Communication with Apple Inc. regarding Digital Driver's License

To Whom It May Concern:

Pursuant to the Texas Public Information Act, I hereby request the following records:

Public Information Officer
Texas Department of Motor Vehicles
P.O. Box 2293
Austin, TX 78768-2293

Subject: Public Information Request under the Texas Public Information Act - Communication with Apple Inc. regarding Digital Driver's License

Dear Public Information Officer,

I am writing to submit a formal request under the Texas Public Information Act (TPIA), requesting access to records held by the Texas Department of Motor Vehicles (DMV). Specifically, I am seeking information related to any communication between the DMV and Apple Inc. regarding the development, implementation, or management of the Digital Driver's License system in Texas.

In accordance with the TPIA, I request access to the following information within the specified timeframe:

Any written correspondence, including letters, emails, memoranda, and faxes, exchanged between the Texas Department of Motor Vehicles and Apple Inc. regarding the Digital Driver's License system between January 1, 2019, and the date of processing this public information request.

Any meeting minutes, agendas, or summaries of meetings, including phone or video conferences, held between representatives of the Texas Department of Motor Vehicles and Apple Inc. regarding the Digital Driver's License system during the same period specified above.

Any contracts, agreements, or memoranda of understanding entered into between the Texas Department of Motor Vehicles and Apple Inc. regarding the development, implementation, or management of the Digital Driver's License system.

Any reports, presentations, or studies prepared by Apple Inc. or shared with the Texas Department of Motor Vehicles pertaining to the Digital Driver's License system.

Any policies, guidelines, or directives issued by the Texas Department of Motor Vehicles in relation to the use of Apple Inc.'s technology or services for the Digital Driver's License system.

To support this request, I would like to refer to the following provisions of the Texas Public Information Act:

Section 552.001: Legislative Declaration - This provision establishes the public's right of access to information held by government agencies in Texas.

Section 552.021: Availability of Public Information - This section outlines the general rule that information held by governmental bodies is presumed to be open to the public, subject to specific exceptions.

I would like to explicitly state that I request that you do not withhold or redact any responsive documents without valid legal grounds. If any redactions are made, I kindly request that you provide an index of the redacted material with specific citations to the applicable exceptions under the Texas Public Information Act.

Furthermore, I request that you take appropriate measures to ensure the preservation of all responsive records. Please refrain from deleting, destroying, or altering any documents that fall within the scope of this request.

Please note that this request covers both electronic and physical records, regardless of format, including but not limited to paper documents, emails, attachments, text messages, and audio or video recordings.

If access to the requested records is denied or only partially granted, please cite the specific legal exceptions or reasons for withholding the information as required by the Texas Public Information Act.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days, as the statute requires.

Sincerely,

Jordan Lassiter