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Sample Demand Letter – Slip and Fall – Floor Mat At Hospital
SACKRIN & TOLCHINSKY, P.A.
2100 EAST HALLANDALE BEACH BOULEVARD
HALLANDALE BEACH, FLORIDA 33009
Alan D. Sackrin, Esq.
Board Certified Civil Trial Lawyer
January 3, 20__
VIA FACSIMILE: 954-763-6322
Robert C., Esq.
Water & Hernandez et. al.
515 E. Las Olas Blvd. Suite 1000
Ft. Lauderdale, FL 33301
RE:R. Costa v. West Boca Medical Center
Palm Beach County Case#:20CA027023XXXXXMB (AO)
I am pleased to enclose a copy of the Humana Insurance Company payout sheet which details the amount of payments ($5,521.01) made in connection with my client’s fall of January 3, 20__ at your client’s facility. The amount paid is substantially less than I had anticipated which may make it easier to resolve the case. You indicated that perhaps I should send you a demand before we start taking additional depositions and possibly adding additional defendants to the case.
As I am sure you recall, Mr. Costa makes a good witness. He is likeable and was candid that the knee injury, although causing him to undergo surgery and endure substantial discomfort for several months, has not left him with any functional impairment. He only has some permanent scarring and/or disfigurement.
Assuming that Mr. Costa has incurred approximately $1,000 in out-of-pocket expenses, and given the amount that has been paid by Humana, demand is hereby made in the amount of $45,000.00 to settle this case. This is certainly a reasonable demand under the circumstances. You client, acting through its agents, knew that there was something wrong with the rug/mat and changed it immediately after the incident.
Should I not hear from you within the next few weeks, I will serve a proposal for settlement, unless you think that would be counter-productive or unless you believe that I should serve it sooner.
I look forward to hearing from you.
Very truly yours,
ALAN D. SACKRIN
This demand letter is a sample document related to a specific set of facts and circumstances and should not be used for any personal injury matter. This form is being provided for illustrative purposes only and should not be relied upon as legal advice. We recommend and urge you to consult with an experienced Florida personal injury lawyer for professional advice as each case is unique. All Rights Reserved.
Slip and falls are the second leading cause of injuries and deaths after car accidents. Every hour an older adult dies as a result of a fall. The most common injuries resulting from slip and falls include, herniated disc, head injury and/or a knee injury. Learn more from Alan Sackrin, an expert slip and fall lawyer.