Monday, February 23, 2015

Concurrent Employment in PA Workers’ Compensation

As more and more people are working multiple jobs, it is not unusual for workers’ compensation lawyers to hear the question: “I was injured at my part-time job, will workers’ comp also pay for lost wages from my full-time job?”

Thankfully, in Pennsylvania the answer is yes.  People who work multiple jobs and are injured at one of the jobs are eligible to be paid wage loss benefits which include the lost wages from both jobs.

The Pennsylvania Workers’ Compensation Act provides “[w]here the employe [sic] is working under concurrent contracts with two or more employers, his wages from all such employers shall be considered as if earned from the employer liable for compensation.”  77 P.S. § 582(e).  This area of the law has developed from the difficult and confusing statutory and case law surrounding pre-injury average weekly wage (“AWW”) calculations.

Some explanation is appropriate.  In short, workers’ compensation “disability” is synonymous with “wage loss.”  The Workers’ Compensation Act seeks to provide a wage loss benefit, described as a total disability benefit or a partial disability benefit, based on how much an injured worker can earn after she is injured on the job.  If she is totally disabled, and she is not released to return to work by her doctor in any capacity, she is generally entitled to total disability benefits, which are frequently calculated to be two-thirds of the workers’ pre-injury average weekly wage.  If she is released to return to some kind of work, with medical restrictions, and can earn something, but not as much as she earned prior to the injury, she is generally entitled to partial disability benefits, which last up to 500 weeks.  Partial disability is calculated by subtracting current earnings from the pre-injury average weekly wage, and multiplying the difference by two-thirds.

It is plain to see that the pre-injury average weekly wage is a highly important figure, essential to correctly calculate an injured workers’ wage loss benefit.  In Pennsylvania, when a worker is injured at one of his jobs, the pre-injury average weekly wages of all of his then-current employers is added together to yield the correct measure of his pre-injury earnings experience, and total or partial disability is then calculated based on that combined average weekly wage.  The workers’ compensation benefit is paid by the carrier insuring the time-of-injury employer.  If the injured worker can resume one of the jobs but not another, then partial disability should be appropriately paid.

Interestingly, this can mean that the insurance company which insures a part time employer might pay far more in wage loss benefits than the actual wages from the part time job, when the injured worker can no longer work his full time job due to the injury.

Not all injured workers in the United States are so lucky.  In some states, injured workers can only be paid based on the earnings from their time-of-injury jobs, and not their concurrent employment.

This article cannot hope to cover all of the intricacies of AWW calculations, concurrent employment considerations, or total or partial disability calculations.  These are complicated concepts, and even experienced workers’ compensation adjusters and lawyers can miss minor details or nuances which can alter the outcome of an injured workers’ claim by thousands of dollars.  Pennsylvania Workers’ Compensation is a specialized area of practice, and is filled with unexpected twists and turns.  Employers are typically provided lawyers by their insurance companies who only practice workers’ compensation law.  Injured workers are well-advised to consult experienced workers’ compensation claimant’s attorneys when they have had a work injury.  Although Pennsylvania is better than some states in this arena, the potential levels of complication leave too many pitfalls for the unwary.  It is best to involve competent counsel early on in the process, to make sure all of the client’s rights are protected.

Wednesday, January 14, 2015

Changes to Pennsylvania’s Power of Attorney Law – What you need to know for the New Year

On January 1, 2015, significant changes went into effect for Power of Attorney documents drafted in Pennsylvania. For anyone who deals with these documents in any capacity, it is important to know that these changes are coming and what impact they will have.  

To give a brief history on this, on July 2, 2014, Governor Tom Corbett signed into law as part of Act 95 of 2014, House Bill 1429, provisions creating changes to Chapter 56 of the Decedents, Estates and Fiduciaries Code, which are the laws that govern Powers of Attorney in Pennsylvania. These changes were made in response to several events; in particular, to overturn the Pennsylvania Supreme Court’s decision in Commonwealth v. Vine, 9 A.3d 1150 (2010) through the legislative process.

 In the Vine matter, a wife executed a Power of Attorney (POA) giving her husband authority to act on her behalf. The husband used the POA to make changes to his wife’s State Employees Retirement System (SERS) account. Several years after the couple divorced, the wife discovered that her husband made changes to her retirement account and confronted SERS. She claimed that she was incapacitated when she signed the POA, and argued that SERS was not able to rely on the authority the POA conveyed to her husband. All the parties agreed that the POA was invalid; however, both the SERS dispute board and the Commonwealth Court agreed that under the language of the POA law, SERS could not be liable, because it relied in good faith on the POA that it believed was valid at the time. 

