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. Thank you for sharing this blog packed with so many information. Visiting your site helped me to get what I was looking for.

  2. Thanks for the tips you have provided here. Cheers!

  3. I’m happy to become a visitor in this amazing site,
    thanks for this excellent info!

  4. This might be the right blog for all who wishes to be familiar with this
    topic. You already know much its practically difficult to argue along.

    Outstanding stuff, simply great!

  5. Surely you’ve got outstanding ideas here and I really like your blog!
    I’ve bookmarked it ensuring that I can come back & read
    more in the foreseeable future.

  6. The truth is that if you can not commit to a distinct plan that calls for a scheduled meal strategy and
    weekly workout system, these diet plan tablets probably
    are not going to give you the benefits that you want.

  7. I was recommended this website by my cousin. I am not sure whether this post
    is written by him as nobody else know such detailed about my
    difficulty. You’re amazing! Thanks!

  8. Very nice post, i absolutely adore this website, keep writing.

  9. I am so happy for this post and thank you for sharing it
    with us.

  10. I really like what you guys are up to. Such clever work and exposure!

    Continue the excellent works guys I’ve incorporated you guys to my own blogroll.

  11. Thanks so much for sharing this great info! I’m looking
    forward to see more posts!

  12. If you’re still on the fence: grab your favorite earphones, head down to a Best Buy and ask to plug them into a Zune then an iPod and see which one sounds better to you, and which interface makes you smile more. Then you’ll know which is right for you.

  13. I’m glad to become a visitor in this great site, many thanks
    for this excellent information!

  14. Between me and my husband we’ve owned more MP3 players over the years than I can count, including Sansas, iRivers, iPods (classic & touch), the Ibiza Rhapsody, etc. But, the last few years I’ve settled down to one line of players. Why? Because I was happy to discover how well-designed and fun to use the underappreciated (and widely mocked) Zunes are.

  15. I merely desired to thank you a lot more for
    your remarkable website you have developed here. It’s
    full of usefuladvice for those who are actually interested in this
    kind of subject, mainly this post.

  16. This website is my inspiration, very excellent design and style and also ideal articles or
    blog posts.

  17. Great I must definitely pronounce, amazed with
    your site. I had no trouble navigating throughas well as related info ended up being
    truly easy to access.

  18. Ӏn this Coѕby Sweater Project, every episode pгovides ɗifferent kinds of game to recreate his magic
    louⅾ shirts. Brief triρs are most likely to ϲonsist of erгands, deliѵering messages and fulfilling guarantees.

  19. I see you don’t monetize your blog,you can earn some additional cash,
    just search in google for; ideas by Loocijano

  20. An outstanding share! I’ve just forwarded this onto a colleague
    who has been doing a little homework on this. And he actually bought me dinner due to the fact that I stumbled upon it for him…

    lol. So allow me to reword this…. Thanks for the meal!!
    But yeah, thanks for spending some time to talk about this topic here on your internet site.

  21. Thanks for sharing with us, I think this site really stands out.

  22. I’m glad I found your article. I would never have made sense of this topic on my own. I’ve read
    several other articles on this subject, however I
    was confused till I read yours.

  23. I admire your work, many thanks for sharing
    all the helpful blogs.

  24. This article comprises wonderful genuine thinking. The informational content here
    proves that things are not so black and white.
    I feel wiser from simply reading this. Keep

  25. Thank you for this amazing post, I am happy I found this site on search engines.

  26. I don’t leave plenty of comments on lots of blogs but
    i sensed i had to here. Quality articles you have here.

  27. Thanks so much for sharing this excellent info!
    I’m looking forward to see more blog posts!

  28. Thank you for another informative blog. Where else could I get that type of information written in such an ideal way? I have a project that I am just now working on, and I have been on the look out for such information.

  29. How can i get Firefox not to prevent the installation of farm ville toolbar, Allow did not really work?

  30. I appreciate you sharing this article post. Awesome.

  31. We made a couple of songs and I want to understand how to alter the copyright laws content on an MP3 document so I may share this online? I wish to add (p) Swagers Studios (2009) towards the copyright content material and was wondering if this was feasible. Any help is significantly appreciated.. Is actually still not really letting myself edit the copyright content. Ive realized that some MP3’s I downloaded off the net have informal copyrights like ZOMG firm. If you can’t help it’s alright.

  32. Can you really register a domain name and start web site through Microsoft Small Business in UAE?.. If it is not possible through Ms small business, please advise me the best internet site to create a new website which could operate from UAE..

  33. How can I get Firefox to save a webpage in the local documents, rather than downloading it from the Internet?

  34. I’ve been exploring for a little bit for any high quality articles or blog posts in this kind of
    house . Exploring in Yahoo I eventually stumbled upon this website.
    Reading this info So i am happy to convey that I’ve a very good uncanny feeling I discovered exactly
    what I needed. I such a lot surely will make certain to do not overlook this
    web site and provides it a glance on a relentless basis.

  35. Thank you for the good writeup. It in fact was
    a amusement account it. Look advanced to more added agreeable
    from you! By the way, how can we communicate?

  36. Many thanks for sharing. I’m amazed with your website. I’ll publish this
    to my facebook wall.

  37. I see you don’t monetize your website,you can make some additional cash, just search in google for: ideas by Loocijano

  38. I haven’t checked in here for some time since I thought it was getting dull, however the last few posts are really good quality therefore I guess
    I’ll add you back to my day-to-day bloglist. You deserve
    it my friend.

  39. Useful information shared. I am very happy to
    read this article. thank you for giving us nice info.
    appreciate this post.

  40. This is getting a bit more subjective, but I much prefer the Zune Marketplace. The interface is colorful, has more flair, and some cool features like ‘Mixview’ that let you quickly see related albums, songs, or other users related to what you’re listening to. Clicking on one of those will center on that item, and another set of “neighbors” will come into view, allowing you to navigate around exploring by similar artists, songs, or users. Speaking of users, the Zune “Social” is also great fun, letting you find others with shared tastes and becoming friends with them. You then can listen to a playlist created based on an amalgamation of what all your friends are listening to, which is also enjoyable. Those concerned with privacy will be relieved to know you can prevent the public from seeing your personal listening habits if you so choose.

  41. You could definitely see your enthusiasm in the work you write. The world hopes for even more passionate writers like you who aren’t afraid to say how they believe. Always go after your heart.

  42. Hey! This website is amazing. I will tell about it to my son and anybody that could be interested in this topic. Great work guys.

  43. Hey very interesting blog!

  44. I see your blog needs some unique articles.
    Writing manually is time consuming, there is tool for this task.
    Just search in gogle for; Fejlando’s tips

  45. Good post. I learn something totally new and challenging on sites I stumbleupon on a daily basis.

    It will always be helpful to read content from other authors and practice a little something from other websites.

  46. Ponemos a tu disposición el maquillaje para la cara con diferentes tonalidades y para todo género de pieles:
    pieles grasas, secas y mixtas, a fin de que escojas el que mejor se adapte a tu color y género de piel.

Speak Your Mind