AI can draft a personal injury demand letter quickly, but only from a verified facts file, and only as a first draft an attorney reviews line by line.
The safe workflow is: gather and verify records, build a chronology and damages table, draft in sections, check every fact and figure, then attorney approval.
This guide is a workflow, not legal advice. It needs qualified attorney review before use, and it does not guarantee compliance with any rule.
What AI Should and Should Not Do
| Task | AI role | Attorney role |
|---|---|---|
| Medical chronology | Draft from records with page citations | Verify and correct |
| Damages table | Total bills from source data | Confirm amounts, liens and adjustments |
| Liability narrative | Draft from police report and statements | Decide theory and tone |
| Demand amount | None | Set based on judgment and client authority |
| Legal authority | Suggest only with citations to check | Verify every citation |
| Sending | None | Approve and sign |
The Seven-Step Workflow
Step 1: Confirm authority and records access. Confirm client authorization for medical records. Under 45 CFR 164.508, providers generally need a valid HIPAA authorization to release records to third parties.
Step 2: Build a verified facts file. Collect the police report, photos, witness statements, medical records, bills, wage documents and insurance details. Mark each item received, missing or disputed.
Step 3: Generate the medical chronology. Have the AI list each visit with date, provider, complaint, diagnosis and treatment, citing source page numbers. A paralegal checks every entry. See medical chronology tools for PI firms.
Step 4: Build the damages table. Pull billed amounts from itemized bills, not narrative records. Separate billed, paid and adjusted amounts where your jurisdiction treats them differently.
Step 5: Draft section by section. Ask for liability facts, injuries and treatment, damages and impact on daily life as separate sections. Smaller drafts are easier to verify than one long letter.
Step 6: Verify everything. Check each date, provider, diagnosis, dollar amount and quote against source documents. Remove anything the AI cannot cite.
Step 7: Attorney review and approval. The attorney sets the demand amount and deadline, checks tone and strategy, and signs. Log who approved what and when.
Worked Example: Damages Table Check
Illustrative example. An AI draft for a rear-end collision lists these medical specials:
| Provider | AI draft amount | Itemized bill | Status |
|---|---|---|---|
| Emergency department | $4,820 | $4,820 | Matches |
| Orthopedic clinic | $3,150 | $3,510 | Corrected, digits transposed |
| Physical therapy | $6,400 | $5,600 | Corrected, duplicate visit removed |
| Imaging center | $1,900 | Bill not received | Removed pending records |
The draft total of $16,270 became $13,930 after verification, with imaging held back until the bill arrives. All figures here are illustrative, not from a real matter.
Verification Checklist Before Sending
• Every date and provider matches the medical records
• Every dollar figure ties to an itemized bill or wage document
• Liens and known adjustments noted for attorney decision
• No diagnosis or prognosis stated that a provider did not record
• No legal citation included unless an attorney verified it
• Client facts consistent with intake notes and statements
• Demand amount and response deadline set by the attorney
• Settlement communication handling considered, such as Federal Rule of Evidence 408 or your state equivalent
Ethics Rules to Keep in View
• Competence: ABA Formal Opinion 512 says lawyers should understand the capabilities and limits of the AI tools they use
• Confidentiality: client medical information is protected under Model Rule 1.6; check vendor terms before uploading records
• Supervision: Model Rule 5.3 requires reasonable measures over nonlawyer assistance, which Opinion 512 applies to AI tools
• Truthfulness: statements of fact to opposing parties must be accurate under Model Rule 4.1
State rules and bar opinions may differ from the ABA Model Rules. Check your jurisdiction.
Common Mistakes to Avoid
• Drafting before records are complete: missing bills lead to undervalued demands
• Letting AI pick the number: the demand amount is a legal and strategic judgment
• Trusting narrative summaries for amounts: use itemized bills
• Uncited medical claims: every injury statement should trace to a record
• Uploading records to unapproved tools: confirm data handling first
Limitations
AI drafts can contain errors, including invented facts or citations. This workflow reduces risk but does not remove it. It is general information, requires qualified attorney review, and does not guarantee any outcome or compliance.
Next Step
If your firm wants intake, records and demand preparation in one governed workflow, LuMay Intake Flow carries verified facts from first contact to demand readiness, with attorney review at each decision point.
• ABA Model Rule 1.6, Confidentiality
• ABA Model Rule 4.1, Truthfulness in Statements to Others
• ABA Model Rule 5.3, Nonlawyer Assistance
