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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 Page 98 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, 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. r.. x J C". `- J _ '. 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 Page 101 of 939 E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT 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 Page 102 of 939 E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT 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 l ! • !i •l^ i 1 utiuLl(. �+ lI AA _ AA 1/ A`A l tlr. •l l A 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 E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT 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 E-FILED 2026 FEES 11 12:56 PM DUBUQUE - CLERK OF DISTRICT COURT ...................... THE CITY OF DiI0IE4" .�. �S�ft7Y�ttl[�•,�Cft 3 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 Page 112 of 939 E-FILED 2026 FEB 11 12:56 PM DUBUQUE e CLERK OF DISTRICT COURT 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 Page 114 of 939 E-FILED 2026 FEB 11 12:56 PM DUBUQUE - CLE F DISTRICT C URT (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", Page 116 of 939 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` Page 118 of 939