E-Scooter Rental Injury Demand Letters

[Date] Via Certified Mail and Email Claims Department Neutron Holdings, Inc. (d/b/a Lime) 85 2nd Street, Suite 100 San Francisco, CA 94105 Re: Personal Injury Claim - E-Scooter Brake Failure Rider: [Client Name] Incident Date: [Date] Scooter ID: [Lime Scooter ID Number] Location: [Street Address, City, State] Dear Claims Representative: This firm represents [Client Name] regarding serious injuries sustained on [Date] when a Lime e-scooter experienced complete brake failure at [Location]. We write to demand compensation for medical expenses, lost wages, and pain and suffering resulting from your company's defective product. FACTS OF THE INCIDENT On [Date] at approximately [Time], our client rented Lime scooter #[ID] using the Lime mobile application. While traveling at approximately 12 mph on [Street Name], our client applied the hand brake to slow for a pedestrian crossing. The brake lever compressed fully without resistance, and the scooter failed to decelerate. Our client was ejected over the handlebars and struck the pavement. Photographs taken immediately after the incident show the brake cable was frayed and the brake pads were worn to bare metal. The scooter's last maintenance inspection, which we request you produce, appears to have been inadequate. LIABILITY ANALYSIS Lime is strictly liable for injuries caused by defective products under [State] law. The brake system's failure constitutes both a manufacturing defect and evidence of negligent maintenance. Your user agreement's liability waiver does not shield Lime from strict product liability claims or gross negligence in maintaining safety-critical components. We acknowledge the arbitration provision in Lime's terms of service and are prepared to proceed through AAA Commercial Arbitration if we cannot reach a reasonable settlement. INJURIES AND DAMAGES Our client sustained the following documented injuries: - Displaced radial head fracture requiring open reduction internal fixation surgery - Facial lacerations requiring 22 sutures and resulting in permanent scarring - Grade II concussion with persistent post-concussive symptoms - Extensive road rash to bilateral upper extremities Current medical expenses total $87,432.16, with an additional $25,000-$40,000 in anticipated future treatment including hardware removal surgery and scar revision procedures. Our client, a [Occupation], has missed [X] weeks of work with lost wages of $[Amount]. DEMAND Based on the severity of injuries, clear liability, and ongoing treatment needs, we demand the total sum of $[Amount] to resolve all claims. This figure accounts for: - Past medical expenses: $87,432.16 - Future medical expenses: $35,000 (estimated) - Lost wages to date: $[Amount] - Future lost earning capacity: $[Amount] - Pain, suffering, and permanent disfigurement: $[Amount] Please respond within thirty (30) days with your settlement position. If we cannot reach agreement, we will file for arbitration and pursue all available remedies. We also request you preserve the subject scooter, all maintenance and inspection records, GPS/telemetry data from the incident ride, and any prior complaints regarding brake issues on Lime scooters. Sincerely, [Attorney Name] Attorney for [Client Name] [Law Firm] [Address] [Phone] [Email] Enclosures: - Medical records and billing statements - Incident photographs - Police report (if applicable) - Lost wage documentation