Lawyers in Boston acting for Deborah and Sunil Eappen have not asked for a specific amount but their submission mentioned previous awards of as much as $18m (pounds 10.8m).
The claim, which the couple said they had made to prevent Ms Woodward profiting by selling her story to the media, estimated Matthew's potential lifetime earnings as between $1,189,779 and $1, 676, 780. This is based on the "intelligence, education and professions" of his parents and the opinion of a vocational expert that "it is likely that Matthew would have graduated from college and obtained an advanced degree".
It also put at "several million dollars" the value of "Matthew's life to his parents".
Ms Woodward, of Elton in Cheshire, has so far not replied to the Eappen case, but her legal team stressed last night that her silence should not be taken as an admission of guilt. Although she has been held liable in default because she had made no submission, her lawyers said that she simply could not afford the cost of responding.
The Eappens' submission coincides with an ongoing investigation by Cheshire police and the Federal Bureau of Investigation into allegations of fraud within the Louise Woodward and Family Trust concerning an invoice allegedly submitted by Ms Woodward's mother, Susan, for more than $9,000 in accommodation expenses.
The documents submitted to US district judge, William G Young yesterday also referred to donations made to the Woodward family during Louise's trial amounting to $500,000.
What is more, they have estimated that Ms Woodward, who was initially found guilty of second-degree murder, could make $3m for an exclusive interview about the case.
The couple have asked the judge to consider punitive damages against their former au pair, citing how she has become in her own words "a minor celebrity" with "a million and one media offers".
In a statement filed with the claim, Sunil Eappen, who also attached photographs of the dead child, gave an emotional description of life without him. It said: "All we have left of Mattie is an empty place in our family, and there is a hole in my heart. Mattie was a uniquely wonderful person. We were so blessed."
The first few pages of the submission cover the events of 4 February1997, a summary of the subsequent trial after which Ms Woodward was released from custody when the judge Hiller Zobel sentenced her to time already served.
Ms Woodward returned to England after an appeal against the conviction failed. She is now a student at South Bank University in London.Reuse content