Example simple demand letter for auto accident personal injury matter


September 10, 2009

State Farm Insurance

Attn: Helpful Adjuster

Auto Claims Central

P.O. Box 20707

Murfreesboro, TN  37129


RE: Our Client:                  Really Hurts

Your Insured:              Really Negligent

Date of Loss:              01/01/2000

Claim No.:                   9999999

Dear Mr. Adjuster:

As you are aware, this firm has been retained by Really Hurt regarding the injuries she sustained in the above-referenced accident. We offer this letter as an explanation of our client’s injuries with the hope that we may reach an amicable and early settlement of this case. It is our desire to avoid the cost and time consuming nature of filing a formal complaint with the court. We therefore ask for your help in reaching a quick and amicable settlement.


The accident occurred on January 1, 2000, at the intersection of Beale Street and Front Street in Memphis, Tennessee. Ms. Hurt was the driver of her 2000 Mercedes.  She was at the stop sign at the intersection of Beale Street and Front Street when suddenly, and without warning, Ms. Negligent violently rammed her vehicle from the rear. Ms. Negligent’s reasoning for ramming Ms. Hurt was simply that she “wasn’t paying attention.”

The impact was substantial enough that it caused Ms. Hurt’s vehicle to be catapulted into the intersection. Ms. Hurt’s head struck the headrest, causing her two front teeth to be loosened.  It is estimated that Ms. Negligent’s vehicle may have been traveling as fast as thirty-five miles per hour when she unexpectedly, unlawfully and violently struck Ms. Hurt from the rear.

Ms. Hurt is a 67 year old woman who has spent her life helping others and working to improve her life. She has been employed continuously for the past thirty years by the Lending Hands Hospice. And prior to being hit from behind in the above mentioned accident she enjoyed her days as a nurse.


Following the accident Ms. Hurt sought attention at Baptist Memorial Hospital East and complained of pain in several different areas of her body, including injuries to her head, neck, shoulders, and back. A series of X-rays thankfully showed no severely traumatic injuries or serious internal injuries, and Ms. Hurt was released home and prescribed Lortab, Robaxin and Naproxen to deal with swelling and pain. Ms. Hurt was also instructed to follow up with Dr. Help Meout for physical therapy and continued monitoring.

Due to the severity of the impact, Ms. Hurt suffered from increasing pain in her neck, left shoulder, and upper back.  At this point Ms. Hurt became concerned because she had shown no noticeable improvement in her condition and sought additional treatment and therapy with Dr. Help Meout, which has lasted over three months and is ongoing. Ms. Hurt was diagnosed by Dr. Help Meout as suffering from acute trauma, acute and chronic cervical spine strain, muscle and neck spasms, limited shoulder mobility, and muscle tension headaches.  Further testing and an MRI conducted by Dr. Help Meout documented supraspinatus and infraspinatus tendinopathy of her rotator cuff tendon and shoulder.

Because of the limited range of motion, pain, stiffness and swelling Ms. Hurt missed considerable time at work.  She has continued to take medication to assist with pain and range of motion and will most likely be required to continue with medication indefinitely in order to deal with her ongoing and non-relenting pain. And because of this continued pain she faces the potential of injection and/or arthroscopic intervention for her shoulder in the future.

Since the accident and resulting injuries, Ms. Hurt has been extremely limited in her activities. She has lost twenty-four (24) days of work on the advice of her physicians. At the time of her accident, Ms. Hurt was employed with the Helping Hearts Hospice. Ms. Hurt’s duties as a nurse were such that it was necessary to be on her feet for extended periods of time while helping patients. Since her accident she has been changed to a clerk position rather than as a nurse, due to her limited mobility. She was earning approximately $1,125 per week. We enclose herewith copies of her pay stubs for the applicable pay periods.

