COMPREHENSIVE DEMAND PACKAGE

IN THE MATTER OF ROBERT AND DIANA VELASQUEZ CLAIM NUMBER 028081935-0101-014

Edwin Duncan, AIG Sr. Account Claims Representative P.O. Box 25250 Lehigh Valley, P.A. 25250

Law Offices

CARLOS J. JIMNEZ, PL
1880 North Congress Avenue, Suite 315 Boynton Beach, FL 33426 Telephone: 561-367-7200 Facsimile: 561-367-1155 ____________________________________________________ A Professional Limited Liability Company May 6, 2008 Edwin Duncan, AIG Sr. Account Claims Representative P.O. Box 25250 Lehigh Valley, P.A. 25250 RE: Our Client Insured Date of the accident Claim No. : : : : Robert & Diana Velasquez Hardrives of Delray 02-09-08 L8808826458

Dear Mr. Ducan: As you know, the undersigned has been retained to represent Robert and Diana Velasquez relative to serious injuries they sustained as a result of the above captioned motor vehicle crash. This package has been compiled to give you sufficient information in order to properly evaluate their claims. I anticipate that once you have had an opportunity to review our demand, you will concur with our evaluation. DECRIPTION OF CRASH On the afternoon of February 9, 2008, at approximately 12:42 p.m., Mr. Velasquez was driving his 2000 Honda with his wife Diana Velasquez as a passenger in the city of Boynton Beach, Palm Beach County, Florida. As Mr. Velasquez passed the toll, he began slowing down, when suddenly and without warning, the other vehicle, a 1988 Mack, operated by , Robert Requeny with the permission and consent of Hardrives of Delray, recklessly failed to pay attention to her surroundings and slammed my clients vehicle, drivers side door. The impact was so severe that it propelled Mr. Velasquezs vehicle forward several feet and caused significant damage to same. Please see Exhibit # 1, pictures of my clients vehicle evidencing serious damages caused to it. Upon impact, Mr. and Mrs. Velasquezs whole bodies were thrown violently from side to side and forward and backward. Fortunately, he was both wearing their lap belt and shoulder harness at the time of the crash. Following the crash an officer Sims from the Boynton Beach Police Department arrived on the scene. Accordingly, it is our position that liability is crystal clear against Robert Requeny.

Moreover, we do not consider comparative fault to be an issue as both Mr. and Mrs. Velasquez were properly wearing their lap belt and shoulder harness and there was nothing they could have reasonably done to avoid the impending collision. As you can see from the police report, Robert Requeny was cited under the FL. Statute # 316.185 for failure to use due care, citation No: 2647SOC. (See Police Report, Exhibit # 2). MEDICAL TREATMENT AND UNDERSTANDING OF THE INJURIES After the crash, Mr. Velasquez began to experience pain in his neck, back, and headaches while Mrs. Velasquez began to experience neck pain and headache. Both were stunned, shaken and confused following the impact; however, by the time they gained some semblance of composure, and not wanting to be an alarmist, all Mr. and Mrs. wanted to do was get home and into bed to rest. As the hours passed, their symptoms and pain only increased in severity. At that point it was obvious to Robert and Diana that they required additional medical attention. CORDERO FAMILY CHIROPRACTIC Mr. and Mrs. Velasquez presented to Cordero Family Chiropractic, for consultation and examination. After a complete examination, treatment plan for the patients included a regiment of physical therapy; chiropractic adjustments, neuromuscular re-education, and extra-spinal manipulation. Both Mr. and Mrs. Velasquez followed the doctors instructions for physical therapy. The above therapy provided the Velasquezs only temporary relief and despite their diligent attempts at physical therapy and home exercise, the aches, pain and stiffness continue to plague them on a daily basis. Mrs. Velasquezs most recent visit with Dr. Edwin Cordero, D.C. occurred on March 31, 2008. On this date, Dr. Corderos final diagnosis indicates Cervical/Branchial Syndrome; radiculitis (lumbar); muscle spasm and thoracic vertebral subluxation. Mr. Velasquezs most recent visit with Dr. Cordero, the final diagnosis indicates cervicalgia; radiculitis (lumbar); subluxation; (thoracic); subluxation C-6; subluxation C5 and lumbar vertebral subluxation. Attached hereto are the medical records from Cordero Family Chiropractic as Exhibit # 3. MRI EXAMINATION Based on the foregoing, Dr. Cordero referred the patients for cervical MRI. As instructed on March 31, 2008, Mrs. Velasquez presented to Wellness Associates of Florida for cervical MRI examination. The study was interpreted by board certified diagnostic radiologist Bruce Rodan, M.D. as revealing: Herniated disk, L5/S1 level Bulging disk, C3/4 and C4/5 level

Herniated disk, C5/6 level to the left Abnormal curvature suggesting muscle spasm

Dr. Rodans impressions of Mr. Velasquezs MRIs included: Bulging disk, L5/S1 level Bulging disk, C4/5 and C5/6 Lordosis suggesting muscle spasm.

