-demand letter assignment I (3)

.docx

School

National University *

*We aren’t endorsed by this school

Course

2

Subject

Business

Date

Jul 2, 2024

Type

docx

Pages

6

Uploaded by ChancellorTeam10131

Litigation 2 PLA 426 Assignment I Demand Letter (15 pts.) Directions : On Sunday, August 6, 2015, at approximately 9:00 AM, Betty Bad-Luck, age 54, was driving to church. Betty was driving in a northerly direction on First Street in the city of La Verne, California at the speed limit of 30 MPH. As Ms. Bad-Luck approached the four-way stop sign-controlled intersection of First and Main Street, she brought her car to a complete stop at the limit- line, looked in both directions and proceeded to drive through the intersection. Betty had just entered the intersection when Cameron Careless, age 22, was speeding along (approximately 50MPH) on the eastbound direction of Main Street. Cameron had just broken-up with his girlfriend the night before and he was suffering a hangover from “drowning his sorrows.” Mr. Careless, unaware of the stop sign, crashed his vehicle into Betty’s car thereby causing Betty personal injuries and property damage. As a result of the accident, Betty was hospitalized four 3 weeks with a broken leg, cracked ribs, and severe concussion. Ms. Bad-luck is currently going twice per week for physical therapy and will continue doing so for approximately one year. Betty can’t continue her employment as a waitress at International House of Pancakes where she was earning $30,000 per year in wages plus tips. Nor can Betty pursue her lifelong ambition of becoming a belly dancer. Betty’s 1977 Ford Pinto automobile, valued at 350.00 was totaled. Your boss, Bob Bush is so impressed with your skills that he has asked you to draft a demand letter for his signature, to Cameron Careless’ insurance carrier. Use your imagination as to facts that I have not provided such as the name & address of Cameron’s insurance carrier. 1
I have included a form that you may revise to the facts of our case or, you may use any other demand letter form. I want a final draft, signed by Bob Bush, turned into me. Essentially, in the demand letter, you will outline the facts of the accident (in the light most favorable to our client), specify Betty’s damages & amounts (you may also want to consider future medical expenses and loss of earning capacity) and then “demand” a settlement amount. 2
California Practice Guide: Personal Injury Justice Zerne P. Haning (Ret.), William F. Flahavan, and Daniel J. Kelly Chapter 4. Bodily Injury Claim Settlements Forms FORM 4:A POLICY LIMITS DEMAND LETTER ABEL & HOWE s Attorneys at Law 101 Court Square Center City, CA 96101 (406) 686-2089   February   21,   ____                                                                                                                                               Fairdeal   Indemnity   Co.                                             911   Sutter   Street                                                       Center   City,   CA   96104                                                                                                                                       Attn:     Donald   Parnell,                                                           Claims   Manager                                                             Re:   Strong   v.   Rose                                                     Date   of   Accident:   August   17,   ____                       Your   Insured:   Donald   and   Rhonda   Rose                 Your   File   No.:   88-2020-1   KWD                                 Settlement   Demand:   $100,000                                   Expiration   of   Demand:   March   21,   ____     As you know, our office represents Mr. Stuart Strong who has a claim for personal injuries and property damage against your insured, Donald and Rhonda Rose, arising out of an incident that occurred on the date stated above. You have previously advised us that the policy limit on Mr. and Mrs. Rose's insurance coverage with your company is $100,000 per claim for personal injury and property loss. The general and special damages sustained by our client, as detailed below, are substantially in excess of that amount, and we believe that if the case goes to trial he will undoubtedly recover far more than $100,000. Nevertheless, because of the limited insurance coverage available in this case, Mr. Strong has authorized us to settle all claims against your insured for the policy limits, $100,000. Mr. Strong's settlement demand is based upon the facts stated below:   1.   Collision   of   vehicles:   On   August   17,   ____,   at   approximately   10:00   P.M.,   our             client   was   proceeding   in   an   eastbound   direction   on   Lincoln   Valley   Road.                 Because   of   the   rainy   weather   and   poor   visibility,   he   was   traveling   less                 than   the   posted   speed   limit   of   35   mph.   As   he   approached   the   curve                             approximately   one   mile   West   of   the   intersection   with   State   Highway   157,   he           was   struck   head-on   by   a   vehicle   driven   by   your   insured,   Mrs.   Rhonda   Rose,             and   registered   to   your   insureds,   Donald   Rose   and   Rhonda   Rose.                                                                                                                                                                                               Physical   evidence   and   the   several   witness   statements   given   to   the   police   at             the   scene   of   the   accident   indicate   that   Mrs.   Rose's   vehicle   had   been                       traveling   westbound   on   Lincoln   Valley   Road;   that   as   she   rounded   the   curve             approximately   one   mile   West   of   State   Highway   157   intersection,   Mrs.   Rose               was   driving   in   excess   of   the   posted   speed   limit   and   her   rate   of   speed   was             also   excessive   for   the   then-existing   road   and   weather   conditions;   that   she           apparently   lost   control   of   her   car;   and   that   it   crossed   over   the   double                 yellow   dividing   line   into   the   eastbound   traffic   lane   and   struck   Mr.               3
Your preview ends here
Eager to read complete document? Join bartleby learn and gain access to the full version
  • Access to all documents
  • Unlimited textbook solutions
  • 24/7 expert homework help