The Pennsylvania Supreme Court heard the case and reversed the Commonwealth Court’s decision. It held that since the POA was not valid, the liability protection under the POA law at the time did not apply to SERS.

This decision essentially put any agent acting under a POA in the impossible position where he or she would have to prove the competency of the principal any time they would present the POA to a third party. Therefore, the Pennsylvania legislature stepped in and changed the law to in an attempt to solve this, and other problems, with the then-current Power of Attorney law.

Revisions to the law provide that if a third party, in good faith, accepts a power of attorney without actual knowledge of the power of attorney being void, invalid, terminated, or that the agent is exceeding or improperly exercising his or her authority, that third party will not be subject to civil liability. Please note that this section actually went into effect when Governor Corbett signed HB 1429 into law. 

In addition, it is important to know that while these changes create third party immunity from civil liability, they also provide for sanctions to a third party who refuses to accept a proper power of attorney. As a third party, if an agent presents a power of attorney to you, you are entitled to ask for the agent’s certification under penalty of perjury, a translation (if it is in another language), and an opinion of counsel as to whether the agent is acting within the given scope of authority. Then, the third party has 7 business days after presentation of the POA to accept it, or request an affidavit, certification, translation, or opinion of counsel; and then has 5 business days to accept after receipt of additional requested information (or provide a “substantial basis” for making an additional request). If the third party refuses to accept a POA and does not meet any of these conditions, then the law states that the third party shall be subject to civil liability for “pecuniary harm to the economic interests of the principal proximately caused by the person’s refusal to comply with the instructions of the agent… and a Court Order mandating acceptance of the POA.” 20 Pa.C.S. 5608(3).  

In addition to potential sanctions, the revisions of the law explicitly provide that a third party cannot require different or additional forms. As an Estate Planning practitioner, I have seen on a number of occasions institutions refusing to honor a POA on the basis that they would only accept POAs on their institution’s form. This was not only frustrating for the principal who thought he or she was planning ahead by having a properly drafted and executed POA, but also to the agent, who was just trying to take care of the principal. From my perspective, this is a welcome revision.

There are other revisions in the requirements for drafting and executing POAs, but the greatest impact will probably be seen with the requirement of 8 powers for which a principal must specifically grant authority, which are as follows: 1. Create, amend, revoke, or terminate an inter vivos trust; 2. Making gifts; 3. Create or change rights of survivorship; 4. Create or change a beneficiary designation; 5. Delegate authority granted under the POA; 6. Waive the principal’s right to be a beneficiary of a joint and survivor annuity, including a survivor benefit under a retirement plan; 7. Exercise fiduciary powers that the principal has authority to delegate; and 8. Disclaim property. Since these powers need to be specifically granted, during the drafting process, principals will be forced to carefully consider what exactly they want their agent(s) to have the ability to do. Quite frankly, no principal should ever sign a power of attorney without carefully considering and understanding what type of authority it grants to another.

If you have any questions about a Pennsylvania Power of Attorney, whether you are a third party being asked to honor one, or you are trying to complete your estate plan, or you are an agent trying to act on behalf of a principal, you should consult with legal counsel. 

Jessica R. Grater, Esquire, is an attorney with the law firm of Wolf, Baldwin & Associates, P.C., with offices in Pottstown, West Chester, and Reading. Ms. Grater concentrates her practice in Wills, Estates, Probate, Orphans’ Court, and Social Security Disability, and litigation related to such matters. She may be reached at 610-323-7436 or by e-mail to 

Friday, December 12, 2014


Wolf, Baldwin & Associates, P.C. is pleased and excited to announce the addition of Jessica R. Grater to the firm.  Ms. Grater is the ninth attorney on staff at the firm, and will focus her practice on Estate Administration and Probate, Estate Planning and Social Security Disability.

“When our search for a candidate to join our probates and estates practice led to Jessica Grater, we were thrilled," said Levi Wolf, managing attorney at Wolf, Baldwin."  She has strong legal skills, she is client-service oriented, and she has deep local ties.  We could not be happier to have her join our team of legal professionals."

