Hendrik Van Pelt vs City of DubuqueCity of Dubuque
City Council
CONSENT ITEMS # 2.
Copyrighted
March 2, 2026
ITEM TITLE: Notice of Claims and Suits
SUMMARY: Alizabeth Chapman for vehicle damage; Nicholas Fuller for
property damage; Hendrik Van Pelt vs. City of Dubuque for
Petition Pursuant to Iowa Code Chapter 22 for Writ of
Injunction or Writ of Mandamus.
SUGGUESTED Receive and File; Refer to City Attorney
DISPOSITION:
ATTACHMENTS:
1. Claim by Alizabeth Chapman
2. Claim by Nicholas Fuller
3. Memo and Van Pelt Petition
Page 93 of 939
THE CITY OF
DUB E
Masterpiece on the Mississippi
CRENNA M. BRUMWELL, ESQ.
CITY ATTORNEY
TO: MAYOR BRAD M. CAVANAGH AND MEMBERS OF THE CITY COUNCIL
DATE: FEBRUARY 23, 2026
RE: OPEN RECORDS LAWSUIT
Dubuque
All•A�eNea 6Iq
1ml'o I
I I
2007-2012.2013
2017*2019
Attached is a petition filed in the District Court in and for Dubuque County alleging an
open records violation by the City of Dubuque. An answer is being filed denying any
violation.
No action by Council is required at this time other than receive and file.
OFFICE OF THE CITY ATTORNEY DUBUQUE, IOWA
SUITE 330, HARBOR VIEW PLACE, 300 MAIN STREET DUBUQUE, IA 52001-6944
TELEPHONE (563) 589-4381 / FAx (563) 583-1040 / EMAIL cbrumwel@cityofdubuque.org
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IN THE IOWA DISTRICT COURT FOR DUBUQUE COUNTY
HENDRIK VAN PELT,
Plaintiff,
V.
CITY OF DUBUQUE, IOWA,
Defendant.
TO THE ABOVE -NAMED DEFENDANT:
Case No. CVCV118196
ORIGINAL NOTICE
You are hereby notified that a petition has been filed in the office of the cleric of this court
naming you as the defendant in this action. A copy of the petition (and any documents filed with it)
is attached to this notice. The attorney for the plaintiff is Molly M. Parker of Shuttleworth & Ingersoll,
P.L.C., whose address is 235 6t}i Street SE, Cedar Rapids, IA 52401. That attorney's phone number
is (319) 365-9461.
This case has been filed in a county that utilizes electronic filing. You should look at Iowa
Court Rules Chapter 16 for general rules and information on electronic filing. Also please refer to
rules Chapter 16, division VI regarding the protection of personal information in court filing.
You must serve a motion or answer within 20 days after service of this original notice upon
you and within a reasonable time thereafter file your motion or answer with the Court for Dubuque
County at the county courthouse in Dubuque, Iowa. If you do not, judgment by default may be
rendered against youfor the relief demanded in the petition.
Ifyou require the assistance of auxiliary aids or services to participate in court because of adisability, immediately
call your district ADA coordinator at 563-589-1300. (If you are hearing impaired, call Relay Iowa TTY at 1-800-735-
2942).
IMPORTANT NOTICE
YOU ARE ADVISED TO SEEK LEGAL ADVICE AT ONCE TO PROTECT YOUR INTERESTS.
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Page 99 of 939
E-FILED 2026 FEB 13 3:41 PM DUBUQUE - CLERK OF DISTRICT COURT
Iowa Judicial Branch Case No. CVCV118196
County Dubuque
Case Title HENDRIK VAN PELT VS CITY OF DUBUQUE
You must file your Appearance and Answer on the Iowa Judicial Branch eFile System, unless the attached Petition and
Original Notice contains a hearing date for your appearance, or unless the court has excused you from filing electronically
(see Iowa Court Rule 16.302).
Register for the eFile System at www.iowacottrts.state.ia.us/l.Iile to file and view documents in your case and to receive
notices from the court.
For general rules and information on electronic filing, refer to the Iowa Rules of Elcoxonic Procedure in chapter 16 of the
Iowa Court Rules at www.l.egi,s.iowa.gov/does/ACO/CourtRtilesChapter/1.6.pdf.
