HF Law

Door 345, Ayala Tower One, Makati City

045.890.342
hazelmer.fernandez@gmail.com

June 24, 2016

DEMAND LETTER
Mr. Tory Lanes
Asia Star Investments
Makati City
(412) 555-2176
asiphilippines@yahoo.com

Mr. Lanes:
As you are aware, our client Mr. Vance Joy was injured in a fall on May 13, 2016 in the
underground parking lot of your building at Door 6750 Palm Tower, Makati. The accident
occurred at about 6:00 p.m. when he was heading for his car parked in the garage. He is an
employee of the South Philippine Import-Export Exchange, which leases offices in the
building. As he crossed the dark garage floor, he slipped on a patch of oil, badly twisting his
left knee and falling to the ground.
His knee swelled greatly and in the following morning, he went to see a physician, Dr.
Herman Cruz. Dr. Cruz advised him to stay off the leg for the next several days. He went
home and rested the leg, missing his next three days of work.

The following Monday, he returned to work and examined the garage where he had fallen. As
the enclosed photographs taken that day show, there were grease and oil spots all over the
floor, some of which had obviously been there for quite a while. To make matters worse,
several of the overhead lights were burned out, leaving dark areas on the floor and hiding the
oil and grease spots. Given that there were several lights burned out, it is clear that no one
had checked or replaced the bulbs for quite some time.

The swelling in Mr. Joys knee subsided after about a week, but the knee continued to be
painful and to catch when bent. He was examined by an orthopedist, Dr. James Basa, who
began a physical therapy course of treatment. Although Mr. Joy obtained some relief from the
soreness, the physical therapy did not eliminate the catch inside his knee when he bent or
twisted it. Therefore, he ended the physical therapy sessions voluntarily.

He was further referred by Dr. Basa to a chiropractor, Lisa Mendoza, for manipulation to
treat the catch in his knee. Ms. Mendoza stopped treatment after a short time and suggested
that our client return to an orthopedic surgeon.

Dr. Cruz referred Dr. Warren Perez, an orthopedic surgeon. Dr. Perez X-rayed the knee and
performed an arthroscopic examination on Mr. Joy. The examination revealed torn cartilage,
which Dr. Perez repaired arthroscopically.

Following the arthroscopic surgery, our client missed another week of work, then resumed
walking and began home exercises prescribed by Dr. Perez. After approximately eight more
weeks, he was able to begin running again, his regular daily exercise that he was unable to do
for almost eight months because of the accident.

Mr. Vance Joys medical expenses for this treatment are:

Herman Cruz, M.D.

Php

500.00

James Basa, M.D. (including X-rays)

Php 18,500.00

Lisa Mendoza

Php 15,800.00

Warren Perez, M.D. (including X-rays)

Php 25,987.00

TOTAL *********

Php 60, 787.00

As the enclosed letter from Mr. Joys employer, South Philippine Import-Export Exchange,
indicates, he missed eight days of work (three immediately after the accident, five more after
surgery), for a total of Php 3,600.00 (Php 450 per day) in lost wages.
Because of the obvious negligence of your management in failing to properly maintain its
building, a dangerous hazard was created that resulted in serious cartilage damage to Mr.

Vance Joys knee, requiring surgery and an eight-month period of recovery and rehabilitation.
Because of the seriousness of the injury and the long time for its recovery, our client
demands Php 100,000 in compensation.
We look forward to resolving this claim in the near future. Please provide us with a response
within 14 days from your receipt of this letter.

Very truly yours,

Atty. Phoebe Ryan
Counsel, in representation of Mr. Vance Joy