Public Integrity Communications (SF City Attorney) - Immediate Disclosure Request

City Attorney's Office:

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Below are new Immediate Disclosure Requests (SF Admin Code 67.25(a)) directed to your agency and its department head.
Your initial response is required by Feb 20, 2020. Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce records.
Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not: provide mere URLs, print and scan electronic records, convert native files to PDFs, or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations:
- All withholding of any information must be justified in writing by specific statutory authority (SFAC 67.27).
- All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to the specific justification for that redaction, and only the minimal exempt portion of any record may be withheld (SFAC 67.26).
- You must respond to emailed requests (SFAC 67.21(b)).
- You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)).
- You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)).
- Do not impose any end-user restrictions upon me (Santa Clara Co. vs Superior Ct, 170 Cal.App 4th 1301); so if you use a third-party website to publish records, please make them completely public without any login or sign-in.

Your agency must do all of the above things in your response, and you cannot wait until we file complaints.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until the City's procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

1. All communications sent to the publicintegrity@sfgov.org email address since Jan 21, 2020 until present.
2. Please also provide an SFAC 67.21(c) written statement of the existence or quantity of these emails in #1 (even if you believe their contents to be exempt) within 7 days (no extensions)

Do not destroy or discard any responsive records - we will appeal all withholdings or Sunshine violations.

Thank you for your anticipated cooperation in this matter.

Sincerely,
Anonymous

Thank you - I will await the quantity statement, due in 7 days, even if exempt. There's no St. Croix to argue for refusing to provide quantities this time.

Furthermore, local law, Charter sections F1.107(c) and F1.110(b), San Francisco Campaign and Governmental Conduct Code, Article IV, sections 4.120 and 4.123, cannot exempt anything not already exempted in the CPRA. Therefore only Evidence Code sections 1040 and 1041, and Government Code section 6254(c) are relevant.

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Thank you - they have responded with a quantity.

This is a new immediate disclosure request for the records described by Herrera in the following memo https://sfmayor.org/sites/default/files/03.10.20%20Memo.pdf as "initial set of records Hui voluntarily provided after [the Feb 18, 2020] interview."

At this time, whatever format you can provide immediately is sufficient.

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

George Cothran,

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Below are new Immediate Disclosure Requests (SF Admin Code 67.25(a)) directed to you individually and your agency.

1. The records described by Herrera in the following memo https://sfmayor.org/sites/default/files/03.10.20%20Memo.pdf as "initial set of records Hui voluntarily provided after [the Feb 18, 2020] interview."
2. "Hui's personal emails" referred to in page 7 bottom para of the above linked document.
3. All exhibits to both memos in the above document.

Your initial response is required by Mar 11, 2020. Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce records.
Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not: provide mere URLs, print and scan electronic records, convert native files to PDFs, or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations:
- All withholding of any information must be justified in writing by specific statutory authority (SFAC 67.27).
- All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to the specific justification for that redaction, and only the minimal exempt portion of any record may be withheld (SFAC 67.26).
- You must respond to emailed requests (SFAC 67.21(b)).
- You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)).
- You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)).
- Do not impose any end-user restrictions upon me (Santa Clara Co. vs Superior Ct, 170 Cal.App 4th 1301); so if you use a third-party website to publish records, please make them completely public without any login or sign-in.

Your agency must do all of the above things in your response, and you cannot wait until we file complaints.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until the City's procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

Do not destroy or discard any responsive records - we will appeal all withholdings or Sunshine violations.

Thank you for your anticipated cooperation in this matter.

Sincerely,
Anonymous

Keslie Stewart,

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Below are new Immediate Disclosure Requests (SF Admin Code 67.25(a)) directed to you individually and your agency.

1. The records described by Herrera in the following memo https://sfmayor.org/sites/default/files/03.10.20%20Memo.pdf as "initial set of records Hui voluntarily provided after [the Feb 18, 2020] interview."
2. "Hui's personal emails" referred to in page 7 bottom para of the above linked document.
3. All exhibits to both memos in the above document.

Your initial response is required by Mar 11, 2020. Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce records.
Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not: provide mere URLs, print and scan electronic records, convert native files to PDFs, or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations:
- All withholding of any information must be justified in writing by specific statutory authority (SFAC 67.27).
- All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to the specific justification for that redaction, and only the minimal exempt portion of any record may be withheld (SFAC 67.26).
- You must respond to emailed requests (SFAC 67.21(b)).
- You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)).
- You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)).
- Do not impose any end-user restrictions upon me (Santa Clara Co. vs Superior Ct, 170 Cal.App 4th 1301); so if you use a third-party website to publish records, please make them completely public without any login or sign-in.

