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Dear Counsel,
This firm represents John Martinez in connection with injuries sustained on January 14, 2026, at your client's premises located at 4720 Mira Mesa Blvd, San Diego, CA. Pursuant to Cal. Civ. Code § 1714(a) and the duty of care owed to business invitees under Rowland v. Christian, 69 Cal.2d 108 (1968), we hereby submit demand for compensatory damages.
I. Statement of Facts. On the date above, Mr. Martinez entered the premises as a paying customer. Surveillance footage (Exhibit A) demonstrates a clear liquid spill in Aisle 7 that remained unremedied for at least 47 minutes prior to the incident. Store policy (Exhibit B) requires hourly aisle inspection…
II. Damages. Special damages total $87,420.18 (medical, itemized at Exhibit C). General damages for pain and suffering, applying a 2.0 multiplier consistent with comparable San Diego jury verdicts, support a fair settlement value of $185,000…
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