Rideshare Passenger Injury Demand Letters

[Date] Via Certified Mail and Email Claims Department Uber Technologies, Inc. 1515 3rd Street San Francisco, CA 94158 Re: Personal Injury Claim - Rideshare Passenger Claimant: [Client Name] Date of Loss: [Date] Trip ID: [Uber Trip ID] Driver: [Driver Name] Claim Number: [If Assigned] Dear Claims Representative: This firm represents [Client Name] regarding serious injuries sustained on [Date] while a passenger in an Uber vehicle. The accident occurred during an active Period 3 trip, triggering your company's $1 million commercial liability policy. We write to demand compensation for medical expenses, lost wages, and pain and suffering. TRIP AND ACCIDENT DETAILS On [Date] at approximately [Time], our client requested an Uber ride from [Pickup Location] to [Destination]. Driver [Name], operating a [Year, Make, Model] with license plate [Number], accepted the request. Trip ID [Number] confirms our client was an active passenger. At approximately [Time], while traveling [direction] on [Street Name] near [Cross Street/Landmark], your driver [describe negligent conduct: ran red light, failed to yield, was following too closely, was distracted by phone, etc.]. The vehicle struck [describe collision: rear-ended stopped traffic, collided with oncoming vehicle, struck pedestrian/cyclist, etc.]. [City] Police responded and prepared report #[Number], which attributes fault to your driver for [violation/negligence described in report]. LIABILITY ANALYSIS Your driver breached the duty of care owed to passengers by [specific negligent acts]. As a passenger in an active Uber trip, our client had no ability to control the driver's operation of the vehicle. Liability is clear and undisputed based on the police report, witness statements, and physical evidence. While Uber classifies drivers as independent contractors, our client's claim is against the commercial insurance policy that Uber is required to maintain for passenger protection. The policy provides $1 million in liability coverage during Period 3 trips. INJURIES AND MEDICAL TREATMENT Our client sustained the following injuries as a direct result of this collision: - Cervical disc herniation at C5-C6 with radiculopathy - Lumbar strain with ongoing muscle spasms - Grade II concussion with post-concussive syndrome - Left shoulder rotator cuff tear (partial thickness) - Contusions and abrasions to face and upper extremities Medical treatment to date includes: - Emergency room evaluation and imaging: $8,432 - Orthopedic consultation and MRI studies: $4,890 - Neurology evaluation and cognitive testing: $2,340 - Physical therapy (24 sessions to date): $3,840 - Pain management injections (3 series): $7,200 - Prescription medications: $1,245 Total medical expenses to date: $27,947 Our client's treating physician, Dr. [Name], has recommended surgical intervention for the cervical disc herniation. Estimated surgical costs are $85,000-$120,000 with 6-12 months of post-operative rehabilitation. LOST WAGES AND EARNING CAPACITY Our client works as a [Occupation] earning $[Amount] annually. Due to injuries, our client has missed [X] weeks of work, resulting in lost wages of $[Amount]. Post-surgery, an additional 3-4 months of disability is anticipated. Total lost wages (past and projected): $[Amount] DEMAND Based on clear liability, significant injuries requiring surgery, and substantial economic damages, we demand the sum of $[Amount] to resolve all claims. This figure accounts for: - Past medical expenses: $27,947 - Future medical expenses (surgery and rehab): $105,000 - Past lost wages: $[Amount] - Future lost wages during recovery: $[Amount] - Pain and suffering (past): $[Amount] - Pain and suffering (future): $[Amount] - Permanent impairment: $[Amount] Given the severity of injuries and clear liability, we believe this claim has significant value that may approach your policy limits. We invite you to evaluate the claim thoroughly and respond with a reasonable settlement offer within thirty (30) days. If we cannot reach resolution, we will pursue all available remedies including arbitration as required by your terms of service and/or civil litigation against all responsible parties. Sincerely, [Attorney Name] Attorney for [Client Name] [Law Firm] [Address] [Phone] [Email] Enclosures: - Trip receipt and confirmation - Police report - Medical records and billing statements - Employer verification of lost wages - Photographs of injuries and vehicle damage