
In a hypothetical file review, a case manager marks a claim ready for demand because the policy, estimate, and photographs are present. The attorney finds missing endorsements, repairs the photographs don't explain, and a carrier letter citing an inspection report nobody has obtained. The folder looks complete, but the evidence doesn't yet support the handoff.
A useful property insurance claim checklist for attorneys separates documents received from questions answered. The test isn't whether an attachment exists. It's whether the attorney can support the factual account, claimed damage, requested amount, and issues the demand will raise.
What Makes a Property Claim File Ready for a Demand
The attorney needs a supported loss account, relevant policy materials, documented damage assessment, the carrier's stated position, and visibility into unresolved questions. Requirements vary by claim, jurisdiction, policy, and firm procedure. This is an internal preparation tool, not a universal legal requirement.
Documentation gaps deserve substantive review. The NAIC's market conduct reporting framework separately measures inadequate-documentation denials and claims closed without payment because of inadequate documentation.
Use this hypothetical working checklist to assign the next action, not just inventory attachments.
Review area | Documents or information to check | Question to resolve | Status | Owner / next action |
|---|---|---|---|---|
Policy completeness | Declarations, base form, endorsements, policy period, limits, deductibles | Does the policy match the claim's period and form? | Received but incomplete | Paralegal: request missing endorsements |
Loss facts and chronology | Client account, discovery and report dates, inspection correspondence | Does each key event have a dated source? | Ready for attorney review | Case manager: confirm dates against letters |
Damage documentation | Dated photographs, inspection notes, contents inventory | Does each claimed area have photographs or an inspection record? | Conflicting information | Case manager: reconcile kitchen scope with photo set |
Repair scope and valuation | Estimate versions, line items, depreciation calculation | Which version is current, and what supports each item? | Received but incomplete | Paralegal: index estimate versions |
Mitigation and related expenses | Invoices, proof of payment, emergency work records | Which charges concern emergency work versus permanent repair? | Requested and outstanding | Case manager: request mitigation invoice |
Carrier position | Acknowledgments, coverage letters, reservations, payment records | Is the position documented, including cited materials? | Requested and outstanding | Attorney: review reservation language |
Outstanding requests | Both sides' requests and request dates | Which requests have passed their expected response window? | Requested and outstanding | Case manager: prepare follow-up draft |
Attorney review | Checklist, chronology summary, open-items list | Is each area resolved or assigned with a reason it remains open? | Ready for attorney review | Handling attorney: decide demand readiness |
Received is not a completion status. Use Not applicable when an area doesn't apply, with a short explanation. Ready for attorney review means the issue is organized for a decision, not that coverage or valuation has been established.
Confirm the Policy and Claim Details
Start by checking identifiers against the actual documents:
Parties and premises: Insured name, property address, claim number, and policy number.
Timing: Reported date of loss and policy period.
Contract materials: Declarations, base forms, exclusions, conditions, and applicable endorsements.
Financial terms: Limits, sublimits, deductibles, and provisions requiring attorney review.
A declarations page summarizes the contract; it doesn't supply all governing wording. California's requirements illustrate the distinction: Insurance Code sections 2084 and 2071 address the complete policy package and provision of a complete, current copy within 30 days after a request, as explained in the California Department of Insurance's property-claims guide.
In a hypothetical mismatch, the declarations name a limited liability company while an individual reported the claim as the homeowner. Flag the discrepancy for attorney review rather than normalizing the names.
Practical rule: Matching the loss date to the policy period doesn't establish coverage.
Record each form number, endorsement, applicable period, and acquisition date. Conflicting addresses, names, dates, or policy versions should remain visible until someone resolves them.
Build the Loss Chronology From Source Documents
Build events from document contents, not upload dates or filenames. Capture the client's account, discovery and reporting, inspections, relevant communications, emergency measures, mitigation, repairs, and material changes in the carrier's position.
These hypothetical entries show the distinction between a documented event and an unanswered question:
Event | Date | Source | Unresolved question |
|---|---|---|---|
Water found in second-floor bedroom ceiling | March 3, as stated by client | Page 2 of signed client statement | No photograph in the file is dated March 3 |
Carrier records first notice of loss | Date stated in acknowledgment letter | Carrier acknowledgment letter, page 1 | Client statement and carrier letter disagree on reported date |

Link each material entry to its source, relevant damage item, and policy provision where implicated. If sources disagree, retain both accounts and assign clarification. Don't select the date that best fits the proposed demand.
An independent reviewer should be able to reconstruct the sequence without oral explanations. The NAIC model claims-settlement regulation uses a comparable reconstruction principle for insurer claim documentation.
Use consistent claim-file naming conventions, but retain original filenames and acquisition information. Record OCR, redaction, or other processing when it matters to authenticity, readability, or a disputed fact.
Match Damage and Requested Amount to Evidence
In a hypothetical claim, an estimate includes $18,400 for kitchen cabinets and flooring, but the photographs show roof damage and a hallway. That's missing support, not proof that the kitchen claim is invalid.
Map each major estimate item to a photograph, inspection observation, invoice, measurement, or other identified source. The NAIC's recovery guidance recommends documenting losses, retaining receipts, inventorying damaged property, and preserving damaged items where possible.

