Personal Injury Demand Letter Template

The 7 sections every effective PI demand letter needs, plus a full text-format template you can copy and adapt. Used by attorneys to extract policy-limit settlements; works for represented and pro-se claimants alike.

Reviewed by Leonard Goldberg, Editor · Last updated May 15, 2026

The 7 Sections (And Why They Matter)

1
Salutation & Reference
Direct the letter to the named adjuster (not just "Claims Department"). Include the claim number, date of loss, and your client's name. Set a 30-day response deadline up front.
2
Facts of Liability
Tell the story chronologically and unemotionally. Reference the police report, witness statements, traffic-cam footage, and any admissions. Tie each fact to the duty-breach-causation-damages chain. Do NOT use "my client thinks" or "appears" — write with confidence.
3
Liability Analysis
Apply the state's fault rule explicitly. "Under Florida's pure comparative negligence rule (Fla. Stat. § 768.81), even if Mr. Smith were found 20% at fault, his recovery would be reduced — not barred." Cite the rule. Pre-empt every comparative-fault argument.
4
Injuries & Medical Treatment
Diagnosis-by-diagnosis recitation. Include the date, provider, ICD-10 codes if available, MRI/imaging findings, and the gap (if any) from accident to first treatment. Attach a complete medical records and bills index — this is the document the adjuster opens first.
5
Damages Calculation
Break it down: medical specials (past + future), lost wages (with W-2/pay stub backup), lost earning capacity (if permanent), property damage, out-of-pocket costs. Then the pain & suffering valuation — show the multiplier you applied and why. Include a settlement number.
6
Policy Limit Discussion (if applicable)
If damages exceed the policy limit, say so explicitly. "Based on $385,000 in documented damages and a $100,000 policy limit, we are demanding the full policy limit of $100,000 within 30 days. Failure to tender will be considered evidence of bad faith." This unlocks bad-faith exposure for the insurer.
7
Demand & Deadline
Specific dollar amount, specific deadline (30 days), specific consequences ("Otherwise, we will file suit on or before [date]"). Don't be vague. The adjuster needs to be able to take a number to their supervisor.

Full Template

Replace anything in [BRACKETS] with your case’s facts. The structure is what matters — every section serves a purpose in the adjuster’s evaluation.

[YOUR NAME / FIRM]
[ADDRESS]
[PHONE / EMAIL]

[DATE]

VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED

[ADJUSTER NAME]
[INSURANCE COMPANY]
[ADDRESS]

Re:  Claim No.: [###]
     Insured: [DEFENDANT NAME]
     Date of Loss: [DATE]
     Our Client: [PLAINTIFF NAME]

Dear [ADJUSTER NAME]:

This firm represents [PLAINTIFF NAME] in connection with injuries sustained
on [DATE] when [DEFENDANT NAME], your insured, [BRIEF FACTUAL DESCRIPTION OF
COLLISION/INCIDENT]. This letter constitutes our demand for settlement.

I.   FACTS OF LIABILITY

On [DATE] at approximately [TIME], [DETAILED CHRONOLOGY OF EVENTS]. [DESCRIBE
ROADWAY, WEATHER, TRAFFIC SIGNALS, AND ANY ADMISSIONS]. The official [STATE]
police report (Report No. [###], attached) identifies your insured as the
party at fault for [SPECIFIC VIOLATION CITED]. [WITNESS NAME], an
uninvolved bystander, [SUMMARY OF WITNESS STATEMENT — attached].

II.  LIABILITY ANALYSIS

[STATE]'s [FAULT RULE — e.g., pure comparative negligence under STATUTE
CITATION] provides that [BRIEF EXPLANATION]. The facts establish [STATE]'s
prima facie negligence: [DUTY], [BREACH], [CAUSATION], and [DAMAGES — see
Section IV below]. No defense of [comparative fault / sudden emergency /
etc.] is supported by the facts.

