Demand letters written the way your firm writes them.

October 27, 2026

VIA EMAIL AND U.S. MAIL

Claims Representative
[INSURER]

Re: Our Client: Maria Perez
Your Insured: Daniel Ortiz
Claim Number: [CLAIM NUMBER]
Date of Loss: June 9, 2026

Dear Claims Representative:

INTRODUCTION

Please be advised that this office represents Maria Perez in connection with the injuries she sustained in the above-referenced collision. Please direct all further communication about this matter to our office, and do not contact Ms. Perez directly. This letter constitutes our formal demand for settlement. It sets out the facts of the collision, Ms. Perez's injuries and treatment, and her damages.

FACTS OF THE COLLISION

On June 9, 2026, Ms. Perez was stopped at a red light in the number 2 lane at the intersection of Brand Boulevard and Colorado Street in Glendale, California. Your insured, Daniel Ortiz, struck her vehicle from behind. The impact pushed Ms. Perez's vehicle forward approximately one car length.

The Glendale Police Department responded and prepared Traffic Collision Report No. GPD-26-044812. According to the report, your insured told the responding officer that he "looked down at his phone" (TCR p. 2). The officer cited your insured for a violation of California Vehicle Code section 22350. No citation was issued to Ms. Perez.

Liability is clear. Ms. Perez was lawfully stopped at a red light when your insured, by his own account looking at his phone, drove into the rear of her vehicle.

INJURIES AND TREATMENT

Ambulance personnel transported Ms. Perez from the scene to the Glendale Adventist Medical Center Emergency Department on June 9, 2026. She complained of neck pain, low back pain, and headache. She was seen for one visit that day. Cervical and lumbar spine x-rays were taken. The radiology findings state: "No acute fracture or dislocation. Straightening of the normal cervical lordosis, which may reflect muscle spasm." She was diagnosed with cervical strain, lumbar strain, and post-traumatic headache. She was discharged with a muscle relaxant and instructed to follow up with primary care or orthopedics and to attend physical therapy as needed. Glendale Adventist Medical Center billed $4,860.00 for this treatment.

Ms. Perez presented to Verdugo Spine & Rehab on June 15, 2026, with complaints of neck and low back pain. At intake, the chiropractor recorded: "Patient reports pain 8/10 radiating into the left buttock; positive straight leg raise on the left." She was diagnosed with cervical sprain/strain, lumbar sprain/strain, and segmental dysfunction of the lumbar region. Her treatment included spinal manipulation, electrical muscle stimulation, therapeutic exercise, and hot/cold therapy. Her radicular symptoms persisted despite this care. On July 27, 2026, her provider noted: "Referred for lumbar MRI due to persistent radicular symptoms after 6 weeks of conservative care." She was also referred for an orthopedic consultation. Ms. Perez treated through September 22, 2026, for a total of 24 visits, and her pain was 3/10 at discharge. Verdugo Spine & Rehab billed $6,240.00 for this treatment.

Ms. Perez presented to Foothill Open MRI on August 1, 2026, for an MRI of the lumbar spine without contrast. This was one visit. The study revealed a "4.5 mm posterior disc bulge at L4-L5 with mild effacement of the thecal sac and mild left neural foraminal narrowing," as well as a "2 mm disc bulge at L5-S1 without significant stenosis." Foothill Open MRI billed $1,950.00 for this study.

Ms. Perez presented to orthopedic spine physician Samuel Keshishian, M.D., on August 18, 2026, with persistent low back pain with left-sided radiculopathy. Dr. Keshishian reviewed the MRI and concluded: "The 4.5 mm disc bulge at L4-L5 correlates with the patient's left-sided radicular complaints. Recommend L4-L5 epidural steroid injection; if no durable relief, patient is a candidate for surgical consultation." He diagnosed a lumbar disc bulge at L4-L5 with left radiculopathy and lumbar radiculopathy. Ms. Perez returned on September 29, 2026, for a total of 2 visits. She remained symptomatic at that visit, and the recommended injection is still pending. Dr. Keshishian estimates the cost of the L4-L5 epidural steroid injection at $3,500.00. Dr. Keshishian billed $1,400.00 for this treatment.

MEDICAL SPECIAL DAMAGES

A summary of Maria Perez's medical special damages is as follows:

These figures do not include the recommended L4-L5 epidural steroid injection, which Dr. Keshishian estimates at $3,500.00.