Personal Injury Demand Letter

DATE: [____________]. TO: [____________] ("Responsible Party" / Insurance Carrier: ____________, Claim No.: ____________), [____________] (Address). FROM: [____________] ("Claimant"), [____________] (Address). RE: Personal Injury Claim, Incident of [____________] at [Location: ____________]. This letter constitutes a formal demand for compensation arising from injuries sustained by Claimant as a result of the negligence and/or wrongful conduct of Responsible Party on or about [____________] at [____________] (the "Incident").

On [____________], Responsible Party [describe how the incident occurred and the specific negligent or wrongful acts: ____________]. Responsible Party owed Claimant a duty of [reasonable care / premises safety / product safety / other: ____________] and breached that duty by [____________]. The Incident was caused solely by Responsible Party's negligence and/or wrongful conduct. Claimant did not contribute to the Incident. In support of liability, Claimant relies upon: (a) [police report / incident report] No. [____________], dated [____________], attached as Exhibit A; (b) witness statements from [____________], attached as Exhibit B; (c) [photographs / surveillance footage / other evidence: ____________], attached as Exhibit C; and (d) [expert opinion from ____________], attached as Exhibit D.

As a direct and proximate result of the Incident, Claimant sustained the following injuries: [____________] (the "Injuries"). Claimant received emergency medical treatment at [____________] on [____________] and has continued to receive treatment from the following providers: (a) [Provider Name / Specialty], Treatment for [____________] from [____________] through [____________]; (b) [Provider Name / Specialty], Treatment for [____________] from [____________] through [____________]; and (c) [other providers: ____________]. Claimant's prognosis is [____________], and Claimant [has reached / has not yet reached] maximum medical improvement as of [____________].

Claimant's medical expenses to date are as follows: (a) Emergency room / hospital: [$__________]; (b) Physician / specialist fees: [$__________]; (c) Surgery: [$__________]; (d) Physical therapy / rehabilitation: [$__________]; (e) Medications and medical supplies: [$__________]; (f) Diagnostic imaging (X-ray, MRI, CT scan): [$__________]; (g) Future medical expenses (estimated): [$__________]; (h) Other medical costs: [$__________]. TOTAL MEDICAL EXPENSES: [$__________]. Itemized medical bills and records are attached hereto as Exhibit E. Future medical expenses are based on the opinion of [treating physician / medical expert: ____________], attached as Exhibit F.

In addition to economic damages, Claimant has suffered and continues to suffer substantial non-economic damages as a direct result of the Injuries, including: (a) physical pain and suffering, including [describe ongoing pain, discomfort, limitations: ____________]; (b) emotional distress and mental anguish, including [describe: ____________]; (c) loss of enjoyment of life, including inability to engage in [recreational activities / hobbies / family activities: ____________]; (d) disfigurement or permanent scarring, specifically [____________]; and (e) [other non-economic damages: ____________]. Claimant values the non-economic component of this claim at [$__________] based on the severity, duration, and permanence of the Injuries.

Claimant has also suffered the following additional economic damages: (a) lost wages and income, Claimant was unable to work from [____________] through [____________] and lost income of [$__________], documented in Exhibit G; (b) loss of future earning capacity, as a result of permanent impairment [of _____%], Claimant's future earning capacity has been diminished by an estimated [$__________]; (c) out-of-pocket expenses, transportation, household services, and other costs of [$__________], documented in Exhibit H; and (d) property damage, [describe: ____________] in the amount of [$__________]. These damages are supported by the documentation referenced herein and the opinion of [vocational expert / economist: ____________], if applicable.

Based on the foregoing, Claimant's total damages are summarized as follows: (a) Past Medical Expenses: [$__________]; (b) Future Medical Expenses: [$__________]; (c) Lost Wages (past): [$__________]; (d) Lost Earning Capacity (future): [$__________]; (e) Pain and Suffering / Non-Economic Damages: [$__________]; (f) Property Damage: [$__________]; (g) Other Economic Damages: [$__________]. TOTAL DAMAGES: [$__________]. Claimant hereby demands the sum of [$__________] (the "Settlement Demand") in full and final settlement of all claims arising from the Incident and the Injuries, including all past and future damages.

To accept this Settlement Demand, Responsible Party / Insurer must provide written acceptance and a signed release agreement on or before [____________] (the "Demand Deadline"). Claimant reserves the right to withdraw or modify this Settlement Demand at any time prior to acceptance. This demand is made in good faith and represents Claimant's current assessment of damages; it does not constitute a waiver of any right to seek greater damages in litigation, including punitive damages where applicable. If this matter is not resolved by the Demand Deadline, Claimant will file suit without further notice, seeking all compensatory and other available damages, together with attorneys' fees where authorized by law. All documentation referenced herein is incorporated into this demand by reference. This letter is protected by applicable attorney-client and work-product privileges to the extent applicable.