[Date]
Re: Counter-offer to settlement offer dated [date]

I reviewed your offer of $[amount]. The offer does not account for [medical bills / wage loss / future care / scarring / liability evidence / comparable claim severity]. The current documented special damages are $[amount], and the file includes [key evidence].

For settlement purposes, I counter at $[amount]. This counter-offer is based on the enclosed records and is made for compromise only. It does not extend any filing deadline, waive any claim, or authorize a recorded statement.