San Francisco Litigation Negotiation Communications - Immediate Disclosure Requests
It is a clone of this request.
| Submitted | Feb. 27, 2021 |
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Communications
From: twitter.com/journo_anon Public Records Requester
The below are immediate disclosure requests to your agency:
Please provide EACH record SEPARATELY as an exact PDF copy using PDFMaker , preserving all To/From/Cc/Bcc email, addresses, attachments, images, hyperlink URLs, formatting.
Please DO NOT combine different emails into one PDF file - it is a lot harder to send to SOTF when each file is huge, and by sending records individually there is no problem using email attachments instead of FTP.
For emails sent BY your agency you must provide records with BCCs, if any, which can only be produced using the employee's sent folders.
Because the PDFMaker individual PDF file is available or easily generated, you must provide it (SFAC 67.21(L)).
Please provide in a rolling fashion all records below (you must provide each record within one day of reviewing that record - SFAC 67.25(d)).
Ensure all records are minimally withheld with each redaction KEYED to a written justification. I will not guess which redaction is which. The other agencies have figured out how to do this, you should too. Ensure all records withheld are justified in writing.
1. All communications of every form between your Office and opposing counsel or parties (in either direction) in: PEOPLE OF THE STATE OF CALIFORNIA, v. UBER TECHNOLOGIES, INC. et al., A160701, A160706 (City & County of San Francisco Super. Ct. No. CGC-20-584402) and all appeals thereof.
From: twitter.com/journo_anon Public Records Requester
The below are distinct immediate disclosure requests to your agency:
Please provide EACH record SEPARATELY as an exact PDF copy using PDFMaker , preserving all To/From/Cc/Bcc email, addresses, attachments, images, hyperlink URLs, formatting.
Please DO NOT combine different emails into one PDF file - it is a lot harder to send to SOTF when each file is huge, and by sending records individually there is no problem using email attachments instead of FTP.
For emails sent BY your agency you must provide records with BCCs, if any, which can only be produced using the employee's sent folders.
Because the PDFMaker individual PDF file is available or easily generated, you must provide it (SFAC 67.21(L)).
Please provide in a rolling fashion all records below (you must provide each record within one day of reviewing that record - SFAC 67.25(d)).
Ensure all records are minimally withheld with each redaction KEYED to a written justification. I will not guess which redaction is which. The other agencies have figured out how to do this, you should too. Ensure all records withheld are justified in writing.
2. All communications of every form between your Office and opposing counsel or parties (in either direction) in: San Francisco Superior Court, Case No. CGC-19-575669; Anthony Economus v. Flint Paul
From: twitter.com/journo_anon Public Records Requester
The below are distinct immediate disclosure requests to your agency:
Please provide EACH record SEPARATELY as an exact PDF copy using PDFMaker , preserving all To/From/Cc/Bcc email, addresses, attachments, images, hyperlink URLs, formatting.
Please DO NOT combine different emails into one PDF file - it is a lot harder to send to SOTF when each file is huge, and by sending records individually there is no problem using email attachments instead of FTP.
For emails sent BY your agency you must provide records with BCCs, if any, which can only be produced using the employee's sent folders.
Because the PDFMaker individual PDF file is available or easily generated, you must provide it (SFAC 67.21(L)).
Please provide in a rolling fashion all records below (you must provide each record within one day of reviewing that record - SFAC 67.25(d)).
Ensure all records are minimally withheld with each redaction KEYED to a written justification. I will not guess which redaction is which. The other agencies have figured out how to do this, you should too. Ensure all records withheld are justified in writing.
3. All communications of every form between your Office and opposing counsel or parties (in either direction) in: HASTINGS COLLEGE OF THE
LAW, et al. vs CITY AND COUNTY OF SAN FRANCISCO, 4:20-cv-03033-JST.
From: twitter.com/journo_anon Public Records Requester
NOTE: All prior requests from this email address are amended to INCLUDE all communications with the opponent prior to filing of the suit with regards to any pre-litigation settlement or claim discussion, and any post-adjudication/dismissal discussion (such as discussion of whether or not both parties are continuing to comply with terms of settlement/ruling).
