Sunday, March 21, 2010
courthouse rotating photos Howard Nations Logo

Burns - Automobile Accident Demand Letter

Automobile Accident

Demand Letter

VII - WENDY GERMAINE

A. PERSONAL INJURIES AND MEDICAL SEQUELAE

The details chronicling the personal injuries and medical sequelae which followed the LifeFlight emergency rescue, the resuscitative efforts at Lakeside Hospital, and the treatment at the St. Stephen Burn Institute are summarized. Medical evidence determined that during the accident, this six-year-old girl was severely burned in the fiery vehicle and suffered lung and bronchial inhalation damages and flame burn injuries over fifty-two percent (52%) of her entire body, forty-six percent (46%) of which were third degree, as detailed below:

1. Burn - scalp 4%
2. Burn - anterior trunk 9%
3. Burn - posterior trunk 6%
4. Burn - right arm 7%
5. Burn - left arm 5%
6. Burn - right hand 2.5%
7. Burn - left hand 2%
8. Burn - right thigh 4%
9. Burn - right leg 3%
10. Burn - left leg 2%
11. Burn - right foot 2%
12. Burn - left foot 2%
13. Burn - right buttock 1.5%
14. Burn - left buttocks 1.5%
15. Collapsed lung - right upper lobe
16. Inhalation injury

In order to save Wendy's life immediately after the accident and to combat the numerous complications that accompany burn victims during the course of the hospital treatment, the following procedures were performed:

1. Escharotomies
2. Eschar skin excision and grafting surgeries x 6
3. Viable skin excision and grafting surgeries x 5
4. Chest tube insertion
5. Swan-Ganz cardiac catheterization
6. Bronchoscopy for visualization of lung x 2
7. Bladder catheterization
8. Nasogastric tube insertion
9. Biopsy of open wound sites
10. Biopsy of bronchi
11. Oral intubation connected to mechanical ventilator
12. insertion of arterial lines
13. Insertion of intravenous lines
14. Antibiotic infusions
15. Tissue cultures

Due to radical fluctuation in blood and fluid volume, infection, and severe lung damage, numerous crises complicated Wendy's recovery, including:

1. Ghosting of grafted skin
2. Necrotic and lost grafts on buttocks
2. Necrotic and lost grafts on both legs
2. Necrotic and lost grafts on both axilla
3. Sepsis
4. Fever spikes of unknown origin
5. Hallucinations
6. Thrombocytopenia
7. Tachycardia
8. Colonization of antibiotic resistant infections

B. HOSPITAL COURSE OF TREATMENT - WENDY

On August 28, 1996, to effectively treat Wendy's extensive burns, inhalation injury and collapsed lung, she was intubated to establish a breathing airway immediately at the scene of the accident. The LifeFlight helicopter rescue team transported her directly to the Smithville Regional Medical Center at Smithville for emergency evaluation by the trauma medical professionals. She was placed on a mechanical ventilator to establish breathing. Due to the severe, rapid swelling resulting from the extensive burns, escharotomy surgeries were performed. The surgery involved cutting through Wendy's charred skin to allow the blood to flow to the tissues of her trunk, left arm and right leg.

Wendy was in excruciating pain, as the medical records note that she was a combative young female moving all extremities. Lung in-halation injuries were confirmed when Wendy produced carbonaceous sputum from her NG [nasogastric] tube. (Bates 000044) Exams revealed that Wendy had decreased breath sounds in the right upper lung lobe. A chest x-ray revealed total collapse of the right upper lobe of her lung. For alleviation of this life-threatening injury, a chest tube was punctured through Wendy's chest wall into her collapsed right upper lung to drain the toxic fluids and gasses and seal any leakage of air.

To prevent hypovolemic shock and adequate blood tissue perfusion, an arterial line was threaded into her artery to monitor her blood acid base balance and oxygen and carbon dioxide contents. A right subclavian tube was threaded into her neck through the subclavian vein to measure her blood volume. A nasogastric tube was inserted up through her nose into her esophagus and lodged into her stomach which allowed her to obtain nutrition and hydration.

