Pain and Suffering Daily-Life Impact Narrative for a PI Demand Package
Turns client interview notes, a symptom diary and witness statements into a specific before/after narrative of daily-life impact for a demand package. Every sentence is traceable to a source, tied to dated records where they exist, with no unsupported adjectives and no dollar figure.
The Prompt
Variables (8)
| Variable | Description | Example |
|---|---|---|
| {{client_name}} | Client Name | Maria Gonzalez |
| {{incident_date}} | Incident Date | 2026-06-14 |
| {{narrative_voice}} | Narrative Voice | Third person, attorney narrative |
| {{target_length}} | Target Length | 500 to 700 words |
| {{interview_notes}} | Client Interview Notes | Before: ran 3 miles four mornings a week with her sister, coached her daughter's U10 soccer team, worked 12-hour shifts. Since: has not run since the collision, stepped down from coaching in August, wakes two or three times a night when she rolls onto her right shoulder... |
| {{symptom_diary}} | Symptom Diary | 7/02: slept in recliner, could not lie flat. 7/09: husband carried laundry basket, could not lift it. 7/21: drove 20 minutes to PT, had to pull over because of neck spasm... |
| {{witness_statements}} | Witness Statements | Sister (statement dated 2026-09-05): "We ran together most weekday mornings for six years. She has not come out once since June." Charge nurse: "She asks for help with every patient transfer now." |
| {{record_excerpts}} | Dated Medical Record Excerpts | PT note dated 2026-07-21, p. 2: "Reports waking 2-3x nightly due to R shoulder pain." Ortho note dated 2026-09-03, p. 3: "No lifting over 10 lbs. Unable to tolerate overhead reaching." |
Expected Output
Two separate parts. Part 1, attorney-only notes: conflicts between sources with the arithmetic, sensitive items withheld (every pre-incident record and contradicted client statement kept out of the document), unsupported statements declined, declined requests (for example a multiplier or a case citation the attorney's notes asked for), missing information with follow-up questions for the client and witnesses, and a source table giving the source, date and corroboration status of each claim. Part 2, the document: a before/after narrative organized by area of life that contains only reconciled, sourced facts, with a plain "TO BE COMPLETED BY ATTORNEY" line where a point is unresolved, closed by the line "END OF DOCUMENT - ATTORNEY-ONLY BELOW". A closing Verification list ends the output.
Usage Notes
Use when assembling the non-economic damages section of a demand package, after the client interview and once treatment records are in. Attach the interview notes, any diary, witness statements and the record excerpts that mention complaints or restrictions. Failure modes to watch: a "before" the model has inferred rather than found, a client overstatement (a count, "not once since") quoted in the narrative beside the evidence that contradicts it, and a pre-incident condition slipping into the document. Read Part 1 first, copy only Part 2 into the demand, and have the client confirm every sentence, because an overstated narrative damages credibility on the whole claim. The prompt will not add a multiplier, a per diem or a case citation even if your notes ask for one; it lists the request as declined. Read the document part line by line before it leaves the office: in testing, a small model sometimes left an internal remark, a comparison with the file or an unresolved point inside the document despite the instructions. Not legal advice. The attorney remains responsible for verifying every fact, figure and authority before use.
Double-check before use
- Check each sentence of the narrative against its source. In testing, two sources were once linked in a way neither stated.
These are the places where this prompt was seen to slip when tested on sample cases with a small AI model.
Legal Sources Referenced
- Fed. R. Evid. 408 (limits on admitting compromise offers and statements made during compromise negotiations)
- Fed. R. Evid. 701 (lay opinion must be rationally based on the witness's perception)
Originally featured in: AI for Personal Injury Lawyers: Prompts for Demand Letters, Medical Summaries & Depositions
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* These prompts are drafting and analysis aids for licensed attorneys. They are not legal advice and do not replace professional judgment. AI output can contain errors, including invented citations and incorrect deadlines: verify every fact, figure, authority and deadline against primary sources before relying on it. Rules vary by jurisdiction, and you remain responsible for the final work product.