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EXHIBIT 1
Case 2:18-cv-00763-RFB-NJK Document 5-1 Filed 04/26/18 Page 2 of 5
V ANNAH & V ANNAH
December 13, 2016
Sent via Email
Jennifer Goldstein, Esq.
200 Hoover Avenue, Suite 1113
Las Vegas, Nevada 89101
Phone: (415) 5176464
Facsimile: (866) 3033067
EMail: jennifer@paradigmsports.com
Re: Your Client : Conor McGregor
Date of Loss : August 17, 2016
Our Client : William Pegg
Dear Ms. Goldstein:
I have been retained to represent the interests of William Pegg regarding the incident
which occurred on August 17, 2016. All records and other documentation submitted as part of
this demand are to be used solely for the purposes of settlement.
LIABILITY
On August 17, 2016, Conor McGregor participated in a prefight press conference in Las
Vegas, Nevada at the MGM Resort Hotel and Casino inside the Copperfield Theater to promote
the upcoming Ultimate Fighting Championship (“UFC”) 202 contest. During the press
conference, M cGregor threw at least two unopened Monster Energy drink cans from the stage
into the direction of the audience. See Athletic Commission Findings of Fact, Conclusions of
Law, and Order, attached as Exhibit 1. One of the Monster Energy cans struck the back left
shoulder/arm area of William Pegg. The force of impact of the can left bruising in the shape of
the can on Mr. Pegg’s back left shoulder. S ee Photos of Bruising, attached as Exhibit 2.
MEDICAL TREATMENT
On August 18, 2016, Mr. Pegg presented to Concentra Medical Center (“Concentra”),
under the care of Gregory Hoversten, M.D., complaining of left arm and shoulder pain with
radiation to his left hand, shoulder bruising, and limited shoulder movement and rotation. Dr.
Hoversten noted a contusion and strain of the left shoulder and ordered xrays of Mr. Pegg’s left
shoulder and cervical spine.
On August 22, 2016, Mr. Pegg returned to Concentra, under the care of Mitulkumar
Patel, M.D., for a follow up of his left shoulder symptoms. Dr. Patel noted there was a trauma to
the deltoid, scapula, and posterior shoulder. Mr. Pegg’s grip strength was decreased on his left
side. Dr. Patel diagnosed Mr. Pegg with a contusion of the left shoulder and brachial radiculitis,
400 SOUTH SEVENTH STREET, FOURTH FLOOR ∗ LAS VEGAS, NEVADA 89101 * PHONE: (702) 3694161 * FAX: (702) 4410808
Case 2:18-cv-00763-RFB-NJK Document 5-1 Filed 04/26/18 Page 3 of 5
inflammation of the brachial plexus.1 Mr. Pegg was referred to a neurologist and a physical
therapist for further treatment and examination. Mr. Pegg was instructed to not reach above his
shoulders or lift more than 10 pounds with his left arm and to limit repetitive use or reaching
with the left arm.
On August 30, 2016, Mr. Pegg returned to Concentra, under the care of Dr. Patel, with
continued complaints of left shoulder pain, tingling, numbness, and weakness. Dr. Patel noted
that Mr. Pegg’s last visit revealed a large hematoma and swelling in the left upper back with
markings of a recent trauma with a heavy soda can. The swelling and pain has gone down some,
however, the tingling, numbness, and weakness from the left upper extremity down to the hand
have been persistent. Dr. Patel noted the Mr. Pegg was awaiting referrals for physical therapy
and neurology.
On September 6, 2016, Mr. Pegg returned to Concentra, under the care of Dr. Patel. Dr.
Patel noted there was no change in Mr. Pegg’s symptoms. Numbness was concentrated in the
finger mostly and there was continued pain in the left posterior shoulder. Dr. Patel again noted
Mr. Pegg was awaiting referrals for physical therapy and neurology.
On September 7, 2016, Mr. Pegg presented to Kelly Hawkins Physical Therapy, under the
care of Jeffrey Hill, P.T., for therapeutic exercise of his left shoulder. Mr. Pegg’s last treatment
with Kelly Hawkins was on October 4, 2016, due to Mr. Pegg’s physicians orders, for a total of
five visits. Mr. Pegg noted that the treatments he received at Kelly Hawkins helped reduce his
shoulder pain, but did not ease his numbness and tingling symptoms.
On September 13, 2016, Mr. Pegg returned to Concentra, under the care of Dr. Patel, for a
follow up of his left shoulder symptoms. Dr. Patel noted less shoulder related pain, but noted
both positional and activity related numbness in the left 4th and 5th fingers.
On September 23, 2016, Mr. Pegg returned to Concentra, under the care of Dr. Patel, with
continued complaints of pain and numbness. Mr. Pegg was referred to an orthopedic doctor for
further evaluation.
