Pursuant to the California Public Records Act (Gov. Code, §§6250 et seq.), we request copies of the following, concerning an incident that occurred April 16, 2018, on the tracks at or near Doheny Park Road and Pacific Coast Highway, at or near mile marker 200.1, involving Metrolink train 609 (“subject train”), that resulted in the death of Ernest Bert Gibson:
- Any and all public records, as defined by Government Code, section 6252(e), concerning and/or relating to the above-described incident, including, but not limited to, photographs, reports, and communications of any kind.
- All video, including but not limited to, from the subject train and the locomotive, from the commencement of the run through one hour after the accident, including, but not limited to, video depicting the accident scene, as well as all video depicting the locomotive engineer(s) and any other persons in the locomotive, the interior of the locomotive, all actions and activities of the locomotive engineer(s) and other railroad personnel operating said train and/or present in the locomotive, and depicting any and all persons in the vicinity of the tracks, including, but not limited to, decedent Ernest Bert Gibson.
- Data from the subject train's locomotive event recorder and all data contained therein from the commencement of the run through one hour after the accident.
- All reports and records concerning or relating to handheld wireless or similar devices in the possession of the locomotive engineer and other persons operating the train and/or present in the locomotive at the time of the above-referenced incident, and all data contained therein.
- All trespassing reports for the period 2008-present involving the railroad tracks, railroad right-of-way, and general vicinity within a mile in each direction at and near Doheny Park Road and Pacific Coast Highway, at or near mile marker 200.1.