Mike Swanson
70ba676176
Author: Mike Swanson Machine: DESKTOP-0O8A1RL Timestamp: 2026-05-13 10:53:57
356 lines
16 KiB
Plaintext
356 lines
16 KiB
Plaintext
GRABB & DURANDO — MEETING PREP
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AI Demand Letter Project
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INTEL FROM PRE-MEETING CONVERSATIONS
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Style/Judgment #5 — ANSWERED (API data / training):
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Robert does NOT want client files used for training or leaked. He's been
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using ChatGPT web UI (where you upload full documents) — he doesn't yet
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know the API works differently.
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KEY POINT TO MAKE AT MEETING: The app uses the Claude API, not the web UI.
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Under Anthropic's standard API terms, inputs are NOT used for training.
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Files are sent per-request and not retained. The only open item is whether
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we need a BAA for HIPAA compliance (medical records). This is solvable and
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shouldn't block the project.
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STILL NEED: His verbal sign-off once he understands the API distinction.
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Scope #7 — ANSWERED (file access):
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App should read directly from the existing F: drive. He doesn't want files
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uploaded or saved to a second location — the case folder stays the source
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of truth. Confirmed: direct SMB read access from the app.
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Vision / Scale — ANSWERED (critical):
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Asked: "What does this app do for you in a year?"
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Answer: "I see this replacing nearly all of my legal assistants entirely."
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Also: He has already tested AI on pleadings and was impressed with the
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quality. He is not afraid of the inaccuracy problem.
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IMPLICATIONS FOR THE MEETING:
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- Robert is thinking PLATFORM, not tool. Phase 1-3 delivers demand letters.
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It does not replace legal assistants. Make the scope explicit so he
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doesn't greenlight demand letters expecting full practice automation.
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- The bigger vision (intake, pleadings, discovery, correspondence) is real
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and achievable — but that's a separate conversation. Don't promise it
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in Phase 1-3. Do validate that the roadmap gets there.
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- His low fear of inaccuracy is a risk factor for a lawyer. The fact sheet
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review step (Phase 1) is the safeguard. Emphasize it as a feature, not
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a limitation.
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- Consider adding a "Phase 4" framing at the meeting — after demand letters
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are production-ready, what's the next module? Pleadings? Correspondence?
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This keeps the larger vision visible without overcommitting.
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QUESTIONS FOR ROBERT
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STYLE AND JUDGMENT CALLS — these define the prompt:
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1. What's your rule for full-narrative vs. short-form? Is it dollar threshold,
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hospitalization, institutional defendant, contested liability — or just your
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call case by case?
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2. When the AI flags an injury mentioned in the intake notes but unsupported by
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records, what do you want it to do? Include and flag, exclude silently, or
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ask staff?
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3. How do you want to handle unconfirmed allegations (DUI suspicion, disputed
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fault)? Always omit, or present and let you decide?
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4. Do you want the UIM demand generated automatically alongside the BI demand
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when UIM coverage is identified, or as a separate step after BI limits are
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tendered?
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5. [ANSWERED — see Intel above. Pivot this to: explain API vs. web UI, then
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ask specifically about the BAA: "Do you have a business associate agreement
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with your health insurer clients' carriers already, or do we need to add
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Anthropic as a covered vendor?"]
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SCOPE BOUNDARIES:
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6. Is the scope limited to auto/PI MVA cases, or does it include premises
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liability, dog bites, commercial cases?
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7. [ANSWERED — direct F: drive read. Confirm: is the app machine always on
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the same LAN as GND-SERVER, or does it need to work from outside the
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office (e.g., Robert at home)?]
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QUESTIONS FOR JEFF
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WORKFLOW:
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1. Walk me through what you do from intake to demand — at what point do you
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write Jeff's Notes, and at what point does the Eval Sheet get filled in?
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2. Is Jeff's Notes always a PDF in the NOTES folder, or do older or unusual
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cases store it differently?
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3. Is the Eval Sheet always complete before demand time, or does it sometimes
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get filled in after?
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4. What's the one thing you always know at demand time that isn't in any
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document in the folder?
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OUTPUT:
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5. When you get the demand draft today, what format is it in and what do you
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do with it? (Word -> edit -> print? Goes into a CMS?)
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6. Would you rather review a fact summary first and approve it, or just get a
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draft letter to redline?
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WHAT YOU NEED ROBERT TO COMMIT TO BEFORE LEAVING
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[ ] 5-10 closed cases for Phase 1 testing. Mix needed:
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- One simple limits case
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- One with contested liability
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- One minor client
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- One with no police report
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- One with large specials (>$30K)
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(SWAILIEH and ORTEGA already have — need 3-5 more)
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[ ] Sign-off on the AI API use question — but first EXPLAIN the API vs.