Your agency must do all of the above things in your response, and you cannot wait until we file complaints.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until the City's procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

Do not destroy or discard any responsive records - we will appeal all withholdings or Sunshine violations.

Thank you for your anticipated cooperation in this matter.

Sincerely,
Anonymous

Jesse Smith,

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Below are new Immediate Disclosure Requests (SF Admin Code 67.25(a)) directed to you individually and your agency.

1. The records described by Herrera in the following memo https://sfmayor.org/sites/default/files/03.10.20%20Memo.pdf as "initial set of records Hui voluntarily provided after [the Feb 18, 2020] interview."
2. "Hui's personal emails" referred to in page 7 bottom para of the above linked document.
3. All exhibits to both memos in the above document.

Your initial response is required by Mar 11, 2020. Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce records.
Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not: provide mere URLs, print and scan electronic records, convert native files to PDFs, or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations:
- All withholding of any information must be justified in writing by specific statutory authority (SFAC 67.27).
- All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to the specific justification for that redaction, and only the minimal exempt portion of any record may be withheld (SFAC 67.26).
- You must respond to emailed requests (SFAC 67.21(b)).
- You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)).
- You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)).
- Do not impose any end-user restrictions upon me (Santa Clara Co. vs Superior Ct, 170 Cal.App 4th 1301); so if you use a third-party website to publish records, please make them completely public without any login or sign-in.

Your agency must do all of the above things in your response, and you cannot wait until we file complaints.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until the City's procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

Do not destroy or discard any responsive records - we will appeal all withholdings or Sunshine violations.

Thank you for your anticipated cooperation in this matter.

Sincerely,
Anonymous

City Attorney's Office:

The following are immediate disclosure requests. Please provide rolling responses if you cannot provide all records immediately.

None of the following are employees of your agency, but your office might be in possession of these records nonetheless:

1. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and London Breed, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

2. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and Mohammed Nuru, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

3. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and Walter Wong/Jaidin Consulting Group, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

4. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and London Breed, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

5. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Mohammed Nuru, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

6. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Walter Wong/Jaidin Consulting Group, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

7. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Harlan Kelly Jr., on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

Your initial response is required by June 12, 2020. Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce records.
Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not: provide mere URLs, print and scan electronic records, convert native files to PDFs, or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations:
- All withholding of any information must be justified in writing by specific statutory authority (SFAC 67.27).
- All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to the specific justification for that redaction, and only the minimal exempt portion of any record may be withheld (SFAC 67.26).
- You must respond to emailed requests (SFAC 67.21(b)).
- You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)).
- You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)).
- Do not impose any end-user restrictions upon me (Santa Clara Co. vs Superior Ct, 170 Cal.App 4th 1301); so if you use a third-party website to publish records, please make them completely public without any login or sign-in.

Your agency must do all of the above things in your response, and you cannot wait until we file complaints.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until the City's procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

Do not destroy or discard any responsive records - we will appeal all withholdings or Sunshine violations.

Thank you for your anticipated cooperation in this matter.

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Sincerely,
Anonymous

Keslie Stewart:

The following are immediate disclosure requests. Please provide rolling responses if you cannot provide all records immediately.

None of the following are employees of your agency, but your office might be in possession of these records nonetheless:

1. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and London Breed, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

2. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and Mohammed Nuru, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

3. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and Walter Wong/Jaidin Consulting Group, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

4. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and London Breed, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

5. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Mohammed Nuru, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

6. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Walter Wong/Jaidin Consulting Group, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

7. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Harlan Kelly Jr., on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

Your initial response is required by June 12, 2020. Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce records.
Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not: provide mere URLs, print and scan electronic records, convert native files to PDFs, or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations:
- All withholding of any information must be justified in writing by specific statutory authority (SFAC 67.27).
- All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to the specific justification for that redaction, and only the minimal exempt portion of any record may be withheld (SFAC 67.26).
- You must respond to emailed requests (SFAC 67.21(b)).
- You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)).
- You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)).
- Do not impose any end-user restrictions upon me (Santa Clara Co. vs Superior Ct, 170 Cal.App 4th 1301); so if you use a third-party website to publish records, please make them completely public without any login or sign-in.

