The Image-Only Copy of the Searchable Case File

RECORD CHAIN

1. The rule. Electronic records must be provided in an electronic format in which the agency holds the information, or in a requested format the agency has used to create copies for its own use or for other agencies GC.7922.570. The November 2025 production is evidence that the City had used a searchable electronic export for this case file: it carried 1,080,979 clean extracted characters N R.25-3549 I2.
2. The November production established the baseline format. The November 2025 590-page case file N was produced under R.25-3549 with /Creator = wkhtmltopdf 0.12.6, no /Author field, and a full extractable text layer. SHA-256: eb324451b81cf67af2a792b0432cbae7abe89b93f3b75f0baf8b9f9bc1f223d5. File size: approximately 51 MB.
3. The April production replaced the searchable format with an image-only print. The April 2026 636-page case file A, produced under R.26-1549, carries no native extractable text; the PDF producer is "Microsoft: Print To PDF"; the /Author field names Melanie Haage and the file's Info dictionary carries no /Creator key (its XMP metadata stream lists Melanie Haage as dc:creator). SHA-256: ff6c83546627aacf46e3ce7a413d2e8e22e57ae91b8c1c96877bb3251088f600. File size: approximately 209 MB. OCR analysis of the image layer yields 1,177,598 clean extracted characters; none is machine-readable from the file's native text layer I2.
4. The April request was opened, released, and closed on April 20, 2026. The R.26-1549 portal record names Melanie Haage as the request's point of contact R.26-1549. The April production's PDF metadata names Melanie Haage as /Author (no /Creator key in the Info dictionary; the XMP stream lists Melanie Haage as dc:creator) A. The request was opened April 20, 2026, and the document was released and the request closed the same day R.26-1549.
5. The requester's April 24, 2026 notice placed the format facts on the portal record. Christopher T. Foley's April 24, 2026 portal message states that the April production was "manually generated using 'Microsoft Print to PDF' on April 20, 2026, at 1:46:33 PM"; states that the November 2025 file is 51 MB and the April 2026 file is 209 MB; and sets out the SHA-256 hashes of both files R.26-1549. The portal record shows no response to that notice, and no later record entry addresses the format change R.26-1549 Card 49.
6. The closure record states no reason for the format change. The City's closure message of April 20, 2026, signed by Mindy Cuppy (City Clerk), states: "The City has collected all documents that appear to be responsive to your request. The documents have been uploaded to the portal." No entry in the portal record, before or after closure, explains why the November searchable export was replaced by an April image-only print, or states that a searchable export was technically unavailable R.26-1549.
7. The two files are distinct records with distinct fingerprints. The November and April productions have different SHA-256 hashes, confirming they are not the same file: eb324451…1f223d5 (November, N) versus ff6c8354…1088f600 (April, A). The producer metadata change from wkhtmltopdf to Microsoft: Print To PDF is embedded in the files themselves N A.
8. The two productions differ in the format the statute addresses. The CPRA's electronic-format provision attaches to the formats the agency holds or has used to create copies GC.7922.570. The City produced this case file as a searchable electronic export in November 2025 N R.25-3549. The April 2026 production of the same case carries no native text layer, and the produced record states no reason for the change R.26-1549. Without a text layer, the file cannot be keyword-searched, text-extracted, or machine-compared except through OCR; the April production's redaction handling is examined in Card 48.

FULL CIRCLE

The expected City answer is that the requester received the same case pages, and that PDF export settings are a delivery detail. GC.7922.570 speaks to format: an agency must provide electronic information in a format in which it holds the information, or in a requested format it has used to create copies. The City had already produced this case file in searchable form N R.25-3549, then produced the April version as an image-only "Microsoft Print to PDF" with no native text layer and no recorded explanation for the change A R.26-1549.

The June 23, 2026 production under Request 26-2487 used the same flattened, no-text-layer "Microsoft Print to PDF" form for the case Summary and the post-May activity extract R.26-2487.2 R.26-2487.3. That recurrence corroborates the finding, which is complete in the April record itself. The April production's redaction handling belongs to Card 48; Card 49 owns the unanswered April 24 notice; Card 4 owns the closure-completeness baseline. This card's finding is the format change alone.

As produced, the record shows one case file released twice — once with its text layer and once without it — and no recorded explanation for the difference.