The Pirnia Law Group

Priscila Chamorro - Case Manager

2315 Westwood Boulevard 2nd Floor
Los Angeles, California 90064
844-747-5294
priscila.chamorro@ThePirniaLawGroup.com
October 5th, 2021.

Geico - Insurance company

1234 Broadway
Harrisburg, PA 17111
Attn: Elizabeth Martin, Claims Adjuster
1734 Independence Ave
Philadelphia, PA 19126.

Re: Claim Number: 872364

Client’s name: Antonina Smith
Defendant: Brad Jones
Date of accident: July 23, 2021

Dear Elizabeth:

As you know I represent Antonina Smith who was injured in an auto accident on July
23rd, 2021 as a result of the following evidence.

My client was driving to work at or about 9:00 AM, approached the intersection of
2nd Street and A Avenue in my 2017 Kia Soul, obeying all traffic laws, maintaining a
speed well within the legal limits. Visibility was clear, and my client was properly
watching my surroundings for traffic signals, signs, other drivers, and pedestrians.
My client saw the insured, Brad Jones, stop his vehicle at the intersection’s stop
sign, before unexpectedly pulling into the intersection and striking the passenger
side of her vehicle. There was no signage affecting her right of way and there was
no obstruction that would have prevented the insured from seeing her vehicle or the
stop sign directing him to stop and yield the right of way.

Brad Jones, failed to yield the right of way at a stop sign, crashing into my client’s
car and leaving her injured. Were it not for her unsafe actions behind the wheel,
neither my client’s property nor herself would have been harmed. This car wreck has
led to considerable personal expense in the form of repair costs for her vehicle,
medical care, missed wages, and pain and suffering that has degraded my client’s
lifestyle. Mrs. Smith has reached the point where further medical improvement is
unlikely and she would like to conclude the matter of the damages done by your
insured with an equitable settlement that compensates her for both the special and
general damages that my client has suffered.

On impact, Mrs. Smith was slammed violently against the driver’s door of my client’s
car, causing immediate sharp pain. The airbags deployed, violently striking her face
and causing her eyeglasses to lacerate the bridge of her nose and cheek. An
ambulance was called, during which she was administered oxygen as she was
taken to the nearest emergency room. My client was treated for bruised ribs, a
broken nose, a concussion, and facial lacerations.

My client’s vehicle was towed from the scene and delivered to a local repair shop,
Johnson Auto Body. The passenger side was extensively damaged. In addition,
mechanical work was required to return the vehicle to an operable condition.

Witness statements, police reports, and the citation issued at the time of the
accident to the insured paint a clear picture of this accident. This wreck is the sole
liability of the insured. His failure to properly yield the right of way at a stop sign in
accordance with California law was the direct cause of the accident and the
following damages:

List of Itemized Damages

Repair: $10,000.00
medical bills $20,000.00
Lost wages $15,000.00
pharmacy receipts $10,000.00
damages for pain $10,000.00
Suffering $8,000.00
emotional distress. $8,000.00
Total $81,000.00
Please find attached the documentation to support these damages.

I believe this compensation would be a fair and just settlement to conclude

this case at this point and time for both parties.

Sincerely.