Swift Atlanta (Georgia World Congress Center Authority)

Received. We will start gathering anything that may be responsive. Thank you.
Sent from my iPhone

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Pargen Robertson

Legal Counsel

Administration

O: (404) 223-4060 | C: (470) 330-0389 | F: (404) 223-4011

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www.gwcca.org<https://www.gwcca.org/>

285 Andrew Young International Blvd., N.W.
Atlanta, GA 30313

Stay up on the latest news about the No. 1 convention, sports, and entertainment destination in the world
– check out the Authority’s blog, unConventional<https://www.gwcca.org/un-conventional/>.

Dear Mr. Koebler:

As I was reading through your request, it occurred to me that I probably should explain that the Georgia World Congress Center is not involved in any way with the booking of these events or negotiating the terms of the deal with these artists and their production companies in Mercedes-Benz Stadium. It is true that Mercedes-Benz Stadium is owned by the GWCCA, but it is operated by the Atlanta Falcons Stadium Company, LLC pursuant to a long-term license agreement (tantamount to a triple net commercial ground lease). In other words, Atlanta Falcons Stadium Company, LLC pays the GWCCA rent for the use of the stadium, but they then book their own calendar of events and pay the expenses for and keep the revenue from those events. We aren’t a party to such transactions at all. All that to say that though we may have a few document which incidentally refer to the Taylor Swift concerts or otherwise are technically responsive to some of these items on your list, we won’t have anything like the type of documents you seem to be seeking. To put it differently, these are not our events.

That being the case, how would you like to proceed? Thank you.

[cid:gwcca-logo-big2_4db8d469-239a-4bbf-b6fc-6a138c6774af.gif][cid:2020_TWP2_19587468-d5eb-4958-a4e9-6f77705f0957.png]

Pargen Robertson

Legal Counsel

Administration

O: (404) 223-4060 | C: (470) 330-0389 | F: (404) 223-4011

[cid:facebook-icon_90331aa7-f35b-4e6c-a9d4-58f35e4c7606.gif]<https://www.facebook.com/GeorgiaWorldCongressCenterAuthority/>[cid:twitter-icon_2ecffa0d-11c0-413b-80ab-e2354748a0f7.gif]<https://twitter.com/GWCC_ATL>[cid:insta-icon_ca1ff275-62b0-4941-8c3f-8a0115b8cb1a.gif]<https://www.instagram.com/gwcca_atl/>

www.gwcca.org<https://www.gwcca.org/>

285 Andrew Young International Blvd., N.W.
Atlanta, GA 30313

Stay up on the latest news about the No. 1 convention, sports, and entertainment destination in the world
– check out the Authority’s blog, unConventional<https://www.gwcca.org/un-conventional/>.

Dear Mr. Koebler:

Good morning. I write to respond to your Georgia Open Records Act request. As I explained in my earlier email, my sense is that your request is based on a misunderstanding of our involvement in the operation of Mercedes-Benz Stadium. That being the case, I am following up on my earlier email to ask how you would like to proceed, so as to avoid the necessity of you incurring unnecessary cost liability to the Authority which, once incurred, we would have to require you to pay.

Absent any other instruction from you, we will proceed under the Georgia Open Records Act, O.C.G.A. Title 50, Chapter 18, Article 4 (the “Act”), to comply with our duties. Under the Act, the Geo. L. Smith II Georgia World Congress Center Authority (the “Authority”) essentially has a duty within three business days of receipt of your request to produce for inspection and copying those public records responsive to your request which do not come within the scope of any exceptions under the Act. See O.C.G.A. § 50-18-71.

However, in those instances where records are unavailable within three business days of receipt of the request, and responsive records exist, the agency shall, within such time period, provide the requester with a description of such records and a timeline for when the records will be available for inspection or copying. Records will be provided or access to the records will be provided as soon as practicable.

Our team is in the process of identifying the documents in our possession, if any, which may be responsive to your request. Because of the extremely broad nature of your request, and because it potentially captures not only electronic communications but other material, we expect our search to take some time and require work searching records by a fairly sizable number of employees. That being the case, we estimate that we may be able to make those documents available for inspection and copying approximately by Monday, December 5.

