What belongs in a US personal injury demand package?

Jurisdiction: United States; state rules and the facts of each matter control. Published: October 13, 2026. This is a legal operations guide, not legal advice.

Start with evidence, not a target settlement figure

A demand package helps counsel present the factual basis for a claim and the support for a proposed resolution. It is not a promise of payment. Before drafting, the supervising attorney should identify the intended recipient, relevant insurance information, disputed issues and any deadline that needs independent confirmation.

Organise the material into a usable record

• Liability: incident reports, photographs, witness material and other records counsel has approved for use. Distinguish documented facts from allegations.
• Medical evidence: a dated chronology with provider names, treatment records and page references. Do not turn a temporal sequence into an unsupported medical causation opinion.
• Damages: bills, wage-loss records and other supporting documents. Keep billed amounts, paid amounts and claimed losses distinct; the legal treatment of these amounts depends on the jurisdiction.
• Exhibits: an indexed collection whose labels match the draft. Check for missing pages, duplication and confidential identifiers.
• Open questions: gaps, inconsistent dates and unverified totals should appear in a separate attorney-review list.

Keep the demand separate from discovery obligations

A pre-suit demand is not the same as federal discovery. If litigation is pending, counsel must separately determine applicable disclosure and discovery duties. Federal Rule of Civil Procedure 26 addresses disclosures and discovery in federal civil proceedings; it should not be treated as a universal demand-letter template for state personal injury cases.

What a virtual paralegal can prepare

OASIS can organise approved records, build an exhibit index, prepare a source-linked medical chronology and draft a package under attorney instructions. The attorney determines legal arguments, valuation, disclosure decisions and whether the demand is sent. The assigned paralegal and authorised quality reviewer check that the work follows the agreed scope before delivery.

Final review before sending

Reconcile totals, verify names and dates against original records, check exhibit references and flag unresolved issues. Confirm the approved transmission channel and recipient. A complete-looking file can still contain an unsupported assertion, so traceability matters more than presentation alone.

Sources and further reading

• Federal Rule of Civil Procedure 26 — disclosures and discovery
• ABA Model Rule 5.3 — responsibilities regarding nonlawyer assistance

Explore OASIS demand package support or view the virtual paralegal offer. ABA Model Rules are models; applicable state rules must be checked.