1. Obtain Photographs from Client
2. Photograph the shoes worn by the Client at the time of the accident, because the client may forget which shoes were worn, and the type of shoe may be an important fact in the case
3. Send e mails and letters by certified mail return receipt requested to the owner and manager of the defendant's premises requesting that all video surveillance files (digital or analog) be preserved and advising that failure to do so will constitute spoliation by which the Court could possibly strike the Defendant's answer.
4. Obtain notarized statements from any witnesses