In any instance in which an agency is required to or has decided to withhold all or part of a requested record, the agency shall notify the requester of the specific legal authority exempting the requested record or records from disclosure by Code section, subsection, and paragraph within a reasonable amount of time not to exceed three business days or in the event the search and retrieval of records is delayed pursuant to this subsection or pursuant to subparagraph (b)(1)(A) of this Code section, then no later than three business days after the records have been retrieved. In this instance, the specific legal authority exempting some requested record or records, if any such records exist, would be the following: O.C.G.A. §50-18-72(a)(41).

The Authority may impose a reasonable charge for the search, retrieval, redaction, and production or copying costs for the production of records pursuant to the Act. The Authority is required to utilize the most economical means reasonably calculated to identify and produce responsive, nonexcluded documents. The charge for the search, retrieval, or redaction of records shall not exceed the prorated hourly salary of the lowest paid full-time employee who, in the reasonable discretion of the custodian of records, has the necessary skill and training to perform the request; provided, however, that no charge shall be made for the first quarter hour. In addition, the Authority may charge a fee for the copying of records or data not to exceed 10¢ per page for letter or legal size documents or, in the case of other documents, the actual cost of producing the copy.

In any instance in which the Authority will seek costs in excess of $25.00 for responding to a request, the Authority shall notify the requester within a reasonable amount of time not to exceed three business days and inform the requester of the estimate of the costs, and the agency may defer search and retrieval of the records until the requester agrees to pay the estimated costs unless the requester has stated in his or her request a willingness to pay an amount that exceeds the search and retrieval costs. In this instance, the Authority estimates that the costs may be approximately $275. Please understand that is only an estimate. I will have a more precise estimate once our team completes its initial review.

Thank you. Please let me know if you have any questions or thoughts to share.

Sincerely,

GEO. L. SMITH II GEORGIA WORLD CONGRESS CENTER AUTHORITY

James Pargen Robertson, Jr.
Legal Counsel

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Pargen Robertson

Legal Counsel

Administration

O: (404) 223-4060 | C: (470) 330-0389 | F: (404) 223-4011

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www.gwcca.org<https://www.gwcca.org/>

285 Andrew Young International Blvd., N.W.
Atlanta, GA 30313

Stay up on the latest news about the No. 1 convention, sports, and entertainment destination in the world
– check out the Authority’s blog, unConventional<https://www.gwcca.org/un-conventional/>.

Good morning Jason. An updated. I’m trying to coordinate with our IT department on our automated document search. The goal is to prevent thousands of false hits (which we’d have to review one page at a time, and you’d have to pay for our time spent reviewing). We prevent false hits essentially by being thoughtful about the search terms words we use. Please see my comments and questions below, and let me know if you have any information that would be helpful.

1) All instructional materials, presentations and presentation materials related to Taylor Swift concerts. This includes A) any notes taken during meetings that discussed Taylor Swift and B) Any other documents related to Taylor Swift including internal documentation, public relations materials, and executive summaries. We definitely don’t have this, at least not as it relates to the concert itself. As I said, we don’t operate Mercedes-Benz Stadium. The Atlanta Falcons Stadium Company, LLC does. As we get closer to the event, we may have documents related to traffic management and public safety outside the stadium related to attendees transiting to and from the event, but of course we aren’t that far along in the planning for this event at this time. And a lot of those types of documents necessarily will come within the scope of exceptions to the Open Records Act, so we wouldn’t be able to give you those even once we obtain them (see, for example, OCGA 50-18-72(a)(25) (“the disclosure of which would compromise security against sabotage or criminal or terrorist acts. . .”)).

2) All "bid books" or functionally equivalent documents provided to or from the stadium/stadium authority for the purposes of soliciting bids for Taylor Swift concerts. As with Item (1), we don’t operate Mercedes-Benz Stadium and were not involved in soliticing bids for Taylor Swift concerts.

3) Any seating charts, "ticket holds," ticket allocation information, sales plans, or other ticket sales/distribution plans relating to Taylor Swift Again, as with Items (1) and (2), the GWCCA doesn’t operate the Stadium and isn’t involved in the sales of tickets to the public.

