BETTERGEORGIA.

COM
Monday, July 28, 2014

OPEN RECORDS ACT REQUEST

Via Fax Transmission to (404) 656-5948 & via First Class Mail

William Ryan Teague, Esq.
Executive Counsel
Office of the Governor
201 State Capital
Atlanta, Georgia 30335

RE: Request for records under Georgia Open Records Act

Dear Mr. Teague:

The Open Records Act, O.C.G.A. 50-18-70 et seq., requires that all documents,
papers, letters, maps, books, tapes, photographs, or similar material that is
maintained, prepared, or received by the Office of Governor in the course of its
operation be open for inspection by any citizen at a reasonable time and place. In
accordance with the Open Records Act, I am requesting an opportunity to review
and copy the following materials:

1. All written communication between you and Holly LaBerge regarding or
related in any way to any complaint against Nathan Deal that has or had
been filed with the Georgia Government Transparency and Campaign
Finance Commission, commonly called the Ethics Commission, related to
Nathan Deals 2010 campaign for Governor. The material requested
includes all written communication, regardless of its form, including
letters and similar paper correspondence as well as e-mails (and all
attachments to any e-mails), text messages, and instant messages (such as
Apples iMessage service). Material responsive to this request also includes
messages sent to or from any private cell phone that you may use,
messages sent to or from all private e-mail address you may use (including
but not limited to wrteague@gmail.com), and messages sent to or from
any private instant- messaging service you may use.

PLEASE NOTE that Governors Offices records subject to
disclosure under Georgias Open Records Act includes material
prepared and maintained or received by a private person (you) in
the performance of a service or function for or on behalf of the
Office of the Governor. See O.C.G.A. 50-18-70(b)(2).

PLEASE ALSO NOTE that you cannot claim that the attorney-client
privilege exempts these requested records from disclosure. The
attorney-client privilege protects from disclosure communications
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between a lawyer and that lawyers client. Ms. LeBerge is not your
client.

2. All written communication between you and Nathan Deal regarding or
related in any way to any complaint against Nathan Deal that has or had
been filed with the Georgia Government Transparency and Campaign
Finance Commission, commonly called the Ethics Commission, related to
Nathan Deals 2010 campaign for Governor. The material requested
includes all written communication, regardless of its form, including
letters and similar paper correspondence as well as e-mails (and all
attachments to any e-mails), text messages, and instant messages (such as
Apples iMessage service). Material responsive to this request also includes
messages sent to or from any private cell phone that you may use,
messages sent to or from all private e-mail address you may use (including
but not limited to wrteague@gmail.com), and messages sent to or from
any private instant- messaging service you may use.

PLEASE NOTE that Governors Offices records subject to
disclosure under Georgias Open Records Act includes material
prepared and maintained or received by a private person (you) in
the performance of a service or function for or on behalf of the
Office of the Governor. See O.C.G.A. 50-18-70(b)(2).

PLEASE ALSO NOTE that you cannot claim that the attorney-client
privilege exempts these requested records from disclosure. The
attorney-client privilege protects from disclosure communications
between a lawyer and that lawyers client. You are the Governors
Executive Counsel. That is a position in state government created
by statute. See O.C.G.A. 45-12- 55. Your client is the Office of the
Governor, not the man Nathan Deal. Any communication between
you and Nathan Deal regarding alleged personal misconduct by him
would not be covered by the attorney-client privilege because he is
not your client; the Office of the Governor is. You are paid to
provide legal counsel to Nathan Deal regarding his official actions
when he as acting in his official capacity as Governor of the State of
Georgia. You are not paid by the State of Georgia to provide counsel
to the man Nathan Deal related to his personal conduct, conduct
that does not involve his exercise of the official powers of the Office
of the Governor.

3. All written communication between Chris Riley and Holly LaBerge
regarding or related in any way to any complaint against Nathan Deal that
has or had been filed with the Georgia Government Transparency and
Campaign Finance Commission, commonly called the Ethics Commission,
related to Nathan Deals 2010 campaign for Governor. The material
requested includes all written communication, regardless of its form,
including letters and similar paper correspondence as well as e-mails (and
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all attachments to any e-mails), text messages, and instant messages (such
as Apples iMessage service). Material responsive to this request also
includes messages sent to or from any private cell phone that Mr. Riley
may use, messages sent to or from all private e-mail address Mr. Riley may
use, and messages sent to or from any private instant-messaging service
that Mr. Riley may use.

PLEASE NOTE that Governors Offices records subject to
disclosure under Georgias Open Records Act includes material
prepared and maintained or received by a private person (Mr.
Riley) in the performance of a service or function for or on behalf of
the Office of the Governor. See O.C.G.A. 50-18-70(b)(2).

4. All written communication between any employee of the Office of the
Governor and Holly LaBerge regarding or related in any way to any
complaint against Nathan Deal that has or had been filed with the Georgia
Government Transparency and Campaign Finance Commission,
commonly called the Ethics Commission, related to Nathan Deals 2010
campaign for Governor. The material requested includes all written
communication, regardless of its form, including letters and similar paper
correspondence as well as e-mails (and all attachments to any e-mails),
text messages, and instant messages (such as Apples iMessage service).
Material responsive to this request also includes messages sent to or from
any private cell phone, messages sent to or from all private e-mail address,
and messages sent to or from any private instant-messaging service.

PLEASE NOTE that Governors Offices records subject to
disclosure under Georgias Open Records Act includes material
prepared and maintained or received by a private person (Mr.
Riley) in the performance of a service or function for or on behalf of
the Office of the Governor. See O.C.G.A. 50-18-70(b)(2).

I believe that none of the material that I am requesting is covered by the
exemptions specified in O.C.G.A. 50-18-72. If you disagree, please provide a
detailed written description of the material that you contend is exempt from
disclosure. Please also identify the statutory provision that you contend
authorizes you to refuse to produce the material for inspection and copying so
that I can evaluate the reasonableness of your denying access to the information.
The Open Records Act guarantees the right of citizens to reproduce records,
subject to a payment of costs based upon the most economical means available
for providing copies of records. If the cost for obtaining copies of the requested
records does not exceed $500, please copy the records and mail them to me
(Better Georgia, P.O. Box 1982, Athens, GA 30603-1982) with an invoice and I
will promptly send payment for the costs. Otherwise, please advise me of any
costs that you plan to assess to respond to my request and state the basis for
computing the charges utilizing the method specified in O.C.G.A. 50-18-71 and
wait for my approval before incurring any costs.
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I eagerly anticipate receiving these records within three business days in
accordance with O.C.G.A. 50-18-71(b).

Thank you for your assistance.

Sincerely,

Bryan Long

Executive Director
Better Georgia