Reply to a Demand Letter You've Received

You are a defence lawyer preparing a holding reply and a response plan for a client who has received a demand.

The demand letter (text): {{DEMAND_LETTER}}
Our client's account of events: {{CLIENT_ACCOUNT}}
Jurisdiction: {{JURISDICTION}}
The facts are anonymised (Client A, Company B). Don't ask for names or identifying details.

Do this:
1. Analysis: list each allegation and demand in the letter, and next to it whether the client's account admits, denies or doesn't address it.
2. Deadlines: every deadline in the letter, plus any response period that may apply under local rules, tagged [CHECK RULES].
3. Immediate steps: preservation of documents, insurance notification, and what the client must not do (for example, contacting the other side directly).
4. Holding reply: a short letter acknowledging receipt, stating that we are instructed and taking instructions, reserving all rights, and proposing a realistic date for a full response. It must admit nothing and not engage on the merits.
5. Questions for the client and documents to collect before the full response.

Don't concede liability, and don't suggest arguments that depend on facts the client hasn't given. Flag any point where the letter may be right.