Your agency must do all of the above things in your response, and you cannot wait until we file complaints.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until the City's procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

Do not destroy or discard any responsive records - we will appeal all withholdings or Sunshine violations.

Thank you for your anticipated cooperation in this matter.

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Sincerely,
Anonymous

George Cothran,

The following are immediate disclosure requests. Please provide rolling responses if you cannot provide all records immediately.

None of the following are employees of your agency, but your office might be in possession of these records nonetheless. You must also indicate whether or not these records exist (independently of whether you are withholding them):

1. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and London Breed, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

2. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and Mohammed Nuru, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

3. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Harlan Kelly Jr. and Walter Wong/Jaidin Consulting Group, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

4. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and London Breed, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

5. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Mohammed Nuru, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

6. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Walter Wong/Jaidin Consulting Group, on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

7. All text, email, or chat messages (including group messages, in any form or application including but not limited to SMS, MMS, WhatsApp, WeChat, Signal, Instagram, Twitter, Facebook, Hangouts, Skype, Teams) sent or received to/cc/bcc/from between Naomi Kelly and Harlan Kelly Jr., on government or personal accounts from Jan 1, 2015 and present (you must search personal accounts pursuant to City of San Jose v Superior Court (2017))

Your initial response is required by June 12, 2020. Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce records.
Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not: provide mere URLs, print and scan electronic records, convert native files to PDFs, or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations:
- All withholding of any information must be justified in writing by specific statutory authority (SFAC 67.27).
- All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to the specific justification for that redaction, and only the minimal exempt portion of any record may be withheld (SFAC 67.26).
- You must respond to emailed requests (SFAC 67.21(b)).
- You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)).
- You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)).
- Do not impose any end-user restrictions upon me (Santa Clara Co. vs Superior Ct, 170 Cal.App 4th 1301); so if you use a third-party website to publish records, please make them completely public without any login or sign-in.

Your agency must do all of the above things in your response, and you cannot wait until we file complaints.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until the City's procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

Do not destroy or discard any responsive records - we will appeal all withholdings or Sunshine violations.

Thank you for your anticipated cooperation in this matter.

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Sincerely,
Anonymous

Thank you - which of #1-7 have records, and which are you withholding on work-product privilege?

City Attorney's office:

You haven't indicated which records you have withheld in your June 22, 2020 email, and complaints will be filed.

The following are NEW immediate disclosure requests. Please provide rolling responses if you cannot provide all records immediately.

None of the following are employees of your agency, but your office might be in possession of these records nonetheless. You must also indicate whether or not these records exist (independently of whether you are withholding them):

8. The Mayor's Office turned over to us the following public records of 2018-2020 communications between the Mayor's staff (using their personal email accounts) and Walter Wong/Jaidin Consulting Group regarding sponsorship of the Mayor's parade floats: https://www.documentcloud.org/documents/6938175-Anonymous-Request-Response-6-5-20-Redacted.html - this request is for any copies in your Office's possession of those same email threads (for example, perhaps with less redaction, or more messages in those same threads).

Your initial response is required by July 2, 2020. Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce records.
Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not: provide mere URLs, print and scan electronic records, convert native files to PDFs, or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations:
- All withholding of any information must be justified in writing by specific statutory authority (SFAC 67.27).
- All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to the specific justification for that redaction, and only the minimal exempt portion of any record may be withheld (SFAC 67.26).
- You must respond to emailed requests (SFAC 67.21(b)).
- You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)).
- You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)).
- Do not impose any end-user restrictions upon me (Santa Clara Co. vs Superior Ct, 170 Cal.App 4th 1301); so if you use a third-party website to publish records, please make them completely public without any login or sign-in.

Your agency must do all of the above things in your response, and you cannot wait until we file complaints.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until the City's procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

Do not destroy or discard any responsive records - we will appeal all withholdings or Sunshine violations.

Thank you for your anticipated cooperation in this matter.

NOTE: THE EMAIL ADDRESS SENDING THIS REQUEST IS A PUBLICLY-VIEWABLE MAILBOX. Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Sincerely,
Anonymous

City Attorney's Office:

On July 13, 2020, the SF Examiner published a document appearing to be a subpoena of the SFPUC issued by the US Attorney on June 15, 2020, and received by the City Attorney's office on June 25: https://www.documentcloud.org/documents/6988152-Grand-Jury-Subpoena-of-the-SFPUC.html - previously reported on July 10 by the SF Chronicle: https://www.sfchronicle.com/bayarea/article/U-S-attorney-hits-SFPUC-with-subpoena-as-SF-City-15400910.php

This is a new immediate disclosure request for:
(a) all records and replies and responses of any form provided by the City in response to the above-linked subpoena, and
(b) all copies of the subpoena, including with any notes or markings.

