Please be advised that this firm represents the interests of Ms. Maria Hernandez de Jesus with respect to the injuries sustained on or about September 20, 2019. Accordingly, we inform you of our representation and ask that all further correspondence and communications be forwarded to this firm and that no contact be made directly with our client.
Our client, Ms. Hernandez, was traveling on the 120 Metro bus to Garfield and Imperial at around 9:30 am.
Please be advised that we are requesting the following information:
Request for Evidence
This letter will further reconfirm your obligation to submit any and all evidentiary items relating to the subject incident, including, but not limited to:
photographs or video of the incident, incident scene (request is made for the native files of any photographs or video);
oral or written statements relating to the incident, incident scene;
photographs, audio and video recordings, maintenance reports, custodial reports, purchase records, service orders, inspection reports, repair invoices, any correspondence relating to the management and care of the facilities, etc.;
all records reflecting oral or written communications or agreements with our client(s) regarding the incident, incident scene;
police or incident report(s) for the incident, including any photographs and videos referenced in said reports(s);
statements, abstracts, recordings and/or writings of parties and/or any witnesses pertaining to the incident;
V I K I N G L A W F I R M , P . C .
photographs, negatives, diagrams, video, motion picture slides and/or visual representations of the accident scene, and/or persons or things involve in the incident, including, but not limited to, the accident scene, and/or the parties taken at any time;
accident and/or incident reports regarding or pertaining to this incident prepared by you or with your input, at any time, including but not limited to those prepared in the ordinary course of business;
the personnel file of the maintenance crew and their supervisors in the maintenance of the premises involved in the incident;
agreements to inspect, maintain and/or repair the subject premises where the incident occurred;
repair orders, invoices, reports, memoranda, and/or correspondence pertaining to the condition, inspection, repair and/or maintenance of the premises and/or the door by you at the time of the incident;
summons, complaints, violations, citations, tickets, and/or warnings issued to any person or entity pertaining to the incident;
violations; notices, citations, tickets, and/or warnings to the subject property where the incident occurred;
a journal or date planner for the date of the incident and for 90 days prior thereto, up to the present time;
documents which document, memorialize, reflect, or record the events, including but not limited to, inspections, maintenance, repairs, that parties took for 90 days prior to the occurrence through seven days subsequent to the incident;
guidebooks, memoranda, policies, procedures, rules, and or regulations which deal with issues of safety, promulgated by you, or which you have adopted even if promulgated by others;
rules, regulations, policies and/or procedures for premises maintenance, and/or the documentation of accidents, including but not limited to, blank accident information forms, promulgated and or used by parties.