III. INJURIES & MEDICAL TREATMENT

As a direct and proximate result, [PLAINTIFF NAME] sustained the following
injuries:

  • [INJURY 1] — [PROVIDER], [DATE OF FIRST TREATMENT], [ICD-10 CODE]
  • [INJURY 2] — [PROVIDER], [DATE], [DIAGNOSIS DETAILS]
  • [PERMANENT IMPAIRMENT IF ANY] — [RATING SOURCE]

Treatment has included [SUMMARY: ER, imaging, PT, surgery, injections, etc.].
A complete index of medical records and itemized bills is attached as
Exhibit A.

IV.  DAMAGES

  Past Medical Specials .............. $[AMOUNT]
  Future Medical (Life-Care Plan) .... $[AMOUNT]
  Past Lost Wages .................... $[AMOUNT] (Exhibit B: pay stubs)
  Future Earning Capacity Loss ....... $[AMOUNT]
  Property Damage .................... $[AMOUNT]
  Pain and Suffering ([MULTIPLIER]× specials) $[AMOUNT]
  -----------------------------------------------
  TOTAL DOCUMENTED DAMAGES ........... $[AMOUNT]

V.   POLICY LIMITS

We understand your insured's policy limit is $[AMOUNT]. As the documented
damages substantially exceed the limit, we hereby demand the full policy
limit of $[AMOUNT]. Failure to tender the policy limit within 30 days will
be construed as evidence of bad-faith claim handling and may expose [INSURER]
to extracontractual liability.

VI.  DEMAND

Based on the foregoing, we demand settlement in the amount of $[AMOUNT].
This demand will remain open for thirty (30) days from the date of this
letter. Absent settlement on or before [DATE], suit will be filed in the
[COURT NAME] without further notice.

Please direct all communications to the undersigned. We look forward to
your prompt response.

Very truly yours,

[YOUR NAME]
[BAR NUMBER, STATE]

Enclosures:
  Exhibit A — Medical Records & Bills Index
  Exhibit B — Wage Loss Documentation
  Exhibit C — Police Report
  Exhibit D — Witness Statements
  Exhibit E — Photos of Vehicle Damage / Scene

Note: This is a general template for educational purposes. Adapt it to your state’s specific statutes and your case’s specific facts. For substantial cases, have an attorney review or draft the demand — the difference in settlement value is usually orders of magnitude larger than the fee.

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Personal Injury Demand Letter Template

Reviewed by Leonard Goldberg, Editor · Last updated May 15, 2026

The 7 Sections (And Why They Matter)

1
Salutation & Reference
Direct the letter to the named adjuster (not just "Claims Department"). Include the claim number, date of loss, and your client's name. Set a 30-day response deadline up front.
2
Facts of Liability
Tell the story chronologically and unemotionally. Reference the police report, witness statements, traffic-cam footage, and any admissions. Tie each fact to the duty-breach-causation-damages chain. Do NOT use "my client thinks" or "appears" — write with confidence.
3
Liability Analysis
Apply the state's fault rule explicitly. "Under Florida's pure comparative negligence rule (Fla. Stat. § 768.81), even if Mr. Smith were found 20% at fault, his recovery would be reduced — not barred." Cite the rule. Pre-empt every comparative-fault argument.
4
Injuries & Medical Treatment
Diagnosis-by-diagnosis recitation. Include the date, provider, ICD-10 codes if available, MRI/imaging findings, and the gap (if any) from accident to first treatment. Attach a complete medical records and bills index — this is the document the adjuster opens first.
5
Damages Calculation
Break it down: medical specials (past + future), lost wages (with W-2/pay stub backup), lost earning capacity (if permanent), property damage, out-of-pocket costs. Then the pain & suffering valuation — show the multiplier you applied and why. Include a settlement number.
6
Policy Limit Discussion (if applicable)
If damages exceed the policy limit, say so explicitly. "Based on $385,000 in documented damages and a $100,000 policy limit, we are demanding the full policy limit of $100,000 within 30 days. Failure to tender will be considered evidence of bad faith." This unlocks bad-faith exposure for the insurer.
7
Demand & Deadline
Specific dollar amount, specific deadline (30 days), specific consequences ("Otherwise, we will file suit on or before [date]"). Don't be vague. The adjuster needs to be able to take a number to their supervisor.

