Airbnb & Vacation Rental Injury Demand Letters

[Date] Via Certified Mail and Email [Host Name] [Host Address or c/o Airbnb Legal Department] 888 Brannan Street San Francisco, CA 94103 Re: Personal Injury Claim - Vacation Rental Property Guest: [Client Name] Property Address: [Rental Address] Airbnb Listing: [Listing URL or ID] Incident Date: [Date] Booking Confirmation: [Confirmation Number] Dear [Host Name]: This firm represents [Client Name] regarding serious injuries sustained on [Date] at your Airbnb property located at [Address]. We write to demand compensation for medical expenses, lost wages, and pain and suffering resulting from dangerous conditions at your rental property. FACTS OF THE INCIDENT On [Date], our client booked your property through Airbnb for a [length] stay. On [Date] at approximately [Time], our client [describe incident - e.g., "fell on the exterior staircase when a wooden step gave way beneath her"]. The [hazardous condition - e.g., "step had visible rot damage and inadequate structural support that was concealed by paint"]. Photographs taken immediately after the incident document [description of defect]. Your Airbnb listing represented the property as [relevant claims from listing, e.g., "recently renovated" or "professionally maintained"], which was materially false. LIABILITY ANALYSIS Under California Civil Code section 1714, property owners owe a duty of care to all persons lawfully on their property. As a paying guest, our client was owed the highest duty of care. You breached this duty by: 1. Failing to inspect and maintain the [hazardous condition] 2. Failing to warn guests of the dangerous condition 3. Misrepresenting property conditions in your Airbnb listing 4. Violating California Building Code requirements for [specific violation] California law imposes liability on property owners who knew or should have known of dangerous conditions. The deteriorated condition of [the hazard] indicates this defect existed for a substantial period before our client's injury. INJURIES AND DAMAGES Our client sustained the following documented injuries: - [Injury 1, e.g., "Comminuted fracture of the right ankle requiring surgical repair"] - [Injury 2, e.g., "Torn ligaments in the right knee"] - [Injury 3, e.g., "Lumbar spine strain with ongoing radiculopathy"] - [Injury 4, e.g., "Extensive contusions and soft tissue injuries"] Current medical expenses total $[Amount], with an additional $[Amount] in anticipated future treatment including [future treatment needs]. Our client, a [Occupation], has missed [X] weeks of work with lost wages of $[Amount]. DEMAND Based on the severity of injuries and clear liability, we demand the total sum of $[Amount] to resolve all claims. This figure accounts for: - Past medical expenses: $[Amount] - Future medical expenses: $[Amount] - Lost wages to date: $[Amount] - Future lost earning capacity: $[Amount] - Pain, suffering, and loss of enjoyment of life: $[Amount] We request you forward this letter to your insurance carrier(s), including Airbnb's Host Protection Insurance program. Please provide insurance information within fourteen (14) days. We expect a substantive response within thirty (30) days. If we cannot reach a reasonable settlement, we will pursue all available legal remedies, including litigation against you personally and claims against Airbnb for negligent platform operation. Please preserve all evidence related to this property, including maintenance records, prior guest complaints, inspection reports, and the current Airbnb listing. Sincerely, [Attorney Name] Attorney for [Client Name] [Law Firm] [Address] [Phone] [Email] Enclosures: - Medical records and billing statements - Incident photographs - Airbnb listing screenshots - Booking confirmation and communications - Lost wage documentation