Situation has been resolved. Thank you!

Contact an attorney. Some states don't allow punitive damages or "pain and sufering".

You need to find out whether Texas is a so-called "no-fault" state. If so, then there are caps in the amount that can be sought for "pain and suffering" and you'll want to find out what those caps are. Your attorney should be able to arrive at a figure that's reasonable in terms of damages suffered and that's also within the parameters of the law.

Again contact an attorney, there is no way we could give you a number it depends on too many factors. If you try to negotiate this without an attorney you will lose out.