Demand Letter

ENTITIES

Plaintiff MS. Mary Smith represented by Cynthia McGuinn

Defendant Mr. Paul Joseph by a Counsel

Ms. Smith was involved in a motor vehicle accident with Paul Joseph on October 3, 1995. As a result of the accident she sustained permanent injuries neck, elbow, and ankle. She had surgery to repair a broken ankle and torn Achilles tendon. Ms. Smith has been unable to work since the accident and has been declared completely disabled by her physicians and is not cleared to work. To date, Ms. Smith has suffered $403,385.40 in special damages. They are itemized as follows:

Past Medical Expenses: $ 6,549.40

Past Lost Wages: $ 12,480.00

Future Loss of Earning Capacity: $163,855.00

Future Loss of Benefits: $ 97,991.00

Pain and Suffering: $ 123,000.00

Total Special Damages to Date: $ 403,385.40

BACKGROUND INFORMATION

As October 3, 1995, Mary Smith,is a retired schoolteacher who, since retirement, earned income working four mornings per week at a local children’s hospital. At the time of the accident he was earning $12,480.00 a year in salary. She had no health problems at all at the time of the accident. She had undergone surgery on both feet two years earlier, but the surgery only prevented further deterioration of her condition and did not alleviate her problem altogether. She also suffered from hypertension, for which she took medication.

Otherwise, she was in excellent health.

FACTS OF THE ACCIDENT

Mary Smith is a 71 year-old widow who was involved in a motor vehicle accident with

Paul Joseph on October 3, 1995. The accident occurred at the intersection of Reservoir Avenue and MaeFair Court in Trumbull, Connecticut. The officer at the scene issued the defendant a citation. It is our...