It is sometimes assumed that the strongest opportunities for developing imagination and empathy through children's writing lie in narrative starting points, whereas other less obviously literary writing forms are more readily associated with functional literacy. Consequently, writing regarded as non-literary is rarely analysed with these qualities in mind. This paper presents an exploratory, textual analysis of children's letter-writing texts, which aims to identify and describe the uses of imagination and empathy. It is suggested that imaginative strategies were integral to this textual construction and that the significance of imagination and empathy in writing development is worthy of further exploration.