Re:       Our Client:                  Mirna Rodriguez

            Date of Birth:              07/19/1952

            Our File No.:               52366.1

            Date of Loss:              11/18/2019

            Time of Loss:              Around 9:00 p.m.

Greetings:

 Please be advised GLP Attorneys, P.S., Inc. represents Mirna Rodriguez with regard to injuries sustained as an invitee at Seattle-Tacoma International Airport (SeaTac Airport) on November 18, 2019. Please provide and preserve the following items in relation to this matter. 

1. Please provide the policy number, name, phone number, address, and all contact information for your liability insurance carrier and any other insurance policies that may apply for this claim.
2. Preserve maintenance and operation records from November 1, 2018 to the present for the escalator where Ms. Rodriguez fell and was injured on November 18, 2019.
3. Preserve and produce any and all video surveillance of the escalator where Ms. Rodriguez fell and was injured on November 18, 2019 from 8:00 p.m. to 10:00 p.m.
4. Preserve and produce any and all video surveillance showing Ms. Rodriguez on November 18, 2019
5. Preserve and produce any and all video surveillance of the surrounding area where Ms. Rodriguez fell and was injured on November 18, 2019 from 8:00 p.m. to 10:00 p.m.
6. Please preserve and produce all still and moving photographs, drawings, videos and any type of depictions made, if any, of Ms. Rodriguez’s bodily injuries that occurred on November 18, 2019.
7. Please preserve and produce any and all written and recorded statements taken of Mirna Rodriguez or any other people regarding her injury on November 18, 2019.
8. Please preserve and produce all written and verbal incident reports and accident reports taken as a result of bodily injuries incurred by Mirna Rodriguez on November 18, 2019. Include all statements, texts, emails, correspondence, and documents created by or for SeaTac Airport employees and all other persons regarding Ms. Rodriguez’s incident and resulting injuries.
9. Please preserve and produce the names and phone numbers of any and all employees working at the time of Ms. Rodriguez’s injury.
10. Please provide the name and contact information of the escalator operator that was controlling the escalator at the time when Ms. Rodriguez fell and was injured.
11. Please preserve and produce all written and verbal incident reports and accident reports taken as a result of any incidents at the escalator where Ms. Rodriguez fell and was injured.

We would appreciate it if you would promptly advise us in writing that SeaTac Airport and Port of Seattle have taken affirmative action to preserve and produce the above listed information. If the requested information is not preserved, then we reserve the right to claim spoliation during any litigation that may arise from this matter.

Please send us copies of all correspondence, medical bills, medical reports or statements you may have obtained. All medical authorization are revoked, and use thereof is expressly prohibited.

If you have any questions or concerns, please contact me at your earliest convenience.  Thank you for your cooperation.