SETTLEMENT SUMMARY

AUTOMOBILE ACCIDENT:	Auto v. Parked Tractor Trailer
COURT:	Los Angeles Superior Court - Long Beach
CASE:	Lilian Santeliz v. Pegasus Building Services
INSURANCE COMPANY:	CNA
PLAINTIFF ATTORNEY:	Michael H. Whitehill, Esq. (KUSSMAN & WHITEHILL) Los Angeles
DEFENSE ATTORNEY:	Robert A. Muhlbach, Esq. (KIRTLAND & PACKARD)

FACTS: Plaintiff, a 24 year old illegal alien from El Salvador, was riding with her boyfriend, and father of her child, Martin Umanzor. Mr. Umanzor and Plaintiff had finished cleaning a commercial premises for Defendant Pegasus Building Services and were in route to Virginia Country Club to do further cleaning on behalf of Pegasus. Mr. Umanzor was employed by Pegasus and Ms. Santeliz assisted him in order to complete the cleaning operations in the allocated time.

While traveling down Long Beach Boulevard at approximately 1:30 A.M. on August 29, 1991, Mr. Umanzor's vehicle ran into a parked tractor-trailer. Ms. Santeliz, who was not wearing her seat belt, suffered catastrophic brain injuries in the accident.

INJURIES: Basal skull fracture rendering Ms. Santeliz comatose.

MEDICAL EXPENSES: Approximately $500,000.00 to date.

LOSS OF EARNINGS: None.

PLAINTIFF'S CONTENTIONS: Martin Umanzor was acting within the course and scope of his employment when he fell asleep at the wheel causing the accident.

DEFENDANT'S CONTENTIONS: Mr. Umanzor claimed the steering wheel stuck. Mr. Umanzor and Ms. Santeliz were on a frolic and not driving within the course and scope of their employment at the time of the accident. Ms. Santeliz's injuries would have been minimal had she been wearing her seat belt. Ms. Santeliz, an assistant to Mr. Umanzor, was acting within the course and scope of her employment and therefore was barred from recovery against Pegasus by the exclusivity remedy of the workmen's compensation law.

SETTLEMENT: $2,000,000.00

INITIAL DEMAND: $2,000,000.00 (Policy Limits)

INITIAL OFFER: $2,000,000.00