Office Number: 312-708-4535 773 State Street
Fax Number: 312-708-4536 Chicago, IL 60602
Website: www.crashandrecover.com
July [30], 2024
VIA CERTIFIED MAIL – RETURN RECEIPT REQUESTED
VIA FAX
AND VIA EMAIL TRANSMISSION TO: [Adjuster Email]
Grandy Ury Insurance
Lou Pohl
PO Box 10101
Richland, WA 99352
RE: Our Client: Sue Yoo
Your Insured: Quick Transport Services
Your Insured Driver: Neg Ligent
Date of Loss: May 15, 2023
Claim No.: GU1LTY111
Policy No.: BD-382937482
Dear [Mr./Ms] Pohl and All Insurance Company Decision-Makers:
Your records should reflect that our firm represents Sue Yoo (“Ms. Yoo” or “our client”)
regarding an incident that occurred on May 15, 2023, involving a vehicle operated by Neg Ligent
(“Mr. Ligent” or “your insured driver”) and owned by Quick Transport Services (“Quick
Transport Services” or “your insured”).
Our firm is currently in a position to resolve our client’s claims and, in connection therewith,
submits the following information and documentation in a good-faith effort to avoid the costly
and time-consuming nature of filing a formal complaint with the court or otherwise proceeding
with litigation.
Pursuant to Il. R. Evid. Rule 408, the information and materials accompanying this letter are for
settlement purposes only and may not be used at trial unless obtained through the legal process.
We expect that you will provide our firm with a list of any additional items you need in order to
properly and fully evaluate this settlement demand within [X] business days of the date of this
letter. We will make a good-faith effort to respond to any requests you make for additional
information regarding this demand. We also ask that this demand be immediately forwarded
to all insurance company decision-makers and, of course, the insured policyholder.
1. FACTS & LIABILITY
Liability is clear and rests solely with your insured. The only issue to be negotiated in this case is
the value of the bodily injury claim.
2. INJURIES & TREATMENTS
We have enclosed all pertinent medical information regarding Ms. Yoo’s injuries, tests, and
treatments. These injuries, tests, and treatments were suffered as a direct and proximate result of
this incident. The chart below represents a non-exhaustive summary of the injuries sustained by
our client:
Objective Test Date Finding Reference
● Asymmetric uncovertebral joint
hypertrophy/spurring at C3-4 right
greater than left with moderate right, left
neuroforaminal stenosis at C3-4.
● T2 sequence hyperintense structure in
the superior mediastinum simulating a
MRI of
rounded structure such as an enlarged Exhibit 7 -
Cervical spine 05/30/2023
lymph node or mixed complexity cyst p. 1
without contrast
more posterior mediastinum simulating
a rounded structure such as an enlarged
lymph node or mixed complexity cyst
measuring approximately 1.5 x 1.1 x 3.2
cm AP by transverse by craniocaudal
dimension.;
Interventional Treatment Date Provider Reference
Ketorolac Injection at the Exhibit 3 - p. 12
05/15/2023 Northwestern Medicine
Intermuscular Right Deltoid & 14
Cervical Facet Joint
Injection at C4-C5, C5-C6, 07/18/2023 APM Surgical Group Exhibit 9 - p. 3
and C6-C7
Left Cervical Facet Joint
Injection at C4-C5, C5-C6, 08/15/2023 APM Surgical Group Exhibit 9 - p. 4
and C6-C7
Cervical Medial Branch
[X] Advanced Physical Medicine Exhibit 3 - p. 94
Block Injection
Trigger Point Injection [X] Advanced Physical Medicine Exhibit 3 - p. 94
ICD Code Description Reference
Spondylosis Without Myelopathy or
M47.812 Exhibit 10 - p. 1
Radiculopathy, Cervical Region
M50.120 Mid-Cervical Disc Disorder, Unspecified Level Exhibit 5 - p. 5
M50.2 Other Cervical Disc Displacement Exhibit 6 - p. 9
M53.8 Other Specified Dorsopathies Exhibit 6 - p. 9
M53.82 Other Specified Dorsopathies, Cervical Region Exhibit 13 - p. 1
M54.12 Radiculopathy, Cervical Region Exhibit 5 - p. 5
M54.2 Cervicalgia Exhibit 8 - p. 1
M54.50 Low Back Pain, Unspecified Exhibit 3 - p. 4
S13.4XXA Sprain of Ligaments of Cervical Spine Exhibit 5 - p. 5
Strain of Muscle, Fascia and Tendon at Neck
S16.1XXA Exhibit 3 - p. 4
Level
S33.5XXA Sprain of Ligaments of Lumbar Spine Exhibit 5 - p. 5
3. PAST MEDICAL EXPENSES
To date, Ms. Yoo has incurred medical costs of $64.908.91.