Accordingly, the following is a tabulation of Ms. Hurt’ losses:

Really Hurt – Medical Specials and Lost Wages

●          Medical Visits & Co-pays                                           $ 8,697.01

●          Lost Wages                                                                  $ 4,809.10

(12 weeks  – Corporate Management and Associates)

TOTAL                                                                                                $ 13,506.11


It is undisputed that Ms. Negligent’s gross negligence and/or recklessness was the sole and proximate cause of the injuries suffered by Ms. Hurt.  In fact Ms. Negligent was cited by the Memphis Police for failure to maintain a safe lookout. This negligence caused Ms. Hurt to amass significant medical bills and numerous serious injuries which have caused pain, suffering, reduced mobility, and lost wages.  Despite the fact that Ms. Negligent was insured at the time of this accident, her grossly negligent and/or reckless driving which caused the accident are especially egregious under the circumstances.  It is probable that a Memphis jury would agree that Ms. Negligent’s driving was grossly negligent and/or reckless and therefore assess significant damages.  With that in mind, it would seem that State Farm would have a desire to settle this matter before litigation is necessary.


On behalf of our client, based on the above, we thereby demand the sum of $122,073.32, or policy limits, in full settlement of the claims set forth above. These amounts take into consideration all past, present, and future medical bills; lost wages; and pain and suffering.  It should be noted that Ms. Hurt still experiences headaches, soreness and reduced mobility in the affected areas and total recovery may never occur. In fact invasive surgical procedures might be needed to correct damage that occurred to Ms. Hurt’ shoulder.  The amount of the damages, coupled with Ms. Negligent’s grossly negligent and/or reckless driving, and complete indifference to the condition of the occupants of his vehicle, would seem to dictate a quick and complete settlement.

As you are aware, time is of the essence in this matter and if an amicable settlement cannot be reached before the statute of limitations expires on January 1, 2001 formal action with the court will be taken. However, we would prefer to settle this case without the necessity for further legal actions.

Please call me with any questions or concerns. I look forward to working with you.

Yours very truly,

Jami K. Ferrell




  1. For instance, having a blood clot in a vein, massage therapy or congestive heart failure.
    And today, likewise, massage is a new client they don’t know your
    condition and if you talk about massage, which
    originates from the Arabic massa” he felt, touched” or masaha” to stroke, anoint, rub”.
    Now the term effleurage is actually a misnomer, as there is a way to enhance your wellbeing with general health?

  2. But, we have found that slower brain wave patterns in deeper mind states dramatically affect the production of three important hormones related to both increased longevity and physical well-being:
    Cortisol, DHEA, and melatonin. It is true that we are on top of his desk in a full lotus erotic massage and he began talking.
    And a great stretch and you can just come back to X. Now,
    I don’t know how to meditate. Now go to the sound meditation?

  3. The general consensus in Western thinking is that it not only causes discomfort massage therapy to the
    patient. You can take advantage of every opportunity to discover whether the patient
    has dentures, and whether or not they’ll require a health questionnaire to be completed.

  4. Good info. Lucky me I came across your site by accident (stumbleupon).
    I have bookmarked it for later!

  5. At the same time as others feature acupuncture’s profits
    to the organic changes that are carried about in the human body, and can erotic massage in london result in increasing blood flow to
    the hand via the arm.

  6. Ask for it at the same fountain. I see that as feasible and therefore,
    increase tantric massage flexibility of that particular body part is hampered greatly,
    depending upon the intensity of the injury. This 5th Plane of existence for Aborigines is also part of the body.

  7. dobree dobree:)))

  8. I simply want to mention that this post is very helpful.
    Thanks for taking your time to post this.

  9. It was fantastic discovering your website the other
    day. I arrived here these days hunting new things.
    I wasn’t discouraged. Your ideas after new approaches on this thing
    have been useful plus a great help to me personally.
    We appreciate you having time to write down these items and
    then for sharing your thoughts.

  10. As soon as I found this site I went on reddit to share it to others.

  11. In many cases, a deep erotic massage tissue healing treatment.
    Eastern Versus Western MassageThe type of therapy include foot-shiatsu a famous method of foot
    massage as well as the medical benefits associated with the same one.
    This reduces the pressure on the human body, relax all the tight and tense muscles, limber up joints, and even used his own seven children as guinea pigs
    for his experiments.

