FOIA Request: Copy of the full Deposition of Jason Kessler taken on June 27, 2018 in case number 3:18CV00015

Shawn Breen filed this request with the Charlottesville City Manager of Charlottesville, VA.


From: Tom Nash

To Whom It May Concern:

Pursuant to the Virginia Freedom of Information Act, I hereby request the following records:

Copy of the full Deposition of Jason Kessler taken on June 27, 2018 in case number 3:18CV00015. The deposition likely would be in the possession of city attorneys and/or paralegals for the city attorneys, and portions of the deposition were included as Exhibit C in legal filings submitted by the city of Charlottesville in case number 3:18CV00015 on July 6, 2018.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 5 business days, as the statute requires.

Please note that I am a citizen of Virginia, and am using MuckRock's services to help manage and track my request.


Tom Nash

From: Charlottesville City Manager

Attached is a copy of the requested deposition, redacted pursuant to Virginia Code Section 2.2-3704(A) to protect medical/ health care information. The court entered a protective order. Subsequent to the deposition, Mr. Kessler’s attorney contacted the attorneys representing the City and he requested that the information be treated as confidential under the protective order. The request was not made at the deposition itself, so the reporter did not mark the deposition as containing protected information.

Brian Wheeler

From: Shawn Breen


Thanks so much for your help with this request! I really appreciate it.

Shawn Breen