1803 South BoulevardHouston, Texas 77098
FRANCIS J. COLEMAN, JR.
Attorney at Law
The Honorable Greg AbbottTexas Attorney GeneralP. O. Box 12548Austin, Texas 78711-2548Attention: Open Records DivisionRe: AG ID# 351739; Texas Public Information request dated May 26, 2009, fromJennifer Peebles for information pertaining to the Houston Airport System, andthe Houston Airport System [sic] Development Corporation.Dear General Abbott:I am General Counsel to HAS Development Corporation, a Texas nonprofit corporation(“
”). My client’s name has been incorrectly referred to in prior correspondence withyour office. It is not “Houston Airport System Development Corporation” but “HASDevelopment Corporation.”I am writing with regard to the captioned request in response to a letter dated June 16, 2009 fromthe City of Houston Legal Department (“
City June 16 Letter
”). By a copy of the City June 16Letter mailed to me, Assistant City Attorney Evelyn W. Njuguna advised me that she had soughtyour office’s advice as to the exception from public disclosure of certain commercial or financialinformation of my client, a representative example of which is contained in Exhibit 3 to herletter.I received by mail a copy of the materials included in Exhibit 3 on June 23, 2009 (“
”). By your rules, I understand that I have ten (10) business days, or until July 8, 2009 torespond. As required by section 552.110(b) of the Act, I wish to demonstrate “based on specificfactual evidence that disclosure would cause substantial competitive harm to the person fromwhom the information was obtained.” Because of the complexity of the issues involved, I amincluding factual evidence in this letter addressing certain statutory exemptions under the Actidentified in the City June 16 Letter. In addition, HASDC believes other statutory exceptionsmay exist under the Act. Accordingly, I wish to reserve the right to supplement this letter untilthe end of ten (10) business days allowed by law (July 8, 2009).Because of the unique factual structure involved, I have prepared a “Background” section thatwill aid in understanding the “factual evidence” that follows, as is required by the Act.