{Today’s Date}
DEMAND LETTER FOR
SETTLEMENT PURPOSES ONLY
Sent via facsimile: {(xxx) xxx-xxxx}
{Adjuster’s Name and Title}
{Insurance Company Name}
{Address – Line 1}
{Address – Line 2}
{City, State, Zip}
Re: Our Client: {Claimant’s Name}
Claim No: {}
Your Insured: {Insured’s Name}
Date of Loss: {}
Dear {Adjuster’s Name}:
As you are aware, this firm represents {client/claimant} for injuries {he/she} sustained in a dog bite incident that occurred on {date of dog bite} while {he/she} was a social guest at the {name of homeowner} located at {address where fall occurred}.
We have enclosed copies of the medical reports and medical billing statements from our client’s healthcare providers for treatment of {his/her} injuries that {he/she} sustained as the direct and proximate cause of {homeowner}’s negligence.
FACTUAL BACKGROUND
On {date of dog bite}, {client/claimant} was visiting {homeowner’s} residence when, without warning, {he/she} was viciously attacked and bit by {homeowner’s} {name of breed}.
{Insert any other relevant facts in your specific claim.}
As a result of this attack, {client/claimant} sustained serious, permanent and disfiguring injuries and scaring that required past medical treatment and will require future treatment for scar revision.
STRICT LIABILITY
In Arizona, a dog owner is strictly liable for the injuries that are incurred as the result of a dog bite. A.R.S. § 11-1025, specifically states:
The owner of a dog which bites a person when the person is in or on a public place or lawfully in or on a private place, including the property of the owner of the dog, is liable for damages suffered by the person bitten, regardless of the former viciousness of the dog or the owner’s knowledge of its viciousness.
Here, it is undisputed that {homeowner} was the owner of the dog that attacked and caused {client/claimant’s} injuries. It is further undisputed that {homeowner} failed to control or supervise {his/her} dog. As a result of {homeowner’s} lack of supervision and control, {client/claimant} sustained bodily injury and pain and suffering.
INJURIES & TREATMENT
As a result of this dog bite, {client/claimant} suffered {and continues to suffer} from the following complaints, injuries, and diagnoses.
{Insert timeline of medical treatment and diagnoses including ICD and CPT codes.}
SPECIAL DAMAGES
- PAST MEDICAL EXPENSES:
{Client/claimant} incurred the following out-of-pocket medical expenses as a result of this accident}:
| DATE OF SERVICE | PROVIDER | AMOUNT |
| $ | ||
| $ | ||
| TOTAL MEDICAL SPECIALS: | $ |
- FUTURE MEDICAL EXPENSES:
{Discuss any future treatment needed by client/claimant and include and future care opinions, including scar revision surgery or surgeries, and calculations made by medical professionals to support this future expense.}
GENERAL DAMAGES
{Discuss client/claimant’s pain, discomfort, suffering, and anxiety already experienced and reasonably probable to be experienced in the future as a result of this accident. See Revised Arizona Personal Injury Damages Instructions (Civil), 4th.}
{Further discuss client’s/claimant’s entitlement to fair compensation for the “loss of enjoyment of life, that is, the participation in life’s activities to the quality and extent normally enjoyed before the injury.” See Revised Arizona Personal Injury Damages Instructions (Civil), 4th.}
{Discuss client/claimant’s prior everyday activities including raising a family, hobbies and other extracurricular activities that {he/she} is no longer able to do at the same level before this dog bite occurred. Discuss if client/claimant was involved in a career and/or hobby that places an emphasis on appearance (e.g. modeling, acting, hosting) and how visible scarring, especially on the face, will impact those hobbies and/or career opportunities.}
TIME SENSITIVE DEMAND FOR SETTLEMENT
Based on the foregoing, {client/claimant} is willing to release his/her claims that arise or may arise as to all defendants and accept a settlement in the amount of ${insert amount}.
This demand expires at the close of business on {insert date}, at {00:00} a.m./p.m. If you have any questions or need any additional information, please feel free to give us a call.
We look forward to hearing from you regarding this matter.
Sincerely,
{YOUR LAW FIRM NAME}
{attorney’s name}
Enclosures