Template Letter Requesting Reduction in Medical Lien

June 28, 2015

Steam Fitters Local #2452l
Ms. Courtney Morzaria
4413 Philadelphia Road, Suite B
Baltimore, Maryland 21237


*Practice Tip*

If you are looking to get a reduction beyond what would be reasonable in the case because of extenuating circumstances, don't delegate the task to even the most competent paralegal or associate. You best chance at getting success in getting a lien reduction is to have the highest person on your law firm's food chain making the call. Why? Because it underscores just how important and necessary the reduction is.

Our Client: Mandy Dennison
Date of Loss: 1/19/2011
Account No.: 264352197

Dear Ms. Reinsfelder

It was a pleasure speaking with you today. As we discussed, we represent a very nice young lady, Mandy Dennision, in a case for personal injuries involving an automobile accident on January 13, 2015.

As a result of her crush injury to her left foot and fibula in this car wreck, Many will never be able to walk again without assistance. She also suffered cervical discectomy and fusion at the C5-C6 level. My understanding is that her current lien amount is $238,320.00. The neurosurgeon that performed her surgery is Dr. Katz, and he is of the opinion that her second surgery and her follow ongoing physical therapyis NOT related to the crash. His opinion is that following her surgery, only 6-8 weeks of therapy would be accepted as related to the crash. I calculated that amount to be a little less than $30,000. We would request that this amount be taken off the lien, leaving the amount in question to be $209,359.26.

The initial offer in this case was $250,000.00, which was made at a mediation in October of 2011. We attended a pre-trial in Frederick County on June 14tth and the offer was increased to $500,000.00. Our counter demand was $1.3 million. Since then, the Defendants have increased the offer to $550,000. The trial date is scheduled for July 5, 2015, which is only five weeks away. Our firm has invested $83,400.13 in prosecuting this case and the expenses continue to increase daily with preparation for trial.

We are requesting that you reduce your lien an additional $150,000 to $59,359.26. This is a significant reduction. We ask for the reduction for two reasons. One, there is a real risk of getting no recover at all at trial. Liability is strongly disputed in this case. In Maryland, if the Defendant shows that Mandy is 1% responsible for this car wreck, she loses and you would recover nothing. Moreover, we are in a conservative jurisdiction, Frederick County. The Judge admonished my clients and told them that "the lucky people get their medical expenses back." The Judge has been on the bench in Frederick County for 18 years and has presided over numerous personal injury cases, and says most Plaintiffs walk away very disappointed. I don't entirely agree with the Judge and I think Mandy will make a special witness. But her point is well taken.

The second, Courtney, is more human. As you know, Mandy will suffer from these injuries for the rest of her life. She has, as you also know, stood strongly behind this union for most of her adult life. We are asking her union to stand behind her now in her time of crisis.

I look forward to hearing from you.

Very truly yours,
Laura G. Zois

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