December 1, 2025
Re: Deficient Production Under PRR-499-2025 / PRR-647-2025 – Formal Notice
of Non-Compliance 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”), O.C.G.A. § 50-18-70 et seq.
The Georgia Attorney General’s ORA Compliance Manual makes clear:
• 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.
• When withholding any record, agencies must specify a legal
exemption, provide an exemption log, and include a description. O.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
• Internal PW staff emails
• Drafts, internal memos, and working papers
• Internal Teams/Slack messages (if used)
• Communications regarding the Osborne Rd./Grove St. storm drain
investigation
2. Contractor/Consultant Communications
• Emails with third-party contractors
• Technical assessments, reports, or correspondence
• Inspection findings and engineering notes
3. Deleted, Archived, or Metadata-Bearing Records
• No deleted-record logs were provided
• No metadata was produced
• No indication that archived mailboxes were searched
4. Field Documentation
• Inspector notebooks
• Field notes or handwritten assessments
• Photo logs
• Daily reports
• Field inspection sheets
5. Photos, Diagrams, Engineering Materials
• Only partial images were produced.
6. Follow-Up Actions, Determinations, and Corrective Measures
• No work orders
• No repair recommendations
• No engineering determinations
• No SOP-required documentation of findings
II. Statutory Requirements Not Met Under O.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:
• Specific statutory exemption
• Description of each withheld record
• Explanation of the exemption
• Citation to O.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
• Internal PW emails
• Contractor/consultant emails
• Inspection logs
• Field notes
• Maintenance and work-order logs
• Engineering determinations
• All photographs, images, diagrams
• Drafts, memos, and working papers
• Follow-up and corrective-action records
2. A Sworn ORA Custodian Statement
Confirming:
• The scope and method of the search
• Whether any responsive records were deleted, destroyed, or archived
• Whether all custodians were contacted
3. A Complete Exemption Log (O.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;
2. File a petition for judicial enforcement, attorney’s fees, and civil
penalties;
3. 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 O.C.G.A. § 50-18-70 et seq.
Please confirm receipt and provide the supplemental production required by
law.
Sincerely,
Sarah Zeeman
On Fri, Nov 21, 2025 at 8:23 AM Loretta Watts (Brookhaven, GA) <
BrookhavenGA@request.justfoia.com> wrote:
> Dear Sarah Zeeman,
>
> Re: Public Records Request
>
> The Open Records Request PRR-647-2025 you submitted has been completed and
> your invoice is attached . Any requested documents have either been
> attached or can be retrieved via the web using the information below:
>
> Go To: https://brookhavenga.justfoia.com/PublicPortal
> <https://url4102.request.justfoia.com/ls/click?upn=u001.nrfdmL-2B1UhWpB4V2ArB2sT42o6qRhzzKknL9VsChBlErP-2BYN9Yn4J1-2BtRfgVVt2vIWRDg-2FA2eBAMinWP8yiEkw-3D-3DMx5p_t-2FCMCYm7Cu5BcfgzyUx0RW8CTCtvZrDawLyRA2zFx3nQm7JC5X33kNzeXMkBNY4urUdoqfKFRY8V2fOb7U5OLyp30ze-2F6CiKuU-2Fk5K-2F1oCVTxbReL81PSxMED8tqolIvF6D9anj4gkikAn3vk3TjszJSaeRB1ggQswvVcjf9vWE3RCv0wSGDpNiQ-2FrcnKK7T7XwtMwAmAKrI-2BM-2FsAz7yQ0uJUUY1hZEXT0sIO7zYGIOfBrvPbfZg5LRASKFCZcgRvElHVlikCwQscPd4Kf-2FKRfhUoPqoSJUpNyoaKMojmzg-3D>
> (or copy and paste the complete web address in your browser)
>
> Security Key: C7E14987
>
> Request Number: