Sample demand language for appeal letter

• Author: Scott M. Riemer/Jennifer L. Hess
• Pages: 263-264

A-245 Appendix: Sample Documents Form 14

FORM 14 SAMPLE DEMAND LANGUAGE FOR APPEAL LETTER

CONCLUSION

For the foregoing reasons, LTD Insurer’s denial of Mr. Claimant’s LTD and





Please be advised that this letter serves as your notice that any prior releases

signed by my client to obtain medical records, medical information, personal infor-

mation or other information of any kind are hereby revoked to the extent that such

authorizations allow you to contact any sources of information in any manner other

than in writing. You may continue to use the previously signed releases or autho-

rizations to obtain records and reports in writing, but any direct communication

outside of writing will be considered an invasion of my client’s privacy.

Please be advised that if LTD Insurer has Mr. Claimant’s evidence reviewed

by a new medical and/or a vocational professional, I hereby request the opportunity



this a formal request for any report issued by such a medical and/or vocational

professional and a request for his or her current curriculum vitae.

Please consider this letter as a preservation demand letter, asking you to

preserve for potential appeal and litigation any documents, tangible things, or

electronically stored information (“ESI”) regarding this claim, Mr. Claimant, or

the issues involved in his claim. This would include, but certainly not be limited to,

information sent to others, information received from others, all internal emails or

other electronic communications, and all emails, letters, or other electronic com-

munications sent to or received from external sources. This request applies to all

ESI whether in your regular system, or in any backup system whether maintained

by you or maintained by others. You are obliged to preserve potentially relevant

documents, tangible things, and ESI even if you do not anticipate producing them.

You are directed to immediately initiate a litigation hold for potentially relevant

documents, tangible things, and ESI, and to act diligently and in good faith to

secure and audit compliance with that litigation hold. You are further directed to

immediately identify and modify or suspend features of your information systems

and devices that, in routine operation, operate to cause the loss of potentially rele-



may seek to hide, destroy or alter documents, tangible things, and ESI and act to

prevent or guard against such actions.

Your preservation obligation extends beyond documents, tangible things, and

ESI in your care, possession, or custody and includes information in the custody of

others that is subject to your direction or control. Accordingly, you must notify any