Recorded Securus Phone Calls and/or Communications Records and Contracts and Supporting Documents

Robert Teel filed this request with the Department of Corrections of Jefferson City, MO.
Est. Completion None
Status
Partially Completed

Communications

From: Robert Teel

To Whom It May Concern:

Pursuant to the Missouri Sunshine Law and the Missouri Public Records Law, I hereby request the following records:

Please provide:

(1) all (i) audio or visual records and recordings, or (ii) written transcriptions, notes, reports, or memoranda, or (iii) other information, about, in connection with, or of, any and all phone calls, emails, videos, or other communications made or received by detainees or inmates using any Securus phone or communication system, including without limitation the Securus Secure Call Platform or the AdvanceConnect Direct Bill, Traditional Collect, Inmate Debit, Jail Voicemail, Video Visitation, Securus Online, or Secure Instant Email, for any detention facilities operated by you, including without limitation the detention facilities set for below, and including without limitation records and recordings of:

(a) the content of the communication;
(b) the prisoners’ first and last names;
(c) the phone numbers they called or received calls from;
(d) the date, time, and duration of the calls;
(e) the inmates’ Securus account numbers;
(f) the metadata for the communication;
(g) the recording URL where the audio recordings of the calls can be downloaded; and
(h) any other information collected by Securus or you in connection with such calls; and

(2) all contracts, agreements, correspondence, documents, statements, writings and recordings of every kind (mechanical, electronic, typed or written) by and between the Missouri Department of Corrections or any other law enforcement agency and Securus, including but not limited to, letters, correspondence, memoranda, notes, audio recordings, reports, and transcriptions in the possession of, or subject to the control of you or Securus.

List of Detention Facilities:

ARNOLD CITY JAIL
AURORA CITY POLICE DEPT
BERKELEY CITY POLICE DEPT
BOONE COUNTY COMMISSION
CAPE GIRARDEAU COUNTY JAIL
CAPE GIRARDEAU POLICE DEPT
CRAWFORD COUNTY JAIL
DALLAS COUNTY JAIL
DAVIESS DEKALB COUNTY REGIONAL JAIL
DONIPHAN CITY JAIL
FERGUSON CITY POLICE DEPT
FESTUS CITY POLICE DEPT
GRUNDY COUNTY DETENTION CENTER
JEFFERSON COUNTY JAIL
JENNINGS ADULT CORRECTIONAL FACILITY
KANSAS CITY POLICE DEPT - VALLEY DIVISION
KANSAS CITY POLICE DEPT CENTRAL DIVISION
KANSAS CITY POLICE DEPT METROPOLITAN DIVISION
KANSAS CITY POLICE DEPT NORTH DIVISION
KANSAS CITY POLICE DEPT SOUTH DIVISICN
KANSAS CITY POLICE EAST PATROL DIVISION
LEEVS SUMMIT CITY POLICE DEPT
MISSISSIPPI COUNTY DETENTION CENTER
MO DOC - ALGOA CORRECTIONAL CENTER
MO DOC - BOONVILLE CORRECTIONAL CENTER
MO DOC - CENTRAL INVESTIGATIONS OFFICE
MO DOC - CHILLICOTHE CORRECTIONAL CENTER
MO DOC - CREMER THERAPEUTIC COMMUNITY CENTER
MO DOC - CROSSROADS CORRECTIONAL CENTER
MO DOC - EASTERN RECEPTION DIAGNOSTIC & CORRECTIONAL CENTER
MO DOC - FARMINGTON CORRECTIONAL CENTER
MO DOC - FULTON RECEPTION & DIAGNOSTIC CENTER
MO DOC - JEFFERSON CITY CORRECTIONAL CENTER
MO DOC - KANSAS CITY COMMUNITY RELEASE CENTER
MO DOC - MARYVILLE TREATMENT CENTER
MO DOC - MISSOURI EASTERN CORRECTIONAL CENTER
MO DOC - MOBERLY CORRECTIONAL CENTER
MO DOC - NORTHEAST CORRECTIONAL CENTER
MO DOC - OZARK CORRECTIONAL CENTER
MO DOC - POTOSI CORRECTIONAL CENTER
MO DOC - SOUTH CENTRAL CORRECTIONAL CENTER
MO DOC - SOUTHEAST CORRECTIONAL CENTER
MO DOC - ST LOUIS COMMUNITY RELEASE CENTER
MO DOC - TIPTON CORRECTIONAL CENTER
MO DOC - WESTERN MISSOURI CORRECTIONAL CENTER
MO DOC - WESTERN RECEPTION DIAGNOSTIC & CORRECTIONAL CENTER
MO DOC - WOMENS EASTERN RECEPTION DIAGNOSTIC & CORRECTIONAL CENTER
MOLINE ACRES CITY POLICE DEPT
MONETT CITY POLICE DEPT
NORTHWOODS CITY POLICE DEPT
OVERLAND CITY POLICE DEPT
PHELPS COUNTY SHERIFFVS DEPT
PIKE COUNTY DETENTION CENTER
PUTNAM COUNTY JAIL
SCOTT COUNTY JAIL
SIKESTON DEPT OF PUBLIC SAFETY
ST FRANCOIS COUNTY JAIL
ST GENEVIEVE COUNTY JAIL
ST. PETERS POLICE DEPT
THREADS TRAINING 2
THREADS TRAINING 3
WASHINGTON COUNTY JAIL
WRIGHT COUNTY JAIL

