Sample Letter to Defense Lawyer

January 4, 2019

Via Facsimile (301-305-4978)
Charles C. Johnson, Esquire
4501 Foster Blvd., Suite 800
Lanham, Maryland 20703

Re: Evans v. Packer

Dear Chuck:

Practice Tip

A lot of personal injury lawyers will not reveal their client’s lien. Why? Because they don’t have to do so when sending a demand package. So they reflexively say no. This may be a good idea when the lien is less than the defense lawyer would expect. But in some cases, the defendant’s understanding fo the lien underscores why the client is making the demand that they are and gives the defendant “cover” to increase the offer

Attached please find a letter from the U.S. Department of Labor dated August 31, 2018, evidencing a lien of $454,964.16. Please note that this lien has increased to $470,337.45, and we are awaiting an updated summary from the U.S. Department of Labor.

Also attached is a copy of 20 C.F.R. 55, §§10.705-10.730 regarding the Federal lien, and a copy of the Long Form Statement of Recovery worksheet and instructions provided to us by the U.S. Department of Labor. I have also attached a worksheet prepared at $2,200,000.00 and the effect that proposed figure would have on my client’s overall recovery, his repayment obligation and the offset he must absorb before he would be eligible for any future federal workers’ compensation benefits.

We are eager to work with you to make sure this process proceeds efficiently.

Please let me know if you require anything further, or if you have any questions or concerns.

Very truly yours,
Laura G. Zois

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