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Demand Readiness
Case Evaluation Memorandum
Prepared for Patrick, Esq. · June 2026 · Bills and lien review in progress; demand not yet sent.
Maria Lopez: Auto Collision in Davidson County, TN. On March 12, 2026, David Chen rear-ended Ms. Lopez while she was stopped in traffic on I-40 in Nashville. Known specials ($38,420) are approaching the $50K per-person limit: evaluate a policy-limits posture as bills finalize.
On March 12, 2026, David Chen rear-ended Ms. Lopez while she was stopped in traffic on I-40 in Nashville. The investigating officer cited Mr. Chen for following too closely, and two independent witnesses reported that he never slowed before impact. Tennessee law required Mr. Chen to keep a safe distance behind Ms. Lopez’s vehicle. Tenn. Code Ann. § 55-8-124(a). His violation of that statute is negligence per se. Whaley v. Perkins, 197 S.W.3d 665 (Tenn. 2006). Ms. Lopez was stopped and did nothing to contribute to the collision. State Farm has reported a $50,000 per-person bodily-injury limit for Mr. Chen’s policy.
Specials of $38,420 against a $50,000 per-person limit. Soft-tissue-plus injuries with injection therapy support a value that likely reaches the policy limit; UM/UIM may be available above it.
Finalize the bills and lien reconciliation, then send a demand positioned at or near the $50,000 limit. Preserve and evaluate the stacked UM/UIM coverage in case value exceeds the at-fault limit.