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 3 business days, as the statute requires.

Sincerely,

Robert Teel

From: Department of Corrections

An acknowledgement letter, stating the request is being processed.

From: Robert Teel

RE: My records request of February 3, 2016

Dear Sir or Madam:

I am inquiring about the status of the above-referenced request. In accordance with the Missouri Open Records Act a response is due no later than three business days after the request. Pursuant to MRS 610.023(3) please either: (1) provide the records and items requested; (2) provide an internet address and link on the agency’s web site to the specific records and items requested; (3) acknowledge that your agency has received the request and provide a reasonable estimate of the time the agency will require to respond to my request; or (4) deny the request and provide a detailed explanation of the grounds, including any provisions of law your are relying on for the denial.

Thank you for your consideration.

Sincerely,
Robert Teel

From: Robert Teel

Dear Mr. Wilson,

I apologize if I missed seeing your letter of February 5th as it clearly addresses my correspondence of February 12. Accordingly please disregard that followup communication.

Please provide me with an estimate of the fees and costs at your earliest convenience. Thank you for your consideration.

Sincerely,

Robert Teel

From: Boresi, Jay

Mr. Teel:

I am writing in response to your sunshine request titled "Missouri Sunshine Law Request: Recorded Securus Phone Calls and/or Communications Records and Contracts and Supporting Documents" sent on February 3, 2016. The Department is currently processing your request, but due to the press of other business and the scope of your request, it has not yet completed its review. I hope to have more information for you soon.

Sincerely
Jay Boresi
Legal Counsel
Missouri Department of Corrections
573-522-1634
jay.boresi@doc.mo.gov

CONFIDENTIALITY STATEMENT: This message from Jay Boresi contains information that is privileged and confidential and is solely for the use of the intended recipient. If you are not the intended recipient, be aware that any review, disclosure, copying, distribution, or use of the contents of this message is strictly prohibited. If you have received it in error, please delete it immediately and please notify us at (573) 526-1634. Thank you.

From: Robert Teel

Thank you Mr. Boresi. I appreciate the update.

Sincerely,

Robert Teel

From: Boresi, Jay

Mr. Teel:

I am reviewing your request this week, and I hope to have more information to you by the end of the week. I appreciate your patience.

Thank you,
Jay Boresi
Legal Counsel
Missouri Department of Corrections
573-522-1634
jay.boresi@doc.mo.gov

CONFIDENTIALITY STATEMENT: This message from Jay Boresi contains information that is privileged and confidential and is solely for the use of the intended recipient. If you are not the intended recipient, be aware that any review, disclosure, copying, distribution, or use of the contents of this message is strictly prohibited. If you have received it in error, please delete it immediately and please notify us at (573) 526-1634. Thank you.

From: Robert Teel

Thank you Mr. Boresi,

I appreciate the update and your courtesy.

Sincerely,
Robert Teel

From: Boresi, Jay

Mr. Teel,

I am providing a partial response to your request today. I am sending you a contract the Department has entered into with Securus along with its request for proposal. Because of the size of the information I will need to send in four parts. Please find part one attached. The Department is still formulating a response to the rest of your request.

