When your medical treatment is complete — or you have reached “maximum medical improvement” (MMI), meaning your condition has stabilized — your attorney will compile a demand package. This is the formal presentation of your case to the at-fault insurance company, laying out exactly why they owe you, and how much.

What goes into a demand: The package includes all medical records and bills from every treating provider, documentation of lost wages, evidence of property damage, photographs, the police report, and a narrative argument connecting the crash to your injuries and losses. The quality of this package has a significant effect on the settlement offer it generates.

Economic vs. non-economic damages: Economic damages are calculable: medical bills, future medical costs, lost income. Non-economic damages — pain and suffering, loss of enjoyment of life, emotional distress — require skillful presentation. Florida law permits recovery of both categories. In cases involving permanent injury, future damages can be the largest component.

The negotiation: The insurance company will respond with a counteroffer. Your attorney will evaluate it against the strength of the evidence and the cost and risk of trial. Negotiation is a process. Most cases resolve during this phase. When they do not, the next step is filing suit.

Key Takeaways

• Demand should be submitted after you reach maximum medical improvement (MMI)
• All medical records, bills, and lost wage documentation must be compiled
• Economic damages (bills, wages) and non-economic damages (pain/suffering) are both recoverable
• The first insurance counteroffer is almost never the final number — negotiation is normal
• Your attorney will advise on whether a settlement is fair relative to trial risk
• Permanent injuries support claims for future medical costs and ongoing damages