Date]

City of Beech Grove Legal Department [Address] Email: [city legal email]

Re: Demand for Immediate Return of Vehicle and Settlement Offer Plaintiff: [Your name] Vehicle: Chrysler Town and Country, VIN: [VIN] Incident Date: May [day], 2025 Police Report No: [#]

To the City Legal Department:

This letter is a formal demand for immediate return of Plaintiff’s vehicle and property and a settlement offer to resolve claims arising from the City’s seizure and continued retention of the vehicle on May [day], 2025.

Facts On May [day], 2025, officers of the Beech Grove Police Department seized Plaintiff’s vehicle. Plaintiff served a written preservation demand for all video and records relating to the seizure. Relevant video and records were not preserved after Plaintiff’s preservation demand. Officer A made an accusatory statement about Plaintiff in the presence and within earshot of Officer B. The City has retained the vehicle without providing Plaintiff a meaningful opportunity to contest the retention.

Demand and Offer

1. Immediate return of the vehicle and all property contained therein within 48 hours of your receipt of this letter.
2. Preservation of all remaining records, audio, video, and communications relating to the seizure and any statements made by officers.
3. Settlement payment of $50,000 in full and final settlement of all claims (constitutional, statutory, and common‑law) if the City accepts and completes the return within the 48‑hour window. Payment and return to be accompanied by a short, agreed retraction statement limited to the language in the settlement agreement.
4. If the City does not accept the $50,000 offer and return the vehicle within 48 hours, Plaintiff will retain counsel and pursue litigation. In that event Plaintiff’s settlement position will likely increase to $75,000 (plus return of the vehicle and other relief), if the attorney charges a 1/3 fee plus expenses. Plaintiff will seek all available relief including replevin, §1983 claims, defamation damages, spoliation sanctions, attorneys’ fees, and costs. 
5. Plaintiff is willing to engage in mediation or nonbinding arbitration. Look it's not like I set you guys up or I troll for this sort of thing. I just need my van back. Your options include: get me my van back, buy me a new one at wholesale price (or just give me a check), or, this week only, give me that cop's cop car (once modified for civilian use.)

Deadline

• Accept the $50,000 offer and return the vehicle within 48 hours of receipt of this letter.
• If no acceptance and no return within 48 hours, this offer is withdrawn and Plaintiff will proceed toward litigation and counsel retention; 

This demand is made without prejudice to any other claims or remedies available to Plaintiff.

Sincerely, [Your name] [Address] [Phone] [Email]