Tampa, Florida 33630 Telephone: (860) 547-5000
Fax: (813) 286-8997
SENT VIA FAX & U.S. MAIL
RE: Our Client: CLIENT NAME Date of Accident: 12/11/2006Dear Sir or Madam,
Please be advised that my firm has taken over the representation of CLIENT NAME for injuries received as a result of the above referenced accident. Pursuant to Florida Statute Section 627.4137, I hereby request that you provide to me, within 30 days of this written request, a statement under oath of a corporate officer, or of your claims manager or superintendent setting forth the following information with regard to each known policy of liability insurance, including excess or umbrella insurance:
(1): the name and address of each insurer; (2): the name and address of each insured; (3): the limits of liability insurance applicable to each such policy; (4): a statement of any policy or coverage defenses which you reasonably believe are available or have been asserted; Please preserve the table which CLIENT NAME was sitting at. Please preserve all video surveillance for the entire restaurant for the dates December 10 – December 11, 2006. Under Florida law, if you fail to preserve said evidence, you may face penalties as determined by the court. I also hereby request that you furnish to me within 30 days of this written request a copy of each such policy as provided by statute. Further, should you discover facts calling for an amendment to your statement we would expect the amendment be made immediately upon such discovery. Thank you for your prompt attention to this matter.Sincerely,
Justin Ziegler