My clear recollection, as well as my contemporaneous notes, confirm that you stated that if the City of Madison provides our responses to previous public records requests in the relevant time frame, that would be sufficient to comply with the subpoenas for purposes of what is considered due on October 15 and 22, 2021, including the requests for interviews. You also specifically stated that the documents could be submitted on a thumb drive and sent by certified mail to the Special Counsel’s Office. To make sure I understood, I repeated that back to you and you confirmed my understanding.

At this point, it is not reasonable to expect that our Mayor, City Clerk and IT Department can compile and produce other records that may be responsive to the broad language in the subpoenas by next Friday, and we plan to provide the records you agreed to yesterday by then. As we also agreed, the Special Counsel can certainly reserve the right to request additional documents and schedule interviews after reviewing the voluminous documents that will be provided.

Please let me know if you have any concerns or questions regarding this approach. We certainly hope we can resolve any questions cooperatively.



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