Please provide exact copies and rolling responses. Please do not destroy any responsive records - all withholdings or redactions will be appealed.

Please do not forget that my original June 11 and subsequent July 7, 2020-dated requests remain outstanding.

NOTE: Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. The email address sending this request is a PUBLICLY-VIEWABLE MAILBOX. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Thanks!
Anonymous

City Attorney's Office:

This is also a new immediate disclosure request for:

(c) all copies of the file "Walter redacted final.pdf" (which was previously provided by SFPUC to us, and then requested to be retracted) containing unredacted texts between Harlan Kelly and Walter Wong. If you redact that file, you must make your own agency's determination of which text messages in "Walter redacted final.pdf" are legally exempt or not, which may result in less redaction than SFPUC made in their subsequent version "Walter redacted final_1.pdf" (see also attached SOTF complaint against SFPUC for context).

(d) all copies of the text messages between Harlan Kelly Jr. and Walter Wong and Harlan Kelly Jr. and London Breed -- see exhibits A and B of records previously provided by SFPUC to us (which you must also provide if in your possession, with your own redaction judgments).

Please provide exact copies and rolling responses. Please do not destroy any responsive records - all withholdings or redactions or failure to comply with all provisions of the Sunshine Ordinance or CPRA will be appealed.

NOTE: Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. The email address sending this request is a PUBLICLY-VIEWABLE MAILBOX. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Thanks!
Anonymous

City Attorney's Office:

This is also a new immediate disclosure request for:

(e) copies of all subpoenas requested by a federal agent, issued by a federal court, to the City or a City officer/agency between Jan 1, 2020 and present. If you have provided copies to anyone else, please provide copies with NO MORE REDACTIONS than provided to others - we will cross-check your replies.
(f) copies of any records prepared OR provided in response to any such subpoena
(g) any affidavits, declarations, or testimony transcripts given by the City or City officer/agency in response to any such subpoena

Please provide exact copies and rolling responses. Please do not destroy any responsive records - all withholdings or redactions or failure to comply with all provisions of the Sunshine Ordinance or CPRA will be appealed.

NOTE: Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. The email address sending this request is a PUBLICLY-VIEWABLE MAILBOX. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

Thanks!
Anonymous

Dennis Herrera and Office of City Attorney:

**PLEASE BE SURE YOU PRESERVE ALL RESPONSIVE RECORDS IMMEDIATELY. You may not destroy records during the pendency of this request and all of its appeals - we will appeal any withholding/redaction of any information.**

Below are Immediate Disclosure Requests (SF Admin Code 67.25(a)). Rolling records responses are requested (SFAC 67.25(d)) if you are unable to immediately produce all records. Exact copies of every responsive record are requested (Gov Code 6253(b)) - do not or print and scan electronic records or provide black and white versions of any color record. Provide only copies of records not requiring fees and in-person inspection of all other records (GC 6253).

Your non-exhaustive obligations: All withholding of any information must be justified (SFAC 67.27). All withholdings by masking or deletion (aka redactions) must be keyed by footnote or other clear reference to justification and only the minimal exempt portion of a record may be withheld (SFAC 67.26). Respond to emailed requests (SFAC 67.21(b)). You must notify us of whether or not responsive records exist and/or were withheld for each below request (Gov Code 6253(c), 6255(b)). You must state the name and title of each person responsible for withholding any information (Gov Code 6253(d)). You must do all of this in your response, and you cannot wait until we file complaints. If you wait to comply with the Sunshine Ordinance until after we file complaints, we will not withdraw any complaints and request SOTF find you in violation, regardless of what you do after filing.

****** We have no duty to, and we will not again, remind the City of its obligations. Instead, we will file complaints for every Sunshine Ordinance or CPRA violation. We will continue to file complaints until your procedures are modified to fully comply with the Sunshine Ordinance and CPRA, without caveat or exception. ******

Provide rolling responses - every record must be provided no later than the end of the business day that it is reviewed - see SFAC 67.25(d).

