California attorney · CA Bar #279869

California personal injury attorney

I'm Sergei Tokmakov, a California attorney. If you were injured in California, CCP § 335.1 gives you two years from the date of injury to file a personal-injury action. I write the pre-suit memo that maps your case, runs the SOL clock, and routes you to a contingency-fee plaintiff-side PI litigator with the file ready to go. Active PI litigation runs on contingency and is referred to specialist firms.

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Cal. Civ. Code § 1431.2
Quick answer

California personal-injury actions are governed by CCP § 335.1, which sets a two-year statute of limitations from the date of injury. Medical malpractice uses CCP § 340.5 (one year from discovery / three from injury, plus a § 364 90-day pre-suit notice). Government claims require a Gov. Code § 911.2 presentation within six months of accrual. Comparative fault is governed by Prop. 51 (Civ. Code § 1431.2), which makes economic damages joint-and-several but non-economic damages proportional. I write the pre-suit memo and refer to contingency-fee PI litigators; I do not handle the active litigation. Memo from $349.

2-year SOL
Personal injury under CCP § 335.1
Comparative
Pure CCP fault apportionment
Prop 213
Uninsured-motorist bar
Fees
Contingency for plaintiffs

What I do for personal injury matters

1

Screen Prop 213 and policy-limits posture.

Prop 213 bars non-economic damages for uninsured-motorist plaintiffs. I screen the case for that bar and for the policy-limits posture before any demand goes out.

Civ. § 3333.4 (Prop 213)
2

Build the comparative-fault math.

California is a pure comparative-fault state under Li v. Yellow Cab. I build the comparative-fault math into the demand so the carrier cannot just point at the plaintiff's contribution and walk away.

Li v. Yellow Cab
3

Post the policy-limits demand with support.

I post a policy-limits demand with documented medical bills, lost wages, and future-treatment estimates so the carrier has to evaluate bad-faith exposure if it refuses.

4

Hand off to a contingency firm intake-ready.

The memo is the intake document for plaintiff-side personal-injury firms. I write it so the contingency firm signs the case on the first call, with the Prop 213, comparative-fault, and limits posture already worked.

Why this calls for an attorney memo before contingency intake

DIY / template

What a self-written letter misses

  • Does not screen against Prop 213
  • Misses the pure comparative-fault calculation
  • Cannot post-tender the policy limits properly
  • Settles for the first nuisance-value offer
Attorney letter

What the attorney letter does

  • Screens Prop 213 and uninsured-motorist bar
  • Builds the comparative-fault math into the demand
  • Posts policy limits demand with documented support
  • Hands the file to a contingency firm intake-ready

The pre-suit memo maps the case to comparative-fault math, Prop 213 exposure, and policy-limits posture, so the right firm intakes it on the first call.

The controlling law

Cal. Civ. Proc. Code § 335.1

The basic california personal-injury statute of

This authority is the basic California personal-injury statute of limitations: two years from the date of injury. The statute applies to actions for injury to a person caused by the wrongful act or neglect of another, including most negligence-based PI cases (car crashes, slip-and-falls, dog bites, assault). The discovery rule extends the clock in some cases (latent injuries, fraud, concealment), but the two-year window is the default starting point.

Cal. Civ. Proc. Code § 340.5 (MICRA)

This authority applies to medical-malpractice cases instead of §

This authority applies to medical-malpractice cases instead of § 335.1. The SOL is one year from discovery or three years from the date of injury, whichever is sooner. CCP § 364 layers on a 90-day pre-suit notice requirement. The MICRA framework also caps non-economic damages under Civ. Code § 3333.2. See the medical malpractice pre-suit attorney page for the dedicated MICRA workup.

Cal. Gov. Code § 911.2

This authority requires a written claim to the public

This authority requires a written claim to the public entity within six months of accrual when the defendant is a government entity (city, county, state agency, public school, transit district). After denial or 45-day deemed denial, you have six months to file. Missing the presentation deadline almost always bars the claim, with very narrow late-claim relief under § 911.4.

Cal. Civ. Code § 1431.2 (Proposition 51)

Abolished joint and several liability for non-economic damages in

Abolished joint and several liability for non-economic damages in California. Each defendant pays only their proportionate share of non-economic damages based on their fault percentage. Economic damages remain joint and several. In multi-defendant cases, this means you can collect the full economic damages from any solvent defendant but only a percentage of pain and suffering, which changes the case math when one defendant is judgment-proof.

