This letter serves as a formal request for copies of any and all documentation held by City of Miami and/or Miami Parking Authority as it relates to the incident at issue herein, including but not limited to incident reports, proof of liability insurance, and any other statements by the City of Miami and/or Parking Authority personnel in connection with this incident. Moreover, you are hereby directed to preserve any and all work logos, time sheets, or other documents that would detail what employees were present at the time of the incident resulting in our Client's injuries, and that would otherwise relate to the premises maintenance procedures and/or employees responsibilities in connection with maintenance of the subject premises.
Furthermore, let this letter further serve as formal notice that you must preserve any and all video surveillance footage and/or any other video/audio recordings pertaining to the incident on or around Lot 26, resulting in our Client's injuries. Specifically, you are are to preserve tending to show the condition within the premises before the incident in question. Therefore, you are hereby duly notified that you are to preserve all video and/or recordings of the city of Miami and/or Miami Parking Authority on or around Lot 26 and other surrounding areas which show the area where the incident occurred, from the open of business on November 10, 2016 through the close of business on November 12, 2016 and any other video recordings otherwise related to the subject incident.
we request that you provide us copies of the documents, video,and other evidence referenced herein within 10 days of the date of receipt of this letter. If you intend to withhold providing us any of the copies requested herein, please advise of the same in writing