Check the materials together:
Scope and versions: Identify the current estimate and explain additions or revisions.
Locations and conditions: Confirm photographs, inspection findings, and mitigation records concern the same rooms, elevations, and damage.
Additional amounts: Locate contents inventories, purchase evidence, loss-of-use records, and relevant expert reports.
Calculation: Reconcile requested amounts with invoices, depreciation, deductibles, and prior payments as applicable.
An estimate addresses proposed work and pricing; photographs address visible conditions. Neither automatically substitutes for the other. Missing kitchen photographs may call for inspection notes, contractor clarification, additional images, or attorney review, rather than immediate removal of the item.
Read the Carrier Position Without Overstating It
A carrier letter stating that roof damage was pre-existing records the carrier's position, not an established fact. Identify acknowledgments, information requests, coverage letters, denials, reservations of rights, carrier estimates, inspection reports, offers, and payments.
Keep an offer separate from payment. Confirm issued funds through check records or a payment ledger, and use bank records when receipt or negotiation matters.
The NAIC's consumer claims guidance describes the adjuster's inspection and resulting loss documentation. When correspondence cites that documentation without attaching it, assign retrieval of the report, photographs, measurements, scope, estimate, engineer findings, and relevant statements or inspection correspondence.
A missing cited report is an evidence gap, not merely an attachment problem.
Compare the report's inspection date, observations, causation opinions, and uninspected areas with the insured's photographs and estimate. Determine whether the carrier evaluated the damage now being claimed and whether intervening repairs changed the conditions.
For denied-claim review, identify what evidence answers each stated reason. A disagreement or delay alone doesn't establish bad faith. Record the conduct, communications, and unanswered requests so the handling attorney can evaluate the issue under applicable law.
Preserve the Evidence Before the Demand Goes Out
When litigation becomes reasonably foreseeable, counsel should assess and implement an appropriate preservation hold. Cover native emails and attachments, texts, claim-portal exports, adjuster notes, call recordings, inspection photographs and metadata, drone files, repair-platform records, and relevant cloud or mobile data.
Federal Rule of Civil Procedure 37(e) addresses certain losses of electronically stored information that should have been preserved, with possible sanctions when its conditions are met, as discussed in the Federal Judicial Center's electronic-information guidance_1.pdf). State procedure may differ.
Physical materials: Preserve damaged property where feasible and safe; separate damaged and undamaged materials.
Before alteration: Photograph conditions and record why urgent work or disposal was necessary.
Samples and components: Maintain a chain-of-custody log identifying collection, transfers, and storage.
In a hypothetical bathroom claim, a contractor demolished the wall before carrier inspection, and no wall-cavity photographs exist. Identify the unavailable evidence and why it's unavailable. Seek substitute records without implying they reproduce observations nobody documented.
Coordinate preservation with necessary remediation. A water-damage restoration checklist can help identify operational records to request, but it doesn't replace counsel's preservation analysis.
Turn Missing Items Into Assigned, Trackable Requests
A vague flag leaves the next person to diagnose the problem again. These hypothetical task descriptions specify what would close the gap:
Vague flag | Specific request | Owner | Completion condition |
|---|---|---|---|
Missing policy | Request complete policy, including forms and endorsements for the relevant period | Paralegal | Endorsement list matches declarations; every form number is recorded |
Need photos | Request dated kitchen cabinet and flooring photographs, identified by room and date | Case manager | Each claimed kitchen item has a dated, located photograph or inspection note |
Missing report | Request inspection report referenced in carrier letter, identifying that letter's actual date | Paralegal | Report, photographs, measurements, and estimate received and indexed |

Use this assignment procedure:
Name the gap from the review table.
Identify the source or party likely to hold the evidence.
Draft a specific request for team review and sending.
Assign an owner, request date, and follow-up date.
Log the response, including partial production or refusal.
Close only when the completion condition is met, or document the attorney's disposition.
Distinguish an internal follow-up target from a legal deadline. Verify applicable response windows against current primary authority for the jurisdiction, identify the triggering event, and flag overdue requests. A response containing the same incomplete declarations page doesn't close a complete-policy request.
Make the Demand Decision as the Attorney
Wamy's Litigation Readiness feature identifies evidence gaps, timeline issues, and exposure risks. Our review can organize incoming documents and correspondence, extract claim and policy information, build source-referenced chronologies, identify conflicts, check firm-specific requirements, and prepare summaries and draft requests for review.
We turn claim analysis into next steps based on the customer's internal procedures, claim type, and jurisdiction. When a new document is uploaded, Wamy re-evaluates completeness and flags new gaps.

Automated flags are inputs, not demand decisions. They don't guarantee completeness, determine coverage, or decide the demand amount. The handling attorney must assess whether an unresolved issue blocks the demand, limits an assertion, or can remain open with an assigned next step.
Track rows by status, open requests and their age, and unresolved conflicts. At closing review, confirm the chronology's sources, reconcile the requested amount, and record the disposition of every open issue. A defensible handoff tells the attorney both what the file supports and what the team still cannot establish.
Review Demand Readiness With Wamy
Wamy reviews the policy, correspondence, estimates, photographs, and reports together to identify missing evidence and conflicting information. It builds source-linked chronologies, checks the file against your firm’s requirements, and prepares summaries and document requests for review. As new material arrives, Wamy re-evaluates the file so your team can see what has been resolved and what still needs attention.
Book a demo to see how Wamy works through a property claim file before the demand goes out.