Court filings are public documents and may contain personal information that should always be kept confidential. For the
rules on protecting personal information, refer to Division VI of chapter 16 of the Iowa Court Rules and to the Iowa
Judicial Branch website at www,iowacourts.gov/�for-theT.
oov/for-the-public/%e resenting-vt>urselt%protect-pettional-ital�c�.rmatiUn/.
Scheduled Nearing_
If you need assistance to participate in court due to a disability, call the disability access coordinator at (319) 833-3332 .
Persons who are hearing or speech impaired may call Relay Iowa TTY (1-800-735-2942). For more information, see
wWw,_ii.ctwrtc oua is.g<�)y/firc_tlie_frujaj c/adP/. Disability access coordinators cannot provide legal advice.
Date Issued 02/13/2026 03:41:33 PM
District Clerk of Court or/by Clerk's Designee of Dubuque County
Is/ Sommer Stevens
Page 100 of 939
E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT
IN THE IOWA DISTRICT COURT FOR DUBUQUE COUNTY
HENDRIK VAN PELT
Plaintiff,
vs.
CITY OF DUBUQUE,
Defendant.
NO. CVCV 118196
PETITION PURSUANT TO IOWA
CODE CHAPTER 22 FOR WRIT OF
INJUNCTION OR WRIT OF
MANDAMUS
Hendrik van Pelt requests that the Court shed necessary light on the City of Dubuque's
(the "City") relationship with the businesses it uses to monitor and surveil its citizens, and why it
seeks to shroud those relationships and surveillance data in secrecy. The City has denied
Plaintiff's efforts to access this information under Iowa's Open Records Act.
PARTIES, VENUE, AND JURISDICTION
1. Hendrik van Pelt is and has at all relevant times been a resident of Clayton
County, Iowa.
2. The City of Dubuque is a city in Dubuque County, Iowa.
3. The City is subject to the requirements of Iowa Code Chapter 22.
4. The City is the lawfiil custodian of the public records Plaintiff seeks.
5. Jurisdiction and venue arise under Iowa Code §§ 22.5 and. 22.10.
BACKGROUND AND FACTS
6. On October 22, 2025, van Pelt, through counsel, submitted an Open Records
Request to the City. See Attached, Ex. 1.
1
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2.
7. The City confirmed receipt of van Pelt's request the same day. See Attached, Ex.
8. The City provided a substantive response to van Pelt's Open Records Request on
November 14, 2025. See Attached, Ex. 3; see also Ex. 2 p. 3.
9. In response to van Pelt's Open Records Request, the City provided some
responsive documentation. However, the City withheld certain documentation under Iowa Code
§§ 22.7(9), 22.7(18), and-22.7(55). See Ex. 3.
COUNT I: VIOLATION OF CHAPTER 22 — INJUNCTIVE RELIEF
AND/OR MANDAMUS
10, Plaintiff re -alleges and repleads paragraphs one through 9.
11. Count I is brought pursuant to Iowa Code § 22.10 against the City to enforce the
statutory requirements of the Iowa Open Records law by any aggrieved person.
12. The City is a government body within the meaning of Iowa Code § 22.1.
13. Upon information and belief, the City has in its possession certain public
government records as defined by Iowa Code § 22.1.
14. The City is the lawful custodian of the records sought.
15. Plaintiff has requested access to these public records. See Ex. 1.
16, The City has not made the records requested available to Plaintiff and instead has
improperly relied on inapplicable disclosure exemptions set out under Iowa Code § 22.7.
17. Alternatively, to the extent the City claims is not in possession of the records
sought, its failure to maintain those records is a violation of Iowa Code § 22.2(2) and/or
§ 23.3A(2)(b).
18. The City's refusal to provide copies of public records constitutes a violation of its
duties under Iowa Code Chapter 22.
2
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19. Pursuant to Iowa Code §§ 22.5 and 22.10, Plaintiff requests that the Court issue
an injunction ordering the City to provide access to and/or produce all records encompassed by
their pending requests.
20. In the alternative, Plaintiff requests that the Court issue a writ of mandamus
commanding the Board to fiilly respond to the pending requests under Chapter 22.
