To Whom It May Concern:
This is a request for public records as provided for in "The Inspection of Public Records Act" (NMSA 1978, Article 14, Chapter 2).
Please provide all city bus video/audio/police report from the incident aboard "a bus owned and operated by the city" on October 21, 2017. I have attached the lawsuit Mireles v Holt, City of ABQ for more clarity (case number D-202-CV-2018-05056).
Defendant Johnathan Holt is described as a city employee (bus driver) in the complaint. Plaintiff Rene Mireles claims Holt "failed to properly restrain him in his wheelchair with a safety belt" when he boarded the bus. The complaint says defendant Holt then got in an accident where plaintiff Mireles was thrown from his wheelchair and injured.
As you know, the Act provides that if portions of any case documents are exempt from release, the remainder must be segregated and disclosed. Therefore, I will expect you to give me access to all nonexempt portions of the records I have requested, and ask you to justify any deletions by reference to specific exemptions of the Act.
If you have any questions, please feel free to call me at (312) 772-8882 or email me at firstname.lastname@example.org. Thank you for your assistance and I look forward to receiving your reply within the deadline mandated by law.