To view the full contents of this free document, simply agree to the terms and conditions to the right and click 'Download'.
Sykes Steel (Wetherby) Stockholders Made-up Limited
4 York Road
5th October 2016
Oliver Boroughbridge v You
Fork Lift Truck Accident on July 2015
We are instructed by our above-named client, regarding a claim for personal injuries, suffered in an accident at work on or about 4 July 2015.
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
We are instructed that you employed our client from 30 August 2011 to 9 September 2015, as a Fork Lift Truck Driver.
Our client instructs us that on 4th July 2014, at around midnight, he was asked to
... continued in document download