Date: November 5, 2026

Our File No.: SR-2025-0842

SENT VIA ELECTRONIC DELIVERY AND U.S. CERTIFIED MAIL, RETURN RECEIPT REQUESTED

Travelers Property Casualty Co. of America
Commercial Casualty Major Case Unit
Attn: Marcus D. Reynolds, Senior Claims Specialist
P.O. Box 430
Houston, TX 77001-0430

Dear Mr. Reynolds:

This office represents Carlos Mendez in connection with the bodily injuries sustained in the incident referenced above. This correspondence and the records enclosed with it constitute our formal, time-limited demand for settlement, supported by the liability analysis, documented course of treatment, and itemized damages set out below.

We request that your file be reserved to reflect the full documented value of this claim. The objective clinical findings, diagnostic imaging, treatment duration, itemized special damages, and general damages set forth below are supported by the enclosed records and should be reflected in your evaluation and in the reserves set on this file.

On March 12, 2025, at approximately 2:15 p.m. CST, Carlos Mendez, a 42-year-old Senior Master Fleet Technician employed by Gulf Coast Fleet Services LLC at 11420 Red Bluff Rd, Pasadena, Texas 77507, was performing a steering component inspection beneath a 2022 Chevrolet Silverado 2500HD. The vehicle had been raised using a TitanLift Professional 3.5-Ton Heavy-Duty Hydraulic Service Jack (Model TL-3500HD, Serial No. TL2023-88419B), manufactured in November 2023 by TitanLift Industrial Equipment Corp.

Without warning, the hydraulic service jack suffered a catastrophic structural shear failure of the primary lifting arm casting adjacent to the hydraulic ram pivot bolt, accompanied by instantaneous pressure decompression across the internal cylinder bypass seal. The lifting arm fractured completely, dropping the vehicle frame onto the concrete apron and trapping Mr. Mendez's right dominant forearm and wrist beneath the lower control arm assembly. Pasadena Volunteer Fire Department & EMS responded to the scene, splinted his deformed and bleeding right wrist, administered 100 mcg of intravenous fentanyl for severe 10/10 pain, and transported him emergently as a Priority 2 trauma patient to Memorial Hermann Southeast Hospital.

TitanLift Industrial Equipment Corp. is strictly liable and negligent for designing, manufacturing, and placing into the stream of commerce a defective 3.5-ton hydraulic service jack that failed under normal commercial operating conditions. Following the incident, the United States Department of Labor Occupational Safety and Health Administration (OSHA Region 6, Houston South Area Office, Inspection No. 1748291.015) conducted a formal metallurgical and physical inspection of the failed equipment on March 13, 2025.

OSHA's inspection of the fractured lifting arm revealed severe subsurface porosity and slag inclusions within the ductile cast-iron lifting arm casting, establishing a foundry casting defect during manufacture. Investigators confirmed zero evidence of operator abuse, zero overload exceeding the jack's rated 7,000-pound capacity (the Silverado front axle curb weight was approximately 3,850 pounds), and zero hydraulic oil contamination. The jack was only 16 months old and well within its normal commercial service life. Based on these findings, OSHA concluded that the equipment failed due to a manufacturing defect in the primary load-bearing structural casting and forwarded a formal Notice of Defective Product to the Consumer Product Safety Commission (CPSC Incident Log #CP-2025-0914).

Upon emergent arrival at Memorial Hermann Southeast Hospital on March 12, 2025, trauma physician Dr. Marcus Vance documented gross angular deformity of the right distal forearm, tense swelling extending into the thenar space, severe pain exacerbated by passive finger extension, and decreased two-point discrimination across the right median nerve distribution. Diagnostic CT and X-ray imaging confirmed a severely comminuted, intra-articular fracture of the right distal radius with 18 degrees of dorsal tilt and 4 mm of radial shortening, a displaced fracture of the right ulnar styloid process, and acute post-traumatic median nerve compression and compartment syndrome.

On March 13, 2025, board-certified orthopedic hand and microvascular surgeon Dr. Andrew J. Vance performed emergency open reduction and internal fixation (ORIF) of the right distal radius using a Synthes 3.5 mm Variable-Angle LCP Volar Two-Column Plate with seven locking screws, open repair and percutaneous pinning of the right distal radioulnar joint, and an emergency open right carpal tunnel release with median neurolysis. Intraoperatively, Dr. Vance observed massive dorsal and intra-articular comminution and noted that the median nerve was hyperemic and flattened under severe hematoma pressure.

Mr. Mendez returned to Houston Orthopedic & Reconstructive Surgery on March 27, 2025, for suture removal, transition into a custom-molded thermomold wrist orthosis, and a prescription for 16 sessions of active occupational therapy. At his six-week post-operative evaluation on April 24, 2025, radiographs showed progressive callus formation, but physical examination revealed severe intrinsic muscle atrophy and right-hand grip strength of only 18 pounds compared to 95 pounds on the left, with a strict two-pound lifting restriction on the right arm.