WHEREFORE, Plaintiff Hendrik ("Cris") van Pelt respectfully requests that the Court
issue an Order finding Defendant the City of Dubuque violated Chapter 22 of the Iowa Code,
and
i) Issuing an injunction or writ of mandamus requiring Defendant to comply with all
Chapter 22 requirements pursuant to Iowa Code § 22.10(3);
ii) Assessing damages against Defendant as appropriate under Iowa Code § 22.10(3);
iii) Ordering the payment of Plaintiff's costs and attorneys' fees pursuant to Iowa
Code § 22.10(3); and
iv) Ordering all further relief the Court deems just.
A/ Molly Parker _
Molly M. Parker AT0012335
Shuttleworth & Ingersoll, PLC
235 6th Street SE
Cedar Rapids, IA 52401
Phone: 319-365-9461
Fax: 319-365-8443
E-mail: mmpAshuttleworthlaw.coin
ATTORNEYS FOR PLAINTIFF
3
Page 103 of 939
Page 104 of 939
E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT
From:
Adrienne Breitfelder
To:
Molly Parker
Subject:
RE; Chapter 22 Request
Date:
Monday, November 24, 2025 2:34:44 PM
Attachments:
Imaae001.ona
11aoe002.n1q
I0jaae003.nna
4mage004.nna
Imaae005.12na
1maoe005.unp
1ma9e007.12n0
Molly,
Just to clarify, the list of camera locations that I reference in my below email is our
Milestone Systems cameras and does not include ALPR locations. The list of ALPR
locations was previously provided to you.
Thank you,
Adrienne
IIIIlff�ii
ra
From: Adrienne Breitfelder
Adrienne Breitfelder, CMC
City Clerk I City of Dubuque
City Hall 150 W. 13th Street
Dubuque, Iowa 52001
563-589-4121
Sent: Monday, November 24, 2025 2:15 PM
To: 'Molly Parker' <MMP@ShuttleworthLaw.com>
Subject: RE: Chapter 22 Request
Molly,
EXHIBIT 2
Page 105 of 939
E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT
Rejecting your definitions did not affect our response; all documents responsive to your
request were provided. I have attached the remaining purchase orders and list of
camera locations. Regarding training materials for other systems in scope of the
request, I have included the applicable links to Milestone Systems below.
Main Link
Documentation Link
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Thank you,
Adrienne
THR C1W OF
Moteipie , on Ow MissisB fit
Adrienne Breitfelder, CMC
City Clerk i City of Dubuque
City Hall 150 W. 13th Street
Dubuque, Iowa 52001
563-589-4121
From: Molly Parker <MM @5hutt1ewt7LthLaw.corn>
Sent: Wednesday, November 19, 2025 9:52 AM
To: Adrienne Breitfelder < t t >
Subject: RE: Chapter 22 Request
Adrienne,
Thank you far your response. Can you please let me know when we can expect the
documents that you've indicated are still being collected?
With respect to the definitions, I understand the City's desire to use commonly relied
upon terms. My concern is that the refusalto apply the definitions I supplied
fundamentally changed the City's understanding of our request. In short, can you please
indicate whether there are documents that would have fallen within my supplied
definitions that did not fallwithin the definition the city applied, and were therefore not
provided on the basis of being outside the scope of the request?
The Freedom of Information laws give my client a right to make any request for public
EXHIBIT 2
Page 106 of 939
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records. I do not thin kthe City can receive a request and unilaterally modify the
terminology of the request if it results in a substantive change to the request or results in
a different set of documents being requested/produced than was actually asked for. In
the event that's what happened here, please supply a response to the actual request we
submitted.
Looking forward to your reply,
Molly
From: Adrienne Breitfelder <r.i.C�?�11�odgbuque_c�r>
Sent: Friday, November 14, 2025 1:53 PM
70: Molly Parker
Subject: RE: Chapter 22 Request
Molly,
Please see the attached letter and supporting documents containing our responses to
your open records request.
