casemark/demand-package
skills/legal/demand-package/SKILL.md
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.
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skillsauthnpx skillsauth add casemark/skills demand-packageInstall this skill globally with one command. Works with Claude Code, Cursor, and Windsurf.
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SKILL.md
- name:
- demand-package
- language:
- en
- description:
- 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.
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
- [ ] Every exhibit referenced in the letter is included and labeled
- [ ] Every factual assertion is supported by a cited exhibit
- [ ] Damage figures match supporting documentation exactly
- [ ] Names, dates, and entity identifiers are consistent throughout
- [ ] HIPAA authorizations obtained for all included medical records
- [ ] Attorney work product and privileged communications excluded
- [ ] PII redacted (SSNs, account numbers, unrelated health info)
- [ ] Demand amount and response deadline clearly stated
- [ ] Package is sequentially paginated with complete exhibit index
- [ ] All cited statutes and cases apply to the governing forum [VERIFY]
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
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