|Multi Request||5G Master License Agreement|
|Submitted||Jan. 3, 2022|
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To Whom It May Concern:
Pursuant to the California Public Records Act, I hereby request the following records:
In 2021 Linda Gerull had 10 meetings with lobbyists from Verizon regarding "5G Master License Agreement".
Please produce meeting notes, prep notes, presentations, slide decks, after-meeting reviews, agendas, transcripts, policy memos (draft or final), created, modified, sent, or received from January 1st 2021 to December 31st 2021 on any of the following topics in the constructive possession of your agency related to "5G Master License Agreement":
1. All communications with lobbyists (Christine Keener, Rudolph Reyes), employees, and subcontractors working on behalf of Verizon.
2. Inventory of CCSF assets that may be part of any 5G Master License Agreement.
3. Any non-disclosure agreement signed by CCSF staff as part of discussions regarding 5G Master License Agreement
4. Maps or drawings shared with Verizon representatives of CCSF Outdoor Public Warning System and Emergency Call Box system
5. Use of CCSF assets including public safety towers, CCSF properties, and CCSF fiber-optic network by Verizon or its subcontractors.
6. Digital City Initiatives
6. Microtrenching within San Francisco
Comply with each clause of the Sunshine Ordinance. Ensure each redaction is justified by a key/footnote, and each withholding is justified in writing. Comply with every consent agreement you may be subject to, including but not limited to: https://www.documentcloud.org/documents/20699602-mayors-office-agreement-to-produce-email-metadata-letter-to-anonymous-and-sotf-re-sotf-file-no-20006-plus-attachments , https://www.documentcloud.org/documents/20983054-signed-mayors-office-letter-amended-letter-to-sotf-and-anonymous-re-sotf-file-no-20052 .
Provide rolling response - SFAC 67.25(d) - for all requests. If providing records via any form of website or file share, ensure that no restrictions like login, terms of service, or identity, apply.
For email and calendar, exact PDF copies of each and every distinct, individual record (including separately, each email in each thread, and meeting entry in each date) are sufficient with the body, invitees, attendees, attachments, email addresses, To/From/cc/Bcc, urls, formatting, and hyperlinks.
For Microsoft Office or office productivity (word processing, spreadsheets, and presentations) documents, produce an exact copy of the record in its original electronic format; do not convert to PDF - preserve all metadata and history and formatting. If Google Drive records are responsive, a view-only hyperlink accessible without login is acceptable, or you may download the file as Word, Excel, or PowerPoint file and provide that file *with all interactive features* - do not provide a non-PDF file as PDF.
For records of any kind with: attachments (must be produced in their original electronic format), images, audio, video, formatting, hyperlinks/URLs, date/time stamps, participant/author names, comments, or history -- be sure to preserve and produce all of those parts.
If communications of any kind are requested, they include every form or type of communication, including but not limited to email, chats, texts, iMessage, direct message, private message, MS Teams, group message, physical letters/memos, and voicemail.
You must search all records deemed in the constructive possession of the City: personal property about the conduct of public business, government property, and City contractors (for records the government has a contractual interest in). You must justify all withholding. You must provide a keyed justification for each and every redaction.
For Microsoft Teams:
I am asking for responsive records in all 4 types of MS Teams systems listed here: https://docs.microsoft.com/en-us/microsoft-365/compliance/teams-workflow-in-advanced-ediscovery?view=o365-worldwide :
- Teams 1:1 chats. Chat messages, posts, and attachments shared in a Teams conversation between two people. Teams 1:1 chats are also called conversations.
- Teams group chats. Chat messages, posts, and attachments shared in a Teams conversation between three or more people. Also called 1:N chats or group conversations.
- Teams channels. Chat messages, posts, replies, and attachments shared in a Teams channel.
- Private Teams channels. Message posts, replies, and attachments shared in a private Teams channel.
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 10 calendar days, as the statute requires.
I am responding on behalf of the City Attorney's Office to your below request. Attached please find the responsive records. Please note we are withholding responsive records covered by attorney-client privilege (Cal. Gov't Code § 6276.04; Cal. Evid. Code § 954) and attorney work product (Cal. Gov't Code § 6276.04; Cal. Code of Civil Pro. § 2018.030). We also suggest that you reach out to MTA, DT, DPW, SFPUC and OEWD directly to see whether those departments have additional responsive records.
Please send replies to firstname.lastname@example.org<mailto:email@example.com>
[image010]Elizabeth A. Coolbrith
Office of City Attorney David Chiu
(415) 554-4685 Direct