E-Bike Rental Defect Injury Demand Letters

[Date] Via Certified Mail and Email Legal Department [Rental Company Name] [Address] AND General Counsel [E-Bike Manufacturer Name] [Address] Re: Product Liability Claim - E-Bike Battery Fire Claimant: [Client Name] Date of Incident: [Date] E-Bike Model: [Make/Model] Serial Number: [Number] Rental ID: [Number] Dear Counsel: This firm represents [Client Name] regarding catastrophic burn injuries sustained on [Date] when a rental e-bike's lithium-ion battery spontaneously caught fire during normal operation. We write to demand compensation from all parties in the chain of distribution for this defective and unreasonably dangerous product. FACTS OF THE INCIDENT On [Date] at approximately [Time], our client rented an electric bicycle (Serial #[Number]) from [Rental Company Name] at [Location]. The e-bike was a [Make/Model] equipped with a [Brand/Model] lithium-ion battery pack. Approximately [X] minutes into the ride, while our client was traveling at normal speed on [Street Name], the battery compartment began smoking without warning. Within seconds, the battery ignited in an intense fire that engulfed the rear of the bicycle. Our client attempted to dismount but suffered severe burns to the lower extremities and hands before escaping the flames. The [City] Fire Department responded (Report #[Number]) and determined the fire originated in the battery compartment. The incident is consistent with lithium-ion thermal runaway, a known defect pattern in e-bike batteries. PRODUCT LIABILITY ANALYSIS Strict Liability The e-bike battery was defective and unreasonably dangerous. Lithium-ion batteries that spontaneously ignite during normal use contain manufacturing or design defects. Both [Rental Company] as the product seller and [Manufacturer] as the product maker are strictly liable for injuries caused by this defective product under [State] law. Our investigation reveals: - The [Battery Brand] has been subject to [X] complaints filed with the Consumer Product Safety Commission - [Manufacturer] issued a voluntary recall of similar battery packs on [Date] due to fire risk - Industry standards require battery management systems that prevent thermal runaway - No warnings were provided regarding fire risk during normal operation Negligence [Rental Company] negligently failed to: - Inspect the battery for signs of damage, swelling, or defect before rental - Remove batteries subject to recall from its rental fleet - Warn riders of known fire risks associated with the battery model [Manufacturer] negligently: - Designed a battery system without adequate thermal protection - Failed to implement quality control to detect defective cells - Delayed recall of known defective battery packs - Provided inadequate warnings regarding fire risk INJURIES AND DAMAGES Our client sustained the following documented injuries: - Third-degree burns to bilateral lower legs requiring skin grafting - Second-degree burns to hands and forearms - Smoke inhalation requiring hospitalization - Permanent scarring and disfigurement Medical treatment to date includes: - Burn unit hospitalization ([X] days): $187,000 - Skin graft surgery (2 procedures): $95,000 - Wound care and dressing changes: $23,000 - Physical therapy (ongoing): $12,000 - Compression garments and scar treatment: $8,000 Total medical expenses to date: $325,000 Our client, a [Occupation], has been unable to work for [X] months due to ongoing wound care and limited mobility. Lost wages total $[Amount] with additional loss of earning capacity during recovery. DEMAND Based on strict product liability, clear defect evidence, catastrophic burn injuries, and permanent disfigurement, we demand the total sum of $[Amount] to resolve all claims against both defendants. This figure accounts for: - Past medical expenses: $325,000 - Future medical expenses (scar revision, ongoing care): $150,000 - Past lost wages: $[Amount] - Future lost earning capacity: $[Amount] - Pain and suffering (past and future): $[Amount] - Permanent disfigurement: $[Amount] We also reserve the right to seek punitive damages if evidence demonstrates knowing concealment of the battery defect. EVIDENCE PRESERVATION DEMAND You are hereby placed on notice to preserve and not destroy, alter, or dispose of: 1. The subject e-bike and battery (if recovered) 2. All maintenance and inspection records for the subject unit 3. All battery supplier contracts and specifications 4. All prior complaints, incident reports, or warranty claims involving similar batteries 5. All internal communications regarding battery fire risks 6. All GPS and telemetry data from the subject e-bike Failure to preserve this evidence will result in appropriate spoliation sanctions. Please respond within thirty (30) days with your settlement position. If we cannot reach resolution, we will pursue litigation against all responsible parties. Sincerely, [Attorney Name] Attorney for [Client Name] [Law Firm] [Address] [Phone] [Email] Enclosures: - Fire department incident report - Medical records and billing statements - Burn injury photographs - CPSC complaint database results - Expert preliminary report (if available)