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by Jason Brenner, Associate at The Haggard Law Firm

Although each negligent security case may bring about different facts or require ingenuity with your strategy, there are certain elements of your case that remain constant.  One of those elements is crime statistics.  The importance of crime statistics in your case cannot be stated enough.  Not only do these statistics help establish notice and foreseeability to the defendants, they are also a treasure trove of information.

With respect to notice and foreseeability, your crime statistics establish what the defendants “knew or should have known” prior to and at the time of subject incident.  So what should you request?  You begin by requesting the calls for service and all police reports for the subject property.  This needs to be done in one request.  From there, depending on your jurisdiction, you will order up to a mile radius for the calls for service.  Once you receive each respective request, you must synthesize the data.  For example, you will detail the violent and non-violent crimes and their frequency on the property.  This provides a picture of what type of crime was going on at the property.  It provides you with the ability to illustrate to the jury the level of crime occurring and can be used effectively to show that it is an improbability for a defendant to be unaware of the police being called to the property.

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