Jay Boresi
Legal Counsel
Missouri Department of Corrections
573-522-1634
jay.boresi@doc.mo.gov

CONFIDENTIALITY STATEMENT: This message from Jay Boresi contains information that is privileged and confidential and is solely for the use of the intended recipient. If you are not the intended recipient, be aware that any review, disclosure, copying, distribution, or use of the contents of this message is strictly prohibited. If you have received it in error, please delete it immediately and please notify us at (573) 526-1634. Thank you.

From: Boresi, Jay

Mr. Teel,

I have not been able to send you parts two and three as I am getting bounce back emails saying that your email server is rejecting them. Is there a better way for me to get you these records?

Jay Boresi
Legal Counsel
Missouri Department of Corrections
573-522-1634
jay.boresi@doc.mo.gov

CONFIDENTIALITY STATEMENT: This message from Jay Boresi contains information that is privileged and confidential and is solely for the use of the intended recipient. If you are not the intended recipient, be aware that any review, disclosure, copying, distribution, or use of the contents of this message is strictly prohibited. If you have received it in error, please delete it immediately and please notify us at (573) 526-1634. Thank you.

From: Robert Teel

Dear Mr. Boresi,

In order to preserve the chain of custody for the materials, please continue to use the original email address with a copy to rlteel@rlteel.com. Thanks.

~ Robert Teel

From: Boresi, Jay

I am still getting bounce back messages. If you give me a physical address, I can put them on a CD and mail them.

Jay Boresi
Legal Counsel
Missouri Department of Corrections
573-522-1634
jay.boresi@doc.mo.gov

CONFIDENTIALITY STATEMENT: This message from Jay Boresi contains information that is privileged and confidential and is solely for the use of the intended recipient. If you are not the intended recipient, be aware that any review, disclosure, copying, distribution, or use of the contents of this message is strictly prohibited. If you have received it in error, please delete it immediately and please notify us at (573) 526-1634. Thank you.

From: Robert Teel

Let's try mailing the CD to:

MuckRock
DEPT MR 23711
411A Highland Ave
Somerville, MA 02144-2516

Thank you Jay.

From: Department of Corrections

A copy of documents responsive to the request.

From: Department of Corrections

A cover letter granting the request and outlining any exempted materials, if any.

From: Boresi, Jay

We'll get them out this morning

Jay Boresi
Legal Counsel
Missouri Department of Corrections
573-522-1634
jay.boresi@doc.mo.gov

CONFIDENTIALITY STATEMENT: This message from Jay Boresi contains information that is privileged and confidential and is solely for the use of the intended recipient. If you are not the intended recipient, be aware that any review, disclosure, copying, distribution, or use of the contents of this message is strictly prohibited. If you have received it in error, please delete it immediately and please notify us at (573) 526-1634. Thank you.

From: Robert Teel

Hello Jay,

I wanted to check to see if the DOC will provide non-investigatory materials between it and Securus, such as correspondence, emails, and the other records set forth in subpart (2) of my original request. These materials include emails and other records in connection with the administration, operation, and maintenance of the system (i.e., emails referring to problems, complaints, glitches, calls not getting through, recording warning prompts, collect calls, recording of private calls, etc.) and call logs.

I have received and reviewed these types of emails (literally thousands of emails) and call logs in other proceedings (in particular the spreadsheet call logs). In short, I do not believe the materials requested such as emails about administration, operation, and management of the system, call logs, and other similar materials are exempt from production.

Without waiving any rights or remedies in connection with the foregoing, I respectfully request production of at least the foregoing emails and call logs. In as much as Securus has an obligation to make this information available to the DOC, please ask Securus to search for and provide any responsive records they have in their possession as well.

Sincerely,
Robert Teel

From: Boresi, Jay

Mr. Teel,

I am reviewing your request presently.

From: Robert Teel

Thank you.

From: Boresi, Jay

Mr. Teel,

Any phone records, recordings, transcripts, or reports responsive to your request are closed pursuant to §§ 217.075, 610.021, 610.011 and/or 47 USC § 222. Regarding emails or other communications, I am still trying to estimate the amount of documents we may have that responsive to your request. Many of those communications will be either fully or partially closed records. I anticipate that the cost of researching this will be substantial. Please let me know how you would like to proceed.

From: Robert Teel

Hello Jay

Let's get an estimate first. It may be possible to narrow down the request depending on the results of your investigation as I am hoping much of the material is electronic.

Thank you for your consideration and have a good weekend.

