casemark/demand-package-compilation

Demand Package Compilation

Assembles a litigation-ready demand package — cover letter, demand letter, and indexed exhibits — for settlement negotiation.

Prerequisites

1. Case facts — incident/breach narrative, dates, party names and roles
2. Damages documentation — medical bills, invoices, wage records, repair estimates
3. Evidence inventory — photos/video, witness statements, expert reports, contracts, correspondence
4. Legal theories — duties breached, applicable statutes or common law claims
5. 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

• [ ] Every exhibit reference in the letter matches an included, labeled exhibit
• [ ] Every factual assertion backed by an exhibit
• [ ] Damages figures cross-referenced to source documents
• [ ] Dates, names, party designations consistent throughout
• [ ] Total demand and response deadline stated clearly
• [ ] No attorney work product or privileged communications included
• [ ] HIPAA: written patient authorization confirmed before transmitting medical records
• [ ] Sensitive PII redacted where not essential
• [ ] Package paginated, bookmarked (PDF), and exhibit-indexed

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)