Writing Samples as a Paralegal
The following collection of legal documents represents professional work product created during my tenure as a paralegal at Jorgensen, Brownell & Pepin, P.C.. These writing samples demonstrate a high level of proficiency in drafting complex demand packages, synthesizing medical and forensic evidence, and advocating for clients in personal injury and wrongful death litigation. Each document highlights the ability to balance technical legal analysis with empathetic storytelling to maximize settlement potential for victims of catastrophic events.
Sample “Demand Letter” (Wrongful Death)
This initial demand letter addresses a tragic incident where a mother was struck and killed in a marked crosswalk by a commercial delivery vehicle. The document showcases my ability to construct multifaceted theories of liability, including respondeat superior and negligent hiring, based on social media discovery that revealed the driver's history of insensitive and racist posts. I meticulously calculated over $3.3 million in total damages by integrating economic losses—such as projected life expectancy and lost SSI benefits—with a profound narrative regarding the heirs' pain and suffering. Furthermore, the letter applies Colorado statutes regarding "felonious killing" to argue for the removal of non-economic damage caps, demonstrating a strategic use of legislative research to enhance the client's position.
Sample “Supplemental Demand Letter” (see above)
Following an inadequate initial offer from the insurers, I drafted this supplemental demand to incorporate findings from a forensic accident reconstruction expert. This writing sample illustrates the capacity to translate highly technical data—including photogrammetry, 3D laser scanning, and pedestrian kinematic analysis—into a persuasive legal argument. By highlighting that the driver accelerated to 35 mph in a 30 mph zone, I established a case for negligence per se and utilized simulation data to prove the death was entirely preventable had the driver obeyed the speed limit. This document serves as an example of tactical negotiation, using scientific certainty to shift the conversation from contested liability to a question of fair damage compensation.
Sample “Request to Tender UIM Benefits”
(First-Party Insurance Claim; MVA)
This comprehensive request to tender UIM benefits focuses on a severe rear-end collision that resulted in chronic, debilitating injuries. The document features an exhaustive medical chronology, detailing a client's transition from conservative chiropractic care to advanced regenerative medicine, such as Platelet-Rich Plasma (PRP) injections. I successfully documented nearly $650,000 in uncompensated damages, including a complex wage loss analysis for a commission-based roofing specialist. Beyond physical injuries like cervical spondylosis and disc herniations, the letter articulates the psychological toll of the accident, integrating clinical diagnoses of PTSD and major depressive disorder to provide a holistic view of the client's loss.