Email sent to: nsg@necropsyservices.com. From: lanemacwilliams@gmail.com. Date: July 10, 2023 at 7:58 PM
Re: FORMAL DEMAND FOR PRESERVATION OF EVIDENCE
Dear Dr. Spangler:
You have conveyed your unwillingness to safely and securely convey to me slides and materials diagnostic of Echinococcus multilocularis, as well as supplementary evidence of illness, in our decease Abyssinian, Oliver.
This letter will serve as a FORMAL DEMAND THAT YOU PRESERVE ANY AND ALL EVIDENCE RELATING TO LIVER, KIDNEYS, CYSTIC FLUID AND HISTOPATHOLOGY SLIDES OF OLIVER'S NECROPSY.
Demand is hereby made for Necropsy Services Group to maintain and preserve in good condition any and all original slides viewed by you on Monday, June 26, 2023 and on following days, in addition to Oliver's kidneys, liver, cystic fluid, and any other materials that may assist in the future identification of Echinococcus multilocularis in Oliver.
ADDITIONALLY, PLEASE IMMEDIATELY FORWARD TO ME PHOTOGRAPHS OF MICROCOPE VIEWSS OF HISTOLOGY SLIDES WHICH CAN DEFINITIVELY IDENTIFY ECHINOCOCCUS MULTILOCULARIS IN OLIVER.
Kindly note that it is imperative that you take affirmative steps to preserve any items related to Oliver's histology slides, kidneys, liver, and cystic fluid. The failure to do so may constitute negligent spoliation of evidence and can result in the imposition of sanctions in any lawsuit or action.
Having ensured that you have preserved all evidence of Echinococcus multilocularis through slides, kidneys, liver, and cystic fluid, you are instructed to convey the rest of Oliver's remains to Animal Memorial Services in Gilroy this Wednesday, July 12, 2023 for individual cremation and prompt return of Oliver's ashes to our home address at 45 Vista Verde Way, Portola Valley, CA, 94028. Please convey to me via email that this transfer has been made on time.
Lastly, please immediately provide to me the contact information for your liability insurance carrier.
Thank you for your professional courtesy and cooperation, as well as your prompt attention to this matter.
Sincerely,
Lane MacWilliams
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