Due to a burn victim's wildly fluctuating blood volume, it was imperative to measure Wendy's hemodynamic status, including intra-arterial pressure, pulmonary artery and capillary wedge pressure, central venous pressure, cardiac output and blood volume. Wendy tolerated a Swan-Ganz cardiac catheterization which forced a deflated ballooned tube into her superior vena cava through the right atrium of her heart, right ventricle, and left atrium. The catheter then lodges into the pulmonary artery. When the balloon is inflated, the catheter becomes wedged in the pulmonary artery and monitors the hemodynamic status.

On August 29, 1996, Wendy endured her first operation of excision of burned skin and grafting of her viable skin. The doctors noted that Wendy developed the complication of thrombocytopenia. (Bates 000056). This life-threatening injury can occur when the platelets, the clotting factors in the blood, decrease. This predisposed Wendy to bleed-outs, hemorrhage and infection.

In order to insure adequate respiratory function and adequate tissue oxygenation, a direct inspection of the extent of lung damage from the smoke inhalation was necessary. A bronchoscopy was performed on August 31, 1996, which required the insertion of a metal light tube, a bronchoscope, through Wendy's nose into her larynx, trachea and into the lung bronchi. Visualization of the airway passage, biopsy and culture of the tissues and removal of pathogens were made to define the extent of the inhalation damage and origin of her infections.

On August 6, 1996, Wendy endured the 3rd surgery for excision of the burned skin and grafting of her viable skin. In his report, Dr. Herndon notes that Wendy has been extremely agitated, has expiratory difficulties with wheezing, had an extremely high heart rate, her donor sites were not healing and there was necrosis on the buttocks with some infection. With the evidence that her heart rate had accelerated rapidly, her donor sites were not healing and were rotting, the doctor ordered daily biopsies from her damaged areas of skin and cultures of bronchial washings and mucus to identify the offending bacterial organism. (Bates 000068)

Wendy's recovery was further impeded by fever spikes indicating sepsis of unknown origin. The worst crisis occurred on August 13, 1996 when Wendy's grafted wounds exhibited ghosting, graft versus host reaction. This signaled impending pathological tissue rejection between the host and the tissue that has been grafted. Bactorban treatment was instituted to cure this complication; however, the infection persisted. (Bates 000044 and 000045)

On August 17, 1996, problems with the ghosting, graft versus host on the nonhealed chest wounds concerned the doctors. The tissue cultures revealed Wendy was infected with the following bacteria: Escherichia coli, a causative agent in suppuration, cystitis, pyelitis; Staphylococcus aureus, a causative agent in osteomyelitis, pyemia, suppuration; and Klebsiella, a causative agent in pneumonia.

On August 20, 1996, Wendy was again forced to endure another excision and grafting surgery, this time she returned from the operating room lying face down to allow the buttocks wounds to heal without the threat of infection. (Bates 000100) The doctor notes his concern that Wendy still had open wound areas not healing on her back, buttocks, chest, abdomen and scalp.

The discharge note on August 27, 1996 states that Wendy can be released from the hospital with a few small open wound areas in her axilla and buttocks which will require further surgery grafting.

C. SURGICAL PROCEDURES - WENDY

The course of therapy for burn victims calls for hemodynamic stabilization, metabolic support, wound debridement, use of topical antibacterial therapy and biologic dressings and wound closure. Prevention and treatment of complications, including infection and pulmonary damage and rehabilitation are also of major importance. Wendy underwent five surgeries which consisted of cutting off her eschar, destroyed charred skin, cutting off her live tissue and stapling and wrapping the live tissue over the removed skin. These surgeries are detailed as follows:

1. DATE: 7-29-96

DIAGNOSIS: Flame burn injury fifty-two percent (52%) over her entire body with forty-six percent (46%) of which were third degree, inhalation injury

PROCEDURE: Excision and grafting of both arms, posterior anterior trunk, both buttocks, both legs. The doctors cut off the charred dead skin from both areas, back and front of Wendy's abdomen, chest and back, both buttocks, both legs. The doctors cut off Wendy's limited viable skin (donor sites) at the anterior right and left thigh, posterior right and left thigh, lower abdominal wall anterior and upper back and chest. Wendy's viable skin was stapled and wrapped on the excised burn skin portions. On 7-30-96, Dr. Herndon notes in his report, "The burn was down to the level of the fascia." Due to poor respiratory status, Wendy continued on ventilator support and developed the complication of thrombocytopenia, reduced blood platelet count which hinders clotting and signals infection and impending shock. (Bates 00045 & 000056)

DOCTORS: Dr. David Herndon, Chief of Staff
Dr. Steven Wolf, Assistant Professor of Surgery
Dr. Michael Trahan, General Surgery Intern

2. DATE: 8-6-96

DIAGNOSIS: Flame burn injury fifty-two percent (52%) over her entire body with forty-six percent (46% of which were third degree, inhalation injury.

