Demand Letter

Dear Sir/Madam,

RE: Personal Injury Claim for Ronald Smith

I represent Jim and Mary Smith, the parents of Ronald Smith, a minor, who was severely injured due to the negligence of your company, Midtown Electrical Company. This letter serves as a formal demand for compensation for the damages suffered by Ronald Smith.

On July 29, 2020, Ronald was riding his scooter on the sidewalk at 1236 Any Street, where your company had recently installed a new street light. The sidewalk was left partially broken and unattended, causing Ronald to trip and fall. As a result of this fall, Ronald sustained significant injuries, including a laceration requiring stitches, a permanent scar, a chipped tooth, and other cuts, scrapes, and bruises. His scooter and eyeglasses were also damaged in the incident.

The negligence of your company is clear in this matter. Midtown Electrical Company had a duty of care to ensure that the sidewalk was safe for public use. This duty was breached when your company left the sidewalk in a hazardous condition and failed to return to repair it as planned. This breach of duty directly resulted in Ronald's injuries.

The medical expenses incurred due to this incident are substantial. Ronald was treated at Mercy Hospital's emergency room, and he has since required treatment from a dentist, a plastic surgeon, an eye doctor, and his pediatrician. The total medical bills amount to $15,000. Additionally, the cost to replace Ronald's broken scooter and eyeglasses is $200.

Furthermore, Ronald has suffered significant pain and suffering due to this incident. He has endured physical pain from his injuries, emotional distress from the trauma of the accident, and inconvenience due to his ongoing medical treatments. For these non-economic damages, we demand compensation in the amount of $30,000.

In total, we are seeking $45,200 in compensation for Ronald's injuries, property damage, and pain and suffering.

We trust that you will take this matter seriously and respond promptly. If we do not receive a satisfactory response within 30 days of this letter, we will have no choice but to pursue legal action to seek the compensation that Ronald is entitled to.

Thank you for your immediate attention to this matter.

Sincerely,

Michael Attorney

Attorney

A. Directions:Prepare a Complaint on behalf of the Smith's from the demand letter scenario. You should sue all responsible parties. You may use the generic format as illustrated in the PCD book.The Complaint is a formal pleading and not a letter.

NOTE:you may embellish any needed facts for theComplaintincluding the amount of any medical bills for each provider or medical liens owed, lost wages, if any, and all out of pocket expenses. Make sure the embellished facts support the claim and remain within the given factual framework. Be sure to explain liability for all responsible parties and damages including pain and suffering. Feel free to use your city and state and any attorney names, addresses etc. should be fictional.

B. Directions:Prepare an Answer to the Complaint on behalf of one of the defendants named in your Complaint. You may use the generic format as illustrated in the PCD book.The Answer to the Complaint is a formal pleading and not a letter.