The below are distinct immediate disclosure requests to your agency:
Please provide EACH record SEPARATELY as an exact PDF copy using PDFMaker , preserving all To/From/Cc/Bcc email, addresses, attachments, images, hyperlink URLs, formatting.
Please DO NOT combine different emails into one PDF file - it is a lot harder to send to SOTF when each file is huge, and by sending records individually there is no problem using email attachments instead of FTP.
For emails sent BY your agency you must provide records with BCCs, if any, which can only be produced using the employee's sent folders.
Because the PDFMaker individual PDF file is available or easily generated, you must provide it (SFAC 67.21(L)).
Please provide in a rolling fashion all records below (you must provide each record within one day of reviewing that record - SFAC 67.25(d)).
Ensure all records are minimally withheld with each redaction KEYED to a written justification. I will not guess which redaction is which. The other agencies have figured out how to do this, you should too. Ensure all records withheld are justified in writing.
4. All communications of every form between your Office and opposing counsel or parties (in either direction) in: CHOI NGOR LI VS. CITY AND COUNTY OF SAN FRANCISCO ET AL, CGC19576285. This includes all communications with opposing counsel or parties (in either direction) prior to filing of the suit with regards to any pre-litigation settlement or claim discussion, and any post-adjudication/dismissal discussion (such as discussion of whether or not both parties are continuing to comply with terms of settlement/ruling).
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: San Francisco City Attorney
Dear requester,
I am responding on behalf of the City Attorney's Office to your below request. We are working on your request, and currently estimate being able to respond within two weeks.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney Dennis Herrera
(415) 554-4685 Direct
www.sfcityattorney.org
From: San Francisco City Attorney
Dear requester,
I am responding on behalf of the City Attorney's Office to your below request. We are working on your request, and currently estimate being able to respond within two weeks.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney Dennis Herrera
(415) 554-4685 Direct
www.sfcityattorney.org
From: San Francisco City Attorney
Dear requester,
I am responding on behalf of the City Attorney's Office to your below request. We are working on your request, and currently estimate being able to respond within two weeks.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney Dennis Herrera
(415) 554-4685 Direct
www.sfcityattorney.org
From: San Francisco City Attorney
Dear requester,
I am responding on behalf of the City Attorney's Office to your below request. We are working on your request, and currently estimate being able to respond within two weeks.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney Dennis Herrera
(415) 554-4685 Direct
www.sfcityattorney.org
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: Muckrock Staff
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on Feb. 27, 2021. Please let me know when I can expect to receive a response.
Thanks for your help, and let me know if further clarification is needed.
From: San Francisco City Attorney
Dear requester,
I am responding on behalf of the City Attorney's Office to your below request. Attached please find the records responsive to your request. Please note we have redacted information based on security concerns on the top of page 83 pursuant to Cal. Gov't Code 6254.19. In the alternative, Cal. Evid. Code section 1040 would also apply to this redaction. The remaining redactions were made under Cal. Evid. Code section 1040. In addition, please note we are withholding some responsive records that are exempt from disclosure under Cal. Evid. Code section 1040 and under Cal. Evid. Code section 1119.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
From: San Francisco City Attorney
Dear Anonymous,
I am responding on behalf of the City Attorney's Office to your below request. Attached please find part one of the responsive records. We will send the remaining parts momentarily.
Please note we have redacted personal contact information due to privacy reasons. See Cal Const., Article I, section 1; Cal. Government Code Section 6254(c), (k); Admin. Code Section 67.1(g). We have also redacted information due to security concerns based on Cal. Evid. Code Section 1040. We have also redacted confidential trade secret information under Cal Evid. Code Section 1060. The redaction basis for each is noted in overlay text on each redaction.
In addition, please note we are withholding some responsive records that are exempt from disclosure under Cal. Evid. Code Section 1040 and under Cal. Evid. Code Section 1119.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image001
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 2.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image002
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 3.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image001
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 4.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image002
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 5.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image001
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 6.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image002
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 7.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image001
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 8.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image002
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 9.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image001
From: San Francisco City Attorney
Dear Anonymous,
Attached is part 10 of 10. This completes our document production.