PROCEDURE: Excision and grafting of bilateral buttocks and extremities and anterior thorax using donor sites from the right anterior and posterior thighs, left lower leg, scalp, upper back, left hip and right lower abdomen. The doctors cut off the burned dead skin from Wendy's buttocks, arm, legs and chest. Wendy's viable living skin was cut off from her right front and back thighs, left leg, scalp, upper back, left hip and right lower belly and stapled and wrapped on the burned skin site.

In his 8-6-96 report, Dr. Herndon notes, "She has been extremely agitated and has expiratory difficulties with wheezing." He also notes that she had an extremely high heart rate from 186 to 221 beats per minute, her donor sites were still not healing and there was some necrosis on the buttocks with some infection. With the evidence that her heart rate had accelerated rapidly, her donor sites were not healing and were rotting, the doctor reviewed Wendy's biopsies which revealed that she had an antibiotic resistant organism [bacterial] (Bates 00068).

DOCTORS: Dr. David Herndon, Chief of Staff

3. DATE: 8-13-96

DIAGNOSIS: Flame burn injury fifty-two percent (52%) over her entire body with forty-six percent (46%) of which were third degree, inhalation injury.

PROCEDURE: Excision and grafting of both legs, both buttocks using donor sites from the upper back, left arm, right arm, left thigh (Bates 000046). The doctors cut the dead skin from both legs, both buttocks. They cut off viable skin from her upper back, both arms and left thigh and stapled the living skin to the burned skin sites. Despite the use of antibiotics and burn care, the skin and pulmonary infections were rampant. The health care personnel began a rigorous regimen of irrigating and suctioning her lungs to clear the infections. Dr. Desai notes that Wendy had problems with the chest wounds with signs of ghosting from the staphylococcus infections. She has been growing an MSRE and E. Coli from her wounds. A staphylococcus aureus from her bronchial washings was also discovered. The sputum culture from the 9th showed an MRSE and Klebsiella. She is covered with antibiotics to attempt to fight the infection. She is having to be suctioned in her bronchi to clear up her rales. (Bates 00086)

4. DATE: 8-20-96

DIAGNOSIS: Flame burn injury fifty-two percent (52%) over her entire body with forty-six percent (46%) of which were third degree, inhalation injury.

PROCEDURE: Excision and grafting of bilateral lower extremities, left arm, buttocks and bilateral axillary releases. Dr. Herndon notes in his 8-20-96 patient care improvement conference that there are remaining open areas on her back and buttocks, chest, and abdomen. She has had one episode of sepsis during the course...she cultured an E. coli and a Klebsiella. She has an open area on the scalp. (Bates 000100)

DOCTORS: Dr. Herndon

5. DATE: 8-27-96

DIAGNOSIS: Flame burn injury fifty-two percent (52%) over her entire body with forty-six percent (46%) of which were third degree, inhalation injury.

PROCEDURE: Essentially closed with only a few small open areas in the axilla and buttock region. She needs to have patch graft to the open areas to get into the school reentry program. (Bates 000114)

DOCTORS: Dr. Herndon

D. PERMANENT DAMAGE - WENDY

Wendy has very massive, major second and third degree burns. Problems predicted in the future are innumerable. As Dr. Parks notes, one of the complications of burns is scar contractures, which describes the term for the build up of scar tissue. This leathery, hardened skin prohibits the movement of joints in the hand, the elbows, the shoulders, the legs. Any scarred part of the body can be affected by burn scar contractures. There are some surgical treatments to correct or alter these contractures, but not completely.

Particular problems with children include the fact that as children grow, the scar tissue does not grow as quickly as the rest of the child's internal body structure. Future problems are unpredictable at this point in time. (DP 12) Generally, progressive burn scar contractures disrupt some aspects of growth. The psychological effects must be considered in children with such massive injuries.

