Question: Draft a demand letter to WaySafe explaining the relevant facts and demanding payment for all costs incurred and to be incurred as a result of
Draft a demand letter to WaySafe explaining the relevant facts and demanding payment for all costs incurred and to be incurred as a result of Alice's injury.
Background Alice Shopper is a client of our firm. She requested help with obtaining reimbursement for all costs incurred as a result of slipping and falling in one of WaySafe's stores. Facts On March 1, 2018, Alice Shopper was shopping with her four-year-old daughter at WaySafe, located at 1010 Commercial Ave, Phoenix Arizona 85003. Alice was reaching for a box of cereal when she slipped on a banana peel and fell on her rear end. She did not see the banana peel as she was focused on getting the groceries and watching her daughter. She felt immediate throbbing in her back. Although there were no witnesses to her fall, she immediately reported it to a store clerk. After several days of pain and discomfort, Alice visited her primary care doctor, Dr. Smith. Dr. Smith sent Alice for x-rays and then an MRI and diagnosed a bulging disk. Dr. Smith sent Alice for physical therapy. Alice completed one month of physical therapy. She is better but not completely healed. Her physical therapist opines that she will need to continue treatment for several months. After Alice learned of the bulging disk, she went back to WaySafe and asked to see the manager, Jon Jeffreys. She told Mr. Jeffreys that she had fallen two weeks earlier and wanted to make a claim. He was not friendly. He denied that Alice had fallen and denied that she ever made a claim to a store clerk. We informed Alice that WaySafe has a duty to keep their premises safe, which includes keeping the floor clear of any slippery items. Alice would like to obtain reimbursement for the following items: (1) Past medical bills, including, $200 to Dr. Smith, $500 to Advanced Radiology, and $1500 to Pete's Physical Therapy (Alice has copies of the bills); (2) Future medical bills related to this injury, estimated to be $2,000 (Alice has copies of the estimates); and (3) Pain and suffering in the amount of $500.
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