Hans Graff, HISD Assistant General Counsel communications

To Whom It May Concern:

Pursuant to the Texas Public Information Act , I hereby request the following records:

As it relates to any computer, computers, HISD issued cell phones (or cell phone whose service is paid for by HISD), tablets, laptops or other device (whether personal or district owned) utilized by Mr. Hans Graff, Assistant General Counsel for any HISD business whatsoever, the following files/documents are requested:

1. Records (of any kind) evidencing any and all communication to the following individuals or domain names:
@po.utexas.edu
The following individuals:
Gordon Appleman
JJ Baskin
Jack Blanton
Gerry Griffin
Jack S. Gray
Steve Ballantyne
Ben Barnes
David Beck
Melinda Hill Perrin
Mike Perrin
Pat Oles
Larry Temple
Pam Willeford
Darrell Windham
Cappy McGarr
Charles W. Matthews
Richard Leshin
Kenneth M. Jastrow II
Joe Jamail
Leslie Cedar

2. Records of visiting any of the following websites, including the date, time, url and extensions within the following sites and/or domains (including any log file which may memorialize the visits to those sites):
The Texas Tribune
Texastribune.org
Austin American Statesman
@statesman.com

3. As it relates to the personnel file of Hans Graff:
Any and all complaints, grievances, adverse employment decisions or other punitive or corrective disciplinary measures filed/instituted or brought against Mr. Graff for the previous 5 years;
The resolution of any and all complaints referenced in 3(a);

4. All emails generated by Hans Graff for the previous three years which contain any invectives and/or epithets, including but not limited to, the following previously used by Graff as “Hans5162” in public postings:

“Stupid”
“Idiot, idiocy”
“Cancer” (when describing an individual or group)
“cancerous” (when describing an individual or group)
Hate, haters
Liar
Fraud, fraudulent
“Whack”, ‘whack job’, ‘whack jobs’
“BS”, “b.s.”
“Hack”
“skeletal anorexic woman”
“suck”
“disabled circus freak”
“cabana boy”
“excise the malignant cancer” (when directed at an individual)
“crazy, paranoid”
“lying douchebag”
“rednecks want to preserve their inalienable right to shoot their ex-wives, sell assault rifles to Mexican drug cartels and blow their brains out”
“a waste of flesh”
“a total douche”
“ass-monkeys”
“dirtbag”
“scumbag”
“dumbass”

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 fees cannot be waived, 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 10 business days, as the statute requires.

Sincerely,

Beryl Lipton

To Whom It May Concern:

I wanted to follow up on the following Freedom of Information request, copied below, and originally submitted on May 5, 2015. Please let me know when I can expect to receive a response, or if further clarification is needed.

Thank you for your help.

To Whom It May Concern:

I wanted to follow up on the following Freedom of Information request, copied below, and originally submitted on May 5, 2015. Please let me know when I can expect to receive a response, or if further clarification is needed.

Thank you for your help.

To Whom It May Concern:

I wanted to follow up on the following Freedom of Information request, copied below, and originally submitted on May 5, 2015. Please let me know when I can expect to receive a response, or if further clarification is needed.

Thank you for your help.

Hi Jason,

Thank you for your estimate. However, I am puzzled by the exorbitant costs you have quoted.

It is my understanding from a review of the HISD website that the district uses a standard Microsoft Exchange server. https://www2.houstonisd.org/portal/site/Technology/menuitem.a81c6066dd6f6b298a4c6510e041f76a/?vgnextoid=6bb4eae7492ee010VgnVCM10000028147fa6RCRD&vgnextchannel=b3af643c26ede010VgnVCM10000028147fa6RCRD#12

Pulling and conducting a search on this one email address should be only cost a fraction of the estimate provided.

The estimate disregards the current state of document management technology and other widely accepted and adopted electronic eDiscovery and Computer Forensic methods. Utilizing software such as NUIX and the legal online review/tag/production software CS Disco - those emails could be processed and converted into any preferred format in a matter of hours afternoon for hundreds, not thousands of dollars. Please provide the size of the individual .pst file. Certified forensic specialists charge approximately $75 per GB to process emails such as those requested. Specifically as it relates to email security and privacy, once the emails are loaded to the Disco system, no one other than those explicitly authorized to review the emails may be given access.

Please reconsider your estimate and get back to me as soon as possible. If we cannot agree on a timely and reasonably priced production of these documents in light of the district’s month long delay to respond in the first instance, I will be required to file a complaint with the Attorney General’s office.

I will await your response.