Pennsylvania procedural guides

Plain-English guides to the Pennsylvania Rules of Civil Procedure, each one tied to the rules it relies on. Every rule named in a guide has its own page with the official text.

• Responding to a Pennsylvania complaint: 20 days, preliminary objections, and why a general denial admitsPennsylvania gives 20 days to plead to a complaint. It also makes a general denial operate as an admission — a rule with no equivalent in most states.
• The Pennsylvania ten-day notice: what it means and the ten days that come after judgmentPa.R.C.P. 237.1 stops the prothonotary entering a default judgment without ten days' written notice. Rule 237.3 then gives ten days after entry when opening the judgment is mandatory.
• Pennsylvania summary judgment: two grounds, thirty days to respond, and no resting on the pleadingsPa.R.C.P. 1035.2 splits summary judgment into two distinct grounds, and Rule 1035.3 gives the adverse party 30 days to file a response identifying record evidence.
• Pennsylvania discovery deadlines: 30 days, and answers go in the spaces providedPennsylvania uses 30 days for interrogatories, document requests and admissions — and Rule 4006 requires verified answers inserted into the interrogatories themselves.
• The Pennsylvania certificate of merit: 60 days, and a clerk can end your casePennsylvania Rule 1042.3 requires a certificate of merit in any professional liability action, with the complaint or within 60 days — and a defendant can take judgment of non pros by praecipe, without a hearing.
• Serving Pennsylvania original process: 30 days, and the reinstatement that keeps a case alivePennsylvania Rule 401 gives 30 days to serve original process inside the Commonwealth — and lets a complaint be reinstated or a writ reissued at any time and any number of times.
• Joining a Pennsylvania additional defendant: 60 days, and no third-party practicePennsylvania Rule 2253 gives a defendant 60 days after service of the plaintiff's initial pleading to join an additional defendant — a practice broader than federal third-party joinder and easy to miss.
• Opening a Pennsylvania default judgment: ten days changes everythingPennsylvania gives a defendant who petitions within ten days of a default judgment a rule that says the court "shall open" it — a far easier standard than the one that applies on day eleven.
• Pennsylvania preliminary objections: eight grounds, all at once, and a twenty-day clock at both endsPennsylvania replaces most Rule 12 motions with preliminary objections under Pa.R.C.P. 1028 — eight enumerated grounds, all of which must be raised in a single filing, with twenty-day windows on both sides.
• The Pennsylvania motion to compel: winning earns you nothing, losing costs youPennsylvania Rule 4019 makes fees discretionary when a sanctions motion is granted but mandatory against the movant when it is denied — and no fees at all on the first motion.
• Pennsylvania garnishment: a stalled garnishment can be terminated after a yearPennsylvania Rule 3111 attaches property that arrives after service, and lets the garnishee or the defendant petition to terminate a garnishment untouched for a year.

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