Twelve Written CPRA Completeness Determinations

Case 23-009185 | Card 4 | 4880 T Street, Sacramento CA 95819

Across the first seventeen CPRA requests in the audit of Case 23-009185, the City issued twelve written closure or release statements containing completeness, apparent-responsiveness, or no-records language in City Clerk/NextRequest formulations. Two requests were denied as wholly exempt (R.26-2110, R.26-2204), several requests that still appeared open in earlier local portal captures have since closed, and the June 23, 2026 request batch is summarized below and in the accompanying packet addendum, PACKET/CPRA_ADDENDUM.md. Under the CPRA, closing a request as complete is a written search-and-disclosure determination GC.7922.530 GC.7922.535 GC.7922.540.

Several of the twelve statements address the case file itself. The first full-case production was closed with the statement "All responsive records have been provided" R.25-3549. A follow-up asking whether one logged email was ever sent to the requester was closed twenty-two minutes after filing with "the City does not have any records that are responsive to your request" R.26-39. The most recent searchable-export request was closed with the statement "All responsive records have been provided," even though the City released a 631-page CitizenServe PDF report rather than the native structured export the request expressly sought R.26-1965 M. Two further requests for system metadata and the case-level audit trail were closed by back-reference: "all records were provided under" the April case-file production R.26-1963 R.26-1964.

The closure statements did not describe the searches behind them. Across these requests -- the first case-file production R.25-3549, the same-day no-records closure of the delivery-trace follow-up R.26-39 Card 45, the inspector note-export request first answered by pointing to an index file and then carried through five rolling extension notices R.26-71 Card 40 Card 42, the five-officer comparator export R.26-1061, and the April case-file re-export R.26-1549 -- the City named no system searched, no custodian, and no record-specific withholding basis, citing only category-level exemptions (GC.7927.705, GC.7930.100). On at least R.25-3549 the requester expressly asked which systems and custodians were being searched; the closure did not say GC.7922.540.

The finding is limited. This card does not assert that every later record contradicts every closure. It establishes the City's own completeness baseline: the twelve written statements against which any record that existed, was responsive to a covered scope, and was not produced at the time of the statement must be measured.

IN PLAIN TERMS

Twelve times, in writing, the City told the requester that a request was complete, that all apparently responsive documents had been collected, or that no responsive records existed. Those statements are the City's formal answers after a public-records search, not casual remarks. If a record later surfaces that existed and fit one of those requests, the record is late in a specific way: the City had already said there were no responsive records, that all had been provided, or that anything withheld had been identified as the law requires. This card collects the twelve statements. Card 32 (the Cosley photograph request), Card 45 (the delivery-trace closure), and Card 46 (the email-bearing completeness contradiction) present specific instances.

RECORD CHAIN

  1. The statutory predicate. The CPRA requires an agency to produce disclosable records, issue a written determination within the statutory window, and identify the responsible official and basis when it denies or withholds records GC.7922.530 GC.7922.535 GC.7922.540. Judicial enforcement lies under the writ statute GC.7923.000. Closing a request as complete, or stating that no responsive record exists, is therefore an affirmative determination about the search.
  2. Twelve closure/release statements across the audit. Twelve requests in the Case 23-009185 audit received completeness, release, or no-records language. Each NextRequest thread or local notice capture time-stamps the statement and identifies the officer, point of contact, or closure message source.
  3. The twelve statements, listed by request. Each entry below gives the request number, action date, closure source or point of contact, the closure or release language, and the scope covered.

R.25-3549, closed 11/07/2025 by Anna Sorensen: "All responsive records have been provided." Scope: all Paul Code Enforcement records 01/01/2020-09/19/2025, narrowed to Aug-Sep 2025 caseload. R.25-4711, 12/29/2025 release notice, Anna Sorensen on the portal, release email signed by Jena Swafford: "The City has collected all documents that appear to be responsive to your request." Scope: the released 09/02/2025 Paul email; see Card 46. R.26-39, closed 01/06/2026 by Jena Swafford: "The City does not have any records that are responsive to your request." Scope: proof or correction of the 09/11/2025 email-log statement. R.26-71, closed 03/26/2026 by Mindy Cuppy: "All responsive records have been provided." Scope: 2025 Paul note/log export, all cases. R.26-1060, closed 04/08/2026 by staff, point of contact Amanda Ramirez: "All responsive records ... have been released ..." Scope: 2025 Code Enforcement personnel/officer roster. R.26-1061, closed 03/25/2026 by staff, point of contact Melanie Haage: "... collected all documents that appear to be responsive ... This closes your public record request." Scope: Nov-Dec 2025 note exports for five named officers. R.26-1265, closed 04/02/2026 by staff, point of contact Amanda Ramirez: "All responsive records have been provided." Scope: citywide B31/B59 violation-code Notice-and-Order search, past five years. R.26-1549, closed 04/20/2026 by Mindy Cuppy: "... collected all documents that appear to be responsive ... This closes your public record request." Scope: the April 2026 case-file production. R.26-1963, closed 05/18/2026 by Mindy Cuppy: "The City does not have any records responsive to this request. All records were provided under 26-1549." Scope: per-entry CitizenServe metadata plus attached communications. R.26-1964, closed 05/18/2026 by Mindy Cuppy with the same back-reference to R.26-1549. Scope: case-level audit trail plus related communications. R.26-1965, closed 05/22/2026 by staff, point of contact Anna Sorensen: "All responsive records have been provided." Scope: a searchable native export, answered with a 631-page CitizenServe PDF report M. R.26-2206, closed 06/04/2026, Mindy Cuppy / NextRequest closure notice: "The City does not have any records responsive to this request." Scope: Bo Cosley's 09/16/2025 photographs at 4880 T Street; the closure is captured at R.26-2206.2, and the conflicting CCTV account (P2–P7) is owned by Card 32.

