KRANKEMANN LAW OFFICES pc.
ATTORNEYS AT LAW
roses “20 STREET, SUITE 100 TeLenione oun a200
peace SANTA ROSA, CALIFORNIA 95408 TACSLE C60 eH
November 9, 2020
‘BY FIRST CLASS U.S. MALL
Liz Torres
Farmers Insurance
PO Box 268994
(Oklahoma City, OK 73126-8994
‘Re: Your Insured: Mark Geiser
Our Client: David Mackey
Date of Inj 1162019
Claim Number: 7000656001-1-2
Dear Ms. Torres,
‘As you know, tis firm represents David Mackey regarding a claim for personal injuries
suffered from a motor vehicle accident occurring on or around November 06,2019 with your
ingured. Please consider this leter Mr. Mackey’s demand for setlement in the above referenced
claim, This letter is intended asa settlement communication and, as such, may not be used for
any purposes in any proceeding pursuant to California Evidence Code section 1152, et se.
Enclosed for your review ate medical records and billings from the following providers:
(1) Sutter Lakeside Hospital; Kelseyville Fire Protection District; Adventist Health.‘The Accident
(On the morning of November 06, 2019, Mr. Mackey was injured due toa head-on trafic
collision with driver Jessica Leyva who was operating a vehicle owned by your insured, Mark
Geiser. It was found that Ms. Leyva was driving while under the influence of alcohol at the time
of the accident.
‘Ms. Leyva was driving the Ford pickup southbound on SR-29 in Lake County, just north
‘of the intersection of SR-281. Mr, Mackey was traveling northbound on SR-29 when Ms, Leyva
aggressively accelerated through the intersection attempting to make a left hand turn while
failing to notice the traffic light was red. The Ford pickup pulled directly out in front of Mr.
Mackey who had a green light when entering the intersection, Mr. Mackey was unable to react
in time and the front of both vehicles collided head-on, sending Mr. Mackey’s vehicle into 8
‘wood fence, continuing onto a dirt mound and overtuming oni lef side. After impact, Mr.
‘Mackey was trapped in his vehicle and extticated by CAL Fire.
California Highway Patrol Officer L. Williams responded to the scene, The Traffic
Collision Report number 9151-2019-00610 found Jessica Leyva caused the crash by operating a
vehicle while under the influence of alcohol in violation of California Vehicle Code section
23152(a) and entering the intersection while facing a steady red arrow in violation of California
Vehicle Code section 21453(¢).
Injuries and Treatment
‘When officers and paramedics arrived on the seene, they observed that Mr. Mackey had
sustained lacerations to his left elbow, temporary loss on consciousness, abrasions to back of legs
and head, and pain in his head, neck, back and torso. He was immediately transported to Sutter
Lakeside Hospital by ambulance.
Upon arrival to Sutter, Mr. Mackey presented with chest and abdominal pain. He
‘underwent an EKG and CT sean and was treated for blunt chest trauma, a chest contusion, and &
laceration with embedded glass in his left elbow which required sutures. Mr. Mackey’s pain was
‘weated with morphine atthe time he was in the emergency room. Upon discharge, he was
prescribed pain medicine, antibiotics, a splint and was advised to follow up with his primary care
physician.
Mr. Mackey followed up with Dr. Warmer who observed that there was nerve damage to
his elbow due o the embedded glass. He still eomplains of pain and discomfort, particularly
‘when sleeping. Dr. Warner has advised that his injury willbe stow healing and require follow up
appointments every few months
‘Asa result ofthis accident, Mr, Mackey has suffered significant economic damages in
the form of medical expenses in the amount of $19,925.16 and wage loss inthe amount of
$718.80.Once you have had an opportunity to review the records please contact our office to
discuss
WP truly yours,
vA Meg
Enelosure(s): Sutter Lakeside;
Kelseyville Fie Protection Distr
Adventist Health
TCR