Demand Letter Template

Key:

Red = Update with your information

Blue = Examples; update with information from your accident

Stephen A. Brown
4876 West Main Street
Denver, CO 80507

Home phone: (555) 791-4862

Cell phone: (555) 251-3699

Email: [email protected]

American Motor Insurance Liability, Inc.

Rebecca Smith – Senior Claims Adjuster
Commonwealth, VA 02839

April 1, 2014

DEMAND LETTER: FOR SETTLEMENT PURPOSES ONLY

Re: Claim Number B-1865J2,

Insured: Amy C. Jones, DOB 08/17/1976
Claimant: Stephen A. Brown, DOB 09/13/1982
Date of Accident: January 25, 2014

Dear Ms. Smith:

On January 25, 2014, I was severely injured when your insured, Amy C. Jones, failed to
stop at a red traffic light and violently struck my car while I was driving through an
intersection with a clearly green traffic light.

My doctors have advised me that my medical condition is now stable. Although I am still
experiencing significant pain and suffering, I am ready to bring this matter to a conclusion.
In order to facilitate settlement of my claim, I have compiled the following information for
your review. I have also included supporting documentation, attached to this letter as
Exhibits A-D.

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Background

On January 25, 2014, at approximately 7:45 a.m., I was driving my 2010 Toyota Prius
westbound on Mountain View Avenue in Denver, Colorado. At all times, I was paying
careful attention to the road, traffic lights, and other vehicles in my line of sight. There
were no severe weather conditions or other unusual road conditions present. I was wearing
my seatbelt.

As I approached the intersection of Mountain View Avenue and Main Street, I could see
that the traffic light was clearly green and in my favor. As I passed through the light,
suddenly and without warning, your insured Amy C. Jones violently struck the front left
half of my Toyota. The primary point of impact was the front left door adjacent to the
driver’s seat. The severe force of the impact sent my car careening through the intersection.
It only came to a stop when it struck a lamp pole at the northwest corner of the intersection.
For more information about the accident, see Exhibit A (the police report) and Exhibit B
(photographs of the accident scene).

Injuries

The force of the sudden impact and the severity of the accident caused me to sustain the
following injuries:

 Fractured my left elbow;

 Tore tendons in both shoulders;
 Lacerated my forehead and upper left arm;
 Experienced severe whiplash at the time of impact;
 Herniated my disk at the C-3 level; and
 Caused deep bruising along the left side of my body.

Emergency personnel did not respond to the scene of the accident for more than 15 minutes.
During that time, I was bleeding profusely from my forehead and was experiencing severe
pain all over my body. When emergency personnel finally arrived to the accident scene, I
was immediately transported to the emergency room at Saint Thomas Hospital in Denver.

At the hospital, I received 15 stitches on my forehead and underwent a series of

examinations and tests. These tests included a magnetic resonance imaging examination
(“MRI”), X-rays, a computer axial tomography scan (CAT scan), and blood tests. I was
informed that I had fractured my left elbow, and doctors applied a full-arm cast to my left
arm. I was also informed that I had sustained a herniated disk at the C-3 level and tore
tendons in both shoulders, both of which would require ongoing chiropractic care. I was
told to regularly ice the severe bruises along the left side of my body. For more information
about my injuries, see Exhibit D (my medical records and associated expenses).

Since the date of the collision, I have undergone months of painful treatment and physical
therapy. I have incurred significant out-of-pocket expenses for prescription medications.

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My physicians and chiropractor instructed me not to work. As a result, I have lost several
thousand dollars in income from my job as a regional manager at Barry’s Sporting Goods.
I have not been cleared to return to work and do not know when I will be able to do so.

My recovery period has been long and extremely painful. It has disrupted my daily life and
relationships since the date of the accident. Due to the significant pain I have experienced,
I have had trouble sleeping and can no longer attend family gatherings or my son’s sporting
events. My inability to earn income has strain my marriage and negatively impacted my
relationship with my children.

Liability of Your Insured

Your insured, Amy C. Jones, is clearly liable for my injuries and other losses. The police
report (Exhibit A) and statements made by witnesses (Exhibit C) confirm that your insured
failed to stop at a red light and hit my car as I was driving through the intersection on a
green light. When questioned by police at the scene of the accident, your insured admitted
to being distracted by a phone call at the time of the accident.

Police Officer Dominic McCarthy issued your insured a traffic citation for failing to stop
at the red light. Your insured’s negligent actions were the direct and proximate cause of
the accident and my resulting injuries.

As a result of the serious accident caused by Amy C. Jones, I have incurred the following
expenses and losses:

Damages

Special damages:

Ambulance ride to hospital $750.00

Emergency room treatment $4,500.00
Total non-emergency medical treatment to-date $3,875.50
Future medical treatment required $9,500.00
Chiropractic treatment $850.00
Prescription medications $425.00
Lost wages $8,750.00

TOTAL SPECIAL DAMAGES: $28,650.50

General damages:

Emotional distress $5,000

Loss of consortium $5,000
Pain and suffering $79,951.50

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 TOTAL GENERAL DAMAGES $89,951.50

TOTAL PERSONAL INJURY DEMAND: $118,602.00

I hereby demand $118,602.00 to account for my injuries and other losses that were directly
and proximately caused by the negligence of your insured, Amy C. Jones. I expect to
receive a reply to this demand letter no later than 21 days from the date of the postmark.

Thank you for your time in considering my claim. Please do not hesitate to contact me for
additional information or with any questions you may have.

Sincerely,

Stephen A. Brown

ATTACHMENTS: Exhibit A, Police Report

Exhibit B, Photographs of accident scene
Exhibit C, Witness statements
Exhibit D, Medical records and receipts

This template is provided for free courtesy of McCormick & Murphy, P.C. Visit us online: McCormickMurphy.com