On September 27, 2016, Mr. Pegg presented to Desert Orthopedic Center, under the care
of Matthew Fouse, M.D., complaining of left shoulder pain and numbness in the ulnar side of his
left hand. Mr. Pegg’s pain is increased with behind the back activity, overhead reaching, and
nighttime pain with radiation. There was decreased sensation noted in the 4th and 5th fingers of
Mr. Pegg’s left hand. Dr. Fouse diagnosed Mr. Pegg with a left shoulder contusion and left ulnar
1
Brachial Plexus: “ The brachial plexus is a complex network of nerves. It starts at the spinal cord and extends like
a braid down the side of the neck behind the collarbone to the arm. Nerves of the brachial plexus control muscles
in the shoulder, arm, forearm, and hand, and they carry sensation (feeling) from the arm to the spinal cord. The
nerves are formed in three trunks (upper trunk, middle trunk, and lower trunk) in the neck. Brachial plexus
problems (or “brachial plexopathy”) show up as pain, altered sensation, and weakness (or paralysis) in groups of
muscles of the shoulder, arm, forearm, or hand.” S ee Cleveland Clinic:
http://my.clevelandclinic.org/health/diseases_conditions/hicbrachialneuritis
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Case 2:18-cv-00763-RFB-NJK Document 5-1 Filed 04/26/18 Page 4 of 5
(pinky) nerve paresthesia. Dr. Fouse recommended Mr. Pegg follow up with a neurologist for
nerve conduction studies related to his continued paresthesia.
On November 22, 2016, Mr. Pegg presented to Las Vegas Neurology Center, under the
care of Paul Janda, D.O., regarding his continued left shoulder radiating pain and numbness
complaints. Dr. Janda noted that the paresthesia initially was along the entire left arm, but had
since abated and was predominantly located along the left hand in the left ulnar nerve
distribution. Dr. Janda recommended a needle EMG extremity with paraspinal and nerve
conduction studies. Mr. Pegg is currently scheduled for these nerve studies on January 10, 2017.
Mr. Pegg’s continued difficulties with his grip strength and hand numbness has prevented
Mr. Pegg from enjoying his everyday activities. One such activity includes driving Mr. Pegg’s
motorcycle which requires the hand strength to operate the clutch with his left hand. Since the
time of the incident, Mr. Pegg had been unable to fully close his left hand into a fist, much less
grip a handle bar. Mr. Pegg’s grip strength has returned to some extent, but he is still unable to
fully make a fist without increased pain and numbness in his left hand up to his left shoulder.
MEDICAL EXPENSES
As a result of the incident of August 18, 2016, William Pegg has incurred the following
medical expenses to date:
PROVIDER CHARGES
Concentra Medical Center $1,018.91
Kelly Hawkins Physical Therapy $1,428.05
Desert Orthopedic Center $369.00
Las Vegas Neurology Center $250.00
January 10, 2017, appointment charges pending
TOTAL $3,065.96
EXHIBITS
1. Findings of Fact, Conclusions of Law, and Order (5)
2. Photos of Bruising (8)
3. Billing Statement, Concentra Medical Center (9)
4. Medical Records, Concentra Medical Center (25)
5. Billing Statement, Kelly Hawkins Physical Therapy (9)
6. Medical Records, Kelly Hawkins Physical Therapy (26)
7. Billing Statement, Desert Orthopedic Center (2)
400 SOUTH SEVENTH STREET, FOURTH FLOOR ∗ LAS VEGAS, NEVADA 89101 * PHONE: (702) 3694161 * FAX: (702) 4410808
Case 2:18-cv-00763-RFB-NJK Document 5-1 Filed 04/26/18 Page 5 of 5
8. Medical Records, Desert Orthopedic Center (8)
9. Billing Statement, Las Vegas Neurology Center (2)
10. Medical Records, Las Vegas Neurology Center (6)
11. Medical Authorizations (4)
CONCLUSION
As a result of the incident on August 18, 2016, William Pegg has incurred $3,065.96 in
medical expenses to date and been subjected to continued pain and suffering. Due to the
intentional nature of Mr. McGregor’s actions, we are making a demand for the current medical
expenses, plus $225,000.00, for a total of $228,065.96. Mr. Pegg will have future medical
expenses. Furthermore, the Nevada Athletic Commission has indicated that a $150,000 fine
would be appropriate to punish Mr. McGregor. However, we suspect that a jury may need to
award more than that to prevent the infliction of future violence on bystanders for promotional
purposes. Your response to this demand must be received, in writing, no later than 5:00 p.m., on
Monday, January 6, 2017, or this offer is withdrawn.
VANNAH & VANNAH
/s/ Matthew R. Vannah
MATTHEW R. VANNAH
400 SOUTH SEVENTH STREET, FOURTH FLOOR ∗ LAS VEGAS, NEVADA 89101 * PHONE: (702) 3694161 * FAX: (702) 4410808