向?qū)Ψ教岢鲑r付請求
VIA REGISTERED INTERNATIONAL MAIL
February 2006
Mr. Jeffery W. Gush, Treasurer
Abama Treasury Department
111 Cleveland Route
Tagoroko, AL 71001
The United States of America
Re: Professors Wenhong Wang & Teng Li, Claimants
Notice of Claim
DOA: December 25, 2005
Dear Mr. Gush:
Please be advised that this firm represents the above referenced claimants.
Pursuant to Title 24, Sections 11-07 and 11-204 of the Annotated Code of Abama,
this letter will inform you of Professor Wang and Li’s claim against the State
University of Abama, arising from a hazardous condition on the campus.
In this regard, please be advised of the following:
1. On Thursday, December 25, 2005, claimants were on the campus of State
University of Abama to attend an international mathematics conference
hosted by said university. At approximately 8:20 a.m., claimants were on
their way to Golden Hall in a crowd of people. As they were proceeding
along an area of sidewalk adjacent to the Holland Dormitory, across the
street from the Recreation Center entrance, Professors Wenhong Wang and
Teng Li fell into a large ditch.
2. The ditch is approximately three feet deep, two feet wide and is located in
the middle of the sidewalk. The area surrounding the ditch was not roped
off, no warning signs were present, and it was and is easily obscured.
3. As a result of this fall, both professors were transported by ambulance to St.
Thomas Hospital, where it was determined that emergency surgery was
required to repair serious fractures of Professor Wang’s hip and Professor Li’s
right leg.
4. As a result of the above referenced injuries, we hereby make a demand for
settlement as follows:
a) USD $75,000.00 for actual damages;
b) USD $25,000.00 for compensatory damages;
c) USD $60,000.00 for pain and suffering;
d) USD $15,000.00 for lost wages; ande) USD $30,000.00 for future medical expenses;
For a total of USD $150,000.00.
5. Claimants’ collective address is Yinghua Xili 3Qu 15-9-202, Chaoyang District,
Beijing 100029, People’s Republic of China.
6. My address and telephone number are shown in the above letterhead.
If you have any questions regarding this claim, please do not hesitate to contact me.
I look forward to hearing from you soon, and to an amicable and expeditious
resolution of this matter.
Thank you in advance for your anticipated attention and cooperation.
Very truly yours,
_________________
Deguang Zhang, Esq.
An Attorney Licensed in the People’s Republic of China
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