4) Any contracts, presentations, instructional materials, budgets, proposals, or non-disclosure agreements between this office/department/the city and any of: Ticketmaster, Live Nation, and/or Live Nation Entertainment As with Item (3), the GWCCA doesn’t operate the Stadium, the Atlanta Falcons Stadium Company, LLC does. Essentially they keep all the revenue and pay all the costs of operating the building. These are their contracts, not ours.

5) Any contracts, presentations, instructional materials, budgets, proposals, or non-disclosure agreements between this office/the city and any of: Taylor Swift Touring, Anschutz Entertainment Group (AEG), and/or the Messina Group or Messina Touring Group. We have none related to these upcoming Taylor Swift concerts. Any material we may have related to AEG and Messina would predate destruction of the old Georgia Dome (which was demolished in 2017). If you want us to search for that material, we can do that, but that search would cover a twenty-six year period, and much of that material would not be in electronic form. It would be hard copies in banker boxes kept in storage. Reviewing old banker boxes in storage will necessarily require thousands of dollars in costs, perhaps tens of thousands of dollars. Stating the obvious, we’ll have to require payment of up front once we generate a more precise estimate. I’m doubtful this is what you really want, but please confirm.

6) Any emails and associated attachments to/from/mentioning “Taylor Swift Touring,” “MTG,” and “Messina Touring Group” sent between August 1, 2022 and the time this request is processed. Our IT Department is running this search (but for the reasons stated, I doubt we have anything).

6) Any emails and associated attachments to/from email addresses that include "@livenation.com" or "@ticketmaster.com" sent between August 1, 2022 and the time this request is processed. The included emails can be further limited to include the words "Taylor" "Swift" and "Taylor Swift" Our IT Department is running this search (but for the reasons stated, I doubt we have anything).

7) Any emails and associated attachments to/from email addresses that include “@messinagroupinc.com” or “@themessinagroup.com” sent between August 1, 2022 and the time this request is processed. Same.

Please let me know if any questions. Thanks Jason.

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Pargen Robertson

Legal Counsel

Administration

O: (404) 223-4060 | C: (470) 330-0389 | F: (404) 223-4011

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www.gwcca.org<https://www.gwcca.org/>

285 Andrew Young International Blvd., N.W.
Atlanta, GA 30313

Stay up on the latest news about the No. 1 convention, sports, and entertainment destination in the world
– check out the Authority’s blog, unConventional<https://www.gwcca.org/un-conventional/>.

Good afternoon. We have completed our search for responsive documents. Expect an email from Dale Aiken, cc:ed here, with a Sharescan link which will allow you to access copies of the responsive documents electronically. Please let me know if any questions. Thank you.

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Pargen Robertson

Legal Counsel

Administration

O: (404) 223-4060 | C: (470) 330-0389 | F: (404) 223-4011

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www.gwcca.org<https://www.gwcca.org/>

285 Andrew Young International Blvd., N.W.
Atlanta, GA 30313

Stay up on the latest news about the No. 1 convention, sports, and entertainment destination in the world
– check out the Authority’s blog, unConventional<https://www.gwcca.org/un-conventional/>.

Aiken, Dale shared a folder with you

Mr. Koebler - Information at the link below is sent at the request of Pargen Robertson, GWCCA Legal Counsel. Please contact Mr. Robertson at probertson@gwcc.com should you have any questions.

<https://gwcca.sharepoint.com/:f:/s/GWCCAOpenRecordsRequests/ElGYrjBsLsNHqQw2vrzsZXkByXe1O40XQpc-zs9H-LVPtA?e=5%3Avclr2G>
Jason Koebler - 11-18-22 ORR

[cid:8f2699e1-e093-43fb-8ac4-689fc039b8df] This link only works for the direct recipients of this message.

Open <https://gwcca.sharepoint.com/:f:/s/GWCCAOpenRecordsRequests/ElGYrjBsLsNHqQw2vrzsZXkByXe1O40XQpc-zs9H-LVPtA?e=5%3Avclr2G>
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Dale Aiken

Executive Office Project Specialist

Administration

O: (404) 223-4006 | C: (404) 771-1979

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www.gwcca.org<https://www.gwcca.org/>

285 Andrew Young International Blvd., N.W.
Atlanta, GA 30313

Stay up on the latest news about the No. 1 convention, sports, and entertainment destination in the world
- check out the Authority's blog, unConventional<https://www.gwcca.org/un-conventional/>.