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The Made-up Restaurant in Leeds Limited
40 York Avenue
1 March 2015
Edwin Ripon v You
Assault at Work on 12 August 2014
We are instructed by our above-named client, regarding a claim for personal injuries, suffered in an assault at work on or about 12 August 2014.
Our client considers that the injuries occurred through your negligence and/or breach of statutory duty and he claims damages accordingly.
Please find enclosed an additional copy of this letter for you to send to your insurers. You must refer the copy letter to the relevant insurers at your soonest. If you do not do so, then this may impact upon your insurance cover and/or the conduct of any potential legal proceedings.
Please note: this is a letter of claim for a personal injury claim, sent in accordance with the Pre-action Protocol for Personal Injury Claims. At this stage, therefore, matters which arise will be dealt with under that Protocol. We trust your insurers will reciprocate by meeting their obligations under the Protocol.
We should like to deal with liability promptly. Once liability is conceded, we hope that it will then allow us to enter negotiations on quantum and explore the possibility of settlement. If liability is not accepted, and/or you blame anyone else for our client’s injuries, please provide full details so that we may consider your position and take our client’s instructions.
This letter only provides a summary of the factual matrix of this claim, and the reasons why it is that you are liable for our client’s injuries. This summary, however, should not be taken to be complete recitation of the facts, and we reserve the right to amend the claim in due course, should we be instructed to do so. Should court proceedings be issued, then we reserve the right to fully plead the claim as we see fit, without reference to this letter of claim.
Circumstances of the Accident
Our client was employed by you as a server at The Mystery Restaurant at 40 York Avenue, Leeds.
At around 9.00pm, our client was asked by some of the customers how much longer they would have to wait for their meals. Our client went into the kitchen to ask the chef on duty, Mr Neville Landless. Mr Landless responded aggressively and verbally abused our client.
When our client asked again, Mr Landless became violent and attacked our client in an unprovoked assault. Mr Landless pushed our client forcefully against the wall, then picked up a meat cleaver and brandished it, threatening our client. Mr John Jasper, the sous-chef, and Mr Paul Bazzard, the Kitchen Manager, were present at this scene and did nothing to help our client or to stop Mr Landless’s behaviour.
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