The Court recognized that the one-month gap between plaintiff requesting FMLA leave and his subsequent termination created a reasonable link that they may be related.

The statutes, regulations, and case law that govern the employer-employee relationship are constantly evolving. If you have questions about a legal situation, contact the Philadelphia employment lawyers at the Law Office of Sidkoff, Pincus & Green P.C. today to schedule a confidential consultation. We can be reached at 215-574-0600 or by submitting a convenient online contact form.

Dittman v. UPMC Ruling – Pennsylvania’s Economic Loss Doctrine Permits Recovery for “Purely Pecuniary Damages” on Negligence Claims

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In 2014, a group of employees from the University of Pittsburgh Medical Center (UMPC) filed a class action lawsuit against the organization, claiming that a breach in data compromised sensitive personal employee information, including social security numbers, tax information, and confidential bank account information. The plaintiffs alleged that UMPC failed to adopt the appropriate security measures, which increased the risk of identity theft and other crimes.

In a landmark decision, the Pennsylvania Supreme Court held that employers have a legal duty to protect employee information that is stored on internet-accessible computer systems. In addition, by limiting the economic loss doctrine, claimants can sue for economic losses resulting from a failure to protect their personal data.

According to the plaintiffs involved in the Dittman v. UPMC case, as a condition of employment, they were required to provide certain personal information, including Social Security numbers and bank account information. As a result, the plaintiffs argued that UPMC had a duty to protect their information against the threat of identity theft crimes.

The plaintiffs alleged that UPMC breached this duty by failing to implement effective security measures, including encryption programs, firewalls, and adequate authentication protocols. The plaintiffs sought economic damages for losses associated with fraudulent tax returns, as well as the potential risk of identity theft crimes.

Significance of the Pennsylvania Supreme Court Ruling

The Court’s decision in the Dittman v. UPMC case made the rule of law in Pennsylvania very clear. Employers who collect personal data must take reasonable measures to protect that information. The Pennsylvania Supreme Court also adopted a wide interpretation of the economic loss doctrine, and found that employees may recover economic losses in a variety of tort actions. By limiting the economic loss doctrine, claimants can now sue for the economic losses resulting from a failure to protect personal data.

The Court’s decision also reflects the rise in cyberattacks, and the growing need for improved cybersecurity frameworks. The lower court found that employers should not be held responsible for security breaches that were not preventable. However, the PA Supreme Court overturned this argument, because companies are now expected to take advantage of the latest cybersecurity systems that protect confidential employee data.

Because of the expansive interpretation of the economic loss doctrine, defendants will not be able to rely on this line of defense to summarily dismiss negligence claims.

Philadelphia Business Lawyers at the Law Office of Sidkoff, Pincus & Green P.C. Represent Employees in Legal Disputes

If your employer failed to take adequate security measures to protect your personal information against the threat of cyberattacks, contact the Philadelphia business lawyers at the Law Office of Sidkoff, Pincus & Green P.C. Protecting your rights is our top priority, and we will work tirelessly to secure the maximum financial compensation you deserve. To schedule a confidential consultation, call us today at 215-574-0600 or contact us online. Our offices are conveniently located in Philadelphia, where we serve clients throughout Southeastern Pennsylvania, South Jersey, and across New Jersey.