From April 1, 2025, through June 25, 2025, Mr. Mendez completed 16 visits of specialized hand rehabilitation at Advanced Hand & Occupational Therapy Rehabilitation, including scar desensitization, fluidotherapy, therapeutic ultrasound, and progressive strengthening.

At his final orthopedic evaluation on July 15, 2025, Dr. Vance determined that Mr. Mendez had reached Maximum Medical Improvement with permanent range-of-motion deficits in right wrist flexion (40 degrees versus 70 degrees on the left), extension (45 degrees versus 75 degrees), and supination (55 degrees versus 85 degrees), assigning an 18% permanent partial impairment of the right upper extremity (11% whole person) under the AMA Guides 6th Edition and imposing a permanent 25-pound lifting restriction on his dominant right arm.

The records address the intervals between documented visits as follows.

June 25, 2025 to July 15, 2025 (20 days). Following his occupational therapy discharge on June 25, 2025, Mr. Mendez returned to Houston Orthopedic & Reconstructive Surgery on July 15, 2025, for his scheduled Final Orthopedic Discharge and Maximum Medical Improvement evaluation, at which Dr. Vance confirmed that the fractures were clinically united and assessed his permanent impairment rating.

Total medical expenses billed: $54,050.00

Total medical expenses paid or incurred: $35,300.00

Medical expenses are stated on a paid-or-incurred basis consistent with Tex. Civ. Prac. & Rem. Code § 41.0105: amounts actually paid by or on behalf of the Claimant together with balances that remain owed, including balances carried on letters of protection.

Memorial Hermann Hospital System has asserted a hospital lien of $11,200.00. Blue Cross Blue Shield of Texas Employee Welfare Benefit Plan has asserted a health plan reimbursement claim of $19,100.00.

The billing records show an outstanding balance owed under a letter of protection to Houston Orthopedic ($3,500.00).

These interests are disclosed so that your evaluation accounts for them. They are not an additional item of damages.

At the time of the incident, Mr. Mendez worked full-time (40 scheduled hours per week) as a Senior Master Fleet Technician for Gulf Coast Fleet Services LLC. Following the March 12, 2025 crush injury and emergency reconstructive surgery, his treating orthopedic surgeon held him off work and subsequently under strict lifting and pneumatic-tool restrictions that prevented him from performing his regular duties through June 25, 2025, before he returned to modified duty on June 26, 2025.

Gulf Coast Fleet Services LLC verified lost wages of $23,887.50.

Lost earnings claimed: $23,887.50

TOTAL SPECIAL DAMAGES: $59,187.50

This catastrophic machinery failure subjected Mr. Mendez to excruciating physical pain from the moment the 3,850-pound truck front axle crushed his dominant right forearm, requiring intravenous fentanyl during ambulance transport and emergency open surgery to decompress his flattened median nerve and reconstruct his shattered wrist with a metal plate and seven locking screws. Beyond the acute surgical trauma and months of intensive hand rehabilitation, Mr. Mendez has been left with permanent hardware in his wrist, persistent median nerve paresthesias upon sustained grasp, significantly reduced wrist mobility, an 18% permanent impairment of his dominant right upper extremity, and a permanent 25-pound lifting restriction that permanently impairs his career as a master fleet mechanic.

In light of the foregoing, the Claimant demands $52,950.00 in general damages for past and future physical pain, physical impairment, and loss of enjoyment of life. Together with the special damages itemized in this letter, the total demand is $112,137.50.

TOTAL SETTLEMENT DEMAND: $112,137.50

This demand is made as an unconditional offer to settle all claims of Carlos Mendez arising out of the incident of March 12, 2025 against your insured, TitanLift Industrial Equipment Corp., in exchange for payment of $112,137.50, a sum within the applicable limits of liability coverage. Upon tender of that sum within the response period, our client will execute a full and final release of your insured as to all claims arising from this incident, will provide any reasonable release language your office requires, and will indemnify your insured against the liens and subrogation interests disclosed above. This demand may be accepted in its entirety by payment alone, requires no act by any other party, and is made so that your insured is fully protected from an excess judgment.

This demand is extended in good faith to resolve this matter without the expense and delay of litigation. It remains open through December 7, 2026, after which it is withdrawn without further notice and this office is instructed to proceed with suit, seeking the full measure of compensatory damages, costs, and pre-judgment and post-judgment interest available at law.

You and your insured are on notice to preserve all evidence relating to this incident, including incident and investigation reports, photographs, video and surveillance recordings, maintenance and inspection records, personnel and training records, communications concerning this loss, and any electronically stored information bearing on liability or damages. Loss or destruction of such evidence after receipt of this letter will be treated as spoliation, and all available remedies will be sought.