Sincerely,
Robert Teel

From: Boresi, Jay

Mr. Teel,

I am currently attempting to determine the scope of people within the Department who may communicate with Securus so that I may determine the quantity of documents and ultimately provide you with a reasonable cost estimate for reviewing these documents for closed information. I hoipe to have more infromation for you soon.
Thanks,
Jay

From: Robert Teel

Thank you Jay.

Sincerely,
Robert Teel

From: Boresi, Jay

Mr. Teel,
I am currently attempting to determine the scope of people within the Department who may communicate with Securus so that I may determine the quantity of documents and ultimately provide you with a reasonable cost estimate for reviewing these documents for closed information. I hope to have more infromation for you soon.
Thanks,
Jay

From: Robert Teel

Thank you Jay.

Sincerely,
Robert Teel

From: Boresi, Jay

Mr. Teel,

Thanks for you patience on this. I'm still trying to come up with an accurate cost estimate. I plan to have something to you by the 9th.

From: Robert Teel

Thank you Jay.

Robert

From: Atkinson, Kyle

Dear Sir or Ma'am:

Our office is in receipt of your recent correspondence directed to Jay Boresi wherein you seek an update on a pending records request. Mr. Boresi is currently out of the office and will return on Monday, October 31, 2016. He will provide a response upon his return.

Sincerely,

S. Kyle Atkinson ǀ Legal Counsel
Missouri Department of Corrections
Office of the General Counsel

From: Robert Teel

Dear Messrs. Atkison and Boresi,

Thank you for your update. Unfortunately, I cannot wait any further for the rest of the records.

I appreciate the DOC's need to be thorough in complying with the Missouri Sunshine Law, however this request has been open for nearly nine months, and no documents other than contract documents have been provided for the last seven. Accordingly, if the remaining records are not provided on or before the close of business on November 11, 2016, I will pursue available legal rights and remedies without further notice.

I mean no offense, but am compelled to point out the DOC’s legal duty to preserve all records, documents, and other evidence which refer or relate to this request. The duty to preserve evidence is triggered when litigation is pending or reasonably foreseeable, at which time a party is required to preserve all relevant evidence and put into place a litigation hold to preserve relevant documents. 

I request you inform DOC employees, contractors, and third-party agents to preserve all the requested information as well as other information relevant to the request itself such as emails, letters, reports, internal instant messages, and other ecords that relate to the handling of this request).

Thank you for your consideration.

Sincerely,

Robert Teel

From: Boresi, Jay

Mr. Teel,

Please find the Department's supplemental response to your request attached.

Sincerely,
Jay Boresi

From: Robert Teel

Hello Jay,

Could you please explain the basis for your estimate of over 1,400 man hours? I see many ways to reduce the volume of records if I can better understand your estimate. For example, how many years does the estimate encompass? How many pages of records do you estimate? What categories of documents are there? The list of ways to limit the request goes on, so I would like to confer with you regarding how we can reach an accommodation that will be most efficient for both of us.

Thank you for your consideration. Nothing set forth herein shall constitute a waiver of any of the undersigned rights or remedies. All such rights and remedies are hereby expressly reserved.

Sincerely,
Robert Teel

From: Boresi, Jay

Mr. Teel,

The vast majority of records I would need to review are emails sent between department employees and securus between the inception of our contract with securus and present. That would be about 5 or 6 years. There are also some other reports and notes of meetings/phone calls I would need to review for responsiveness and closed information.

I am figuring two minutes to retrieve, review, and redact any closed information on each email. I believe the majority of these emails are from the last year or two. If you can limit the emails in scope time wise, assuming there is a specific period of time you are concerned about, it could reduce the time and cost significantly.

A number of different groups within the Department also communicate with Securus employees on a somewhat regular basis (our offender finance office may communicate regarding specific offender accounts, DAI staff may communicate regarding service issues, etc). If you want records from any one group inparticular it may also reduce the voume of documents.

From: Robert Teel

Thank you for the reply Jay. Without waiving any rights and remedies (all such rights and remedies are hereby expressly reserved), at this point I can limit one category of the request to DAI staff communications regarding service issues for the last four years. I do not need emails regarding specific offender accounts at this time. Just so you can understand my frame of reference for this request, I received over 2,300 emails in connection with another request in another jurisdiction going back 4 years without charge (the records were electronic). Many of them were duplicative email strings and it took me less than seven hours to "flyspeck" (read carefully) them. That's about 10 seconds an email. Again, many of these were duplicative email strings (I estimate there were actually more like 500 emails which were complete strings and the others were partial emails comprising the string) so I hope your estimate would go much quicker than two minutes an email.