Ms. Grater earned her Juris Doctor degree in 2007 from Widener University School of Law, where she graduated in the top one-third of her class and earned a Certificate of Achievement in Constitutional Law-Seminar. 

“Wolf, Baldwin & Associates, P.C. is a highly respected general practice firm,” said Ms. Grater.  “They have a wonderful reputation for working hard for their clients while treating each of them with compassion and dignity.  I am excited and honored to become part of its respected legal team."

Prior to joining Wolf, Baldwin & Associates, P.C., Ms. Grater managed the firm of E. Kenneth Nyce Law Office in Boyertown.  Previously she worked for Rabenold, Koestel, Scheidt from 2007-2009.

Wolf, Baldwin & Associates, P.C. is a general practice law firm, with offices in Pottstown, Reading and West Chester.  The firm’s areas of practice include Workers’ Compensation, Business and Corporate Law, Estate Planning, Estate Administration and Probate, Municipal Law, Real Estate, Family Law and general civil litigation.

Tuesday, December 9, 2014

Financial Implications of Divorce – Support and Alimony

Finances are of course one of the biggest concerns of a potential client during a divorce consultation. Depending on the client’s role, he or she will want to know, how much will I be receiving, or how much will I be paying? There are three important legal terms associated with separation and divorce that come into play: Spousal Support, Alimony Pendente Lite (“APL”) and Alimony. In order to qualify to receive or have to pay any of these obligations, both spouses must be “living separately” or their finances need to be separate.

 “Alimony” is money that is only paid after the entry of the divorce decree and is set forth in a legal divorce document, (either a Divorce Decree itself, or an agreement called a Post Nuptial Agreement or a Marital Settlement Agreement). Alimony in Pennsylvania is based on need, but in practice it is handled differently by the judges of different counties across the state and even different masters and judges within the counties. Some people have the idea that one year of alimony might be awarded for every three years of marriage. In practice, this is not necessarily true and in fact most divorce masters and judges tend to award what they perceive to be an appropriate amount of equitable distribution of current assets rather than award alimony. Additionally, it is not unusual for a master or judge to decline to award alimony unless a couple has been married for a significant amount of time, perhaps seven or eight years. If the parties cannot agree on the terms of alimony, the court will evaluate the needs of the parties and attempt to effectuate economic justice based on the factors set forth in the divorce law. Those factors include the reasonable needs of the parties, taking into account the lifestyle and standard of living established by the parties during the marriage, and the spouse’s ability to pay. Alimony commonly terminates if the recipient dies or remarries, but this can be modified by a court order or the agreement of the parties.

Spousal Support” is a payment on account of the care, maintenance and financial assistance of the dependent spouse, and is not actually dependent on a divorce action being filed. Spousal support can be awarded once the parties are separated; i.e. when the parties no longer hold themselves out to be spouses and typically have ended marital relations and separated their finances.

 Unlike spousal support, alimony pendente lite (“APL”) is only available when there is a divorce action pending between the parties; pendente lite is Latin for “during the litigation.” One cannot receive both spousal support and APL, although in certain cases counsel fees and costs can be awarded in addition to spousal support or APL. Both spousal support and APL, like are determined by using statewide support guidelines that take into account the parties’ incomes. Without child support issues, spousal support and APL are frequently 40% of the difference between the parties’ net incomes. It is important to note that spousal support, alimony, and APL payments are tax deductible for the payor and are considered taxable income to the recipient. 

The calculation of alimony, spousal support, or APL can be challenging and full of pitfalls for the unwary. Although the internet contains some Pennsylvania support calculators, consultation with an experienced family law attorney is advisable for people with questions about how much they might have to pay, or how much they might be entitled to receive.

Kristen Doleva-Lecher, Esquire is an attorney in the law firm of Wolf, Baldwin and Associates, P.C.. She practices primarily out of the Reading office, but the firm has additional offices in Pottstown and West Chester. She is a certified mediator and practices in the areas of family law and business representation. She may be reached by telephone at 610-374-2400 or by e-mail to

Tuesday, November 11, 2014

The Truth…About Title Insurance

      I am admittedly a big fan of the AMC television series, Mad Men. In one episode, advertising executive Don Draper, frustrated about losing a large tobacco client, pens an open letter and has it published in The New York Times entitled “Why I Am Quitting Tobacco.” The point of Don’s article was an attempt to attract business in a different way by pointing out the very real, but largely unpublicized at the time, dangers of cigarette smoking. I am undertaking this column after a similar experience with one of my own long time clients, which illustrates what the business of title insurance is really about.

