19Adc035 Ora Deficiency Cob Prr 499 2025 Prr 647 2025 2¶

December 1, 2025 Re: Deficient Production Under PRR-499-2025 / PRR-647-2025 - Formal Notice of NonCompliance With the Georgia Open Records Act

Dear City Clerk, Public Works, and City Attorney: This letter follows my Open Records Request originally submitted under PRR-499-2025 and later referenced in your November 21, 2025, “completion” notice as PRR-647-2025. After a detailed review of the documents provided, the production is incomplete and does not comply with the Georgia Open Records Act (“ORA”), 0.C.G.A. § 50-18-70 et seq. The Georgia Attorney General’s ORA Compliance Manual makes clear: e

Agencies must contact and gather records from all custodians reasonably likely to possess responsive documents.

¢

Deleted emails, metadata, and prior versions are subject to ORA if they existed at the time of the request.

e

When withholding any record, agencies must specify a legal exemption, provide an exemption log, and include a description. 0.C.G.A. § 50-18-72(h).

No such explanations or exemption logs were provided.

Categories Missing, Incomplete, or Not Searched

Internal Public Works Records e

Internal PW staff emails

e

Drafts, internal memos, and working papers

e

Internal Teams/Slack messages (if used)

¢

Communications regarding the Osborne Rd./Grove St. storm drain investigation

1. Contractor/Consultant Communications e

Emails with third-party contractors

¢

Technical assessments, reports, or correspondence

e

Inspection findings and engineering notes

1. Deleted, Archived, or Metadata-Bearing Records e

No deleted-record logs were provided

¢

No metadata was produced

e

No indication that archived mailboxes were searched

4. Field Documentation e

Inspector notebooks

e

Field notes or handwritten assessments

e

Photo logs

e

Daily reports

e

Field inspection sheets

1. Photos, Diagrams, Engineering Materials e

Only partial images were produced.

1. Follow-Up Actions, Determinations, and Corrective Measures ¢

No work orders

e

No repair recommendations

e

No engineering determinations

¢

No SOP-required documentation of findings

II. Statutory Requirements Not Met Under 0.C.G.A. §§ 50-18-71 and 50-18-72, the City must: 1. Conduct a full, meaningful, and good-faith search. 2. Provide written justification for each withheld document, including: e

Specific statutory exemption

e

Description of each withheld record

e

Explanation of the exemption

e

Citation to 0.C.G.A. § 50-18-72(h)

III. Demand for Compliance Please provide the following within three (3) business days: 1. A Full Supplemental Production e

Internal PW emails

e

Contractor/consultant emails

e

Inspection logs

e

Field notes

e

Maintenance and work-order logs

e

Engineering determinations

e

All photographs, images, diagrams

e

Drafts, memos, and working papers

e

Follow-up and corrective-action records

2.

A Sworn ORA Custodian Statement

Confirming: e

The scope and method of the search

e

Whether any responsive records were deleted, destroyed, or archived

e

Whether all custodians were contacted

1. A Complete Exemption Log (0.C.G.A. § 50-18-72(h)) IV. Notice of Remedies

If the City does not comply within three (3) business days, I will: 1. File a complaint with the Georgia Attorney General Open Government Mediation Program;

1. File a petition for judicial enforcement, attorney’s fees, and civil penalties;

2. Seek sanctions under O.C.G.A. § 50-18-74(b)(1). This letter is not a threat; it is a formal preservation-of-rights notice issued to ensure

compliance with the Georgia Open Records Act and to preserve all remedies available under 0.C.G.A. § 50-18-70 et seq. Please confirm receipt and provide the supplemental production required by law.

Sincerely, Sarah Zeeman