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web UI distinction. His concern (training/leakage) is valid for the
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web UI; the API doesn't work that way. Then get his verbal on proceeding
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under API terms, and flag the BAA question for HIPAA.
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[ ] His answer on the style rule (short-form vs. full-narrative trigger)
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— this is the single most important architectural decision for the prompt
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[ ] Explicit scope conversation: confirm Phase 1-3 = demand letters only.
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Acknowledge the larger vision (practice automation). Don't let him
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sign off on "demand letters" while expecting "replace legal assistants."
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Ask: "After demand letters are solid, what's the next module you'd want?"
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THE PLAN
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PHASE 1 — Fact Extractor (3-4 weeks)
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Point it at a case folder. Reads Jeff's Notes, Eval Sheet, and all
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text-readable medical records. Outputs a one-page structured fact sheet:
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- Liability summary
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- Injury list
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- Medical chronology
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- Specials table (provider by provider)
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- Lien status
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- List of everything it couldn't read (scanned docs flagged by name)
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Staff reviews and corrects. Nothing goes to an adjuster yet.
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PHASE 2 — Demand Generator (3-4 weeks)
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After staff approves the fact sheet, select style (short-form or
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full-narrative) and generate. Also generates UIM demand variant where
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applicable. Output is a Word doc matching the firm's current format.
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Compare output to 10-15 actual closed-case demand letters to tune.
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PHASE 3 — Live Refinement (2-3 weeks)
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Run on real active cases. Attorney reviews each output and flags anything
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off. Tune omission rules, specials presentation, and style triggers based
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on actual feedback. End state: attorney signs off that output is
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production-ready.
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TOTAL: 8-11 weeks. Phase 1 gives them something to react to in a month.
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KEY MESSAGE FOR THE MEETING
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"The AI's job is to do the tedious reading so Robert and Jeff can focus
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on judgment. It will never make the call on what to include or exclude —
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that's always a human decision. The fact sheet review step is the
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checkpoint where attorney judgment replaces document parsing."
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GLOSSARY — ABBREVIATIONS
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LEGAL / INSURANCE
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BI Bodily Injury
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The liability coverage carried by the at-fault driver's insurance
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policy that pays for injuries caused to others. This is always the
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primary demand target. BI limits are typically written as
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25/50 ($25K per person / $50K per accident).
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UIM Underinsured Motorist
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Coverage on the client's own auto policy that pays when the
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at-fault driver's BI limits are insufficient to cover the damages.
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A UIM demand is sent to the client's own carrier after the BI
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carrier tenders (pays) their policy limits.
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UM Uninsured Motorist
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Similar to UIM but applies when the at-fault driver has no
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insurance at all. Also on the client's own policy.
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MedPay Medical Payments Coverage
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First-party coverage on the client's own auto policy that pays
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medical bills regardless of fault, up to the policy limit (often
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$5K-$10K). No subrogation right — carrier cannot recover it back.
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Usually collected before or alongside the BI demand.
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PIP Personal Injury Protection
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Similar to MedPay but broader; includes lost wages. Required in
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no-fault states; Arizona is an at-fault state so PIP is rare here.
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PD Property Damage
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Coverage for vehicle damage. Settled separately from the injury
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claim, usually early. PD settlement does not release the BI claim.
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LOA Letter of Authorization / Letter of Attorneys
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The rep letter sent by the firm to the insurance carrier putting
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them on notice that the firm represents the claimant. Required
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before the carrier will communicate with the attorney.
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DEC Page Declarations Page
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The summary page of an insurance policy showing coverage types,
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limits, named insured, policy period, and premium. Key document
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for identifying available coverage.
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LOP Letter of Protection
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A document the firm issues to a medical provider promising to pay
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the provider's bill from any settlement proceeds. Allows the
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client to treat without upfront payment. Creates a lien on the
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settlement.
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ERISA Employee Retirement Income Security Act
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Federal law governing employer-sponsored health benefit plans.
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An ERISA health plan has strong subrogation rights — it can
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recover what it paid in medical bills from any settlement. ERISA
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lien holders (like BCBS of Florida, Cigna) are harder to reduce
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than government liens.
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AHCCCS Arizona Health Care Cost Containment System
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Arizona's Medicaid program. Has a statutory subrogation right
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under A.R.S. § 36-2915. Lien is managed through Optum/Katch.
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Generally more negotiable than ERISA.
