Demand Package Compilation
Assembles a litigation-ready demand package — demand letter, itemized damages, and organized exhibits — for plaintiff-side pre-filing or settlement negotiations in U.S. commercial matters.
Prerequisites
Collect before drafting:
- Incident/breach documentation — contracts, incident reports, triggering event records
- Damages documentation — bills, invoices, pay stubs, repair estimates, receipts
- Medical records (if applicable) — HIPAA authorization must be confirmed
- Correspondence history — emails, letters, prior settlement communications
- Witness statements / expert reports (if available)
- Demand amount and response deadline — confirmed with supervising attorney
Quick Start
A complete package has four components assembled in order:
- Cover letter — parties, file/claim number, transmittal statement, response deadline
- Demand letter — facts, legal theories, damages, demand figure
- Damages calculation — itemized by category with exhibit citations
- Exhibit index + exhibits — sequentially numbered, matching letter citations
Core Workflow
1. Draft the Demand Letter
| Section |
Content |
| Introduction |
Client identity, adverse party, basis for claim |
| Statement of Facts |
Chronological narrative with dates, cited to exhibits |
| Legal Theories |
Causes of action, duties breached, statutory basis |
| Damages |
Itemized breakdown by category, total demand figure |
| Liability Summary |
Why liability is clear; address known weaknesses proactively |
| Demand & Deadline |
Dollar amount, response deadline, consequence of non-response |
2. Calculate Damages
Economic — cite supporting documentation for each:
- Past/future medical expenses (bills, EOBs, expert projections)
- Past/future lost wages or earning capacity (pay stubs, employer records, vocational expert)
- Property damage / repair costs (estimates, invoices)
- Out-of-pocket expenses (receipts)
Non-economic:
- Pain and suffering, emotional distress, loss of enjoyment of life
- Loss of consortium (where applicable)
Punitive (if applicable):
- State legal basis and specific conduct justifying the award
3. Organize Exhibits
Number sequentially (Ex. 1, 2, 3…) in the order cited in the demand letter:
| Category |
Examples |
| Incident documentation |
Reports, photographs, video |
| Medical records & bills |
Treatment records, EOBs, billing summaries |
| Employment / wage records |
Pay stubs, employer letters, tax records |
| Property damage |
Repair estimates, invoices |
| Witness statements |
Signed statements, affidavits |
| Expert reports |
Medical, vocational, engineering, economic |
| Contracts & agreements |
Relevant provisions highlighted |
| Correspondence |
Chronological communications with adverse party |
| Legal authority |
Statutes, regulations, key cases [VERIFY citations] |
Pre-Submission Checklist
Common Pitfalls
- Privilege leaks — exclude all attorney-client communications and work product without exception
- HIPAA violations — never include protected health information without valid written authorization
- Unsupported assertions — every factual claim needs an exhibit citation; unsupported claims undermine credibility
- Inflammatory tone — keep language professional and factual; let evidence carry persuasive weight
- Omitting weaknesses — address known weaknesses proactively but frame favorably; omission invites skepticism
- Incomplete package — the package must stand alone; the recipient should need no supplementation to evaluate the claim
1---2name: demand-package3description: Compiles pre-suit or pre-settlement demand packages for U.S. commercial litigation plaintiffs. Assembles demand letter, damages calculation, and exhibit set. Use when drafting demand packages, pre-litigation settlement demands, or breach-and-cure notices.4license: Apache-2.05---67# Demand Package Compilation89Assembles a litigation-ready demand package — demand letter, itemized damages, and organized exhibits — for plaintiff-side pre-filing or settlement negotiations in U.S. commercial matters.1011## Prerequisites1213Collect before drafting:1415- **Incident/breach documentation** — contracts, incident reports, triggering event records16- **Damages documentation** — bills, invoices, pay stubs, repair estimates, receipts17- **Medical records** (if applicable) — HIPAA authorization must be confirmed18- **Correspondence history** — emails, letters, prior settlement communications19- **Witness statements / expert reports** (if available)20- **Demand amount and response deadline** — confirmed with supervising attorney2122## Quick Start2324A complete package has four components assembled in order:25261. **Cover letter** — parties, file/claim number, transmittal statement, response deadline272. **Demand letter** — facts, legal theories, damages, demand figure283. **Damages calculation** — itemized by category with exhibit citations294. **Exhibit index + exhibits** — sequentially numbered, matching letter citations3031## Core Workflow3233### 1. Draft the Demand Letter3435| Section | Content |36|---|---|37| Introduction | Client identity, adverse party, basis for claim |38| Statement of Facts | Chronological narrative with dates, cited to exhibits |39| Legal Theories | Causes of action, duties breached, statutory basis |40| Damages | Itemized breakdown by category, total demand figure |41| Liability Summary | Why liability is clear; address known weaknesses proactively |42| Demand & Deadline | Dollar amount, response deadline, consequence of non-response |4344### 2. Calculate Damages4546**Economic** — cite supporting documentation for each:47- Past/future medical expenses (bills, EOBs, expert projections)48- Past/future lost wages or earning capacity (pay stubs, employer records, vocational expert)49- Property damage / repair costs (estimates, invoices)50- Out-of-pocket expenses (receipts)5152**Non-economic:**53- Pain and suffering, emotional distress, loss of enjoyment of life54- Loss of consortium (where applicable)5556**Punitive** (if applicable):57- State legal basis and specific conduct justifying the award5859### 3. Organize Exhibits6061Number sequentially (Ex. 1, 2, 3…) in the order cited in the demand letter:6263| Category | Examples |64|---|---|65| Incident documentation | Reports, photographs, video |66| Medical records & bills | Treatment records, EOBs, billing summaries |67| Employment / wage records | Pay stubs, employer letters, tax records |68| Property damage | Repair estimates, invoices |69| Witness statements | Signed statements, affidavits |70| Expert reports | Medical, vocational, engineering, economic |71| Contracts & agreements | Relevant provisions highlighted |72| Correspondence | Chronological communications with adverse party |73| Legal authority | Statutes, regulations, key cases **[VERIFY citations]** |7475## Pre-Submission Checklist7677- [ ] Every exhibit referenced in the letter is included and labeled78- [ ] Every factual assertion is supported by a cited exhibit79- [ ] Damage figures match supporting documentation exactly80- [ ] Names, dates, and entity identifiers are consistent throughout81- [ ] HIPAA authorizations obtained for all included medical records82- [ ] Attorney work product and privileged communications excluded83- [ ] PII redacted (SSNs, account numbers, unrelated health info)84- [ ] Demand amount and response deadline clearly stated85- [ ] Package is sequentially paginated with complete exhibit index86- [ ] All cited statutes and cases apply to the governing forum **[VERIFY]**8788## Common Pitfalls8990- **Privilege leaks** — exclude all attorney-client communications and work product without exception91- **HIPAA violations** — never include protected health information without valid written authorization92- **Unsupported assertions** — every factual claim needs an exhibit citation; unsupported claims undermine credibility93- **Inflammatory tone** — keep language professional and factual; let evidence carry persuasive weight94- **Omitting weaknesses** — address known weaknesses proactively but frame favorably; omission invites skepticism95- **Incomplete package** — the package must stand alone; the recipient should need no supplementation to evaluate the claim
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