Thankyou,
Adrienne
7UR CITY Of
Masterpiece n th, Mh5sissi pi
Adrienne Breitfelder, CMC
City Clerk I City of Dubuque
City Hall 150 W. 13th Street
Dubuque, Iowa 52001
563-589-4121
From: Adrienne Breitfelder
Sent: Monday, November 10, 2025 2:13 PM
To: `Molly Parker'<MMELu�Sliutt.lewQi-t[iLaw.corn>
Subject: RE: Chapter 22 Request
EXHIBITge
P107 of 939
E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT
Molly,
We are finalizing the response and will provide it to you by the end of this week.
Thank you,
Adrienne
Adrienne Breitfelder, CIVIC
T14E CITY OF City Clerk i City of Dubuque
City Hall 150 W. 13th Street
UUB6
E Dubuque, Iowa 52001
563-589-4121
Masterpiece on, themis'qiSmPpi 000000
From: Molly Parker <M1MII'@5hUttl worthl.aw.Com>
Sent: Monday, November 10, 2025 1:11 PM
To: Adrienne Breitfelder < a. ' e >
Subject: RE: Chapter 22 Request
Adrienne,
Please provide an update about when I can expect to receive the documents I
requested.
Thankyou,
Molly
From: Adrienne Breitfelder <. t t o >
Sent: Wednesday, October 22, 2025 3:02 PM
To: Molly Parker <1�shur, orthj,t3w.cor��>
Subject: Re: Chapter 22 Request
EXHIBIT 2
Page 108 of 939
E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT
Ms. Parker,
confirm receipt of your request. I will follow up after consulting with the relevant
departments to determine what information can be provided, along with the associated
time and cost estimates.
Thankyou,
Adrienne
Cii'1t ov
Mwtap%ece an the Mssissippi
Adrienne Breitfelder, CMC
City Clerk I City of Dubuque
City Hall 150 W. 13th Street
Dubuque, Iowa 52001
563-589-4121
From: Molly Parker <MMP�Shutll'Wfk1�l-�1Vl1rri>
Sent: Wednesday, October 22, 2025 2:37 PM
To: Adrienne Breitfelder <Abreitfe @cityafdubuaue.or&>
Subject: Chapter 22 Request
Ms. Breitfelder,
Please see the attached Freedom of Information Act Request, submitted under Iowa Code Chapter
22.
Please do not hesitate to contact me if you have any questions.
Thanks,
Molly
WE MOVED! Please note that as of July 15, 2024 my physical office
location is 235 6th St. SE, Cedar Rapids. My email address and phone
number have not changed.
EXHI� ge 109 of 939
E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT
�;hutd' wsi, u_ftli
&.INGERSOLL
A'E3 L tSi f E D IF154
Molly M. Parker (she/her/hers)
Shuttleworth & Ingersoll, P.L.C.
235 6th Street SE
Cedar Rapids, IA 52401
Phone. (319) 365-9461
Fax: (319) 365-8443
E-mail m n shuttleworthlaw.cg
Website I
This message is covered by the Electronic Communication Privacy Act, 18 USC Section 2510-2515, is intended
only for the use of the person to whom it is addressed and may contain information that is confidential and subject
to the attorney -client privilege. It should also not be forwarded to anyone else. If you received this message and
are not the addressee, you have received this message In error. Please notify the person sending the message
and destroy your copy and all attachments.
Since email messages sent between you and Shuttleworth & Ingersoll P.L.C. and its employees are transmitted
over the Internet, Shuttleworth & Ingersoll P.L.C. cannot assure that such messages are secure. You should be
careful in transmitting information to Shuttleworth & Ingersoll P. L.C. that you consider confdential. If you are
uncomfortable with such risks, you may decide not to use email to communicate with Shuttleworth & Ingersoll
P. L. C.
EXHIBIT 2
Page 110 of 939
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......................
THE CITY OF DiI0IE4"
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Masteipiece can the .Mississippi ......... ...c.x
November 14, 2025
Via email to MMPi )Shuttleworthl-aw.com
Molly Parker
Shuttleworth & Ingersoll
Ms. Parker,
City Clerk's Office
City Hall
50 W. 13t" Street
Dubuque, IA 52001-4864
(563) 589-4100 office
(563) 589-0890 fax
ctyclerk@cityofdubuque.org
www. city cfd u buq ue. org
The City of Dubuque has received your records request dated October 22, 2025, wherein
you request certain records "created, edited, or received by the City during the time period
beginning January 1, 2024, and ending as of the date of [your] letter," unless otherwise
indicated. Your letter also contains definitions for "Surveillance System," Surveillance
Device," and "Surveillance Vendor" for purposes of your request. The City declines the
invitation to adopt those definitions; instead, the City applies the usual and customary
meanings of each such term.
