Thank you for chatting with me. The purpose of this email is to memorialize what we discussed, and confirm our mutual and respective understandings of your continuing obligations under the subpoena duces tecum for October 15. As discussed, our office wants to be as helpful and reasonable as possible so that there is no undue production burden on your city.

As discussed, your office will collate and produce to this Office a physical copy (e.g. a flash drive) containing all responsive communications you may reasonably produce by next Friday, October 15, specifically including but not limited to the open records productions you have already made. As we have already discussed your record-retention and production policies, the individual from your office who delivers the physical copy will not need to spend any substantial time with us–merely sign in and confirm delivery of the physical copy. We understand that there has been some public misinformation out there on this point.

If and when we have follow-up questions or specific production requests pursuant to the subpoena, we are confident in your assurances that your office will continue to be as cooperative as you have already agreed to be.

If I have omitted or misstated any material point of our discussion, please advise as soon as possible.


Andrew Kloster

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