1. The original email "Corruption at DHR..." sent by Micki Callahan as received by any City Attorney office employees, with all metadata and headers and attachments.
2. All responses to that email and all forwards and other messages in that thread by any City Attorney office employees, with all metadata and email headers and attachments.
3. Copies of Rebecca Sherman's alleged written admission "that she had forged documents and lied to a city employee about that employee’s EEO case"
4. Copies of Sherman's allegedly deleted records from reports printed from the EEO Division’s database (if those deleted records are backed up on a server or a deleted items or trash folder, you must recover them and provide them, per your own opinion).
5. Sherman's allegedly forged and unauthorized settlement agreement with allegedly forged department head’s and two Deputy City Attorneys’ names on the document.
6. All contents of Sherman's Deleted Items, Recycle Bin, or similar folders in both her sfgov Outlook (for email) and her computer drives (for files) (if your office has possession of any of them)
7. City Attorney’s Office notice to the employee who received the forged agreement that it will stipulate to the employee withdrawing the dismissal
8. The stipulation mentioned in #7 if it was actually filed
9. Every physically mailed letter, email, text, or chat message sent or received by City Attorney's office employee or Dennis Herrera between Jan 1 2020 and present (inclusive) containing the case insensitive phrase "Rebecca Sherman". Note that those documents already sent for example to the concerned employee or their attorneys or to the tribunal handling their case cannot be privileged.

Please indicate "no responsive records" for each request if that is true.

NOTE: Please be certain you have properly redacted all of your responses. Once you send them to us, there is no going back. The email address sending this request is a publicly- viewable mailbox. All of your responses (including all responsive records) may be instantly and automatically available to the public online via the MuckRock.com FOIA service used to issue this request (though the requester is an anonymous user, not a representative of MuckRock). Nothing herein is legal, IT, or professional advice of any kind. The author disclaims all warranties, express or implied, including but not limited to all warranties of merchantability or fitness. In no event shall the author be liable for any special, direct, indirect, consequential, or any other damages whatsoever. The digital signature, if any, in this email is not an indication of a binding agreement or offer; it merely authenticates the sender. Please do not include any confidential information, as I intend that these communications with the City all be disclosable public records.

--Anonymous

Ms. Buta,

Thank you. However I requested rolling responses - you don't need to complete the review of all records to give me some records. You need to give me any records so far collected and reviewed, by the end of the business day they were collected and reviewed - SFAC 67.25(d).

--Anonymous

Thank you for the records. I want to confirm your answer #4. Are you stating that Herrera's office has no responsive records for #4? I understand I can go to DHR, but if your office has any copies of that in its possession, you must tell me, and either give them or justify not giving them.

Thanks,
Anonymous

You received a records request "All City comms with Mr. Kelly's yahoo accounts - immediate disclosure request" on Feb 24, 2021.
Please direct all of your responses to this email address.

Your responses will be available to the public on MuckRock.com

Thank you,
Anonymous

You also received a records request which you have retitled to "PRA Received 2-25-21 re: personal email account".
Please direct all of your further responses to this email address.

Your responses will be available to the public on MuckRock.com

Thank you,
Anonymous

Please provide all communications between your office and Stephanie Hinds since Jan 1 2020, whether email, text, chat or any other form, on personal or government accounts, including exact electronic copies of all records with all attachments, To/Cc/From/Bcc email addresses, hyperlink urls, images, audio, video, date/time stamps, and participant identities. Note that you are not merely required to provide communications about the City's business but about the conduct of *public* business, so your employees discussing federal matters on your employees' personal devices is still a public record.

Immediate disclosure request for All communications between your office and Recology, its Sunset Scavenger and Golden Gate affiliates, its and their affiliates, and its and their attorneys in the settlement and lawsuit discussed here: https://www.youtube.com/watch?v=Y1KE3ypMEzo today by Herrera. Provide all emails as exact PDF copies with attachments, To/From/Cc/Bcc, images, formatting, using PDFMaker.

Immediate disclosure request:
1. All communications between John Cote or Meiling Bedard and members of the press by text, chat, or instant message from Feb 1, 2021 to present on government and personal accounts. Don't forget attachments inside the texts.
2. All emails from John Cote or Meiling Bedard to members of the press from Feb 1, 2021 on government and personal accounts as exact PDF copies with attachments, images, formatting, To, From, Cc, bcc email addresses.

And no, reporters that CAO speaks to, or strategically leaks to, are not protected by PRA exemptions =)

Re Hinds request: Thanks - please also provide records of communications illustrating your search and any responses from your staff. You have previously for example produced records of DCA Givner informing other staff of the request. I'd like to know whether anyone actually searched their personal property...

