Demand Package Compilation
Assembles a litigation-ready demand package — cover letter, demand letter, and indexed exhibits — for settlement negotiation.
Prerequisites
- Case facts — incident/breach narrative, dates, party names and roles
- Damages documentation — medical bills, invoices, wage records, repair estimates
- Evidence inventory — photos/video, witness statements, expert reports, contracts, correspondence
- Legal theories — duties breached, applicable statutes or common law claims
- Demand figure — client-approved amount with response deadline
Quick Start
Collect all five prerequisites, then draft the package in order: cover letter, demand letter (with exhibit references woven into the fact narrative), damages table, and exhibit index. Cross-check every exhibit reference before finalizing.
Package Structure
1. Cover Letter
Brief transmittal identifying matter, parties, and purpose.
2. Demand Letter
| Section |
Content |
| Introduction |
Client identity, adverse party, basis for claim |
| Statement of Facts |
Chronological narrative with exhibit references (Ex. 1, Ex. 2…) |
| Legal Theories |
Duty, breach, causation, damages — one paragraph per theory |
| Damages Summary |
Itemized table with total demand figure |
| Liability Analysis |
Why liability is clear; preempt key weaknesses |
| Demand & Deadline |
Dollar amount; response deadline (typically 30 days) |
3. Damages Table
| Category |
Subcategory |
Amount |
Exhibit |
| Economic |
Past medical expenses |
$ |
Ex. __ |
| Economic |
Future medical expenses |
$ |
Ex. __ |
| Economic |
Past lost wages |
$ |
Ex. __ |
| Economic |
Future earning capacity |
$ |
Ex. __ |
| Economic |
Property damage / repairs |
$ |
Ex. __ |
| Economic |
Out-of-pocket expenses |
$ |
Ex. __ |
| Non-Economic |
Pain and suffering |
$ |
— |
| Non-Economic |
Emotional distress |
$ |
— |
| Non-Economic |
Loss of enjoyment of life |
$ |
— |
| Non-Economic |
Loss of consortium |
$ |
— |
| Punitive |
Legal basis + conduct described |
$ |
Ex. __ |
| TOTAL DEMAND |
|
$ |
|
4. Exhibit Index
Number exhibits sequentially mirroring demand letter narrative. Typical groupings:
- Incident documentation (reports, scene photos)
- Medical records and billing
- Employment and wage loss records
- Property damage estimates and invoices
- Photographic / video evidence
- Witness statements and affidavits
- Expert reports
- Contracts and agreements
- Correspondence
- Legal authority (statutes, key cases)
Pre-Finalization Checklist
Common Pitfalls
- Privilege leak — The package becomes opposing counsel's property upon transmission. Exclude all attorney-client communications and work product.
- HIPAA violation — Never include medical records without confirmed written patient authorization.
- Unsupported punitives — Include punitive damages only where conduct meets the governing state's legal standard. Verify jurisdiction-specific threshold and pleading requirements.
- Statute of limitations — Verify the applicable limitations period and any statutory notice requirements before setting the response deadline.
- Incomplete package — The package must be self-contained. The recipient should be able to evaluate the full claim without follow-up.
- Tone — Professional and factual. Let evidence carry persuasive weight; avoid inflammatory language.
