Re: Marie XXXX
Date of accident: 25/01/05
Our reference: L-276

Dear Sir/Madam,

We act on behalf of Marie xxxxx with regards to the personal injury that she suffered upon her arrival in Tel-Aviv on January 25th 2005. Due to Lufthansa's negligence, there was a change in surface elevation which caused Ms. Lazar to misstep and fall over the threshold whilst exiting the airplane.

To the best of our understanding, three essential elements can be easily identified in Ms. XXXX case:

1. The Airline’s duty of care towards XXXXXXX

2. The Airline’s breach of duty, as explained above

3. Damages and personal injury sustained as a result of the Airline’s breach of duty (Ms. Lazar sustained trauma to her face and acute FX to her right shoulder. Further information pertaining to her injuries can be found in the attached Medical documents, marked “1”).
 
Accordingly, Marie XXXXX has instructed us to demand from you damages based on the extent of the personal injury she has suffered, as follows:

1. Non-economic loss (pain and suffering). Notification should be made to the fact that her vacation in Israel was destroyed - $25,000

2. Out of pocket expenses such as doctor, chemist and hospital accounts (receipts are attached) - $10,000

3. Future out of pocket expenses such as future medical expenses (some receipts as proof are attached and marked "2”) - $20,000

4. Wage loss (based on the wage specified in 2004 – attached and marked "3”). Ms. Lazar was only able to return to work on 27th of April 2005 - $16,000

5. Likely future wage losses - $80,000

6. Unpaid home care - $20,000

In the event that Lufthansa fails to provide the abovementioned sum, our client will reserve the right to commence immediate legal proceedings without further notice.

Yours faithfully,

Adv. Oren Bushari