PLAINTIFF’s REQUEST FOR PRODUCTION & INSPECTION OF VIDEO SURVEILLANCE FOOTAGE FROM HCA KINGWOOD HOSPITAL
Published: Oct 19, 2022
Mark Burke, Plaintiff, files this request for production and inspection from KPH – Consolidation Inc., DBA HCA Houston Healthcare Kingwood, a domestic For-Profit Corporation, Defendant herein;
Plaintiff herein requests, per Tex. R. Civ. P. 196.4, production of electronic data in the form of the video surveillance footage as identified in Plaintiff’s operative complaint ( See; https://kingwooddr.com/burke-v-kph-consolidation-inc-dba-hca-houston-healthcare-kingwood/) and Spoilation letter I (See; https://kingwooddr.com/spoilation-letter-to-hca-kingwood/ ) and II (See; https://kingwooddr.com/spoilation-letter-ii-to-hca-kingwood/ ) submitted to HCA.
Production Period (Aug. 9-13, 2022)
The period of the footage should be from the early evening of Tuesday, August 9th, 2022 , when Mark Burke arrived at HCA’s Kingwood Hospital ER, until his departure in the early morning of Saturday, 13th August, 2022.
Production Format (.mp4 Video)
Plaintiff requests the video surveillance footage be made available on the cloud in .mp4 video format, with downloadable link(s) available for Plaintiff to access and download said video footage at the expense of Defendant, per Tex. R. Civ. P. 196.6.
RESPECTFULLY submitted this 19th day of October, 2022.
“The threat is equally present whether the lawyer or doctor is fully licensed or is a pretender sporting a vest or white coat and displaying a fake diploma. In both cases, the wrongdoer is using the ostensible position to facilitate or conceal the crime” – U.S. v. Gill, 99 F.3d 484, 489 (1st Cir. 1996)
Email to Defendant and Defendant’s Known Counsel
See attached re case # 202268307 (via email, 12.01 PM, to emails per certificate of service).