  1. A later-produced responsive record falls into one of three categories. A record that existed, was responsive to one of the twelve closed or release-scoped requests, and appears only after the City's statement is one of three things: a record the City said did not exist, a record the City said was already supplied, or a record withheld without the identification the statute requires GC.7922.540.
  2. Closures after the earlier portal captures. R.26-1986, R.26-1987, R.26-2204, and R.26-2206 appeared open in earlier local portal captures. All four have since closed. R.26-1986 closed June 11, 2026, referred to the city portal. R.26-1987 closed June 11, 2026; the local capture lists a released document, 26-1987 Responsive.pdf, but does not itself show the PDF contents or page-level coverage. R.26-2204 closed June 4, 2026, denied under GC 7927.705 and related privacy/public-interest language. R.26-2206 closed June 4, 2026 with "The City does not have any records responsive to this request" for Bo Cosley's 09/16/2025 photographs at 4880 T Street R.26-2206.2. That no-records closure is included in the twelve-statement inventory above; Card 32 owns the separate CCTV-photographing account P2–P7. R.26-1863 is used only for the limited point that comparator case-file extracts exist and the public request ID is known; the portal thread has since been captured locally, and request 26-1863 closed 05/12/2026 with complainant/victim-ID and personal-info exemptions noted.
  3. A retraction would itself document the gap. A written City retraction identifying previously withheld or undisclosed records would itself show that responsive records existed and were not produced during the closed period.
  4. Eight further case-audit requests were filed June 23, 2026; five closed the same day. Several were labeled "duplicates" of earlier requests although they sought broader or different records, per the packet's request inventory, CPRA_MASTER_INDEX.md. The request for the current complete case file in native format, expressly including Accela data and system fields, closed about three and a half hours after filing as a "duplicate" of an inspection-reports request R.26-2488.1. The request for Accela inspection and parcel-condition records, photographs/attachments, and the export's query/report definition for this case and property also closed the same morning as a "duplicate" R.26-2489.1. That request sought the Accela export named in the City's R.26-1987 production; the one Accela export produced under R.26-71 is a calendar-year-2025 roster that the packet index records as not containing Case 23-009185 or 4880 T Street CPRA_MASTER_INDEX.md R.26-1987.2. The expanded re-request for Cosley's 09/16/2025 photographs, now attaching the property's CCTV stills, was closed the same day as a "duplicate" of the R.26-2206 no-records closure R.26-2492.1 Card 32. A fifth June 23 request for search and determination records for R.26-2206, R.26-2110, and R.26-2204 was closed the same morning as a "duplicate" of R.26-1986, even though the targeted request numbers were different R.26-2494.1. The City's File Summary Report dated 06/23/2026 marks Case 23-009185 "Status: Closed; Close Date 06/18/2026; Disposition: Work Completed" R.26-2487.2. That report carries the same date as the "duplicate" closures of the requests for the complete current case file R.26-2488.1 and the case-specific Accela inspection records R.26-2489.1. Card 39 tests that "Work Completed" disposition against the produced inspection record.

FULL CIRCLE

Twelve City Clerk/NextRequest statements told this requester that a request in the Case 23-009185 audit had been answered in full, that documents appearing responsive had been collected, or that no responsive record existed. Under the CPRA, a closure is a determination about a search and production GC.7922.530 GC.7922.535, and the City's identification duties attach when it denies or withholds records GC.7922.540.

The expected response is that CPRA completeness is per-request, not global; a later-created or out-of-scope record can be produced later without contradicting any closure; and several scopes are not limited to this one case.

That response narrows the finding without answering it. This card does not treat every later record as contradicting a closure or release statement. It addresses records that were responsive to a covered scope and existed when the statement was made; such a record cannot be squared with the City's completeness, release, or no-records language for that scope. The case-file-specific closures and back-reference denials are directed to this case.

The twelve closure and release statements are the City's operative completeness baseline for the first seventeen-request phase of this audit. This card supplies that baseline; the cards that test specific later-produced records against it are cited above. It does not treat later-created or out-of-scope records as contradictions.

APPLICABLE LAW

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