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A.R.S. Arizona Revised Statutes
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The codified laws of Arizona. Demand letters cite specific A.R.S.
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sections for traffic violations (e.g., failure to yield) to
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establish statutory negligence.
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TPD Tucson Police Department
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Most common police agency in G&D's cases. Police reports are
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TPD Reports. Other agencies: PCSD (Pima County Sheriff), DPS
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(Department of Public Safety), Marana PD, etc.
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PCSD Pima County Sheriff's Department
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DPS Arizona Department of Public Safety (highway patrol)
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SSCIP Social Service Contractors Indemnity Pool
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A specialized liability pool insuring group home operators and
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social service contractors in Arizona. Appeared in the Ortega
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case (FHL Group Home). Policy limits tend to be high ($1M+).
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DOCUMENT CATEGORIES
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R&B Records and Bills
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The combined file of medical records and itemized billing
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statements from a provider. Requested together; received together.
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Standard naming: "[Provider] R&B.pdf"
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IML Integrated Management Log
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HP iLO server log — records hardware events including thermal
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shutdowns. Referenced during VWP server investigation.
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OCR Optical Character Recognition
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Technology that converts scanned images of text into machine-
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readable text. Critical issue for G&D because police reports and
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intake forms are always image-only scans.
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SMB Server Message Block
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The file-sharing protocol used on Windows networks. G&D's case
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files are on an SMB share at F:\Shares\Company Data\CLIENTS\.
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CASE / DEMAND TERMS
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DOL Date of Loss
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The date the accident occurred. Central reference date for the
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entire case — all medical chronology, statutes of limitations, and
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insurance correspondence are measured from DOL.
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MVA Motor Vehicle Accident
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Standard abbreviation for an auto accident case.
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PI Personal Injury
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The practice area. Encompasses MVA, premises liability, dog bites,
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etc. G&D's primary practice.
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Specials Special Damages
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Quantifiable economic losses: medical bills, lost wages, out-of-
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pocket costs. Contrasted with "generals" (pain and suffering).
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Demand letters present gross billed specials by provider.
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Generals General Damages
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Non-economic losses: pain and suffering, loss of enjoyment of
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life, emotional distress. Not itemized; argued as a multiplier
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of specials or as a standalone value.
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Eggshell Eggshell Plaintiff Doctrine
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Plaintiff Legal principle that a defendant takes the plaintiff as they find
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them. If the plaintiff had a pre-existing vulnerability (prior
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injury, thin skull, fragile health), the defendant is still fully
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liable for all harm caused, even if a "normal" person would have
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been less injured. Robert invokes this in cases with pre-existing
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conditions or unusual severity.
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Subrogation The right of an insurer or lienholder to recover what they paid
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(in medical bills or benefits) from a third-party settlement.
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Health insurers (BCBS, AHCCCS) assert subrogation rights against
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PI settlements.
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Lien A legal claim against settlement proceeds. Common lien holders:
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health insurer subrogation, MedPay, hospital LOP, attorney fees.
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Must be resolved before net settlement can be distributed to client.
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Tender When an insurance carrier pays out their policy limits in full.
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"Mendota tendered their limits" means Mendota paid their full
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$25K BI policy. This triggers the UIM demand to the client's
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own carrier.
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CMS Case Management System
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Generic term for practice management software. G&D uses a system
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(DDT = DUI Defense Team is a separate module) for tracking cases,
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contacts, and documents.
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Demand The settlement demand letter sent to the at-fault carrier's
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Letter adjuster. Summarizes liability, damages, medical treatment, and
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specials. Does not state a dollar demand — asks the carrier to
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respond with an offer. Standard G&D practice.
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Adjuster The insurance company employee who evaluates and negotiates the
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claim. The demand letter is addressed to the adjuster by name
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(or claim number when no adjuster is assigned).
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TECHNOLOGY
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API Application Programming Interface
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A way for software systems to communicate. The Claude API is
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what the app uses to send documents to the AI and receive the
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fact sheet / demand letter output.
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BAA Business Associate Agreement
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A HIPAA-required contract between a covered entity (or its
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business associate) and a vendor who handles protected health
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information (PHI). Required if sending medical records to cloud
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services like Azure or Anthropic.
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HIPAA Health Insurance Portability and Accountability Act
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Federal law protecting the privacy of medical information.
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Relevant because G&D's case files contain medical records.
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JSON JavaScript Object Notation
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A structured data format used for the Stage 1 fact extraction
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output. Allows staff to review extracted facts in a readable
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table before the demand letter is generated.
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Generated: 2026-05-13 | Arizona Computer Guru LLC | Grabb & Durando Project
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================================================================================
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