Dear Ms. Jordan:
We represent Scott Anderson. Mr. Anderson was injured on Saturday, August 17, 2019 while working as a Longshoremen at the Port of Tacoma Terminal 10-4, Pier 4. The ship was Northern Jaguar and Mr. Anderson was working as dockman at approximately 4-5p.m.
Please consider this a Public Records Request and Spoliation Notice for video footage of that event/incident.
Please take notice that it is requested that all videotape and/or other data compilations which might impact on the subject matter of this potential claim be preserved and that any ongoing process of document destruction involving such documents cease.If the videotape or data requested herein has previously been destroyed, and/or written over, you are requested to describe in detail the circumstances of and reasons for such destruction and to produce all documents which relate to either the circumstances or the reasons for such destruction. This includes all electronic data created by the Port of Tacoma or any of its agents from the date of the incident through the present must be preserved. Please ensure that all current back-up tapes, disks or drives that contain data for the relevant time period identified above are not rewritten. Stop any rotation, alteration and/or destruction of electronic media that may result in the alteration or loss of any electronic data relating to the issues in this lawsuit. Do not alter and/or erase active, deleted files or file fragments on any electronic media that may have any relation to this matter. Do not conduct any maintenance such as defragging, reformatting or upgrading any hard drives that may contain data relevant to this litigation. Do not dispose of any electronic media storage devices replaced due to failure and/or upgrade that may contain electronic data having any relation to this matter.
Thank you in advance for your assistance. Please call or e-mail us with any questions or concerns.
Jeffery M. Campiche