Dr. Parks comments that the same type of problems with environment as experienced by adults pose major problems with children in that the child is limited by her vocational outlook and activity outlook in the future. (DP 12)

Special garments and splints will be necessary to control the development of contracture of Wendy's scar tissue, although there is absolutely no way known to prevent or to completely control scar tissue. The scars are permanent and really can be modified very little in the future. (DP 10)

Webbing and scarring between Wendy's fingers limit her from spreading the fingers a part, and surgical correction will be necessary to correct this complication.

Wendy will need to avoid outdoors and apply sunscreens, due to the sun and light sensitivity of the scar tissue. She will also need to practice conscientious hygiene due to her susceptibility to infection.

The scar tissue that covers the majority of Wendy's body will never grow hair, never manufacture oil or sweat glands. She cannot regulate her body temperature and has no reserve of physiology to help control her internal temperature. She is at risk of sunstroke or heat stroke and dehydration. Wendy must avoid outdoor work due to the temperature and high humidity. This will be difficult since Wendy is a seven-year-old girl. In summation, the psychological distress that accompanies her physical disfigurement is permanent and will be a major factor for the rest of her life.

E. MEDICAL EXPENSES - WENDY

The life-care plan for Wendy Germaine is currently being prepared by Dr. Charlene F. Johansen. We anticipate that the life care will be approximately the same as Lee Lynette Waymond. For our present purposes, we regard the medical expenses as follows:

a. Past medical: $420,190
b. Future medical: $362,025
Total Medical Expenses: $782,215

F. HEALTH CARE PROVIDERS - WENDY

Steven Wolf, M.D. - Assistant Professor of Surgery
David N. Hendron, M.D. - Chief of Staff
Manu H. Desai, M.D. - Professor of Surgery
Linda Roberts, OTR
Karen Mendiola, OTR
Trahan, M.D.
Amy Grace, P.T.
Jacqueline Thompson, M.D. - Clinical Burn Fellow
St. Stephen Burn Institute
815 Market Street
Smithville, Texas 55555
(555) 555-5555
7/28/96

LifeFlight - Lakeside Hospital
4444 Farmington Road
Orchard, Texas 55555
(555) 555-5555
7/28/96, 8/3/96 - 9/2/96

Eastern Regional Medical Services
Riggs
J. Miller
Charles Riggs
600 . Halberry
Red Oak, Texas 55555
(555) 555-5555
7/28/96

Smithville Regional Medical Center - Smithville
Darien Bradford, M.D. - Chief Trauma Resident
G. Shulman, M.D. - Pathology
S. John, M.D. - Radiology
Sunken, M.D.
Susan John, M.D. - Radiology
William Mileski, M.D. - Trauma Faculty
M. Griffin, M.D.
555 University Blvd.
Smithville, Texas 55555
P.O. Box 555555
Orchard, Texas 55555
(555) 555-5555
7/28/96

Red Oak Regional Hospital
Outpatient, Physical Therapy
Stephanie Wilkinson, P.T.
B. Field, P.T.
B. Fold
C. Bones
M. Chiles, P.T.
C. Lopez, P.T.
P.O. Box 1797
Red Oak, Texas 5555
(555) 555-5555
9/10/96 - 9/30/96

G. DAMAGES - WENDY

1. Basis of Recovery

Wendy Germaine is entitled to recover personal injury damages for her own extensive personal injuries which consist of burns over fifty-two percent of her total body surface area.

2. Life Expectancy

Wendy Germaine was born on August 30, 1989, and spent her seventh birthday in excruciating pain, completely wrapped and immobilized in the St. Stephen Burn Institute in Smithville, Texas. Her life expectancy, according to the 1993 United States Life Table, was 73.1 years.

3. Per Diem Evaluation

One of the accepted methods under Texas law for arguing damages in cases of this type is the per diem argument. A life expectancy of 73.1 years gives Wendy a future of 26,681.5 days which calculated at 16 waking hours per day totals 426,904 hours. This is the calculation we will use for the per diem computations for purposes of this demand letter.

4. Personal Injury Damages - Wendy

a. Physical Pain: The physical pain which this child endured during the first ninety days after this tragedy is incalculable, but we will ask a jury to award a minimum of $100 per hour for the first ninety-day period at 16 waking hours per day. This will be a total of $144,000.