The City maintains cameras for many purposes, including:
Asset Protection,
Personal Safety, for employees and the public,
Quality Assurance, and
Assisting City Departments in operations.
As an example, our STREETS project is used to improve mobility, reduce congestion,
improve safety, and provide information for travelers. You can find more information on
the project at: httns://www.cityofdubugue.orcg/2945/STREETS-Project.
Cameras within City facilities, such as City Hall and the City's parking ramps, are primarily
for the safety of the public and City staff, and the security of City property and
infrastructure.
Each part of your request is addressed below, following the order in which you outlined
them:
1. Records (including contracts, agreements, purchase orders, and any other
writings evidencing any agreement) regarding or between the City and any
EXHI Page 111 of 939
E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT
Surveillance Vendor related to any the City's purchase, trial of, lease of, or rental
of any Surveillance System or Device.
Attached are records covering the requested timeframe for the Axon and Flock systems.
Records pertaining to other systems within the scope of the request are currently being
gathered and will be provided as they become available.
2. A list of locations of all Surveillance Devices. For Surveillance Devices not held
in an identifiable physical location (i.e.: software), please provide the name of the
person or entity that hold the license or other authorization for the City's use of the
software.
Attached is a list of all ALPR locations within the City. Records pertaining to other systems
within the scope of the request are currently being gathered and will be provided as they
become available.
3. Records evidencing any technical integration between the City's ALPR system
and the Iowa NCIC system, or any other law enforcement system similar to the
IOWA NCIC system (including but not limited to NLIETS and INTERPOL).
None. Any such integration would have been between the State of Iowa and FLOCK.
4. Records (including current manuals, polices, guidelines, and training materials)
governing or related to the operation of and access to any Surveillance System
used by the City.
The City's applicable administrative policies are attached. Records pertaining to other
systems within the scope of the request are currently being gathered and will be provided
as they become available.
5. Records related to the "Secure Dubuque Personal Surveillance System"
(SDPSS) and devices, including owners and locations of participating devices.
All such records are confidential pursuant to Iowa Code § 22.7(18).
6. Flock Audit Logs (records of searches conducted within the agency and
searches of the organization's Flock network by any agency in the Flock system,
available for download from the Flock "Insights" tab).
The link to the City's transparency portal is provided below. Please note that data is only
retained for 30 days, hops://transparency.flocksafety.com/dubugue-ia-pd
The formatting issue in the "searchDate" column of the Public Search Audit CSV
spreadsheet does not affect the underlying data. The date and time will display correctly
after double clicking on the cell in question.
EXHIBIT 3
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The Insights tab reflects raw daily counts, including the number of plates and searches
conducted each day. These aggregate figures are already published on the transparency
portal.
All other requested information is confidential pursuant to Iowa Code §§ 22.7(9) and
22.7(55).
7. Any and all Records, contracts, or documents related to provision of City funding
for construction related in any manner to Dubuque Childcare Coilaborative, LLC.
None.
8. ALPR Records, including all data captured by the ALPR system (including but
not limited to photographs) at the following location between July 1, 2025 and
October 1, 2025:
The requested information is confidential pursuant to Iowa Code § 22.7(55). Attached is
the Iowa Public Information Board decision regarding this.
Thank you,
Adrienne Breitfelder
City Clerk
EXHIP`age 113 of 939
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(VI ORNEYSl1T.LMV + ]s4.L BL1,1AIL?ll 1854
October 22, 2025
VIA EMAIL
Adrienne N. Breitfelder
Dubuque City Clerk
abreitfe e,cityofdubuque.org
Re: Iowa Code Chapter 22 Information Request
Ms. Breitfelder:
I am writing to request that you provide me with certain public records and information pursuant
to Iowa Code Chapter 22, Iowa's Freedom of Information Act. It is my intention that this letter
be directed to any governmental entity that is a lawful custodian of the documents requested
herein, which I understand to include the Dubuque Police Department, the Dubuque Department
of Engineering, and the City of Dubuque Information Services Department. Please let me know
if you require letters separately addressed to each entity.