To Brad Russi and the Office of the City Attorney:

1. Please produce the email from Brad Russi pictured here: https://twitter.com/dizz_h/status/1383483428851519493/photo/1 / https://archive.ph/zTPzN - From the formatting of that record, I believe it was produced by DPW using NextRequest. Since your client, DPW, has disclosed it, you should be able to.

2. Please produce every reply to/forward of that email, and every email that that email is a reply to or forward of (i.e. all threads containing that email).

Either exact PDF copy via PDFMaker/Acrobat Pro, or via NextRequest's built-in email production system usually used by DPW, is acceptable. Attachments, email addresses, formatting, images must be preserved.

As far as I can tell this is not from one of my own requests... HDizz however often does a better job than me in finding great nuggets in my requests, so if it is from mine, you can just point me to the existing request.

For some reason the screenshot is super blurry, so I've transcribed the record below to help you find it:

=======

From: "Russi, Brad (CAT)" To: "Degrafinried, Alaric (DPW)" , "Sawyer, Amy (MYR)" Sent: Thu, 29 Oct
2020 02:24:40 +0000 Subject: Bag and tag policy, cont... Co: "Goldman, Jeremy (CAT)"

Alaric and Amy ??"

BALA is now pressing for another meeting to discuss their proposed changes to the bag and tag policy
(and other issues unrelated to DPW, see below). Per our discussion several months ago, I went through
their suggested edits and made revisions. I did not modify the edits that I had suggested and sent to BALA
months ago after DPW approved such changes. I understand that Public Work raised questions with
regard to some of those previous edits in our call, but we would need a compelling reason to renege on
agreements already made and communicated to BALA. Please take a look at the attached and let me
know if you would like to discuss further or have edits or concerns.

A couple of things to note:

1. The lawsuit against Los Angeles in which the court found the bulky item exception to be unlawful
has been appealed. We have not agreed to changes to the bulky item exception in the policy, and we
told them we are monitoring the appeal of the Los Angeles case. But you should prepare for the
possibility that the Court of Appeal will uphold the district court??s decision and we will need [sic]
make a change. It??s also possible that BALA could bring a legal challenge to our policy before
the appeal is resolved.
2. My understanding is that Public Works does not want the policy to require notice before bagging
and tagging in response to 311 complaints. This is legally risky as we have previously advised and
could form the basis for a successful challenge to the policy
3. They have continually asked about a reasonable accommodation policy and training. Has your ADA
coordinator been consulted and is there any update?

I would prefer to reach agreement internally on the proposed changes and send to BALA but not agree to
any further meetings on this subject. Jeremy, feel free to chime in if you have other thoughts on how to
proceed or if I??ve missed anything.

Hope you are both well. Thanks!

Bradley Russi
Deputy City Attorney
Office of City Attorney Dennis Herrera
(415) 554-4645 Direct

========

Sincerely,
An anonymous journalist

To Jeremy Goldman and the Office of the City Attorney:

1. Please produce the email from Brad Russi pictured here: https://twitter.com/dizz_h/status/1383483428851519493/photo/1 / https://archive.ph/zTPzN - From the formatting of that record, I believe it was produced by DPW using NextRequest. Since your client, DPW, has disclosed it, you should be able to.

2. Please produce every reply to/forward of that email, and every email that that email is a reply to or forward of (i.e. all threads containing that email).

Either exact PDF copy via PDFMaker/Acrobat Pro, or via NextRequest's built-in email production system usually used by DPW, is acceptable. Attachments, email addresses, formatting, images must be preserved.

As far as I can tell this is not from one of my own requests... HDizz however often does a better job than me in finding great nuggets in my requests, so if it is from mine, you can just point me to the existing request.

For some reason the screenshot is super blurry, so I've transcribed the record below to help you find it:

=======

From: "Russi, Brad (CAT)" To: "Degrafinried, Alaric (DPW)" , "Sawyer, Amy (MYR)" Sent: Thu, 29 Oct
2020 02:24:40 +0000 Subject: Bag and tag policy, cont... Co: "Goldman, Jeremy (CAT)"

Alaric and Amy ??"

BALA is now pressing for another meeting to discuss their proposed changes to the bag and tag policy
(and other issues unrelated to DPW, see below). Per our discussion several months ago, I went through
their suggested edits and made revisions. I did not modify the edits that I had suggested and sent to BALA
months ago after DPW approved such changes. I understand that Public Work raised questions with
regard to some of those previous edits in our call, but we would need a compelling reason to renege on
agreements already made and communicated to BALA. Please take a look at the attached and let me
know if you would like to discuss further or have edits or concerns.