In addition, I would like to know if the DOC be willing to provide the spreadsheet for the database which the Securus system provides for the last four years with a reference simply as to whether or not the calls have been recorded? Perhaps we can reach an interim compromise which would provide some of the information requested and which may (or may not) obviate the need for the rest. The Securus database contains the following columns:
Site PortLoc Ctry Wireless Dialed# Dest Zone Start Time End Time Dur.(s) Acct# PIN Prepaid First Name Last Name Call Type Call Status Term Cat. BlkReason Priv Wat'd Int'l 3Way VB Amount Taxes & Fees Promo Call Test Call Language Dtmf Detect Dtmf Digits Text2Connect RCF LIVECONNECT Tracking Number 1 Shared 1 Note 1
As a compromise (again without any waiver implied), and in order to address the costs without resort to legal process, I request that the spreadsheet database be redacted as to any objectionable identifier(s), and then be produced setting forth the dialed number, the destination zone, the start time, the end time, the duration, the call type, the term category, the amount, the taxes and fees, privilege status, Dtmf detect, Dtmf digits, and whether the call is liveconnect. In addition, I request a record simply indicating whether the call was recorded or not.

Finally, I know Securus has the capability to put the information it collects at "at law enforcements' fingertips" and has the capability to query all telephone numbers marked private and "Do Not Record" that were in fact actually recorded. In fact, this information should be reflected on the spreadsheet reports generated by the Securus system. Would the DOC be willing to provide the the emails and spreadsheet limited to all telephone numbers marked private and "Do Not Record" that were in fact actually recorded? As to the spreadsheet, It is literally a matter of pushing a button and redacting one column.

If a phone call could help us reach an interim compromise, please advise. Thank you for your consideration Jay. I appreciate it.

Sincerely,

Robert Teel

From: Boresi, Jay

Regarding the first part of your email, when you say you can limit part of your request, are you requesting those emails specfically or are you excluding those emails from your request?

From: Robert Teel

I would request the DAI staff communications and exclude the offender finance office emails from the production at this time.

Sincerely,

Robert Teel

From: Boresi, Jay

Mr. Teel,

I will pull DAI emails so I can get an acurate tally of how many of just those emails there are. In response to your request for a master spreadsheet that encompasses the past 4 years, as I explained in previous correspondence. If the Department of Corrections has such a document it would be closed pursuant to sections 217.075.1, 610.021, and 610.011.1 RSMo., and section 222 of the Communications Act of 1934 ( 47 USC 222).

From: Robert Teel

Thank you Jay,

Sincerely,

Robert Teel

From: Boresi, Jay

Mr. Teel,

I'm writing to give you an update on your request. Our IT is having trouble pulling emails from DAI from before March of last year, however, I'm confident they will be able to get them going back four years. I will let you know as soon as I have those emails.
Thanks,
Jay

From: Boresi, Jay

Mr. Teel,

I have received all the emails we discussed earlier. There are 2785 emails responsive to your amended request. To review and redact these emails and attachments I anticipate that it will take approximately 30 hours and cost approximately $772.50. If I am able to give you electronic copies of emails that do not need to be redacted, and I only need to print emails requiring redaction, costs for copies should be relatively low (Less than $50 most likely).

From: Robert Teel

Dear Jay,

Thank you for the estimate. As I’m sure you know, the Missouri Sunshine laws allows: (1) fees for copying, duplicating, search, and research time to fulfill records request; and (2) cost of copies, staff time for making copies and programming, and the cost of the electronic medium (disks, tapes, etc.) for providing access to electronic records. It is not clear to me whether fees may be charged for review and redaction of records which is a function solely for the benefit of the agency and not directly related to the cost of fulfilling the request or providing access to electronic records. In any event, $800 seems a little high to me to review 2,800 emails, many of which will be duplicative email strings.

Assuming, arguendo, the DOC may charge for review and redacting, I would like to suggest an initial cursory review be performed to simply identify which emails do not require redaction. I would hope that would be a shorter scan and much less costly (as I mentioned, I carefully “flyspecked” and reviewed over 2,300 emails from another jurisdiction in less than seven hours) and will give me an idea if the DIA emails contain the information I am seeking.

