Demand Package Compilation
demand-package-compilation
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 bun...
SKILL.md
Full skill instructions
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
- 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)