|Submitted||May 13, 2021|
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Please provide exact electronic copies of the following, pursuant to the CPRA and on personal property City of San Jose v Superior Court (2017):
1) The current list of Blocked Accounts for all twitter accounts of each board member (for example, City Attorney Herrera responded to this request with the following public records which is what I am expecting: https://www.documentcloud.org/documents/6667876-Responsive-Request-1 and https://www.documentcloud.org/documents/6667878-Responsive-Request-2 ). Do not modify the blocked lists before you provide a copy as of the time you receive this request.
2) From Oct 1, 2020 to present: Texts, email, chats, or other communications of any form (including but not limited to Signal, Telegram, Twitter, Facebook, Instagram, WhatsApp, WeChat) SENT by any board member TO any 1 or more other board members (including group messages received by at least 1 board member and other non-board members), outside of a noticed public meeting. We are verifying your compliance with the serial meeting prohibitions in the Brown Act.
Provide rolling/incremental responses.
Preserve all parts of each record (attachments, date and timestamps, identities of all participants in any conversation, email addresses, hyperlinks, To/From/Cc/Bcc, email headers).
Justify in writing any withholding of records, and each redaction you make.
Thank you for your expected cooperation.
If you do not comply, suit will be filed for writ of mandate.
Unlawful withholdings will be appealed.
See my track record of public record appeals: https://sunshine-advocacy.gitlab.io/san-francisco-ca-us/
To Whom It May Concern:
I wanted to follow up on the following California Public Records Act request, copied below, and originally submitted on May 13, 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.
Please see the attached response to your California Public Records Act
Sr. Deputy General Counsel & Equity Specialist
Legal Department & Office of Equity
San Francisco Unified School District
In light of the COVID-19 outbreak, all attorneys and staff in the Legal
Division are working remotely. There is also limited access to the
District Office. Therefore, we are not able to receive mail in a timely
manner. Please send all correspondence, pleadings, discovery or other
documents via email or voluminous materials through a document sharing
app. Thank you for your understanding and professional courtesy.
1. We intend to litigate your complete refusal to produce records. You are incorrect about unlawful threads-as-meetings requiring a quorum - multiple threads each consisting of less than a quorum which are used to convey the positions of at least a quorum also constitute unlawful seriatim meetings. Your legal counsel knows or should know this. SFUSD cannot hide its communications to avoid public responsibility. You are reminded that the Board must preserve and cannot destroy responsive records until after the final adjudication of our appeals.
2. You have asked for a narrowing. While we do not waive our rights to all records responsive to the original requests, we are also issuing a new, distinct, request, that does not replace any prior request: All communications sent or received by Ali M Collins to other board members during Oct 1, 2020 to present discussing any of the following topics: school renaming, school reopening, her own potential resignation, her removal from vice presidentship and the election of board officers, her lawsuit against SFUSD, and allegations that she is prejudiced against Asian persons (including but not limited to Signal, Telegram, Twitter, Facebook, Instagram, WhatsApp, WeChat).
-- Records requester