1) There is no legal rule about what is required to settle a lawsuit. Since settlement is voluntary--the other party and/or its insurer has to choose to settle--anything that satisfies them is what you need to send; if they are not satisfied, either by the evidence or by the amount you're seeking, they won't settle. Therefore, you can try with just the medical bills if you like.2) YOUR medical records belong to YOU. Your medical care provider has *no* right to withhold them from you. If you want them, you can get them. They may be allowed to charge you the reasonable cost of reproducing them (I believe they can keep a copy for their own files; or in this case, they'd most likely keep the original and provide a copy), but again, these are your records and the medical care provider cannot withhold them.