Chapter 1 - FORM 1-31 : DEMAND LETTER

• Jurisdiction: Colorado

Form 1-31: Demand Letter

[date]

SETTLEMENT COMMUNICATION SUBJECT TO C.R.E. 408

[name of opposing counsel or insurance company]
[address]

Re: [case name]

Dear Counselor:

As you know, this office represents plaintiff [name of plaintiff] in the above-referenced dispute. This letter constitutes an offer of compromise and a demand for payment by [name] as a result of the [brief description of the claim, including negligence and damages] caused by your [choose one: client OR insured], [name of client or insured]. This letter is written, and the offer is made, pursuant to C.R.E. 408.

Based on your defendant's Initial Disclosures, [name of defendant]'s insurance policy limits are $___. As is set forth in [name of plaintiff]'s Disclosures, [name of plaintiff]'s damages are approximately $___ plus interest at a rate of eight percent (8%) compounded annually, for a total of approximately $___ as of the date of this letter.

[Name of Defendant]'s Liability

[Describe why plaintiff is alleging defendant is liable.]

The details supporting Plaintiff's claim of $___ has previously been provided to you in our demand letter dated [date of previous letter] and in Plaintiffs Initial Disclosures.

Demand

[Insert amount of demand or, if asking for policy limits, consider using the following language or a...