July 4, 2019
VIA HAND DELIVERY
1899 Metropolitan Pkwy. SW
Atlanta, GA 30315
To whom it may concern,
I am providing this letter on behalf of Mr. Hidy Lee Graves, who was seriously hurt on or about June 29, 2019 when a garbage truck collided with him and ran over his legs, causing very serious injuries. I think you may have a surveillance camera that captured video footage of this event. Obviously, that video footage will be very important evidence in Mr. Graves’s legal case. Please save that video. Our law firm will reimburse you for any reasonable expense involved with preserving the video or making a copy of it.
We do not know the exact time of the event, but believe that it was in the early morning hours (between 3:00am and 7:00am) of Saturday, June 29, 2019. We do not know the exact place, but believe it happened near the south end of the Value Village store, furthest from Metropolitan Parkway / US 41. I visited the area this afternoon and saw a camera there, by the loading dock and dumpster.
Please do not allow any video footage from that time period to be lost, destroyed, recorded over, or altered. In a case like this, the law requires that the evidence be preserved—in fact, there could be adverse consequences if the video is not preserved. ALMI Residential Props. Inc. v. Georgia Power Co., 293 Ga. App. 358, 363 (2008).
Please contact me at your convenience. At a time and place convenient to you, I’d very much like to get a copy of the video.
BUTLER KAHN LAW FIRM