ATTN: Lt. German Gutierrez | MLB correspondence with Medley PD | Marcell Ozuna and Genesis Guzman

To Lt. Gutierrez (or your relevant records custodian)

Pursuant to the Florida Sunshine Law, I hereby request the following records:

1) All phone, text or email correspondence between your department and Major League Baseball (MLB) staff referencing Marcell Ozuna (DOB: 11/12/1990) or Genesis Guzman between 05/15/2020-11/29/2021.

While correspondence between your department and MLB staffers may include conversations beyond the following names, I've provided these people to assist with your search:

Moira Weinberg:
moira.weinberg@mlb.com
Rick Burnham:
rick.burnham@mlb.com
Mehtab Brar:
mehtab.brar@mlb.com
Liam Rich:
liam.rich@mlb.com

2) All records referencing Marcell Ozuna (DOB: 11/12/1990) and Genesis Guzman including:

-- 911 calls (including call logs, audio and transcripts)
-- arrest reports
-- investigative records (which can include chronological records of events, property and evidence logs, witness lists, interview notes from officers examining the case, photos and videos included in the case file, search warrant affidavits, case summaries, and charges recommended to the prosecuting agency)

between 05/15/2020 and the date this request is received.

3) We're also requesting a FOIA log for related requests referencing Marcell Ozuna (DOB: 11/12/1990) and Genesis Guzman. We want:

1) The log or file number
2) The date the request was received
3) The name of the persons/organization (besides ourselves) making requests related to the above
4) A description of the information sought
5) The date the response was sent
6) The type of response your office sent (granted, denied or partial release)

If you determine that some but not all the information is exempt from disclosure and that you intend to withhold it, I ask that you redact it for the time being and make the rest available on a rolling basis. In any event, please provide a signed notification citing the legal authorities on which you rely if you determine that any information is exempt and will not be disclosed.

The requested documents will be made available to the general public free of charge and processed by a representative of the news media/press and is made in the process of news gathering and not for commercial usage.

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 also ask that our request be filled electronically, by e-mail attachment if available (email: holler@bwd.nyc and yelenadzhanova@gmail.com) – if not, secure file transfer, thumb drive, or CD-ROM. I am also available via phone at 718.360.6359 to discuss any questions you have about the request.

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.

Sincerely,

Bradford Davis and Yelena Dzhanova