Treatment Amount
Provider Reference
Period Charged
5/15/2023 -
Northwestern Medicine $9,004.50 Exhibit 4 - p. 1
5/16/2023
5/22/2023 -
Advanced Physical Medicine $23,781.41 Exhibit 6 - p. 8-13
10/5/2023
American Diagnostic MRI 5/30/2023 $2,250.00 Exhibit 8 - p. 1
7/18/2023 -
APM Surgical Group $17,367.50 Exhibit 10 - p. 1-2
8/15/2023
Greater Chicago Anesthesia 7/18/2023 - $2,905.50 Exhibit 12 - p. 1-2
8/15/2023
7/19/2023 -
Argus Medical Supply $9,600.00 Exhibit 13 - p. 1-2
8/10/2023
Total $64,908.91
If you claim that any of Ms. Yoo’s medical treatment was unnecessary or that any of the bills
related to her treatment were unreasonable, please identify in writing which bills you dispute and
the factual basis for such dispute. If you dispute them with a qualified expert opinion from a
doctor willing to testify, then please provide us with a copy of his or her report. If not, please
confirm in writing that you dispute the bills as a claims adjuster and/or administrator and not as a
qualified medical professional. If you do not respond in writing as requested, we will assume that
you do not dispute the necessity of Ms. Yoo’s medical treatment, nor the reasonableness and
amount of her medical bills set forth within this demand package.
4. DEMAND TO SETTLE
In light of the foregoing, Ms. Yoo hereby offers to settle her claims for [$64,908.91] under the
applicable policy providing coverage for the May 15, 2023, incident at issue. This demand will
remain open until 5:00 P.M. [insert time zone] on the [X] day after receipt, upon which it will
be automatically withdrawn if not accepted. Please do not hesitate to contact our firm if you
would like to discuss this matter further.
We do not doubt that you will recognize the contractual obligation owed to the insured pursuant
to the terms of the insurance policy maintained with your company at the time of the May 15,
2023, incident. Your company has a legal duty to act in good faith to resolve this matter.
While this correspondence is subject to Il. R. Evid. Rule 408, nothing contained herein shall be
construed to limit or impair, in any way, any of our client’s claims, rights, remedies, or defenses
in this matter, all of which are hereby expressly reserved. In the spirit of cooperation and in a
further attempt to resolve these issues informally and amicably, if you have any further
questions, please feel free to contact the undersigned upon receipt of this settlement demand so
that we may discuss the foregoing.
Yours truly,
Payne N. Sufferen
Exhibit List
Exhibit No. Description
1 Illinois Traffic Crash Report
2 Property Damage Photographs
3 Northwestern Medicine - Records
4 Northwestern Medicine - Bills
5 Advanced Physical Medicine - Records
6 Advanced Physical Medicine - Bills
7 American Diagnostic MRI - Records
8 American Diagnostic MRI - Bills
9 APM Surgical Group - Records
10 APM Surgical Group - Bills
11 Greater Chicago Anesthesia - Records
12 Greater Chicago Anesthesia - Bills
13 Argus Medical Supply - Bills
