Re: Georgia Cotton vs. Michael Person, et al.
American Modern Property and Casualty Insurance Company vs.
Georgia Cotton and The Cotton Educational Trust (Counterclaim)
Circuit Court for the County of Saint Louis – State of Missouri
Cause No.: 20SL-CC00458
Date of Loss: 08/12/2019
Our Client: Michael Person
To Whom it May Concern:
This law firm represents Michael Person in the lawsuit brought against him concerning property damage allegedly sustained by Georgia Cotton on or around August 12, 2019. This is a request for records on the Missouri Sunshine Law, Chapter 610, Revised Statutes of Missouri. I request that you make available to me the following records:
- All reports, documents, surveys, complaints, requests for investigation, memoranda, e-mails, correspondences, statements, videos, electronic files, testing, recordings, photographs or other materials in MSD’s possession concerning or mentioning:
- 3664 Knollstone Drive, Ferguson, Missouri 63135
- 1480 Alicia Ave., Ferguson, Missouri 63135
- Michael Person
- Georgia Cotton
- Any water issues, remediation efforts, flooding, pooling, ponding or other issues concerning any property located on Knollstone Drive in Ferguson, Missouri.
It is our understanding that the water issues were ongoing and as such our request is not limited in time. Please mail the requested records to me at the address noted below. If you have any questions or concerns, please do not hesitate to contact me directly. Thank-you for your immediate attention to this matter.