After the first three months, the pain associated with this injury was materially reduced and we ask for an award of $1 per hour after the first ninety days which is a total of $425,464. Thus, the total which we will seek from a jury for the physical pain and suffering of Wendy Germaine as a result of her personal injury is $569,464.

b. Mental Anguish: For the mental anguish which this child will endure for every waking moment for the rest of her life we will ask the jury for a comparatively modest award of $5 per hour. At 436,904 hours, this totals $2,184,520. an amount for which no juror would trade places with Wendy Germaine.

c. Physical Disability: Dr. Stan V. Smith, President of Corporate Financial Group, Ltd., will testify that the loss of enjoyment of life to Wendy Germaine is $3,338,604, as set out in the exhibit which is provided with this demand letter.

d. Physical Disfigurement: The videotape accompanying this demand letter shows graphically the horrible disfigurement which this child has experienced over fifty-two percent of her body. We will ask a jury to award $5 per hour to compensate Wendy Germaine for the horrors of this disfigurement. At 436,904 hours, this totals $2,184,520.

e. Loss of Wage Earning Capacity: Dr. Stan V. Smith has calculated Wendy's wage earning capacity over her lifetime at $836,526. We will persuade a jury that, as a result of this horrible tragedy, Wendy has lost seventy-five percent of that wage earning capacity, which totals damages in the amount of $627,421.50.

f. Medical Expenses: Dr. Charlene F. Johansen, President of LifeCare Planning, Inc., will testify as to the reasonable and necessary medical expenses which Wendy Germaine can anticipate after age eighteen. This calculation is not complete but we anticipate that it will be the same as Lee Lynette Waymond, which is in the amount of $175,066.56.

5. James Germaine - Personal Injury to Wendy

a. Medical Expenses to Age 18: Dr. Charlene F. Johansen of LifeCare Planning, Inc. in Orchard is calculating the medical expenses which Wendy Germaine has incurred in the past and will incur for the remainder of her life in the future. The cost of the total past medical is expected to be in the range of $400,000. The one-time cost of future medical is $153,020. The annualized cost of recurring medical through Wendy's eighteenth birthday is approximately $35,000. Thus, James has a total cost of medical expenses for Wendy Germaine through age eighteen in the amount of $588,020.

b. Loss of services: James Germaine is entitled to recover for the reasonable value of services which Wendy Germaine would have rendered had she not been incapacitated. For purposes of this mediation we are evaluating the loss of services at $5,000 per year for the eleven-year period to Wendy's eighteenth birthday for a total loss of $55,000.

c. Mental Anguish: Pursuant to the holding of the Texas Supreme Court in Birchfield vs. Texarkana Memorial Hospital, 747 S.W.2d 361 (Tex. 1987) James and Judy Germaine are entitled to recover for their mental anguish as a result of the injury to their child. We are making a very modest claim for a mental anguish recovery to James Germaine in the amount of $50,000.

6. Judy Germaine - Personal Injury to Wendy

a. Loss of services: Judy Germaine is entitled to recover for the reasonable value of services which Wendy Germaine would have rendered had she not been incapacitated. For purposes of this mediation we are evaluating the loss of services at $5,000 per year for the eleven-year period to Wendy's eighteenth birthday for a total loss of $55,000.

b. Mental Anguish: Pursuant to the holding of the Texas Supreme Court in Birchfield vs. Texarkana Memorial Hospital, 747 S.W.2d 361 (Tex. 1987) James and Judy Germaine are entitled to recover for their mental anguish as a result of the injury to their child. We are making a very modest claim for a mental anguish recovery to Judy Germaine in the amount of $50,000.

H. JURY VERDICT POTENTIAL - WENDY

1. Wendy Germaine
a. Physical pain and suffering $ 569,464
b. Mental anguish $ 2,184,520
c. Physical disability $ 3,338,604
d. Physical disfigurement $ 2,184,520
e. Damage to wage earning capacity $ 627,421
f. Medical expenses after age eighteen $ 175,066

2. James Germaine - Personal Injury to Wendy
a. Medical expenses to age eighteen $ 588,020
b. Loss of services $ 55,000
c. Mental anguish $ 50,000

3. Judy Germaine - Personal Injury to Wendy
a. Loss of services $ 55,000
b. Mental anguish $ 50,000

I. SETTLEMENT DEMAND - WENDY

Based upon the foregoing review of the liability and damages aspects of this case, we are offering to settle all claims of Wendy Germaine arising out of this tragic occurrence for cash or a combination of cash and structured settlement of equal value on the following basis:

