Legal Correspondence: Income Replacement Claim - Mega Insurance

This assignment is a practical legal exercise where a licensed paralegal drafts a letter to Mega Insurance Company on behalf of their client, Edmund Reid, who was involved in a motor vehicle accident. The letter outlines the details of the accident, the injuries sustained (whiplash, herniated disc, fractured wrist, concussion, and soft tissue injuries), and the claim for income replacement benefits. It emphasizes that the client's income replacement benefits were terminated while medical benefits were covered. The letter includes details of the accident, policy information, and supporting documentation such as medical reports, tax returns, and pay stubs. The paralegal requests the insurance company to reconsider the termination of income replacement benefits and provide a written response regarding the claim's acceptance or denial. The assignment also includes a certificate of service confirming the application's delivery to Mega Insurance.

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Name of the Students
Name of the University
Authors Note

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Part-B (Letter to Mega Insurance Company serving the application)
Seneca Paralegal Professional Association located 101 – 1234 South Street,
Licensed paralegal Firm , Brampton, Ontario,
Pin: L2L 2L2, PO Box12,
Tel: [phone],
Fax: [phone].
Date: 03/01/2020
To
The Manager,
Mega Insurance Company,
215-6789 Rose Avenue, Mississauga, Ontario,
Pin: L3L 3L3,
Tel: [phone],
Fax: [phone].
Sub: Application for claiming interest on the income replacement but not on the
medical benefits.
Sir/Madam,
Under instruction from and on behalf of our client, Edmund Reid, having its
resident at 1234 Main Street, Brampton, Ontario, Pin: L1L 1L1, Tel: is 905-555-1212, we
address you as under:
It is hereby to inform you that, our client has a policy with your insurance company in the name
of his wife, Matilda Reid and the policy number is JL4X59282. However, our client’s wife

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Matilda did not purchase additional optional benefits. On April 26, 2019, our client, Edmund
Reid, met with a motor vehicle accident in the intersection of Steeles Avenue West and
McLaughlin Road in Brampton. The collision was severe and Edmund’s airbag was deployed.
The driver of the other vehicle was charged with careless driving under the Highway Traffic Act
but Edmund was not charged. He got severe injuries including whiplash, a herniated back disc, a
fractured right wrist, a mild concussion, and soft tissue injuries. On the very next day April 27,
2019, my client informed the entire matter to your company and claimed benefit under the claim
number 38729797 to the file. Your company took all necessary steps in this regard. In spite of
that, a letter have been received by our client on September 18, 2019, by stating that his income
replacement and medical benefits were terminated effective September 13, 2019. Our client’s
physician, namely, Dr. Jackson again on September 27, 2019 confirmed by letter that his injuries
had not healed sufficiently to return to work. In the mean-time, no further initiative has been
taken on your end to resolute the dispute. Our client received the entire amount of physiotherapy
cost but did not receive the amount of income replacement cost since September 13, 2019.
Therefore, our client claim the amount of income replacement with effect from
September 13, 2019. You can provide your answer in writing. The reply must include whether
the claim will be accepted or denied by your company along with proper reasons. For the
purpose of settling the dispute, following documents are being enclosed with this letter:
a) Dr. Jackson report dated August 28, 2019;
b) Dr. Jackson report dated September 27, 2019;
c) Mark Smith, physiotherapist, report dated October 4, 2019;
d) Income tax return for 2018; and
e) Last pay slip before the accident dated April 19, 2019.

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Thanking you,
For Seneca Paralegal Professional Association located
Attorney

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Part-C (A Certificate of Service of the application on Mega Insurance)

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