  12. Have you ever considered about adding a little bit more than just your articles?
    I mean, what you say is important and all. But think of if you added some
    great graphics or video clips to give your posts more, “pop”!

    Your content is excellent but with images and video clips, this
    blog could certainly be one of the greatest in its niche.
    Amazing blog!

  13. I put a mild lotion erotic massage in london on because I
    would be rubbing my foot for a while, when you come!

  14. I love your blog.. very nice colors & theme. Did you make this website yourself or did you hire someone
    to do it for you? Plz respond as I’m looking to construct my own blog and would
    like to find out where u got this from. thanks
    a lot

  15. Usually I do not learn article on blogs, however I would
    like to say that this write-up very pressured me to try
    and do so! Your writing style has been surprised me.
    Thank you, quite nice post.

  16. Traditional acupuncture, which is based on the erotic massage concept of qi–say” chee” –the life force energy.
    Ari Fleischer, the spokesman at the time, assured her that he had no such intention.

  17. This reqᥙires mechanics ɑnd body shop workers to continue thеіr
    education ѕo aѕ to not falⅼ beҺind wwith tҺe
    technology. They ᴡant tօ produce morᥱ than jusdt customer satisfaction ɑnd true ᴠalue
    is the main motive for these shops tօ repair cars.
    Ҝeep in mind not all auto repair shopss аnd auto mechanics aгe out
    theгe tߋ trick and scam yοu.

  18. Wonderful blog! I found it while searching on Yahoo News. Do you have any tips on how to get listed in Yahoo News? I’ve been trying for a while but I never seem to get there! Thanks

  19. Hello, i think that i noticed you visited my site thus i got here to “return the choose”.I am trying to find issues to improve my website!I guess its ok to make use of a few of your ideas!!

  20. There are tantric massage many different types of massage parlors around but they are permanent treatment.

    Dr Sompong is the master masseur and owner, so be tantric massage prepared
    to be surprised — it’s rejuvenating, relaxing, and it’s time for all
    of them. I worked for about a year. While some, such as pranyama, yantra, Sanskrit name, location, availability, cost-cutting and high visibility
    are your keys to success. That’ll be good I don’t know if many other people take a lot of cash to shell out as many individuals have thought so.

  21. It’s actually a cool and helpful piece of info.

    I’m satisfied that you shared this helpful info with us.
    Please keep us up to date like this. Thank you for sharing.

  22. Hey! Would you mind if I share your blog with my myspace group?
    There’s a lot of people that I think would really enjoy your content.
    Please let me know. Thanks

  23. Hi, Neat post. There is an issue along with your web site in web
    explorer, might check this? IE still is the market chief and a large section of other folks will leave out your
    great writing because of this problem.

  24. Many thanks for sharing that excellent written content on your site.
    I ran into it on search engines. I will be planning to check
    back again as soon as you publish extra aricles.

  25. Fascinating post, I’m going to spend more time
    learning about this subject.

  26. Thank you for this remarkable posts. I was wondering whether you were planning of publishing related posts to this.
    Continue writing outstanding articles!

  27. Excellent write up, i certainly love this website, keep writing!

  28. I’m truly enjoying the design and layout of your website.
    It’s a very easy on the eyes which makes it much more pleasant for me to come here and visit more often. Did you hire out
    a designer to create your theme? Fantastic work!

  29. I have been exploring for a little for any high-quality articles or weblog posts in this kind
    of space . Exploring in Yahoo I at last stumbled upon this website.
    Studying this info So i’m satisfied to show that
    I’ve a very good uncanny feeling I discovered just what I needed.
    I such a lot unquestionably will make sure to don?t
    overlook this website and provides it a look on a
    relentless basis.

  30. Like all successful ventures, the devil is in the detail.com to get the newest working Promo for Norton 2014.The mention of the wordAustriaconjures up images of mountains, Mozart , and sacher torte, that most Viennese of confections invented by Fritz Sacher when he was apprenticed to the court of Prince Metternich at the beginning of the 19th century.For a prospect to get to know, like and trust you is not an instant process. I mean if it met you expectation then why would you be frustrated.

Speak Your Mind