Please find attached the medical records and the MRI report as Exhibit # 4. ORTHOPEDIC SURGEON GARRY WEXLER, MD Based on Mr. and Mrs. Velasquez continuous complaints of pain, stiffness, and discomfort they presented to board certified orthopedic surgeon Garry Wexler, MD for consultation. On February 27, 2008, Mr. and Mr. Velasquez presented to Dr. Wexler with complaints of pain to neck and discomfort, shoulder pain and rib pain. Dr. Wexlers orthopedic examination of Mrs. Velasquez demonstrated: cervical sprain/strain; herniated disc w/o myelopathy; lumbar sprain/strain and DD displacement, bulging-lumbar w/o myelopathy.

Mrs. Velasquez returned to Dr. Wexler for follow up on March 19, 2008. On this date complained of discomfort in the low back. Dr. Wexler impression indicates: DD Displacement, bulging-lumbar w/o myelopathy; lumbar sprain/strain; cervical sprain/strain and herniated disc w/o myelopathy..

Mrs. Velasquez most recent visit with Dr. Wexler occurred on April 09, 2008. On this date Dr. Wexler opined that Mrs. Velasquez will require additional treatment in the future including physical therapy, prescriptions for muscle relaxants and antiinflammatory, repeat MRIs and x-rays, pain management. Attached hereto are Dr. Wexlers records as Exhibit #5.. PAST MEDICAL SPECIALS The following is a schedule of medical specials to date related to the care and treatment of Robert and Diana Velasquez as a result of this crash. All medical statements are attached hereto on Exhibit # 6.

MEDICAL WORKUP FOR DIANA VELASQUEZ: HEALTH CARE PROVIDER CORDERO FAMILY CHIROPRACTIC DATES OF SERVICE AMOUNT 04-14-08; 04-07-08; 04-04- $6,320.00 08; 03-31-08; 04-01-08; 03-24-08; 03-28-08; 03-2508; 03-12-08; 03-21-08; 03-24-08; 02-29-08; 03-0308; 03-05-08; 03-10-08; 0318-08; 02-13-08; 02-1608; 02-15-08; 02-20-08 and 02-27-08 03-17-08 and 03-03-08. $3,300.00 04-17-08; 04-09-08; 03-31- $2,086.00 08; 03-19-08; 03-11-08; 02-27-08. $ 11,706.00 $3000 per year X 10 years $ 30,000.00 $ 75,000.00 $116,706.00

WELLNESS ASSOCIATES OF FLORIDA, BRUCE A. RODAN, M.D. PALM BEACH ORTHOPAEDIC INSTITUTE, P.A.
TOTAL PAST MEDICAL SPECIALS

Pain management, MRI, x-rays, physical therapy; injections) Discectomy and Fusion TOTAL PAST AND FUTURE SPECIALS

MEDICAL WORKUP FOR ROBERT VELASQUEZ: HEALTH CARE PROVIDER CORDERO FAMILY CHIROPRACTIC DATES OF SERVICE AMOUNT 04-21-08; 04-14-08; 04-07- $5,240.00 08; 04-07-08; 03-31-08; 04-04-08; 04-01-08; 03-2408; 03-28-08; 03-25-08; 02-29-08; 03-03-08; 03-0508; 03-10-08; 03-18-08; 02-13-08; 02-15-08; 03-1708. 03-17-08 and 03-03-08 $3,300.00 03-31-08; 03-19-08; 04-17- $2,086.00 08; 04-09-08; 03-11-08; 02-27-08. $

WELLNESS ASSOCIATES OF FLORIDA, BRUCE A. RODAN, M.D. PALM BEACH ORTHOPAEDIC INSTITUTE, P.A.
TOTAL PAST MEDICAL SPECIALS

Pain management, MRI, x-rays, physical therapy; injections) Discectomy and Fusion TOTAL PAST AND FUTURE SPECIALS

$3000 per year X 10 years

$ 30,000.00 $ 75,000.00 $115,626.00

PRESENT CONDITION At the present time, every aspect of Robert and Diana Velasquezs lives continue to suffer adverse affects as a result of this significant crash. Mr. Velasquezs symptoms are aggravated by simple everyday activities such as driving, sitting for extended periods of time, computer work, Mrs. Velasquez has similar symptoms especially with activities such as sleeping, working on the computer, and watching a movie. Prior to this crash, Mr. and Mrs. Velasquez did not have any such problems. Additionally, as a result of the injuries suffered, Mr. and Mrs. Velasquezs social activities have been significantly curtailed. They are concerned about future treatments options, including epidural injections Overall, this crash has had a devastating effect on this couple's life and future plans. SETTLEMENT DEMAND In light of the clear liability on the part of your insured, as well as the significant injuries to Robert Velasquez and Diana Velasquez, past and future medical expenses, past and future loss earnings/loss of earning capacity, pain and suffering, disfigurement, disability, loss of ability to enjoy life, bodily injury, aggravation of pre-existing condition, enhanced insurance costs, and other non-economic damages, the Velasquezs are willing to resolve this matter the stated policy limits of One Hundred Thousand ($100,000.00) Dollars at this time only for each of them, a total of Two Hundred Thousand ($200.000.00) Dollars. Please tender the policy limits within the next twenty (20) days from the date of this letter, via this office to Robert Velasquez and Diana Velasquez and Carlos J. Jimenez, P.L. their attorney. If you require any additional information in order to complete your evaluation, please immediately advise the undersigned in writing. We look forward to your timely response. Sincerely yours, CARLOS J. JIMENEZ CJJ/gbo Enclosure cc: Mr. and Mrs. Velasquez.