# PUBLIC RECORDS REQUEST
## Pursuant to RCW 42.56 — Washington Public Records Act

**To:** City of Redmond, City Clerk's Office
**From:** [YOUR NAME]
**Date:** [DATE]
**Re:** Old Fire House (OFH) — Comprehensive Records Request

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Dear Public Records Officer:

Pursuant to Washington's Public Records Act, Chapter 42.56 RCW, I am requesting copies of the following records. This request is based on a thorough analysis of the four installments previously produced under Request #32782, which revealed significant gaps in the production.

I request the response be provided in electronic format (native file format preferred — .msg, .eml, .pdf, .docx as applicable) via electronic delivery.

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## SECTION 1: MISSING OUTGOING EMAILS — PROVEN WITHHELD

Analysis of the prior production demonstrates that multiple City employees and officials received reply emails ("Re:") addressed to them, proving they sent outgoing messages that were not included in the production. I request **all outgoing emails (sent items)** from the following individuals for the period **January 1, 2024 through present**:

1. **Mayor Angela Birney** (abirney@redmond.gov) — 82 reply-to instances in production prove missing outgoing emails
2. **Mayor's Office** (mayor@redmond.gov) — 108 reply-to instances prove missing outgoing emails
3. **Malisa Files** (mfiles@redmond.gov) — 84 reply-to instances prove missing outgoing emails
4. **Darrell Lowe** (dlowe@redmond.gov) — 169 emails addressed to, zero outgoing produced
5. **S. Fields** (sfields@redmond.gov) — 114 reply-to instances prove missing outgoing emails
6. **O. Salahuddin** (osalahuddin@redmond.gov) — 105 reply-to instances prove missing outgoing emails
7. **C. Payne** (cpayne@redmond.gov) — 20 reply-to instances prove missing outgoing emails
8. **C. Cornwell** (ccornwell@redmond.gov) — 242 emails addressed to, zero outgoing produced
9. **M. Plocke** (mplocke@redmond.gov) — 223 emails addressed to, zero outgoing produced
10. **A. Wynn** (awynn@redmond.gov) — 151 emails addressed to, zero outgoing produced
11. **D. Tuchek** (dtuchek@redmond.gov) — 160 emails addressed to, zero outgoing produced
12. **S. Allen** (sallen@redmond.gov) — 145 emails addressed to, zero outgoing produced

These individuals are not peripheral. They received hundreds of communications about the Old Fire House, and in many cases other employees replied directly TO their addresses — proving outgoing messages existed that were excluded from production.

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## SECTION 2: COUNCIL COMMUNICATIONS

All emails, text messages, instant messages, Teams/Slack messages, and other electronic communications sent to, from, or among the following addresses/accounts, related in any way to the Old Fire House, teen services, or the OFH property, for the period **January 1, 2023 through present**:

1. council@redmond.gov — 120 reply-to instances in production prove missing communications
2. cityclerk@redmond.gov — 15 reply-to instances prove missing communications
3. All individual City Council member email accounts
4. All individual City Council member government-issued or personally-used devices where government business was conducted (per *Nissen v. Pierce County*, 2015)

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## SECTION 3: STEPHERSON ASSOCIATES — CONTRACTOR RECORDS

Under the "functional equivalent" doctrine established in *Cedar Grove Composting, Inc. v. City of Marysville* (2015), communications with and records created by contractors performing governmental functions are public records. Stepherson Associates was engaged by the City to conduct public communications and outreach regarding the OFH transition. I request:

1. **All emails to/from all Stepherson Associates addresses**, including but not limited to:
   - adinh@stephersonassociates.com (Aileen Dinh — 401 emails in production)
   - dedmunds@stephersonassociates.com (D. Edmunds — 1,050 appearances, zero outgoing, 178 reply-to proofs)
   - hrudin@stephersonassociates.com (H. Rudin — 719 appearances, zero outgoing, 178 reply-to proofs)
2. **The complete Stepherson Associates contract/scope of work** with the City of Redmond related to OFH
3. **All invoices submitted by Stepherson Associates** related to OFH work
4. **All deliverables** produced by Stepherson Associates, including but not limited to:
   - Communications plans
   - Outreach strategies
   - Engagement plans
   - Key messaging documents
   - Talking points (multiple versions referenced in production)
   - Social media content/graphics
   - Reports on community engagement outcomes
5. **All internal Stepherson Associates communications** related to the City of Redmond OFH engagement

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## SECTION 4: ATTACHMENTS — STRIPPED FROM PRIOR PRODUCTION

The prior production included 4,109 emails that reference attachments, but **no actual attachment files were provided**. Documents referenced in the email bodies include, but are not limited to:

1. Staff Talking Points (multiple versions, referenced in SharePoint links)
2. FAQ documents (multiple versions)
3. News release drafts
4. "Embargoed materials" PDF sent by Brant DeLarme on March 10, 2025
5. Engagement Plan documents
6. Team check-in meeting notes (Feb 18, 2025 and subsequent)
7. Web content drafts
8. Digital notification content drafts
9. Teen Services Questionnaire results/compilations
10. Cost Recovery Model presentations
11. OFH Demolition Questions documentation
12. All documents stored on or linked to SharePoint (redmondgov.sharepoint.com) related to OFH, teen services, or the Old Fire House property

I request **all attachments from all emails** in the prior production, plus any documents referenced by SharePoint/OneDrive links contained in those emails.