For purposes of this request, please apply the following definitions:
"Surveillance System" or "Surveillance Device" means any system or device,
including software systems, for CCTV, Automated License Plate Readers
(ALPR), facial recognition, gunshot detection, use of drones, or any other means
by which to monitor and/or identify any person, vehicle, or property, whether
such use is the primary purpose of the system or an ancillary feature of the
system.
2. "Surveillance Vendor" means any person or entity that provides Surveillance
System or Surveillance Device installation, monitoring, software, storage, or
ongoing support, including but not limited to Centralsquare, Milestone, and Flock
Safety, and Fusus by Axon.
3. "The City" means the City of Dubuque and its specific agencies, including but not
limited to the Dubuque Police Department, Dubuque Information Services, and
Dubuque Engineering.
4. "Records" means the definition set out in Iowa Code Chapter 22.1(3) and a
request for "Records" includes a request for any and all specified Records.
Shuttleworth & Ingersoll, P.L.C. Cedar Rapids Office Coralville Office Waterloo Office
Phone: 319.365.9461 235 6th St. SE 327 2nd St., Suite 300 314 E. 4th St.
Pax: 319.365.8443 Cedar Rapids, IA 52401 Coralville, IA 52241 Waterloo, IA 50703
www.ShuttleworthLaw.com EXHIBIT 1
Page 115 of 939
E-FILED 2026 FEB 11 12.56 PM DUBUQUE - CLERK OF DISTRICT COURT
Shuttleworth & Ingersoll, P.L.C.
October 22, 2025
Page 2
I request production of the following records created, edited, or received by the City during the
time period beginning January 1, 2024, and ending as of the date of this letter, unless a different
time period is noted in the specific request:
Records (including contracts, agreements, purchase orders, and any other writings
evidencing any agreement) regarding or between the City and any Surveillance
Vendor related to any the City's purchase, trial of, lease of, or rental of any
Surveillance System or Device.
2. A list of locations of all Surveillance Devices. For Surveillance Devices not held
in an identifiable physical location (i.e.: software), please provide the name of the
person or entity that hold the license or other authorization for the City's use of
the software.
3. Records evidencing any technical integration between the City's ALPR system
and the Iowa NCIC system, or any other law enforcement system similar to the
IOWA NCIC system (including but not limited to NLETS and INTERPOL).
4. Records (including current manuals, polices, guidelines, and training materials)
governing or related to the operation of and access to any Surveillance System
used by the City.
5. Records related to the "Secure Dubuque Personal Surveillance System" (SDPSS)
and devices, including owners and locations of participating devices.
6. Flock Audit Logs (records of searches conducted within the agency and searches
of the organization's Flock network by any agency in the Flock system, available
for download from the Flock "Insights" tab).
7. Any and all Records, contracts, or documents related to provision of City funding
for construction related in any manner to Dubuque Childcare Collaborative, LLC.
S. ALPR Records, including all data captured by the ALPR system (including but
not limited to photographs) at the following location between July 1, 2025 and
October 1, 2025:
As you are aware, the City must promptly respond to this request under Chapter 22. Please send
the records within twenty (20) days of the date this letter was sent. Otherwise, please provide a
date by which you anticipate you can provide these records.
Shuttleworth.
& "-W31 "S"01,1-j",
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E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT
Shuttleworth & Ingersoll, P.L.C.
October 22, 2025
Page 3
If you decline to produce the requested records, please provide the rationale for that decision. If
you allege that the records are exempt from disclosure, please identify the specific exemption
under Iowa Code Chapter 22 you allege is applicable, and identify which specific category of
requested documents you allege the exemption applies to. If you allege that the records are
exempt from public disclosure on a basis other than the exemptions listed in Chapter 22, please
provide a specific citation (statutory or otherwise) for authorizing the withholding of the records.
Please do not hesitate to contact me if you have any questions,
Very truly yours,
Molly Parker
r .
F f • .•
'� :R u 6`
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