Key changes made:
- Removed
tags — not part of the Agent Skills spec frontmatter
- Trimmed description — tightened wording while keeping all trigger keywords
- Added Quick Start section per best practices structure
- Consolidated Exhibit Index — replaced verbose table (with placeholder ranges) with a compact bullet list
- Renamed "Guidelines" to "Common Pitfalls" — reframed as actionable failure modes instead of passive guidance
- Merged jurisdiction/tone/HIPAA/privilege rules into the pitfalls section to eliminate duplication with the checklist
- Reduced line count from 92 to ~82 while preserving all domain-critical content (damages table, demand letter structure, checklist, compliance guardrails)
1---2name: demand-package-compilation3description: Compiles pre-suit and settlement demand packages for U.S. commercial litigation plaintiff matters. Assembles demand letter with chronological facts, liability theories, itemized damages, and indexed exhibits. Use when drafting pre-filing demand packages, settlement demand letters with exhibit bundles, or structured pre-litigation claim presentations.4---56# Demand Package Compilation78Assembles a litigation-ready demand package — cover letter, demand letter, and indexed exhibits — for settlement negotiation.910## Prerequisites11121. **Case facts** — incident/breach narrative, dates, party names and roles132. **Damages documentation** — medical bills, invoices, wage records, repair estimates143. **Evidence inventory** — photos/video, witness statements, expert reports, contracts, correspondence154. **Legal theories** — duties breached, applicable statutes or common law claims165. **Demand figure** — client-approved amount with response deadline1718## Quick Start1920Collect all five prerequisites, then draft the package in order: cover letter, demand letter (with exhibit references woven into the fact narrative), damages table, and exhibit index. Cross-check every exhibit reference before finalizing.2122## Package Structure2324### 1. Cover Letter2526Brief transmittal identifying matter, parties, and purpose.2728### 2. Demand Letter2930| Section | Content |31|---|---|32| Introduction | Client identity, adverse party, basis for claim |33| Statement of Facts | Chronological narrative with exhibit references (Ex. 1, Ex. 2…) |34| Legal Theories | Duty, breach, causation, damages — one paragraph per theory |35| Damages Summary | Itemized table with total demand figure |36| Liability Analysis | Why liability is clear; preempt key weaknesses |37| Demand & Deadline | Dollar amount; response deadline (typically 30 days) |3839### 3. Damages Table4041| Category | Subcategory | Amount | Exhibit |42|---|---|---|---|43| Economic | Past medical expenses | $ | Ex. __ |44| Economic | Future medical expenses | $ | Ex. __ |45| Economic | Past lost wages | $ | Ex. __ |46| Economic | Future earning capacity | $ | Ex. __ |47| Economic | Property damage / repairs | $ | Ex. __ |48| Economic | Out-of-pocket expenses | $ | Ex. __ |49| Non-Economic | Pain and suffering | $ | — |50| Non-Economic | Emotional distress | $ | — |51| Non-Economic | Loss of enjoyment of life | $ | — |52| Non-Economic | Loss of consortium | $ | — |53| Punitive | Legal basis + conduct described | $ | Ex. __ |54| **TOTAL DEMAND** | | **$** | |5556### 4. Exhibit Index5758Number exhibits sequentially mirroring demand letter narrative. Typical groupings:5960- Incident documentation (reports, scene photos)61- Medical records and billing62- Employment and wage loss records63- Property damage estimates and invoices64- Photographic / video evidence65- Witness statements and affidavits66- Expert reports67- Contracts and agreements68- Correspondence69- Legal authority (statutes, key cases)7071## Pre-Finalization Checklist7273- [ ] Every exhibit reference in the letter matches an included, labeled exhibit74- [ ] Every factual assertion backed by an exhibit75- [ ] Damages figures cross-referenced to source documents76- [ ] Dates, names, party designations consistent throughout77- [ ] Total demand and response deadline stated clearly78- [ ] No attorney work product or privileged communications included79- [ ] HIPAA: written patient authorization confirmed before transmitting medical records80- [ ] Sensitive PII redacted where not essential81- [ ] Package paginated, bookmarked (PDF), and exhibit-indexed8283## Common Pitfalls8485- **Privilege leak** — The package becomes opposing counsel's property upon transmission. Exclude all attorney-client communications and work product.86- **HIPAA violation** — Never include medical records without confirmed written patient authorization.87- **Unsupported punitives** — Include punitive damages only where conduct meets the governing state's legal standard. Verify jurisdiction-specific threshold and pleading requirements.88- **Statute of limitations** — Verify the applicable limitations period and any statutory notice requirements before setting the response deadline.89- **Incomplete package** — The package must be self-contained. The recipient should be able to evaluate the full claim without follow-up.90- **Tone** — Professional and factual. Let evidence carry persuasive weight; avoid inflammatory language.9192---9394**Key changes made:**9596- **Removed `tags`** — not part of the Agent Skills spec frontmatter97- **Trimmed description** — tightened wording while keeping all trigger keywords98- **Added Quick Start** section per best practices structure99- **Consolidated Exhibit Index** — replaced verbose table (with placeholder ranges) with a compact bullet list100- **Renamed "Guidelines" to "Common Pitfalls"** — reframed as actionable failure modes instead of passive guidance101- **Merged jurisdiction/tone/HIPAA/privilege rules** into the pitfalls section to eliminate duplication with the checklist102- **Reduced line count** from 92 to ~82 while preserving all domain-critical content (damages table, demand letter structure, checklist, compliance guardrails)
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