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## SECTION 5: PROPERTY AND FINANCIAL RECORDS

All records related to the Old Fire House property (real estate, valuation, disposition, development), for the period **January 1, 2018 through present**, including but not limited to:

1. All property appraisals, assessments, or valuations
2. All surplus property declarations or proceedings
3. All communications with real estate developers, brokers, or prospective buyers
4. All letters of intent, memoranda of understanding, option agreements, purchase and sale agreements
5. All communications with **Daniel P. Kenny** (dpkenny@omwlaw.com, Ogden Murphy Wallace PLLC) related to:
   - The OFH property
   - Amendment to Transfer Option Agreement
   - PSH Omnibus Financing Resolution
   - City of Redmond-Plymouth Housing transactions
   - Any other real property transactions involving OFH or adjacent parcels
6. All communications with **Andrea Sato** (Kantor Taylor) related to the above
7. All budget documents, cost analyses, or fiscal impact assessments related to:
   - OFH building maintenance, renovation, or demolition costs
   - Teen services program costs
   - RCCMV transition costs
   - Property disposition revenue projections
8. All executive session agendas, minutes, and materials where the OFH property, OFH building disposition, or OFH teen services were discussed

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## SECTION 6: CHANNEL-SWITCHING COMMUNICATIONS

The prior production contains 52 instances of employees directing discussions about OFH off-email ("give me a call," "discuss in person," "let's take this offline"). Pursuant to *Nissen v. Pierce County* (2015), I request:

1. **All text messages** (SMS, iMessage, Signal, WhatsApp, or any other messaging application) sent or received by the following individuals related to OFH, teen services, or the OFH property, for the period **January 1, 2025 through present**:
   - Kyle Muir (kmuir@redmond.gov)
   - Derek Wing (dwing@redmond.gov)
   - Brant DeLarme (bdelarme@redmond.gov)
   - Erica Chua (echua@redmond.gov)
   - Jeff Hagen (jhagen@redmond.gov)
   - Zach Houvener (zhouvener@redmond.gov)
   - Lisa Maher (lmaher@redmond.gov)
   - Loreen Hamilton (lhamilton@redmond.gov)
   - Mayor Angela Birney
   - Malisa Files
   - All City Council members

2. **All Microsoft Teams, Slack, or other internal messaging platform communications** among the above individuals related to OFH

3. **All calendar entries, meeting invitations, and meeting notes/minutes** for meetings related to OFH, teen services, or the OFH property

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## SECTION 7: THE APRIL GAP AND BEYOND

The prior production effectively ends on March 30, 2025, with only 12 emails from April 8-10. Given that the March 25 City Council meeting generated significant public engagement and the matter remained active, I request:

1. **All records responsive to the original Request #32782 scope** for the period **March 31, 2025 through present**
2. All records related to any community engagement, workshops, or public meetings held after March 25, 2025 regarding OFH or teen services
3. All records related to any decisions made regarding the OFH building or property after March 25, 2025

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## SECTION 8: RECORDS RETENTION AND MANAGEMENT

1. The City of Redmond's **current email retention policy** and schedule
2. Any **litigation hold** or **records preservation** notices issued related to the OFH, teen services, or related topics
3. Any records documenting the **search methodology** used to identify and produce records responsive to Request #32782
4. The identity of the individual(s) who determined which records were responsive and/or exempt from production under Request #32782

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## LEGAL NOTICE

I note for the record that analysis of the prior production under Request #32782 demonstrates a pattern of incomplete production. Specifically:

- **10 City employees/officials** whose outgoing emails are provably missing (reply-to analysis)
- **73 individuals** who appear extensively in To/CC fields but have zero outgoing emails in the production
- **41 conversation threads** where only reply/forward messages exist but the originating message was not produced
- **4,109 email attachments** referenced but not provided
- **An effective cutoff date** of March 30, 2025 despite the matter remaining active

Under RCW 42.56.030, the Act must be liberally construed to promote access. Under RCW 42.56.550, wrongful denial subjects the agency to per-day penalties and mandatory attorney fee awards. Under RCW 40.16.020, willful destruction, concealment, or falsification of public records by a public officer is a Class B felony.

I request that the City conduct a thorough and good-faith search for all responsive records and preserve all records identified herein.

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**Response requested within 5 business days per RCW 42.56.520.**

Respectfully,

[YOUR NAME]
[ADDRESS]
[EMAIL]
[PHONE]

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*This request was prepared with the assistance of forensic document analysis of prior PRA production #32782, comprising 7,573 documents across four installments.*