     Imagine yourself at a car dealership, preparing to sign on the dotted line to purchase a vehicle costing anywhere from $30,000 to $80,000 when the salesman turns to you and states: “Hey, you know you need insurance on this beauty. Harrisburg says you gotta. How about I just place that for you? Our dealership has a financial interest in the insurance company.” Of course this doesn’t ever happen, mostly because people know that they have a choice as to where they get insurance. They know they can go with the reptile, Flo or maybe the guy with the deep voice to get their auto insurance, because auto insurance has been defined as a product by mass marketing, or advertising by a company such as the fictional Sterling Cooper Draper Pryce. But that is how title insurance is ordered every day, by allowing your realtor to order your title insurance, most likely from a company in which the real estate company or realtor has a financial interest. If your realtor was from one of the “big boys” in the real estate industry, that is almost definitely the case.

     Tell me the last title insurance commercial you saw watching any sporting event on television. I’ll wait. Never seen one? How about during your favorite news program? Nope. I would venture to say, with reasonable certainty, that you have never seen a title insurance commercial. Can someone explain how a product that protects your home ownership – which is worth probably ten times the value of your automobile – is given absolutely no respect and is utilized as an additional profit center by the real estate company?
      In 1974, Congress passed the Real Estate Settlement Procedures Act (“RESPA”) to regulate the costs consumers pay to settle their real estate transactions. The statute states: The Congress finds that significant reforms in the real estate settlement process are needed to insure that consumers throughout the Nation are provided with greater and more timely information on the nature and costs of the settlement process and are protected from unnecessarily high settlement charges caused by certain abusive practices that have developed in some areas of the country. 12 U.S.C § 2601(a). Further, ownership of a title insurance agency became, for the first time, available to realtors under the theory that the “bundling” of services would affect certain economies of scale that would result in lower prices to the consumer. 

      Let’s see how home buyers and sellers have fared in Pennsylvania since HUD gave the realtors the ability to own title companies.

      Since the title insurance premium is regulated by the Commonwealth of Pennsylvania Insurance Department, your title insurance premium, which is based on the purchase price of your house, is the same whether you purchase it from the realtor’s company or an independent title agency whose focus is on protecting your interests alone. So the consumer saves nothing by using the realtor’s company. 

      Have costs to the consumer increased since the title agency ownership changed from 100% independents to a mix of realtor owned and independent agencies? Sadly, yes. In addition to the real estate commission (somewhere between 3% to 6% of the sale price of the house), some real estate agencies collect “conveyancing fees.. These fees, ranging from $100 to $250 or more, and typically charged to the seller, are for the exact same services that the independent title agency performs as part of the title insurance underwriting (ordering tax certifications, obtaining mortgage payoffs, etc.), at no extra charge. So, instead of reducing costs, actually the opposite has occurred, as consumers are paying more for services that they used to get for free. 

      Another “charge” a real estate agency imposes on a buyer is something that used to be called a “broker service fee”; this fee, ranging from $200 to $550, is now called an “additional commission.” Some consumers initiated litigation in several states claiming that the fee being charged was unearned and therefore in violation of RESPA when:  (1) a fee is charged but “no, nominal, or duplicative work is done” in exchange for the fee;  or (2) a fee is charged that is unreasonably excessive in light of the services actually performed in exchange for the fee. One of the results of the litigation was not that the fee was relegated to the ashcan of history where it belonged, but that its name was changed.

      All of the above only drives home the need on the part of the Buyer or Seller of real estate to consult with an experienced real estate attorney before contacting a realtor for the sale or purchase of your home. You need to know what charges should be negotiated out of any buyer agency contract or listing agreement into which you enter, and you especially need to know the advantages of hiring a truly independent title agency to represent your interests in the most important purchase most of you will ever undertake. Your federally mandated right to choose an independent title agency should not be usurped by your realtor to allow the realtor, or their agency, additional profit.

