The Demand Package Checklist: What to Assemble Before You Send

The demand anatomy post earlier in this series ended on a claim I'll stand behind: demands fail in the assembly far more often than they fail in the writing. This post is that claim made operational — the complete pre-send checklist, the same discipline I run before any demand package leaves with my name on the assembly.

The logic of the checklist is the adjuster's logic: every item below is something that lets the person on the other end verify, value, and justify. Every hole is an invitation — either to a lowball (justified internally by "incomplete documentation") or to the six-week delay of a supplemental-request cycle. Run the list, close the holes, and the package does its job.

(A printable one-page version of this checklist is available to newsletter subscribers — signup below. The fictional-case house rule applies to the examples, as always.)

Section 1 — Claim mechanics

The unglamorous items that let the package be processed at all:

• Claim number, insured's name, date of loss — on the cover letter, correct, matching the carrier's file
• Your representation letter / letter of protection status — confirmed on file with the carrier
• The demand's terms — amount, response deadline, and any conditions, stated identically in the letter body and any cover page (mismatched deadlines between cover and body happen more than anyone admits, and defense counsel notices)
• Time-limited demand requirements, if applicable — every jurisdiction-specific element verified; this is its own discipline and its own post later in the series

Section 2 — Liability documentation

• Police/incident report — complete, including diagrams and supplements, not the first page
• Photos — vehicles/scene/conditions, organized and labeled; property damage estimates or total-loss documentation
• Witness statements — with contact information current as of sending
• Citations or convictions related to the incident, documented

The test for this section: could a skeptical reader reconstruct fault from the exhibits alone, without trusting a single adjective in the letter?

Section 3 — Medical documentation (where most holes live)

• Complete records from every treating provider — every provider the records themselves mention: the urgent care referenced in the PCP note, the imaging center behind the MRI report. Records that reference absent providers are the #1 hole in demand packages; the adjuster reads the same reference you missed
• All bills, itemized — matching the specials summary to the dollar
• The treatment timeline reconciled — gaps identified and addressed in the letter rather than left for discovery (the credibility play from the anatomy post: explain it before they find it)
• Prior records where relevant — if pre-existing conditions are in play, the package that includes and distinguishes them controls that narrative; the one that omits them concedes it
• Diagnostic films/reports — the actual MRI report, not just the orthopedist's reference to it

Section 4 — Damages beyond the medicals

• Wage loss — employer verification on letterhead, pay stubs or tax documentation, disability notes covering the missed period; self-employed claims need the tax returns and the math shown
• Liens and subrogation — health insurer, med-pay, government-payor interests identified and stated; surprise liens kill settlements at the finish line, and carriers know to ask
• Out-of-pocket expenses — receipts, mileage, the small items that are only credible documented
• General damages support — the specifics that make pain-and-suffering concrete: activity restrictions in the records, household impact, the before/after that exhibits can carry

Section 5 — The package itself

• Exhibit index — numbered, titled, paginated; every exhibit cited from the letter, every citation landing where it points
• Internal consistency check — the number in the demand paragraph matches the damages math matches the specials summary; dates consistent across letter, chronology, and records
• Legibility pass — every scanned page readable; illegible exhibits are absent exhibits
• Delivery and proof — sent per the carrier's required channel, with delivery confirmation calendared against the response deadline

The pattern behind the list

Is it complete? Is it consistent? Can every claim be verified without trusting us?The checklist is three questions asked five ways

That's the entire discipline. It's also — candidly — tedious, detail-heavy, deadline-adjacent work, which is exactly the profile of work that slips when an attorney is carrying it personally on top of a caseload. (The caseload post covered why that slippage is structural, not personal.)

Assembly is delegable. The strategy and the number stay yours; the package that makes the number defensible is what I do all day. If your office sends demands monthly, put the printable version of this list where the assembly happens — and if you'd rather the assembly simply arrive done, you know where to find me.

Questions attorneys ask

Educational content for legal professionals — not legal advice. All case examples fictional.