March 5, 2016
Mr. Henry Smith
539 Eagle Ln.
Your Town, CO 80555
RE: Demand for Payment
Dear Mr. Smith:
This is a demand for payment, made on behalf of Rita Hilton by her mother Betty Hilton, for injuries suffered by Rita at the Lions, Tigers and Bears Pet Store on or about January 8, 2009. Enclosed are the following:
1. Rush to Care Ambulance 1/08/09
Billing, transport report
2. County Medical Center 1/29/09
Admit/discharge summary
3. Dr. James Whitman 1/15/09
Billing, Medical chart
4. Dr. Penelope Gidrose 1/15/09
Psychological Report
5. Emerg. Med. Billing (inclusive) $12,485.00
6. Psychological evaluation $5,000.00
7. Optometrist Group S.W. Billing $41,348.00
You will recall that Betty Hilton entered the Lions & Tigers & Bears Pet Shop with her three-year-old daughter, Rita. While there, Betty purchased a large parrot. A sign saying "Beware of Parrot" was next to the bird, but the store owner, Greg Peters, claimed that it was only to keep people from annoying the bird. Shortly after they arrived home, the parrot attacked the Rita, damaging her eye. We have since been informed by one of the store?s employees that the parrot had a disease that increased its propensity to attack.
Enclosed are copies of photographs depicting Rita's eye both immediately after the incident, and after surgery. It now appears that she will make a full physical recovery. However, she is severely scarred emotionally by the incident and has developed an extreme fear of all animals, wild or domestic. Inasmuch as documented physical care has plateaued as indicated, and insofar as there is no other contributory cause, demand for resolution of this claim is made in the sum of $58,833.00 for Rita's actual medical expenses, and for $1,500,000.00 for pain, suffering, emotional distress, and future medical attention. Please review the materials enclosed and respond in writing to this demand within 20 days.
Yours,
_______________________________
Corey Lightner, Attorney at Law
Bar No. 85-455
795 Colfax Ave.
Denver, CO 80223