The City’s own inventory names a 95 KB statement PDF Christopher Foley attached, logs it as “uploaded to documents” — and the closed-as-complete production contains none of its content.
Christopher Foley, the property owner’s friend and helper, sent the city inspector an email and attached a PDF he called his “statement and supporting facts.” R.25-4711 The city’s own paperwork shows what happened to it: a documents index names the file, gives its size (95 KB), M022 and a case note says the document was “uploaded to documents.” M036 So by the city’s own records the document arrived and was saved. But when the city later handed over its complete file, the words inside that PDF are nowhere in it — the file is named in the index, yet none of its actual content was produced. R.25-3549 R.26-1549 R.26-1965 This only became visible once the owner’s side pulled the related email through a separate records request, which let the named, “uploaded” attachment be matched against what the production actually contains. Govt Code §7920.000
Bottom line: the city’s own file lists a 95 KB statement Foley attached and says it was uploaded — but produces none of its content, and that gap only surfaced after the owner’s side forced the underlying email out.Christopher Foley — the property owner’s friend and helper, who signs only as “Chris” — emailed Bo Cosley and attached a PDF he described as “my statement and supporting facts” and “my attached letter makes clear that I consider my own involvement finished.” R.25-4711 The City’s own case note records receipt of that email and document and states the document “has been uploaded to documents.” M036 The City’s documents inventory lists the attachment by name — “Jackie Case ? Final Letter & Facts.pdf,” 95 KB — dated, described as “Document from handy man,” and catalogued under type “Case Photo.” M022 The produced case file then reproduces the email body — Foley’s message text — at and after the inventory pointer. M036 The 95 KB PDF’s own statement-and-facts content is reproduced on no produced page. R.26-1965 Govt Code §7920.000
Two things sit on the face of the City’s own entries. The City’s inventory names the attachment and gives its size, 95 KB. M022 And although the City’s note logs the document as “uploaded to documents,” M036 the production does not contain it. That gap is visible only because a separate CPRA request produced the underlying Outlook-print of Foley’s email — allowing the named, inventoried attachment to be matched against what the production actually contains. R.25-4711
His email to Cosley states: “The attached PDF sets out my statement and supporting facts,” and “my attached letter makes clear that I consider my own involvement finished.” R.25-4711 This establishes that a PDF was attached and that its author identified it as a substantive statement of facts — not a blank or placeholder.
The documents index lists “Jackie Case ? Final Letter & Facts.pdf,” 95 KB, “Document from handy man,” type “Case Photo,” dated 09/11/2025. M022 The City’s own note at the same page likewise calls the sender the “handyman,” so the inventory label tracks the City’s contemporaneous note. The City named the document, gave its file size, and typed it into its own record system.
Lovato’s 09/11/2025 case note states: “I received an email from property owners handyman along with a document. Document has been uploaded to documents and email states:” — followed by the quoted email body (not the attachment’s own content). M036 The note confirms the City received the document, logged its receipt, and logged it as uploaded to the City’s own document system.
The attachment came from Foley, who wrote and signed (as “Chris”) the email it rode on. R.25-4711 The City named it in its inventory M022 and logged it as uploaded. M036 A record that names a document, gives its file size, and logs it as uploaded, but then reproduces none of its content, is the inventory of a document the production does not include. Govt Code §7920.000 Card 47
Foley handed the City a document — his statement and supporting facts, attached to an email the City has itself produced. R.25-4711 The City’s own inventory names it and gives its size M022 and its own note logs it as “uploaded.” M036 What the City’s file does not do is reproduce a word of its content. A record that names a document and logs it as uploaded, but reproduces none of its content, is the inventory of a document the production does not include. R.25-3549 R.26-1965
The strongest City answer is that the attachment was catalogued and retained in the native CitizenServe documents tab; its non-appearance in the produced text is a CPRA export or format artifact; and the “handy man” label is a harmless clerical description. That answer does not resolve the gap. The City closed the production as complete, so an export that drops a 95 KB document the City’s own inventory names is the gap the completeness obligation addresses. Govt Code §7920.000 The City could close it in one move by producing the PDF. The label is not the claim; the absent content is. Card 25 Card 47 Card 48