1. Personal Injury: Self $ 4,500,000
2. James Germaine $ 345,000
3. Judy Germaine $ 50,000

VIII - DEATH OF ANNETTE RAWLINS

A. AUTOPSY REPORT OF ANNETTE

The office of the Medical Examiner of Clements County at Joseph Miltner Forensic Center, conducted the Pathological Diagnosis on the seven-year-old girl and passenger of the Glider , Annette Rawlins. It is the examiner's opinion that the child came to her death as a result of a charred body, motor vehicle accident, passenger. Annette's aunt, Sally Waymond, had to identify her charred body which was found in the right rear passenger position trapped in the burning Glider . Annette Rawlins was burned from the skin down to the bone, one of the most agonizing ways to die in excruciating pain as the skin was seared through the dermis, tissues, muscles and bones, cooking the bodily organs.

The postmortem examination is extremely detailed describing that the child, Annette Rawlins, suffered a frightful, harrowing death in the rear passenger's seat in the Glider . The reports indicate that as a result of this accident, Annette's body was severely burned with nearly all of her skin and tissues burned away. Shockingly, Annette Rawlins's brain, heart and other internal organs were literally cooked in the extensive fiery heat. The examination, summarized in grisly detail, explains the effect of the blaze on Annette Rawlins's body.

1. Head - Annette's entire top skull was burned away severely, cooking her brain and exposing the dura and brain contents. The brain contents had severe heat and cooking artifact over the entire internal structures. The cerebral hemispheres were severely charred and thickened. The skin over Annette's face was totally burned away, exposing her underlying muscles and bones of the face. Her teeth were exposed and severely charred. Her mandible was exposed due to burning away of the tissue over it. Annette's tongue tip was severely burned, blackened and thickened. No soot or carboneous debris within her larynx or trachea was found. Her thyroid gland was severely charred.

2. Chest - Annette's chest skin was burned, extremely thickened and firm due to the severe heat and cooking artifact. Her left chest was burned away, exposing her muscles and left ribs. Her right sternum ribs were missing as they had been completely burned away.

The little girl's heart had a severe heat artifact of the right lower chamber. Her lungs were severely charred and cooked. The right lung was shrunken, thickened and blackened due to the severe burning effect on her body. The left lung had heat artifact of the lower lobe and lower tip of the left upper lobe.

3. Abdomen - Most of the skin and fat had been totally burned away from Annette's belly, exposing her charred right lung, intestines and liver. Her right liver lobe was severely charred and firm because of the burn artifact. Her pancreas had severe heat artifact. Only her left adrenal was found, supposedly, the right adrenal was burned away in the fiery accident. The appendix was not found, apparently also burned off. The right side of the colon and small intestine were severely charred and burned. The stomach was charred and the esophagus was firm and thickened due to the heat artifact.

4. Genitourinary - Annette's right and left kidney were severely charred and the right kidney was shrunken due to severe burn artifact.

5. Legs - Annette's left thigh showed severe charring of the skin as well as large area in which the skin was burned completely away, exposing the muscles large areas which were ruptured. The left leg was attached and intact at the joint. The left leg showed the tissue and muscle to be burned away exposing the tibia and fibula. The tissues and muscles of the left foot were burned away, exposing underlying bones and muscles.

The right mid femur was missing. There was severe charring of the end of the bone. All the muscles of the right upper thighs were severely charred and exposed. The right foot and ankle were severely charred with the skin burned away. The right leg was separated into two large fragments one of which was identified as a charred knee joint. The lower leg was absent due to the heat fracture of the femur. A small remnant of the knee joint was attached by a muscle to the lower thigh.

6. Arms - Annette's right arm was fractured in the middle of the humerus and was severely burned. The skin of the right arm was burned away exposing the muscles, some of which were ruptured. The distal humerus bone was missing, supposedly burned away.

The left arm was intact, but the wrist had separated from the radius and ulna. Phalanges of the left hand were severely burned, shrunken and charred. The elbow joint was exposed through the left arm, as fractured and the proximal portion was missing. Her right humerus, just above the elbow, was fractured, and the rest of the arm was severely shrunken and burned with contracture. Her bones were exposed and several of her muscles had ruptured from the heat.

Valid XHTML 1.0 Transitional