After that, if necessary, we could further discuss the cost of the emails which are set aside for review and possible redaction as well as the rest of the materials in the original request for which I was provided a $36,000 fee estimate. The problem I am having with trying to narrow the request even further is not knowing whether the information I am seeking is in the DIA emails, or the finance department emails, or other emails, or other records, or does not exist at all, and I’m sure neither of us wishes to spend unnecessary resources.

Notwithstanding the foregoing, the requested information in the Securus spreadsheet form may obviate the foregoing issue(s), however It appears we have a disagreement regarding the exempt nature of that information. I would like to avoid unnecessarily resorting to legal process, but If that is inevitable I would like to confer telephonically after the New Year holiday regarding the most efficient way to proceed.

I suggest that If we are unable to make any progress on the spreadsheet, it would make sense to submit that information to the court for in camera review and put the other items on hold. That may address the foregoing issues the most efficiently since in any event I believe most, if not all, of the information in the spreadsheet is non-exempt.

Nothing set forth herein shall constitute a waiver of any of my rights or remedies. All such rights and remedies are hereby expressly reserved.

Thank you for your consideration.

Sincerely,
Robert Teel

From: Boresi, Jay

Mr. Teel,

You're email leads me to believe you are looking for something specific, but that you do not know where it is. If you tell me specifically what you are looking for I may be able to search for records more easily, but so far your requests have been extraordinarily broad.

From: Boresi, Jay

Mr. Teel,

I’m writing because I’ve received another sunshine request similar to yours. In researching this second request, I have learned that there are some documents that may be responsive to your request that I did not consider in my prior response to you. These documents are notes/memoranda and reports kept by our Inspector General’s office. The Investigator General keeps two kinds of documents that may be responsive to your request, intelligence entries and investigative reports. Generally intelligence entries, which may originate based on monitored phone calls, can lead to investigate reports. These documents may or may not be partially or entirely closed and they will need to be reviewed individually to determine that.

The other request I am looking at is more limited in time than yours but still captures over 9,000 intelligence entries and almost 6,000 reports. I can automatically screen reports based upon investigator assigned, event date, facility, person involved (suspect, victim or witness), or code type. I can search intelligence entries by date filed, date of incident, facility, or investigator. If you would like to limit this section of your request, let me know and I will provide you with an updated cost estimate. I am attaching a list of codes so you can use that to limit your request if you choose to do so.

From: Robert Teel

Dear Jay,

Thank you. I will review and follow up on your last email. As to the prior email, I could narrow my request to information, whether in spreadsheet form or not, regarding calls made to or from detainees to their attorneys. The spreadsheet contains such information, including without limitation all attorney numbers marked private. I can provide you with an example.

In addition, I could narrow my request for materials, including emails, pertaining to the recording of calls between detainees and their lawyers as well as emails between Securus and DOC pertaining to the data leak reported by The Intercept on or about November 12, 2016. Finally, Securus acknowledges it can determine which telephone calls between detainees and their lawyers are on the "Do Not Record" or "Private" list (a column on the spreadhseet) AND were nonetheless recorded. I can narrow my request to materials on that issue as well.

If any of this would help get this request done please let me know, otherwise it appears we may need a court's assistance to resolve our differences. As always, nothing set forth herein shall constitute a waiver of any of my rights or remedies. All such rights and remedies are hereby expressly reserved.

Sincerely,

Robert Teel

From: Boresi, Jay

Mr. Teel,

Regarding the second part of your request, I will run an email search for emails between securus and DOC employees from November 1, 2015 forward. I will search for emails that contain the words "attorney," "call," and "the intercept." Is that amenable to you?

From: Robert Teel

Hello Jay,

I apologize for the delay. I appreciate your willingness to work together to try and make progress on the request, particularly as it pertains to the emails. To get things going, could you add the search terms "private", and "do not record" to the email filter?

While I sincerely appreciate your efforts to make headway, I need to reiterate that nothing set forth herein shall constitute a waiver of any of my rights or remedies. All such rights and remedies are hereby expressly reserved.

~ Robert Teel

From: Boresi, Jay

I'm having our IT run your search now.

From: Boresi, Jay

Mr. Teel,

I ran the search two ways. I ran it with my terms alone and came up with 19 emails. I assumed your terms were intended to broaden the search not narrow it, so I ran it with your terms and asked for a hit any time any of the terms were used and it came up with over 40,000 emails. Obviously, searching 40,000 emails is going to be costly. Do you want to use my three suggested search terms instead?

Sincerely,
Jay Boresi

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