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image002
From: San Francisco City Attorney
ÂÂ
This is an official message sent by the City & County of San Francisco to requests@muckrock.com.
Sender's message / comments:
Instructions: Elizabeth.Coolbrith@sfcityatty.org invited you to a shared folder called Hastings PRA Response 6-30-22 on our SFSecureShare.sfgov.org site.
View folder
For any help or assistance for this service, please contact the City HelpDesk at (628)652-5000 or dtis.helpdesk@sfgov.org
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From: San Francisco City Attorney
Dear Anonymous,
I am responding on behalf of the City Attorney's Office to your below request. We are transmitting the responsive records to you via FTP which is standard practice for files of this size. The responsive records are over 20MB, which would require them to be broken up into approximately 10 parts in order to email to you, given the size restrictions on your email account. If you would prefer to receive them in a series of emails, please let us know, and we will do so.
Please note we are withholding some responsive records that are exempt from disclosure under Cal. Evid. Code Section 1040 and under Cal. Evid. Code Section 1119.
You will be receiving an email from CCSF SFTP NO-Reply (no-reply@sfgov.org<mailto:no-reply@sfgov.org>) with a link to the responsive records. For best results, use Microsoft Edge internet browser. Please check your junk mail folder if you do not see the email in your inbox. Below are download instructions.
If you do not have an CCSF account then please register a new account as Guest Login. Your access will expire in 30 days.
Guest Folder Files Download
1. Open the CCSF SFTP No-Reply email, click on View folder button
2. SFSecureShare will prompt to Register a new account or Guest Login if you have an existing account
3. After logging in, check box next to the folder files
4. Select Download button to download the files
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
From: twitter.com/journo_anon Public Records Requester
Which exemptions are you using under evid code 1119, there are three distinct exemptions, each of which relate solely to "mediation or a mediation consultation"
From: San Francisco City Attorney
This message is being sent to you by the City Cybersecurity Team.
SFSecureShare Notification:
Hastings PRA Response 6-30-22 (Elizabeth.Coolbrith@sfcityatty.org): CCSF-PRA_0000608.xlsx was downloaded by requests@muckrock.com from 23.227.140.189 on 7/1/2022 at 12:46:50 AM.
For help or assistance for this service, please contact the City HelpDesk at (628)652-5000 or dtis.helpdesk@sfgov.org
This message is being sent to you by the City Cybersecurity Team.
SFSecureShare Notification:
Hastings PRA Response 6-30-22 (Elizabeth.Coolbrith@sfcityatty.org): CCSF-PRA_0000609.xlsx was downloaded by requests@muckrock.com from 23.227.140.189 on 7/1/2022 at 12:46:56 AM.
For help or assistance for this service, please contact the City HelpDesk at (628)652-5000 or dtis.helpdesk@sfgov.org
This message is being sent to you by the City Cybersecurity Team.
SFSecureShare Notification:
Hastings PRA Response 6-30-22 (Elizabeth.Coolbrith@sfcityatty.org): Responsive Records.pdf was downloaded by requests@muckrock.com from 23.227.140.189 on 7/1/2022 at 12:48:04 AM.
For help or assistance for this service, please contact the City HelpDesk at (628)652-5000 or dtis.helpdesk@sfgov.org
From: San Francisco City Attorney
Dear Anonymous,
Thank you for your email. We are withholding records in reliance on Cal. Evid. Code Sec. 1119 subsections (a), (b) and (c).
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
From: San Francisco City Attorney
Dear Anonymous,
I am responding on behalf of the City Attorney's Office to your below records requests. After a reasonable and diligent search, our office determined we have no disclosable records in our custody.
We are withholding records responsive to this request under California Evidence Code Section 1040 and also under California Government Code Section 6254(b) because the City is currently involved in litigation regarding People of the State of California v. Uber Technologies and the matter has not yet been finally adjudicated or otherwise settled. Cal. Govt Code § 6254(b).
Please send replies to cityattorney@sfcityatty.org<mailto:cityattorney@sfcityatty.org>
Best,
[image010]Elizabeth A. Coolbrith
Paralegal
Office of City Attorney David Chiu
(415) 554-4685 Direct
www.sfcityattorney.org
-
image001
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