提出和解的具體金額
VIA FIRST CLASS MAIL
May 18, 2006
Mr. Stingy Hand
Never Paiu Insurance Corp.
Mail Box # 000
Welfare, NV 11011
Re: Our Client: Mrs. Travel
D.O.A.: 12/25/05
Your Insured: Mr. Hitter Hard
Your Claim Ref. #: Nopei-000000
Dear Mr. Hand:
Pursuant to my letter of July 7, 2005, I am enclosing Dr. Examiner’s medical report in
regard to Mrs. Travel’s facial scarring and the prognosis for plastic surgery.
As you probably are aware, liability is not an issue as your insured failed to maintain
proper control of his automobile, striking a guardrail head on at Accident Avenue
near the Penn Station intersection.
As a result of the accident and injury, Mrs. Travel has been forced to endure constant
and severe pain in her head, back and neck. She has experienced dizziness and
numbness throughout her body, and to this day, continues to have problems with her
vision.
Additionally, Mrs. Travel was forced to spend the night in the hospital and was
required to undergo hours of burdensome and uncomfortable diagnostic medical
tests including a CT scan. The injuries sustained by my client were such that her
normal life activities were and will continue to be impaired. He also has expended
considerable sums of money for her medical treatment as outline below:
AMBULANCE USD $300.00
HOSPITAL USD $4,513.00
DOCTORS
H.R. Hospital physicians USD $2,700.00
Drs. Yoo, Sader, Painer (Ophthalmology) USD $3,100.00
Dr. Examiner (Plastic surgery) USD $500.00
FUTURE SURGERY (estimate) USD $5,000.00
TOTAL USD $16,113.00
As a further result of the accident, and as is noted by Dr. Examiner, Mrs. Travel has
scarring to her face, some of which is permanent. In order to
correct that scarring, which can be improved, Mrs. Travel will require plastic surgery.
Notwithstanding the fact that Mrs. Travel is till experiencing pain and discomfort,
which will require additional treatment, we are now in a position to settle this matter.
We believe that a fair and equitable amount to settle this claim would be the sum of
USD $163,274.00 for actual damages including, but not limited to, the pain and
suffering Mrs. Travel has endured and continues to endure as a result of this accident
and injury.
Thank you for your attention to and cooperation in this matter, and I look forward to
hearing from you soon.
Sincerely yours,
Zhang, Wang & Lee
_________________
Deguang Zhang, Esq.
DGZ/ct
Encl. (1)
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