Deborah and Sunil Eappen, whose son died of "shaken baby syndrome", are demanding the millions in compensation for the death of their baby, as well as punitive damages.

The Eappens did not ask US District Court Judge William Young for a specific amount, but their submission mentioned previous awards of "as much as $18m (£10.7m)".

In a statement filed with the claim, Sunil Eappen, who also attached photographs of the dead child, gave an emotional description of life without the child.

The court was told that Matthew was shaken to death

He said: "All we have left of Mattie [is] an empty place in our family and memories that we cling to.

"That void is more apparent to me with each day that passes."

His wife said in her statement: "There is a hole in our family, and there is a hole in my heart.

"Mattie was a uniquely wonderful person. We were so blessed."

The detailed, 34-page submission outlines issues including the background to the case, and specifies the amount Matthew Eappen might have earned in his life.

Medical expenses in the attempt to save Matthew's life are then stated as $43,368.50 and "funeral and related expenses" as $5,299.15.

Estimated total life earnings

But the major part of the claim is for the value of Matthew's "reasonably expected net income" throughout his life.

An expert vocational expert, named in the document as Arthur J O'Shea, said "it is likely that Matthew would have graduated from college and obtained an advanced degree, such as a PhD, Md or JD".

Basing his opinion in part on the "intelligence, education and professions" of his parents he estimated his total life earnings would have been between $1,189,779 and $1,676,870.

Woodward, 20, from Elton, Cheshire, has not contested the civil case because she cannot afford legal representation, which means the Eappens have already won by default.

The judge simply has to decide how much she should be liable for.

Stop her selling story

The Eappens' lawyer said they knew the former au pair did not have much money, but they wanted to make sure she did not profit from selling her story.

The claim mentions the "worldwide media coverage" of the trial and donations of "$500,000" made available to Louise Woodward and her family.

It adds: "In the opinion of Plaintiff's expert literary agent, Defendant [Woodward] could earn up to $3m for the media rights to a first-person account."

Woodward has always said she has no plans to sell interviews.

Even if she did, the Eappens would probably only be able to collect money from her if she made it in the United States.

The guilty verdict is delivered ...

The judge is expected to decide on the level of damages in about a month.

On Monday, Paul Barrow, the UK lawyer for Woodward, said: "We will certainly consider all aspects of the submission but until I have taken instructions from my client I can't comment any further."

Her legal team said she could not afford to reply to the Eappen complaint but it was not an admission of guilt.

Woodward was initially convicted of Matthew Eappen's second degree murder in October 1996.

She was sentenced to life imprisonment in February of that year.

On appeal, her conviction was reduced to manslaughter, and her sentence to the time she had already served - about nine months.