Draft a letter from the attorney to the client, Mrs. Ipana, discussing whether this is a reasonable settlement in light of Mrs. Ipaa's injuries and the legal issues in the case. What are the pros and cons of settlement? The office has received a settlement offer of $75,000.00 from the defendant. Here is the Client intake form and Complaint filed in court.

COURTS OF THE TRIAL DIVISION OF ANYTOWN, USA IDA IPANA JURY TRIAL DEMANDED 249 Harrison Avenue Anytown, USA 11111 Plaintiff, FILED SEPTEMBER 13, 20XX V . CASE NO. 10-7575 SHIGLEY'S SUPERMARKET, INC. 1675 State Street Anytown, USA 11111 Defendant. Case No. CIVIL ACTION COMPLAINT 1. Plaintiff, Ida Ipana, is an adult individual who resides at 249 Harrison Avenue, Anytown, USA. 2. Defendant, Shigley's Supermarket, Inc., is a corporation organized and existing under and according to the laws of Anytown, USA having its principal place of business located at 1675 State Street, Anytown, USA. 3. On or about November 11, 20XX, plaintiff, Ida Ipana, was a business invitee of defendant, Shigley's Supermarket, Inc., when she was caused to slip, trip, stumble or fall due to the dangerous and defective condition of the defendant's premises, thereby sustaining the serious and severe injuries hereinafter described more fully. 4. At all times material to the within cause of action, defendant, Shigley's Supermarket, Inc., acted by and through its agents and employees who were then and there acting within the scope of their employment and authority. 5. At all times material to the within cause of action, defendant, Shigley's Supermarket, Inc. knew or should have known of the dangerous and defective condition of its premises.6. The aforesaid incident was caused solely and proximately by the actions of the defendant acting as aforesaid and which consisted, inter alia, of the following: a. Failing to properly maintain the premises so as to furnish business invitees, including plaintiff, with a safe environment in which to conduct business; Improperly maintaining the premises so as to furnish business invitees, including plaintiff, with a safe environment in which to conduct business; Failing to repair defects that existed prior to plaintiff's fall; Improperly repairing defects that existed prior to plaintiff's fall; Failing to properly supervise its employees in the maintenance and care of the premises; Improperly supervising its employees in the maintenance and care of the premises; . Failing to inspect the premises; Improperly inspecting the premises Failing to warn plaintiff and other invitees of the dangerous and defective condition that existed on the premises; Improperly warning plaintiff and other invitees of the dangerous and defective condition that existed on the premises; Otherwise failing to exercise due care in the maintenance of its premises and in its duty to plaintiff. 7. Solely as a result of defendant's negligence, carelessness, and recklessness as aforesaid, plaintiff has sustained severe and possibly permanent injuries to her body, back, neck, and limbs including, but not limited to, concussion, headaches, nausea, dizziness, blurry vision, slurred speech, cervical sprain and strain and lumbar sprain and strain. 8. Solely as a result of defendant's negligence, carelessness, and recklessness as aforesaid, plaintiff has been and may continue to be forced to expend monies on medical treatment and care in an effort to cure herself of her injuries. 9. Solely as a result of defendant's negligence, carelessness, and recklessness as aforesaid, plaintiff has suffered and may continue to suffer a loss of earnings and earning capacity all to her great detriment and loss. 10. Solely as a result of defendant's negligence, carelessness, and recklessness as aforesaid, plaintiff has and may continue to endure embarrassment, humiliation, pain and suffering. WHEREFORE, plaintiff demands judgment against the defendant, Shigley's Supermarket, Inc. in an amount in excess of FIFTY THOUSAND ($50,000.00) DOLLARS together with interest and costs of the suit. MAXINE FONTANA, ESQUIRE MacDonald & Fontana One Hightower Place Suite 108 Anytown, USA 11111 Attorney ID # 090909 Attorneys for PlaintiffCLIENT INTAKE TYPE OF CASE: Fall Down CLIENT INFORMATION: FULL NAME: Ida Ipana MAIDEN/ALIAS: Rockwell (maiden CURRENT HOME ADDRESS: 249 HarrisonAvenue, Anytown, USA 11III Home: 555-555-7690 Business: same Cell: 555-555- 9999 SOCIAL SECURITY NUMBER: 000-00-0055 DATE/PLACE OF BIRTH: January 25, 19XX, Anytown, USA MINOR: YES NO V GUARDIAN: CHILDREN/NAMES/AGES: Hilary, 10; Douglas, 7: Susan; 4 MILITARY RECORD: none CRIMINAL RECORD: none NAME/ADDRESS CURRENT EMPLOYER: Publishers' Warehouse 78356 Center Boulevard Anytown, USA 11III POSITION/YEARS EMPLOYED: Telemarketer / 4 years CURRENT SALARY/EARNINGS: 20* commission on all magazine salex Works 20-25 houryper week. Most sold in one week: $2,000.00 earning commission of $400.00. INCOME PAST 5 YEARS: between $10-20,000 per year SPOUSE INFORMATION: FULL NAME: Isaac Ipana MAIDEN/ALIAS: none CURRENT HOME ADDRESS: 249 HarrisonAvenue, Anytown, USA 11III Home: 555-555-7690 Business: 555-555-8222 Cell: 555-555-9998 SPOUSE'S EMPLOYER: Liberty University, full-time faculty INSURANCE: USA Health Care Group # ABC 54444XY; insured through husband'splanINCIDENT DESCRIPTION: DOA: Saturday, November 11, 20XX POA: Shigley's Supermarket, frozen food aisle OTHER PARTY: NAME: Shigley's Supermarket ADDRESS: Anytown Shopping Plaza 1675 State Street Anytown, USA 11111 PHONE: 555-555-4466 DESCRIPTION OF INCIDENT: Was food shopping at Shigley's Supermarket Saturday morning November 11, 20XX. Arrived at approximately 9:30 am. Carrying shoulder bag and shopping list. Placed shoulder bag in infant seat part of a shopping cart while outside the front doors and proceeded inside to first aisle to select produce. Then stopped at the meat counter and selected several packages of chicken and meat. Skipped Aisle 2 and proceeded to frogen foods in Aisle 3 which is lined with freeger cases. Plaintiff was looking in the freezer cases trying to find a particular brand. No more than 4-5 steps into the aisle, feet went out from under her. Fell backwards, struck shoulders against floor and then her head hit floor hard. Feltpain and then everything went black. Woke up in hospital On day of accident was wearing jeans, sweater, leather bomber jacket and boots with 2-inch heels. Brought home clothes worn that day when discharged from hospital Clothes stained with dirt and what looked like water or fluid stains.INJURIES/DAMAGES COMPLAINED OF: Cerebral concussions cervical injury; lumbosacral injury; slurred speech, headaches MEDICAL TREATMENT: GoodHeart Hospital, hospitalized 1 week/ Intensive Care In night Dr. Claudia Grossman, family physician -5 months Dr. Judith Kuperman, M.D., neurologist -3 visits PRIOR INJURIES: 20XX back injury while water skiing WITNESSES: Other customers and store employees - names unknown NAME: ADDRESS: PHONE: SUMMARY OF INFORMATION KNOWN TO THIS WITNESS