From the Office of
Michael C. Ross
(916) 923-2215 – ssorleahcim@comcast.net – F (916) 923-2216 – www.michaelross.net 

To: Ms. S.  Maalouf                                                                               7-13-09
From: Michael C. Ross
 
Re: Charles Downes: claim #841N6078
                                                                                       
Dear Ms. Maalouf;
 
I am writing today in an effort to follow up on Charles Downes and claim #841N6078.
 
Thank you very much for providing me with the information I requested the other day. Professionally, I appreciate it.
 
Anyway, I am writing today for 2 specific reasons, with the first being to update you on my clients status and second, my client has requested/demanded/ordered me to.
 
In both instances, we are asking both your help & understanding with respect to our circumstances, as well as our willingness to settle this matter as soon as possible, and that it is our wish to do so based on some very real life and uniquely scary circumstances.
 
Without beating around the bush, Doctors have found that Mr. Downes has a medical condition that depending on whom you speak to, MIGHT be related to the accident. This condition first came to light at the beginning of the year when his legs swelled up to twice their size. After several medical visits,  he was told that he has serious circulation problems that are related to a heart condition and diabetes. After a series of tests,  medical professionals have stated that the condition is directly related to the accident, whole others have said that it is not.
 
Obviously, no matter who you believe or which direction you take, this complicates things. Even so, we have a solution to separating the issues and keeping your clients out of the issues surrounding the problems.
 
Before I get into the solution, I want to assure you that this condition arose unexpectedly and is considered life threatening.
 
And that is why, Mr. Downes has asked me to contact you - He would like to settle this matter immediately so that he can focus on other more important issues and live out the rest of his life without the stress of this action hanging over his head.
 
With that in mind, I know you are curious about the medical condition is. As I stated above, Mr. Downes underwent a series of medical tests and treatments for swelling of his legs. Based on the tests, Mr. Downes has been diagnosed as having a serious heart condition and that this heart condition was brought about by diabetes and smoking. What impacts your clients is this: the medical professionals believe that the diabetes (and related stress that brought about high blood pressure) was brought on by the accident, especially since he was on his back for several months recuperating and not able to undertake his normal activities. In other words, a case can be made that since he could not undertake his normal routine, he could not burn off the sugars & fats necessary to control any signs of diabetes, especially since he was in pain and had to lay in bed and recuperate.   
 
No matter which avenue you take, Mr. Downes has been told that he has between 6 and 12 months to live – with 18 being the outset.
 
As such, we are caught in a bad situation – either include this claim in a suit against the company and see it drag on for years (in which he will probably be deceased before its settled) , or settle it as soon as possible and move on with the rest of his life – what’s left of it.
 
As I am sure you can guess, Mr. Downes has chosen the second avenue and would like to not only settle this claim, but remove you’re client’s labiality, saving them time and money by settling this matter as soon as possible. We believe that by settling this matter, Mr. Downes will be able to enjoy what remaining time he has left in peace, quite and without the stress of this matter hanging over his head.
 
Mr. Downes has asked that I relay the following settlement request to you:
 
1) That all outstanding bills be paid off immediately. This can be done in one of two ways. Either a check can be cut and given to him so he can pay them, or the company you represent can pay them off.
2) Second, he has asked me to make this one time settlement offer of $47,325, and insists that this offer expires on 7/20/09 at Noon.
 
In closing, as I have attempted to stress in this letter, Mr. Downes is very anxious to settle this matter and move on with the remaining days of his life without this hanging over his head.  Any assistance that you can provide relative to this matter would be greatly appreciated.
 
Thank you very much. I look forward to hearing from you