A couple of things to note:

1. The lawsuit against Los Angeles in which the court found the bulky item exception to be unlawful
has been appealed. We have not agreed to changes to the bulky item exception in the policy, and we
told them we are monitoring the appeal of the Los Angeles case. But you should prepare for the
possibility that the Court of Appeal will uphold the district court??s decision and we will need [sic]
make a change. It??s also possible that BALA could bring a legal challenge to our policy before
the appeal is resolved.
2. My understanding is that Public Works does not want the policy to require notice before bagging
and tagging in response to 311 complaints. This is legally risky as we have previously advised and
could form the basis for a successful challenge to the policy
3. They have continually asked about a reasonable accommodation policy and training. Has your ADA
coordinator been consulted and is there any update?

I would prefer to reach agreement internally on the proposed changes and send to BALA but not agree to
any further meetings on this subject. Jeremy, feel free to chime in if you have other thoughts on how to
proceed or if I??ve missed anything.

Hope you are both well. Thanks!

Bradley Russi
Deputy City Attorney
Office of City Attorney Dennis Herrera
(415) 554-4645 Direct

========

Sincerely,
An anonymous journalist

This is a request for all calendar/meeting entries, physical or electronic, evidencing meetings between Dennis Herrera and either London Breed or any PUC Commissioner from Jan 1 2021 to present. You must search Prop G and Non prop G calendars; government and personal accounts; Herrera's and other staff's (such as Feitelberg's) records. Provide exact copies of each such record, including but not limited to all ICS/iCalendar metadata showing who invited whom, when they were invited, who accepted, and all other details.

Please provide:
(a) the entirety of the July 18, 2012 Hoeper "Draft Report of Investigation." (described in Hoeper v. City of San Francisco, A151824, 12 (Cal. Ct. App. Feb. 13, 2020))

Please provide, as a separate request:
(b) exact copies of the communications between your office and the SF Chronicle and the Westside Observer, with all enclosures and attachments, described here: "The City later provided copies of its response to the San Francisco Chronicle and the Westside Observer. On September 5, 2014, the City Attorney's press secretary emailed a Westside Observer reporter and enclosed a copy of the response. "I read with interest your column on former Deputy City Attorney Joanne Hoeper's claim against city taxpayers for monetary damages, and thought you might be interested in the City's formal response to a related claim she filed with the California Division of Labor Standards and Enforcement. It is attached for your perusal, and it was covered in today's Chronicle."" (Hoeper v. City of San Francisco, A151824, 17 (Cal. Ct. App. Feb. 13, 2020))

1. This is a new request: provide exact PDF copies of all emails or chats (with all embedded attachments) between your office and Heather Knight or Jill Tucker before Feb 1, 2021 of any discussion about the (then-not-yet-filed) SFUSD lawsuit AND all convos with either of them from Jan 1 2021 to Feb 1 2021. This latter clause is to avoid any argument that is made that you cannot identify each no-context messages are indeed about the SFUSD suit.

2. What follows is NOT a new request, and was required to be disclosed in https://cdn.muckrock.com/foia_files/2021/05/25/Responsive_Records_Redacted.pdf

You have provided a copy of a document starting on p. 496 above labeled a "CONFIDENTIAL DRAFT." Please provide - without any alterations whatsoever - including the name of the file - the original document as you shared it with the media of that document. I am asking for an exact copy of the file (i.e. the version produced to the media), in the format you previously shared it, with all the metadata - since you previously shared it, none of that metadata can be withheld from me. Note that the name of a file is a "writing" and by combining all these records into one PDF - again for reasons that are unclear, you are withholding the distinct names of each of these records. It's also unclear to me who received that confidential draft and which email it is an attachment to. Again for reasons that are unclear, in this PDF you have stripped embedded attachments - you don't normally do that. I can guess that it is "SFUSD Petition 02.02 HK.pdf" but it is unclear as it is in different order. And I don't have to guess.

Please provide an exact PDF copy of all communications with persons who are not City employees that attached or included that CONFIDENTIAL DRAFT - I want to know who got it and when.

Also, for reasons that I cannot understand you appear to have again stripped all of the hyperlinks. As I have now argued many times (and won), this unlawfully withholds the URLs - for example the many in your press releases that I cannot click on and thus cannot know what you are referring to. URLs are information. You cannot withhold any public information without a justification.