      Andrew J. Monastra, Esquire recently joined the law firm of Wolf, Baldwin and Associates, P.C., which has offices in Pottstown, West Chester, and Reading. He has represented consumers and businesses in real estate transactions for over 23 years, and he is the owner of Heartland Abstract, Inc., an independent title agency located in Pottstown. He may be reached by calling 610-323-7436, or by e-mail at

Tuesday, October 28, 2014


     Levi S. Wolf has achieved the AV Preeminent® Rating - the Highest Possible Rating from Martindale-Hubbell® for both ethical standards and legal ability. As explained on the website, “The Martindale-Hubbell® Peer Review Ratings™ are an objective indicator of a lawyer's high ethical standards and professional ability, generated from evaluations of lawyers by other members of the bar and the judiciary in the United States and Canada.” The AV Preeminent is a significant rating accomplishment and a testament to the fact that a lawyer's peers rank him or her at the highest level of professional excellence.

     “Prior to the age of the internet,” said Mr. Wolf, “Martindale Hubbell ratings were one of the only ways to get any objective measure of a lawyer’s proficiency and standing in the legal community. When I was a young lawyer, I knew that anyone with an AV rating would be knowledgeable in his or her field, and considered by his or her peers to have the highest ethical standards. Although today there are many more sources of ratings on the internet, the AV rating is still a humbling achievement and I am honored that my peers hold me in such high esteem.”

     Mr. Wolf also holds the highest rating, 10 out of 10, on, an internet-based rating site for lawyers.

     Mr. Wolf practices primarily in the areas of workers’ compensation and family law. He is one of approximately 180 lawyers across the state who are certified as specialists in the practice of workers' compensation law by the Pennsylvania Bar Association's Section on Workers' Compensation Law as authorized by the Pennsylvania Supreme Court. He was admitted to the bar in 1996 and has practiced in Pottstown since that time.

     Wolf, Baldwin & Associates, P.C. is a general practice law firm, with offices in Pottstown, Reading and West Chester. The firm employs 19 people, including 8 attorneys. The firm’s areas of practice include Workers’ Compensation, Business and Corporate Law, Estate Planning, Estate Administration and Probate, Real Estate, Family Law and general civil litigation.

Thursday, October 9, 2014

Death Benefits under the Pennsylvania Workers’ Compensation Act

Workers’ Compensation death claims, otherwise known as fatal claims, provide a measure of relief for families which have lost a loved one due to an on-the-job injury.  Section 307 of the Workers’ Compensation Act (77 P.S. § 561) provides for a weekly compensation benefit and burial expenses where a death results from a work injury or an occupational disease.  This type of benefit could potentially last a lifetime depending on the facts surrounding the death of an employee.  The most common example of a fact scenario that results in a death benefit is when a person is killed on the job.  For example, if a construction worker falls from a building and passes away, his spouse and potentially his children would be entitled to a workers’ compensation benefit which would be based on very specific calculations outlined in the Workers’ Compensation Act.  However, deaths resulting from an accident on the job are not the only example of facts in areas which could potentially produce a death benefit.  Another example might be a lethal infection resulting from a surgery needed to treat a work-related injury.  However, what exactly is owed to the survivors of such an unfortunate accident?

First, if the injury or death which resulted at work is not immediately recognized as related to work, the dependents of the decedent must first prove that 1) they are dependents of the decedent and 2) the death was work-related.  While these factors may sound obvious, they are often points of great controversy.  For example, if an employee is playing a sport at a work-sponsored event and suffers a fatal heart attack, would her death result in workers’ compensation benefits?  The case law on this type of death is rather clear.  Even though the decedent was not necessarily in the course and scope of her regular employment, she was certainly participating in an event that was set up by the employer and has some benefit to the employer’s business.  Such work functions are generally regarded to further the employer’s business.  Thus, generally, in this situation the death of this employee would be considered work-related and any dependents would have a right to a death benefit.

The next question would be who is entitled to a death benefit?  It is important to note that even if a worker dies on the job from a clear work injury, if he has no dependents then no fatal claim benefits would be due.  Generally, a surviving spouse would be entitled to the death benefit at a rate of 51% of the decedent’s preinjury average weekly wage.  If the deceased also had one minor child, the widow and the surviving child would be entitled to 60% of the decedent’s average weekly wage.  If employee had has two minor children or more, the percentage goes to 66 2/3%.  The surviving spouse must show that he or she was married to the employee at the time of death, and must actually be dependent on the employee as well.  If the surviving spouse lived separately from the decedent and did not have any financial support from the decedent, a workers’ compensation insurance carrier could certainly make the argument that while the couple was legally married, the surviving spouse was not actually dependent on the decedent.  With regard to the surviving children, only children under the age of 18 are entitled to be considered at the time of death.  However, surviving children would be entitled to be included in the class of dependents up to the age of 23 if they are enrolled in college or graduate school.

