City "Family" Messages - Dennis Herrera/Anne Herrera - Immediate Disclosure Request

Dennis Herrera and the Office of the City Attorney:

DO NOT DESTROY OR FAIL TO PRESERVE RESPONSIVE RECORDS CURRENTLY IN YOUR POSSESSION. WE WILL APPEAL ALL WITHHOLDINGS.

Pursuant to the CPRA and Sunshine Ordinance, I hereby request the following records - immediate disclosure request:

1. all communications of any form, any app (including but not limited to email, SMS, Facebook, iMessage, text, chat, instant message, Signal, WhatsApp, Teams, Telegram or any other app, encrypted or not), any type (physical or electronic), any location (government or personal property) between you (Dennis Herrera) and SF Parks Alliance board member Anne Herrera. Include any group messages. You may redact purely personal material. Note that normally messages between family members on *personal property* are subject to the City of San Jose "relate in some substantive way to the conduct of the public's business" test, but because Mrs. Herrera is on the board of a City contractor - contracts which you have a responsibility as City Attorney to review and approve - I will argue that the exemption of "only purely personal" information (a higher bar for exemption) should apply here (San Gabriel Tribune v. Superior Court).

Provide rolling responses from the most recent records working backwards. Justify each redaction and withholding with specificity. Provide all emails as exact copies preserving Bcc, To, From, Cc email addresses, hyperlinks, images, attachments. Preserve all attachments, date time stamps, participant names, audio, video, and images, in text, chat, and instant message.

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.

Sincerely,

Anonymous Journalist

Please provide any text, chat, or instant messages of any kind between Dennis Herrera and any of Harlan Kelly Jr., Naomi Kelly, Juliet Ellis, or Rudolph (Dwayne) Jones, Mohammed Nuru, or Willie Brown, Jr.

Please provide any text, chat, or instant messages of any kind between Dennis Herrera and any of (a) Michael Carlin, (b) London Breed, or (c) John Cote.