Pi Demand Summary

---
name: pi-demand-summary
description: Generates structured personal injury demand summaries covering liability analysis, chronological injury documentation, itemized damages, and settlement positioning. Covers MVA, premises liability, product defect, and medical malpractice claims. Use when preparing settlement packages, demand letters, pre-trial evaluations, or insurance adjuster negotiations for plaintiff-side PI matters.
---

# Personal Injury Demand Summary

Synthesizes case materials into a persuasive demand summary for settlement negotiations or internal case evaluation.

## Prerequisites

Gather before starting:

- **Case file**: police/incident reports, witness statements, photos, correspondence
- **Medical records**: ER through current treatment, imaging, surgical notes, discharge summaries
- **Billing records**: itemized medical bills from all providers
- **Wage records**: pay stubs, tax returns, employer verification letters
- **Expert reports** (if available): life care plans, vocational assessments, accident reconstruction
- **Insurance info**: known policy limits, prior adjuster correspondence

## Quick Start

Structure the demand summary in five sections:

1. **Executive Overview** — incident snapshot and demand amount
2. **Liability Analysis** — duty, breach, evidence, comparative fault
3. **Injury Documentation** — chronological treatment narrative
4. **Damages Itemization** — economic + non-economic breakdown
5. **Settlement Positioning** — verdicts, risk assessment, terms

## Core Workflow

### 1. Executive Overview

Include: incident date/location, parties, case type (MVA / premises / product defect / med mal), one-sentence liability theory, total demand amount.

### 2. Liability Analysis

- [ ] Identify defendant's specific acts/omissions constituting breach
- [ ] Cite supporting evidence: police reports, eyewitness accounts, expert opinions
- [ ] Reference applicable legal standards (traffic laws, building codes, statutes)
- [ ] Address and rebut comparative fault arguments
- [ ] State liability apportionment conclusion

### 3. Injury Documentation (Chronological)

Organize by treatment phase:

- **Emergency/acute**: date, facility, complaints, diagnoses, imaging
- **Surgical**: procedures, dates, operative findings, hardware
- **Post-op/rehab**: PT/OT frequency/duration, progress, functional benchmarks
- **Ongoing/maintenance**: current treatment, medications, remaining complaints
- **Prognosis**: MMI status, permanent impairments, future treatment needs

Distinguish **objective findings** (imaging, labs, surgical notes) from **subjective complaints**. For pre-existing conditions, delineate aggravation vs. new injury causation.

### 4. Damages Itemization

**Economic damages** — itemize each with source and amount:

- Past medical expenses (by provider, date, amount)
- Future medical expenses (life care plan or physician projection)
- Past lost wages (employment records, pay period, rate)
- Future lost earning capacity (vocational expert or wage analysis)
- Out-of-pocket (transportation, home mods, Rx, assistive devices)

**Non-economic damages** — support each with specific evidence:

- Pain and suffering (treatment intensity, duration, medication)
- Emotional distress (mental health treatment, documented impact)
- Loss of enjoyment of life (activities curtailed, before/after)
- Permanent disfigurement/disability (functional limitations, rating)
- Loss of consortium if applicable (spousal testimony, relationship impact)

Present totals: economic subtotal + non-economic subtotal = total demand.

### 5. Settlement Positioning

- [ ] Cite comparable jury verdicts in the jurisdiction
- [ ] Note policy limits considerations
- [ ] Assess litigation risk (strengths and vulnerabilities)
- [ ] Evaluate causation strength
- [ ] Estimate comparative fault exposure percentage
- [ ] Set response deadline and conditions (confidentiality, structured settlement, liens)

## Pitfalls and Checks

- **Every factual assertion must trace to a specific document** — cite by document name/date
- **Flag documentation gaps** needing additional discovery
- **Do not fabricate medical causation** — rely on treating physician opinions only
- **Note jurisdiction-specific damage caps** (e.g., non-economic caps) if applicable
- Mark unverified legal citations with `[VERIFY]`
- Maintain persuasive but professional tone — specific human impact, not emotional appeals
- Present damages credibly with negotiation room