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Demand Readiness
Case Evaluation Memorandum
Prepared for Patrick, Esq. · June 2026 · Liability contested on notice; records outstanding.
Luis Romero: Premises Liability in Davidson County, TN. On April 15, 2026, Mr. Romero fell on a broken stair tread in the common stairwell of his Lakeside Apartments building. Coverage is sufficient for a surgical-ankle case, but liability is contested on notice. Build the notice record before valuing the claim.
On April 15, 2026, Mr. Romero fell on a broken stair tread in the common stairwell of his Lakeside Apartments building. This draft is directed to Nationwide as the general-liability carrier for Lakeside under a $500,000 per-occurrence policy. Premises liability turns on notice. The landlord denies prior notice of the defective tread. Tenant complaint history and the building’s maintenance file are being gathered. We will produce what those records show. We are not asking Nationwide to accept actual or constructive notice on a file that does not yet contain them. This letter will not go out as a finished demand until that notice record is in.
A surgical ankle fracture would otherwise command strong value, but premises liability turns on notice, which the landlord disputes. Range is wide and conditional on establishing actual or constructive notice.
Prioritize the notice investigation by pulling the tenant complaint and maintenance history before valuing the claim. Complete the Nashville Orthopedic surgical records in parallel.