And finally, we will be challenging the EC 1040 invocation - as always you must specify which of the two exemptions you used, and neither of them allow you to hide info being traded in a "favor" between John Cote and a reporter...

None of the above in #2 is a new request - it is all information that should have been provided.

As mentioned in the other calendar request, you have withheld the description in https://cdn.muckrock.com/foia_files/2021/05/26/Responsive_Records_redacted.pdf as an info sec record. It isn't. If you provide the normal PDF this doesn't really matter but you haven't provided those here.

Please provide the Prop G calendar entries showing ALL meetings - telephonic, virtual, or in person or any other form - wherein Herrera and Breed discussed Breed's nomination of Herrera for PUC GM. Herrera cannot have secret meetings of any kind with Breed due to Prop G. And this issue is NOT a legal issue nor is it attorney-client privileged. This issue and its meeting(s) thus must have been recorded and must be disclosed.

Secret meetings to protect the deliberation of a government decision do not exist in San Francisco.

--Anonymous

Supervisor of Records Herrera,

This is a petition under Admin Code 67.21(d) to determine the attached redactions public and order them disclosed.

Your office redacted this information under the Official Information Privilege.
Your office has not proven that any of this convo is prohibited from disclosure by state or federal law (EC 1040(b)(1)).
Your office also has not shown that the public interest in non-disclosure clearly outweighs the public interest in disclosure in the interests of justice (EC 1040(b)(2)).

Remember: neither Cote's, nor Herrera's, nor Tucker/Chronicle's private interests are what is measured.

And merely the apparent promise by Cote to Tucker to "not share with anyone" is not sufficient to make public records exempt. Confidential acquisition is only ONE of the requirements needed to be privileged. Also, what is redacted is BOTH Cote's message to Tucker, and Tucker's message to Cote.

How exactly is the *public* and the interests of justice harmed by this disclosure?

--Anonymous

As a reminder for the below petition, the private economic interests of the SF Chronicle are not relevant to an Official Information Privilege assertion...
Keep that in mind when you respond to this petition.

Supervisor of Records Herrera,

This is a petition under Admin Code 67.21(d) to determine the attached redactions public and order them disclosed.

Your office redacted this information under the Official Information Privilege.
Your office has not proven that any of this convo is prohibited from disclosure by state or federal law (EC 1040(b)(1)).
Your office also has not shown that the public interest in non-disclosure clearly outweighs the public interest in disclosure in the interests of justice (EC 1040(b)(2)).

Remember: neither Cote's, nor Herrera's, nor Tucker/Chronicle's private interests are what is measured.

And merely the apparent promise by Cote to Tucker to "not share with anyone" is not sufficient to make public records exempt. Confidential acquisition is only ONE of the requirements needed to be privileged. Also, what is redacted is BOTH Cote's message to Tucker, and Tucker's message to Cote.

How exactly is the *public* and the interests of justice harmed by this disclosure?

--Anonymous

City Attorney Herrera: Please produce exact copies of all direct messages between you or your office (or its employees) and https://twitter.com/sf_dtd on government or personal accounts. Include originals of all images or attachments without altering any of the metadata in those files provided to SF_DTD or received from them.

Please provide any communications about or of https://oag.ca.gov/system/files/attachments/press-docs/Comments%20of%20States%20and%20cities%20in%20support%20of%20repeal.pdf (or of any earlier or draft versions thereof) where any party is not an SF city employee prior to June 11, 2021.

City Attorney's Office: Please produce all letters or documents or records (including exhibits/attachments) transmitted by AECOM/Parsons to PUC or your office on June 16, 2021. "AECOM/Parsons" is defined as AECOM, Parsons, its or their joint venture(s)/joint venture board(s) contracting with PUC, and its or their attorneys or other representatives.

Please also separately produce communications between your office and AECOM/Parsons negotiating the release of the above-discussed records.

To be clear the following request requires rolling production. The letter in the first part should be quite easy to produce.

"City Attorney's Office: Please produce all letters or documents or records (including exhibits/attachments) transmitted by AECOM/Parsons to PUC or your office on June 16, 2021. "AECOM/Parsons" is defined as AECOM, Parsons, its or their joint venture(s)/joint venture board(s) contracting with PUC, and its or their attorneys or other representatives.

Please also separately produce communications between your office and AECOM/Parsons negotiating the release of the above-discussed records."

We will appeal this response in full.

Please produce the so-called common interest agreement you referenced.