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name: demand-package-compilation language: en description: 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.

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.

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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)