The class of dependents is not always so clear.  For example, if at the time of death one child is enrolled in college, but then a few months later drops out of college, the number of dependent children who could be included in the class for determination of the percentage to be paid to the dependents might change.  Further, what happens if that child re-enrolls in college?  Should the percentage go back up?  These questions are not immediately clear, and the case law related to these questions is relatively sparse.  This is because many claims related to death benefits often settle relatively quickly.

In Pennsylvania, the surviving spouse and any dependent children are entitled to the statutory specific percentages of the decedent’s average weekly wage.  The preinjury average weekly wage calculation itself can be quite complicated, but in simple terms it is typically a snapshot of the earnings from year preceding the employee’s date of injury.  This average weekly wage forms the basis of the death benefit to be paid. 

Generally, death benefits are payable to the surviving spouse so long as she lives and does remarry or enter into a “meretricious relationship.”  This term has generally been considered to describe when a surviving spouse either lives with or marries another person.  However, it is questionable whether the mere act of sexual relations with another person would render the surviving spouse ineligible for any further death benefits.  For this reason alone, these cases often settle before the benefits are paid for many years.  Death claim cases settle for a number of other reasons as well.  If the surviving spouse dies for any reason, the only additional benefits owed would be to any surviving children so long as they are either under the age of 18 or under the age of 23 and enrolled in a college or graduate school.  Thus, if a surviving spouse were to die after the surviving children reach the age of 23, the death benefit would essentially end.  Thus, surviving spouses often elect to try to settle the case for some type of lump sum to guarantee that the family of the decedent gets some money.  So the question becomes, what is the value of a death claim if it is paid in a lump sum?

To answer this question, attorneys will often use the U.S. Life Tables or other actuarial methods to try to predict the life expectancy of the surviving spouse.  For example, a surviving spouse who is 50 years old may have a life expectancy of 30 years.  That spouse may be entitled to a weekly check of $600.  Thus, the resulting yearly rate would be $31,200.  If the surviving spouse were to receive those benefits for 30 years, or her life expectancy, the resulting total would be $936,000.  So would the value of the case be $936,000?  The simple answer is no.  A more accurate method is to try to determine the present value of the expected stream of income.  The present value of the stream of $600 per week for 30 years is similar to figuring out how much a similar annuity would cost.  Of course, the present-day value of $936,000 paid as an annuity over 30 years is much less than $936,000.  The exact calculations related to the above example go beyond the scope of what this article covers.  However, the important question the surviving spouse must ask is how much money is the insurance company willing to pay right now to avoid the possibility that the surviving spouse may live well past their life expectancy?  Further the surviving spouse must ask themselves whether they believe that they will be unmarried and living alone over the next 10, 15, or possibly 20 years.  This question is difficult to contemplate immediately following the death of a loved one.  However, the surviving spouse must ask herself whether she will remain unmarried and living alone for the rest of their lives.  This answer may be easy if the surviving spouse is at an advanced age.  However, if the surviving spouse is 35 years old, can that person reasonably expect that they will live out the rest of their lives without entering into a new relationship?

These are just some of the questions which come up when deciding how to proceed with the death claim.  The initial step is to establish that there is in fact a valid death claim.  Once that occurs, neither the insurance company nor the surviving spouse is under any obligation to settle the claim. However, because of the uncertainty of how much will be paid and for how long, both parties will typically have an interest in working out a resolution which shares the risk among all the parties.  One thing is clear – experienced workers’ compensation counsel is a must for anyone going through the very sad situation of an untimely death of a loved one caused by work.  The situation is difficult enough.  It is important for surviving spouses and children to learn their rights and to have competent counsel direct them through the process of litigation and settlement.

Daniel E. McCabe, Esq., is an associate in the law firm of Wolf, Baldwin & Associates, P.C..  He and managing attorney Levi S. Wolf are two of less than 200 lawyers across the state who have been certified as specialists in the practice of workers’ compensation law by the Pennsylvania Bar Association’s Section on Workers’ Compensation Law as authorized by the Pennsylvania Supreme Court.  His practice, located in the firm’s West Chester office, concentrates on the representation of injured workers and medical providers.  He can be reached by phone at 610-436-8300, or by e-mail at