Full Template

Replace anything in [BRACKETS] with your case’s facts. The structure is what matters — every section serves a purpose in the adjuster’s evaluation.

[YOUR NAME / FIRM]
[ADDRESS]
[PHONE / EMAIL]

[DATE]

VIA CERTIFIED MAIL — RETURN RECEIPT REQUESTED

[ADJUSTER NAME]
[INSURANCE COMPANY]
[ADDRESS]

Re:  Claim No.: [###]
     Insured: [DEFENDANT NAME]
     Date of Loss: [DATE]
     Our Client: [PLAINTIFF NAME]

Dear [ADJUSTER NAME]:

This firm represents [PLAINTIFF NAME] in connection with injuries sustained
on [DATE] when [DEFENDANT NAME], your insured, [BRIEF FACTUAL DESCRIPTION OF
COLLISION/INCIDENT]. This letter constitutes our demand for settlement.

I.   FACTS OF LIABILITY

On [DATE] at approximately [TIME], [DETAILED CHRONOLOGY OF EVENTS]. [DESCRIBE
ROADWAY, WEATHER, TRAFFIC SIGNALS, AND ANY ADMISSIONS]. The official [STATE]
police report (Report No. [###], attached) identifies your insured as the
party at fault for [SPECIFIC VIOLATION CITED]. [WITNESS NAME], an
uninvolved bystander, [SUMMARY OF WITNESS STATEMENT — attached].

II.  LIABILITY ANALYSIS

[STATE]'s [FAULT RULE — e.g., pure comparative negligence under STATUTE
CITATION] provides that [BRIEF EXPLANATION]. The facts establish [STATE]'s
prima facie negligence: [DUTY], [BREACH], [CAUSATION], and [DAMAGES — see
Section IV below]. No defense of [comparative fault / sudden emergency /
etc.] is supported by the facts.

III. INJURIES & MEDICAL TREATMENT

As a direct and proximate result, [PLAINTIFF NAME] sustained the following
injuries:

  • [INJURY 1] — [PROVIDER], [DATE OF FIRST TREATMENT], [ICD-10 CODE]
  • [INJURY 2] — [PROVIDER], [DATE], [DIAGNOSIS DETAILS]
  • [PERMANENT IMPAIRMENT IF ANY] — [RATING SOURCE]

Treatment has included [SUMMARY: ER, imaging, PT, surgery, injections, etc.].
A complete index of medical records and itemized bills is attached as
Exhibit A.

IV.  DAMAGES

  Past Medical Specials .............. $[AMOUNT]
  Future Medical (Life-Care Plan) .... $[AMOUNT]
  Past Lost Wages .................... $[AMOUNT] (Exhibit B: pay stubs)
  Future Earning Capacity Loss ....... $[AMOUNT]
  Property Damage .................... $[AMOUNT]
  Pain and Suffering ([MULTIPLIER]× specials) $[AMOUNT]
  -----------------------------------------------
  TOTAL DOCUMENTED DAMAGES ........... $[AMOUNT]

V.   POLICY LIMITS

We understand your insured's policy limit is $[AMOUNT]. As the documented
damages substantially exceed the limit, we hereby demand the full policy
limit of $[AMOUNT]. Failure to tender the policy limit within 30 days will
be construed as evidence of bad-faith claim handling and may expose [INSURER]
to extracontractual liability.

VI.  DEMAND

Based on the foregoing, we demand settlement in the amount of $[AMOUNT].
This demand will remain open for thirty (30) days from the date of this
letter. Absent settlement on or before [DATE], suit will be filed in the
[COURT NAME] without further notice.

Please direct all communications to the undersigned. We look forward to
your prompt response.

Very truly yours,

[YOUR NAME]
[BAR NUMBER, STATE]

Enclosures:
  Exhibit A — Medical Records & Bills Index
  Exhibit B — Wage Loss Documentation
  Exhibit C — Police Report
  Exhibit D — Witness Statements
  Exhibit E — Photos of Vehicle Damage / Scene