Demand Letter Preparation Services

Addressee:

XXX XXXX

Claims Adjuster

YYYYY Insurance Company

Re:

My Client: Patient XXXX

Your Insured: YYYY YYYYY

Claim Number: XX-YYYY-XXXXXX

Incident Date: January 18, XXXX

Dear XXXXX:

Please consider this correspondence as my client's demand for the full and final resolution of the above referenced claim.

Facts and Liability

On January 18, XXXX, at approximately 2:15 pm, Patient XXXX was operating her 2021 Honda Civic northbound on Main Street in the city of XXXX XXXX. She was stopped at a red traffic signal at the intersection of Main Street and Oak Avenue, waiting in the left-hand lane.

Your insured, YYYY YYYYY, was operating his 2019 Ford F-150 pickup truck, also traveling northbound on Main Street, directly behind Ms. XXXXXX’s vehicle. When the traffic signal turned green, Ms. XXXXXX began to proceed forward through the intersection. However, Mr. YYYYYY failed to maintain proper control of his vehicle and rear-ended Ms. XXXXXX’s Honda Civic at moderate speed.

A Traffic Crash Report was prepared by the Sssssss Police Department (Report #XX-YYYY-XXXXXX), which determined that Mr. YYYYYY caused this collision by following too closely and failing to reduce speed to avoid a collision, in violation of Illinois Vehicle Code Section 11-710(a). The investigating officer cited Mr. YYYYYY for improper following distance. (Exhibit-1)

Property Damage

As a result of the collision on January 18, XXXX, the 2021 Honda Civic that Ms. XXXXXX was operating sustained significant damage to its rear bumper, trunk, taillight assembly, and rear quarter panel. The vehicle was towed from the scene by Quick Tow Service and transported to Sssssss Auto Body for repair. The total cost of repairs was estimated at $8,742.50, which has been paid by Ms. XXXXXX’s insurance carrier with a $500 deductible paid by Ms. XXXXX. Ms. XXXXXX is entitled to reimbursement of this deductible amount.

Summary of Physical Injuries

As a result of the collision, Ms. XXXXX, a 30-year-old woman, sustained the following injuries:

Treatment of Injuries

Following the collision on January 18, XXXX, SSSSSS Fire Department paramedics (Exhibit-2) arrived at the scene and examined Ms. XXXXX. She complained of immediate onset of neck pain, upper back pain, lower back pain, and headache. A physical examination and vital signs were obtained. Her neck was immobilized with a cervical collar as a precautionary measure. She was then transported by ambulance to SSSSSS Hospital Emergency Department for further evaluation and treatment.

Ms. XXXXXX was examined by Dr. MMMM MMMMM, M.D., in the Emergency Department of SSSSSSS Memorial Hospital (Exhibit-3) for complaints of neck pain, upper and lower back pain, headache, and right knee pain. She reported her pain level as 7/10 in her neck and 6/10 in her lower back. She stated that she felt the impact from behind and her head snapped backward and then forward.

A physical examination revealed tenderness over her cervical spine, thoracic spine, lumbar spine, and right knee. She had decreased range of motion in her neck due to pain and muscle spasm. X-rays of her cervical spine, thoracic spine, and lumbar spine were obtained and reviewed. The X-rays showed no evidence of fracture or dislocation but revealed straightening of the normal cervical lordotic curve, consistent with muscle spasm.