This demand letter was generated in 4 hours

Dear Sir or Madam:

1. Representation and Purpose

This firm represents Sofia Martinez in connection with personal injuries she sustained in a motor vehicle collision that occurred on January 15, 2024, on the 405 Freeway near the Culver Boulevard exit in Los Angeles County, California. This letter constitutes a formal demand for settlement of all personal injury claims arising from this incident.

2. Liability

On January 15, 2024, Ms. Martinez was lawfully stopped in traffic on the southbound 405 Freeway when a commercial vehicle operated by your insured, Apex Logistics, Inc., failed to maintain a safe following distance and struck Ms. Martinez's vehicle from behind at approximately 35 mph.⁴ The investigating officer, Officer M. Rodriguez (CHP Badge #7234), issued two citations to the driver: Vehicle Code § 22350 (Unsafe Speed for Conditions) and Vehicle Code § 21703 (Following Too Closely).⁴

Under California Civil Code § 1714(a), every person is responsible for injury caused by their want of ordinary care. The citations issued, the mechanism of collision, and the physical evidence conclusively establish that your insured's negligence was the sole proximate cause of all injuries sustained by Ms. Martinez.

3. Medical Treatment Summary

Ms. Martinez was transported by ambulance to Cedars-Sinai Emergency Department on the date of the collision, where she presented with severe cervical and lumbar pain, rated 8/10.¹ Physical examination revealed tenderness over C5-C6, limited cervical range of motion (flexion 25°, extension 15°), and positive Spurling's test bilaterally.¹ She was diagnosed with cervical strain (ICD-10: S13.4XXA) and lumbar sprain (ICD-10: S33.5XXA).¹

Lumbar MRI performed on February 3, 2024 at Advanced Imaging Center confirmed disc herniation at L4-L5 with moderate neural foraminal narrowing and mild impingement of the traversing L5 nerve root.² Ms. Martinez was referred to Dr. James Park at LA Spine & Orthopedic, where she underwent 24 sessions of physical therapy over the course of 8 months.³ Her most recent functional assessment on October 28, 2024 documented persistent limitations in prolonged sitting (>30 minutes), lifting (>15 lbs), and bilateral grip strength deficit.³

4. Special Damages

5. Demand

Applying a general damages multiplier of 3.5× to special damages of $34,032.00, general damages total $119,112.00. The total demand is:

We demand payment of $153,144.00 on or before April 23, 2026. This demand will expire without further notice on that date.