Demand Letter

March 5, 2016 Mr. Henry Jones, Jr.1138 Thax HighwayChicago, NV 94555 RE: Malcolm Reynolds v. Crowger Grocery Dear Mr. Jones:We represent Malcolm Reynolds and are pursuing compensation for injuries he sustained at your downtown supermarket, Store No. AA-23 on November 16, 2015. The FactsOn the morning of November 16, 2015, just before your store opened, and at your direction, one of your employees, Jorge Garcia, walked through the entire store to make sure the floor was free of debris or any foreign substance that might prove a danger to your patrons.According to Jorge’s written statement,1 he gone through the pharmacy, the home goods and pet supplies sections, and had just completed going through the deli when his immediate supervisor, Janice Watkins, told him to go unlock the front doors. Jorge told Janice that he hadn’t yet checked the produce department or the aisles, but Janice told him to unlock the doors anyway.What Janice and Jorge did not know is that when the night crew was spraying down the produce the night before, they left a puddle of water on the floor just below the stand with the Gala apples.Malcolm Reynolds, who arrived right when the store opened, entered the store and went to the produce department while Jorge was checking the aisles. He had just decided he was going to forego his regular purchase of oranges for some delicious-looking Gala apples when he found himself on his back, looking towards the ceiling, and in extreme pain. He did not see the water on the floor and slipped. Medical TreatmentMalcolm did not purchase his apples. Instead, he took an ambulance to Mercy General, where the doctors discovered a fractured skull and bleeding in his brain, which was compressing his brain tissue. 2 He spent three days in the hospital and has since had emergency surgery to reduce the pressure on his brain.3 The surgery involved drilling a hole in his skull and draining the blood. He has also had to take diuretics and corticosteroids.4Since he cracked his skull, Malcolm has had chronic headaches and blacks out two to three times per week.5 His doctor estimates that his blackouts will eventually subside, but will probably still occur at least monthly, and that the headaches may last the rest of Malcolm’s life.6 The LawIn Nevada, a premises owner is responsible for either removing or warning others of dangerous conditions on their premises where the owner causes, knows of, or through the use of reasonable care should know of, the dangerous condition.7 Where those dangerous conditions are the proximate cause of harm to a guest to the premises, the landowner is liable for negligence.8 In your case, the dangerous condition was water on the ground. Nevada has long recognized water on the floor to be a dangerous condition for negligence purposes.9The dangerous condition was both caused by you (your night crew put it there) and would have been detected by you, had your employees followed your ordinary safety procedures (had Jorge finished his rounds before allowing patrons in the store). Instead, you put revenue before safety by allowing paying customers to enter before you had cleared the store of dangerous conditions.This dangerous condition was not only the proximate cause, but the only cause of Malcolm’s injuries because he did not have a cracked skull or bleeding brain before his head smashed against your floors. You are therefore liable to Malcolm in negligence. Damages<table class="MsoTableGrid" style="border-collapse:collapse;border:none" border="1" cellspacing="0" cellpadding="0"><tbody><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;background:#9CC2E5;padding:0in 5.4pt 0in 5.4pt">Category of Damages</td><td width="144" valign="top" style="width:1.5in;border:solid windowtext 1.0pt;border-left:none;background:#9CC2E5;padding:0in 5.4pt 0in 5.4pt">Amount</td></tr><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;border-top:none;padding:0in 5.4pt 0in 5.4pt">Mercy General ER</td><td width="144" valign="top" style="width:1.5in;border-top:none;border-left:none;border-bottom:solid windowtext 1.0pt;border-right:solid windowtext 1.0pt;padding:0in 5.4pt 0in 5.4pt">$13,859.68</td></tr><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;border-top:none;padding:0in 5.4pt 0in 5.4pt">Neurosurgeon</td><td width="144" valign="top" style="width:1.5in;border-top:none;border-left:none;border-bottom:solid windowtext 1.0pt;border-right:solid windowtext 1.0pt;padding:0in 5.4pt 0in 5.4pt">$28,456,53</td></tr><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;border-top:none;padding:0in 5.4pt 0in 5.4pt">Home care nurse</td><td width="144" valign="top" style="width:1.5in;border-top:none;border-left:none;border-bottom:solid windowtext 1.0pt;border-right:solid windowtext 1.0pt;padding:0in 5.4pt 0in 5.4pt">$67,541.33</td></tr><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;border-top:none;padding:0in 5.4pt 0in 5.4pt">Lost wages</td><td width="144" valign="top" style="width:1.5in;border-top:none;border-left:none;border-bottom:solid windowtext 1.0pt;border-right:solid windowtext 1.0pt;padding:0in 5.4pt 0in 5.4pt">$13,112.10</td></tr><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;border-top:none;padding:0in 5.4pt 0in 5.4pt">Total Past Economic Damages</td><td width="144" valign="top" style="width:1.5in;border-top:none;border-left:none;border-bottom:solid windowtext 1.0pt;border-right:solid windowtext 1.0pt;padding:0in 5.4pt 0in 5.4pt">$123,022.11</td></tr><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;border-top:none;padding:0in 5.4pt 0in 5.4pt">Estimate of future care</td><td width="144" valign="top" style="width:1.5in;border-top:none;border-left:none;border-bottom:solid windowtext 1.0pt;border-right:solid windowtext 1.0pt;padding:0in 5.4pt 0in 5.4pt">$389,476.12</td></tr><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;border-top:none;padding:0in 5.4pt 0in 5.4pt">Pain and suffering</td><td width="144" valign="top" style="width:1.5in;border-top:none;border-left:none;border-bottom:solid windowtext 1.0pt;border-right:solid windowtext 1.0pt;padding:0in 5.4pt 0in 5.4pt">$1,500,000.00</td></tr><tr><td width="234" valign="top" style="width:175.25pt;border:solid windowtext 1.0pt;border-top:none;padding:0in 5.4pt 0in 5.4pt">Total Damages</td><td width="144" valign="top" style="width:1.5in;border-top:none;border-left:none;border-bottom:solid windowtext 1.0pt;border-right:solid windowtext 1.0pt;padding:0in 5.4pt 0in 5.4pt">$2,012,498.23</td></tr></tbody></table> DemandMalcom hereby demands $2,012,498.23 for full and final settlement of his claims. This is a time-sensitive demand. Please respond within 30 days of receipt. Yours, _______________________________ Lawrence Tureaud, Attorney at LawBar No. 85-4551983 Baracas LaneDetroit, NV 90555 1 The written statement is attached hereto as Exhibit 1.2 See Mercy General ER Records, attached hereto as Exhibit 2.3 See Neurosurgical Records, attached hereto as Exhibit 3.4 See Prescription Records, attached hereto as Exhibit 4.5 See Exhibit 3.6 Id.7 Sprague v. Lucky Stores, Inc., 109 Nev. 247, 250, 849 P.2d 320, 322 (1993).8 Id.9 Worth v. Reed, 79 Nev. 351, 353, 384 P.2d 1017, 1018 (1963).

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