When repping multiple clients in an accident, do you typically send out multiple demands for each client or do one demand with a global settlement? Or one demand apportioning the amount?

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Separate demands. Other than crash facts being the same, each client’s recovery and personal impact is different and should be talked about.

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You can talk about everyone’s damages in the same demand. That’s what headings are for.

Just a little extra thought, make sure you handle the conflict potential properly. I catch my team slipping often.

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I agree. this was something that came to mind, whether it would pose a potential conflict in the future. It is Parent/child, where the child just turned 18 and only suffered soft tissue injuries.

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One demand with breakout of each medicals with Client approval, this generally works

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This!

Depend on the purpose of the demand. If you have a policy limit case with all your clients, and one of your hopes is that they don’t accept and thus open the policy, then only do global. In fact, if i don’t represent all the injured parties i will call the other plaintiff lawyer and we will demand the policy jointly and agree to mediate/arbitrate among ourselves if there is a dispute as to allocation. Global demands for policy limits open policies. Separate demand won’t do it. If it’s a huge policy that you have no chance of opening, then it doesn’t matter.

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Agree with Attorney 3 - 100%

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Always separate

Why is this wrong? Is it a state by state thing or are you saying its wrong ethically? Because we have always sent out separate demands too and I am not sure why that would be wrong.

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