Dear Mr. Jones: This firm represents the IAFF, Local 587. This is a request for records pursuant to Fla. Stat. Sections 119 and 447, Part II. The documents are relevant and necessary for the representation of bargaining unit members. This request is directed to you as counsel of record in this matter. If you are not the custodian of the records request, please forward to the appropriate records custodian. Please provide a copy of the following records:
- Any and all documents and things, including but not limited to witness statements, audio or video recordings, etc., that the City/Department reviewed, considered, or relied on in issuing the discipline at issue to Mijail Orozco.
- Any and all documents and things that the City intends to introduce, refer to, or rely on at the arbitration hearing.
- A copy of any and all investigations and/or investigatory files relating to Orozco’s discipline and/or the underlying allegations that form the bases for the discipline.
- A copy of Orozco’s personnel file.
- A copy of any and all things, documents, and communications, internal or otherwise, that relate, in any way, to the allegations of misconduct against Orozco and/or the discipline at issue in this matter.
Please provide these records within the next two weeks, and please call me if you have any questions. Thank you.