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Settlement Demand Letter for Personal Injury Litigation

April 24, 2013


SUITE 5055


ATTN: 0.J. Kildum,


RE:      My Client:                   G. Howett Hurt

Your Insured:              Scott Free

Your Claim No.:         0123456789000000

Dear Mr. Kildum:

Enclosed are the complete medical bills and reports for my client, G. Howett Hurt. You are already in possession of original photographs taken of Mr. Hurt while he was standing at the accident intersection.

The medical specials are as follows:

Newtown Square Fire Co #1 Newtown Community Hospital M.E.P.S. Services

Dr. David Smith

Main Line Open MRI

Dr. Michael M. Johnson


$285.00 181.66

355.00 12,455.00 1,000.00 1,525.00 $15,801.66

Mr. Hurt was severely injured on February 9, 2012 as the direct result of the negligence of your insured, Scott Free. Mr. Free drove his motor vehicle directly into Mr. Hurt while he was lawfully crossing at the intersection shown in the photographs. Your insured struck my client without any warning of any kind.

Newtown Square Fire Company rushed Mr. Hurt to MercyCommunityHospital. He was diagnosed at the hospital with contusions of his left hand and left thigh. The hospital notes document an abrasion on his fingers and a hematoma covering one third of his thigh. The x-rays at the emergency room were of his pelvis, lower back, fingers of the left hand, left hip, and left knee.

My client began treatment with Dr. David Smith on February 15, 2012. He had cervical spine x-rays on that date, since his neck had begun hurting after the day of the accident. Although these x-rays were negative for any acute fractures, Mr. Hurt did show a severely decreased cervical lordotic curve. Mr. Hurt complained at the time of Dr. Smith’s initial exam of dizziness, pain to his head, neck, thoracic spine, lumbosacral spine, and left leg.

My client received consistent treatment from Dr. Smith through February 16, 2012. His treatment included soft tissue manipulation, electrical stimulation, ultrasound therapy, cryotherapy, hydroculator therapy, as well as osseous manipulation. He received ninety-four treatments during his year of therapy. The treatment helped Mr. Hurt slowly progress through his neck, left knee, and lumbosacral pain. The pain in the latter region radiated to his left lower extremity.

Dr. Smith reported that he experienced “slow, but steady improvement of his condition both objectively and subjectively. However, there were periods when the symptomotology was somewhat severe and as a result of the persistent symptomology he was referred out for neurological testing as well as an MRI study.” Dr. Smith felt that his radicular symptoms and his radiculopathy were caused by this accident and that as of February 16, 2012, his condition had become permanent and stationary. He therefore elected to discharge my client at that time with a poor prognosis.

Dr. Smith referred Mr. Hurt to Michael Martin Johnson, M.D. Dr. Johnson examined Mr. Hurt on June 8, 2012, at which time Mr. Hurt complained of frequent headaches, neck pain, paresthesia, and numbness in his hands. Dr. Johnson noted his radiating lower back pain that moved into his right lower extremity down to the toes. His impression was bilateral lumbosacral radiculopathy, cervical strain, and post-traumatic headache syndrome. The EMG performed on June 8, 2012, was abnormal for both the right and left lower extremities for early subacute L5-S1 radiculopathy.

Mr. Hurt had only $5,000.00 in medical bill coverage. This was exhausted and claim is hereby made for the excess. In view of the clear liability and the severity of the damages sustained, settlement demand is hereby made in the amount of $75,000.00.

Please contact me after review of this claim is complete.

Very truly yours,


EKA/sb Enclosure

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