Cal. Civ. Code § 3342

Strict liability on dog owners for

This authority imposes strict liability on dog owners for bites in public places or while lawfully on private property. No "one bite rule" in California; the owner is liable regardless of prior bite history. Premises-liability cases involving dogs combine § 3342 with the general premises-duty framework. See the California premises liability attorney page .

The SOL math. Car crash on March 15, 2024: under CCP § 335.1, the filing deadline is March 15, 2026. Same crash involving a city bus: under Gov. Code § 911.2, the written claim was due September 15, 2024, six months from accrual, and missing that date almost certainly bars the case. The pre-suit memo runs the calendar math first because the wrong calendar kills the case.

What clients send me

The pre-suit memo is built from records and a structured intake. Before drafting, I ask for:

  • Police report or accident report if law enforcement responded
  • Medical records for treatment received as a result of the injury (ER, urgent care, primary care, specialists, physical therapy, imaging)
  • Photographs of the accident scene, the injuries (especially in the days following), and any property damage
  • A written timeline of events: what happened, where, when, with whom, and what you did in the hours and days after
  • Insurance information for the defendant (carrier name, policy number if known, claim number if a claim has been opened)
  • Your own insurance information (auto, health, MedPay, uninsured/underinsured-motorist coverage)
  • Witness names and contact information if any are available
  • Medical bills for the treatment received so far
  • Lost-wages documentation: pay stubs, W-2s, employer letter on missed time
  • Any communications you have already had with the defendant or their insurance carrier (especially recorded statements, which you should not give without an attorney)

If records are incomplete, send what you have. I tell you what is missing and whether the gaps affect the memo before quoting.

What I send back

How the engagement runs

1
Send facts

Incident date, injuries, treatment.

2
Liability theory

Negligence, premises, or product.

3
Damages model

Medical, wage, and pain-and-suffering.

4
Draft demand

Statutory citations + insurance demand.

5
Send certified

Insurer + tortfeasor + counsel.

6
Negotiate

Three rounds before contingency hand-off.

Choose your path

Start here if

Case memo

$349
  • You want a written legal evaluation first
  • You may refer to a contingency firm later
  • Statute or evidence questions are unsettled
Accept memo - $349
Start here if

Demand + draft lawsuit

$1,200
  • Counterparty needs to see the lawsuit is real
  • Multiple claims or institutional defendant
  • You may file pro se after the demand
Accept package - $1,200

Pricing

Note on litigation: Active California personal-injury litigation runs on contingency-fee economics and is referred to plaintiff-side specialist firms with the medical-expert relationships and trial infrastructure to run a case to verdict. The handoff includes the memo, the records, and the intake summary. For smaller cases that contingency firms decline (typically under $15,000 in settlement value), I can draft a $575 attorney demand letter directly to the insurer instead; scope is discussed at intake.

