The Named 95 KB Statement Missing from the Production

Case 23-009185 | Card 29 | 4880 T Street, Sacramento CA 95819

The City's own file names a document, gives its size, says it was uploaded — and the case file the City has produced three times does not contain it. The City's case file names a 95 KB statement PDF [M022] from the owner's helper [E3] and logs it as uploaded [M036], yet none of the three case-file productions reproduces the attachment's content. The owner's helper, signing as "Chris," emailed Bo Cosley [E3] and attached a PDF he described as "my statement and supporting facts [E3]." The City's case note, dated 09/11/2025 [M036], records receipt of the 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 [M022]," 95 KB, dated 09/11/2025 — described as "Document from handy man" [M022] and catalogued under type "Case Photo [M022]." The case note quotes the body of the helper's email [M036], but no produced case-file page reproduces the attachment's own "Final Statement on Jackie’s Case" [S7] content. Each closed export contains the inventory line [M022] and the email-body note [M036], not the attachment's content: R.25-3549, R.26-1549, R.26-1965.

Two City entries identify the document: the inventory line, with name and file size [M022], and the case note logging it as "uploaded to documents" [M036]. The omission is visible because a separate CPRA request, R.25-4711, produced the underlying Outlook print of the helper's email [E3], which permits the inventoried attachment to be matched against what the productions contain. The City closed all three with one sentence: "The City has collected all documents that appear to be responsive to your request." [R.25-3549.1] (Request 25-3549 [R.25-3549.1], Request 26-1549 [R.26-1549.1], Request 26-1965 [R.26-1965.1]). One of them asked for exactly this kind of record: Request 26-1549 [R.26-1549.1] asked for "All attachments currently linked to the case record in City systems, including photographs, uploaded documents" [R.26-1549.1] and was received and closed on April 20, 2026 [R.26-1549.1]. The copy-production provision of the Public Records Act is GC.7922.530; the completeness baseline is Card 4. The City's own inventory names the document [M022], its own note logs it as uploaded [M036], and Request 26-1549 asked for the uploaded documents and was closed the same day [R.26-1549.1] — so where, in that production or in the file the City produced in May 2026 under Request 26-1965 [R.26-1965.1], is the 95 KB statement?

IN PLAIN TERMS

The owner's helper emailed the City a PDF with his statement. The City's own records name that PDF, give its size [M022], and say it was uploaded to the case file [M036]. But the case file the City has produced three times holds only the body of the email; the attachment is not there. One of those requests, Request 26-1549 [R.26-1549.1], asked for the uploaded documents by name and was closed the same day. The check is possible because a separate records request produced the email itself [E3]. The question for the City: the City says it uploaded the document and closed a request which asked for the uploaded documents — so where, in that production or in the May 2026 file [R.26-1965.1], is the 95 KB statement?

RECORD CHAIN

  1. September 2, 2025 — the statement, attached to the email. His email to Cosley [E3] states: "The attached PDF sets out my statement and supporting facts [E3]," and "my attached letter makes clear that I consider my own involvement finished [E3]."
  2. September 11, 2025 — the City inventories it: 95 KB, "Document from handy man". The documents index [M022] lists "Jackie Case ? Final Letter & Facts.pdf [M022]," 95 KB, "Document from handy man [M022]," type "Case Photo [M022]."
  3. September 11, 2025 — the City logs it as uploaded. Paul Lovato's case note [M036] states the document "has been uploaded to documents [M036]."
  4. November 2025 – May 2026 — three productions, each closed with the same sentence, without it. Where the inventory [M022] lists the attachment, the produced file reproduces the email body — the helper's message text [M036] — not the attached PDF's statement-and-facts content. The attachment's text is separately available in the "Final Statement on Jackie’s Case" [S7] copy, but no page of the three productions reproduces it. Request 26-1549 [R.26-1549.1], received April 20, 2026, asked for "All attachments currently linked to the case record in City systems, including photographs, uploaded documents" [R.26-1549.1] and was closed that evening: "The City has collected all documents that appear to be responsive to your request." [R.26-1549.1] The May 22, 2026 file under Request 26-1965 [R.26-1965.1] closed the same way: "The City has collected all documents that appear to be responsive to your request." [R.26-1965.1] That comparison copy is the sender's own file, not a City production page; the finding rests on the City's two entries — the inventory line naming the file and its size [M022] and the note logging it as uploaded to documents [M036] — held against what the produced pages contain.
  5. The inventory and the upload note are the City's own records. The owner's helper wrote and signed (as "Chris") the email carrying the attachment [E3]; the City created the inventory line [M022] and the upload note [M036]. Comparing those entries with the produced email print [E3] and the attachment copy [S7] identifies the missing content.

FULL CIRCLE

The owner's helper delivered his statement and supporting facts as an attachment to an email the City has itself produced [E3]. The City's inventory names the attachment and gives its size [M022]; its note states the document "has been uploaded to documents" [M036] and its produced case file does not reproduce the attachment's "Final Statement on Jackie’s Case" [S7] content.

The expected City answer is that the produced file is the CitizenServe case print report, which lists the documents tab [M022] but does not embed the uploaded files, so the 95 KB PDF remains in the native "Case Photo" [M022] or documents tab and can be asked for as a document of its own. That answer fits a request for the case file; it does not fit Request 26-1549 [R.26-1549.1], which asked for "All attachments currently linked to the case record in City systems, including photographs, uploaded documents" [R.26-1549.1] and was closed the same day with "The City has collected all documents that appear to be responsive to your request." [R.26-1549.1] The other two productions closed on the same sentence — Request 25-3549 [R.25-3549.1] and Request 26-1965 [R.26-1965.1] — and each, as produced, holds the inventory line [M022] and the upload note [M036] without the content of the document they describe. The copy-production provision is GC.7922.530. The Outlook-print completeness exemplar is Card 46.

What would defeat this card is a page reproducing the 95 KB document's content, or a City correction stating that the inventory entry [M022] or the "uploaded to documents" note [M036] was in error; the file the City produced in May 2026 under Request 26-1965 [R.26-1965.1] (631 pages) holds neither, and the April 2026 closure of Request 26-1549 [R.26-1549.1] says nothing about it. The finding is an inventoried-but-absent document. Card 4 is the completeness baseline (what the file the City produced means, and does not mean).

APPLICABLE LAW

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