Frequently asked questions

You
What is the California personal injury statute of limitations?
S
CCP § 335.1 sets the basic personal-injury statute of limitations at two years from the date of injury. The discovery rule extends the clock in some cases (latent injuries, fraud, concealment), but for typical car-crash, slip-and-fall, or assault cases, the two-year window from the date of the accident or assault is the controlling deadline. Medical malpractice is different: CCP § 340.5 sets one year from discovery or three years from injury (whichever is sooner). Government tort claims have a six-month presentation deadline under Gov. Code § 911.2. Minors generally toll until age 18 (CCP § 352).
You
Why does Sergei do pre-suit memos instead of full PI representation?
S
California personal-injury litigation is contingency-fee work. The plaintiff-side firms that handle PI cases run on contingency (typically 33.3 percent pre-filing, 40 percent after filing) and absorb expert costs, medical-record retrieval, deposition costs, and the 12-24 months of litigation time before any recovery. The economics only work at scale, which is why dedicated PI firms exist. I do not have the contingency-fee infrastructure or the medical-expert relationships to handle PI cases at the volume those firms do. I do the front end: SOL preservation, the case map, the demand-letter draft when settlement is realistic, and a clean handoff to a contingency PI litigator I trust.
You
What is in the $349 personal injury memo?
S
A written legal memo covering: (1) the SOL analysis under CCP § 335.1 (or § 340.5 for medical, or Gov. Code § 911.2 for government claims) with the calendared filing window, (2) a liability theory based on the facts you provide (negligence elements, comparative fault under Prop. 51), (3) a damages framework distinguishing economic damages (medical, lost wages, future care) from non-economic damages (pain and suffering, emotional distress, loss of consortium), (4) an outline of what a credible settlement demand looks like for your case, and (5) a referral recommendation to a contingency-fee plaintiff-side PI litigator I work with, with the memo, medical records, and intake summary delivered to them at handoff.
You
Can I send a demand letter myself without an attorney?
S
You can, but insurance adjusters know within the first sentence whether they are reading a pro se letter or an attorney letter. Pro se demand letters typically get a token offer (5 to 20 percent of the settlement value) and then go to claims-closing because the adjuster knows the file is unrepresented. The MICRA-style pre-suit memo I write is not the same thing as a demand letter, it is a case-evaluation memo that a contingency PI litigator can hand to an adjuster to anchor the case at a credible number. If your case is small enough that a contingency firm will not take it (settlement value below $15,000 or so), I can draft a $575 attorney demand letter directly to the insurer; scope is discussed on intake.
You
What if the injury was caused by a government employee or vehicle?
S
California government claims are governed by the Government Claims Act (Gov. Code § 810 et seq.). Before suing a public entity, you must present a written claim within six months of accrual (Gov. Code § 911.2). If the claim is denied or deemed denied after 45 days, you have six months from denial to file suit. Missing the presentation deadline almost always bars the claim, with very narrow exceptions for late-claim relief. Government tort claims are aggressive on technicalities, so the pre-suit memo prioritizes the presentation deadline above everything else when a public entity is involved.
You
How does Proposition 51 affect my recovery?
S
Proposition 51 (codified at Civ. Code § 1431.2) abolished joint and several liability for non-economic damages in California. Each defendant pays only their proportionate share of non-economic damages (pain and suffering) based on fault percentage assigned at trial. Economic damages remain joint and several, so any defendant can be tagged for the full economic-damages amount. The practical effect: in cases with multiple defendants of varying solvency, you can collect the full medicals and lost wages from any solvent defendant but only a percentage of pain-and-suffering. The memo flags whether Prop. 51 changes the case math for your specific defendants.
You
What is the discovery rule for personal injury cases?
S
The discovery rule tolls the SOL until the plaintiff knows, or through reasonable diligence should have known, of the injury and its negligent cause. It applies to latent injuries (chemical exposures, defective medical devices, asbestos), fraud and concealment cases, and some delayed-onset trauma cases. Garden-variety car-crash cases do not benefit from the discovery rule because the injury is contemporaneous with the accident. The memo addresses whether your specific facts support a discovery-rule extension; if they do, the calendar window is calculated from the date of reasonable discovery.
You
What evidence do I need to send before the memo?
S
Police report (if any), medical records for treatment connected to the injury, photographs of the accident scene and visible injuries, contact information for the defendant or their insurer, witness names and statements if available, your own written timeline of events, pay-stubs or employer documentation of lost wages, and any communications you have already had with the defendant or their insurance carrier. If records are incomplete, send what you have. I tell you what is missing and whether the gaps affect the memo before quoting.
You
When should I contact a personal injury attorney?
S
Sooner is always better. Insurance carriers start building the defense file the day after the accident; recorded statements, social-media monitoring, and surveillance can all damage a case in the first weeks. Medical records contemporaneous with the injury are the strongest evidence; gaps in treatment are read against the plaintiff. The two-year SOL feels generous until medical bills accumulate, witnesses move, and physical evidence disappears. I quote turnaround at seven to ten business days once records arrive; getting the memo done early and the case to a contingency litigator with time on the clock is the right pattern.
You
What kinds of injuries does this practice area cover?
S
The CCP § 335.1 two-year SOL covers most California personal-injury cases: motor-vehicle accidents (car, motorcycle, truck, rideshare, pedestrian, bicycle), premises liability (slip-and-fall, dog bites under Civ. Code § 3342 strict liability, security negligence), assault and battery, products liability (also subject to discovery rule for latent defects), and most intentional torts. Medical malpractice is under § 340.5 (MICRA). Asbestos and toxic-tort cases have separate windows under CCP § 340.2 and § 340.8. The memo identifies the controlling limitations statute for the facts you present.

Injured in California? Let me write the pre-suit memo.

Email me a short paragraph about the incident, the date, and the injuries. I'll respond same day with a scoped flat-fee quote.

Email owner@terms.law