Petition For Writ of Mandamus KSAT Lawsuit

CAUSE NO.
__________________
TEXAS TRIBUNE, § IN THE DISTRICT COURT OF

ABC NEWS, §
CBS NEWS, §
CABLE NEWS NETWORK, INC., §
DOW JONES & CO., §
THE E.W. SCRIPPS COMPANY, §
GANNETT CO., INC., §
GRAHAM MEDIA GROUP, HOUSTON, §
GRAHAM MEDIA GROUP, SAN ANTONIO, §
HEARST NEWSPAPERS, LLC, §
NBC NEWS, §
THE NEW YORK TIMES CO., §
PRO PUBLICA, INC., §
SINCLAIR BROADCAST GROUP, INC., §
TEGNA INC., §
TELEVISAUNIVISION, §
THE WASHINGTON POST §
§
Plaintiffs, §
§
v. § UVALDE COUNTY, TEXAS
§
CITY OF UVALDE, §
UVALDE CONSOLIDATED INDEPENDENT §
SCHOOL DISTRICT, §
UVALDE COUNTY SHERIFF’S OFFICE, §
§
Defendants. § _____ JUDICIAL DISTRICT
PETITION FOR WRIT OF MANDAMUS
TO THE HONORABLE COURT:
Plaintiffs Texas Tribune; ABC News; CBS News; Cable News Network, Inc.; Dow Jones
& Co.; The E.W. Scripps Company; Gannett Co., Inc.; Graham Media Group, Houston; Graham
Media Group, San Antonio; Hearst Newspapers, LLC; NBC News; The New York Times Co.; Pro
Publica, Inc.; Sinclair Broadcast Group, Inc.; TEGNA Inc.; TelevisaUnivision; and The
Washington Post (collectively “Plaintiffs”) are a coalition of news media organizations (“Media
Coalition”) who collectively bring this action against the Defendants, City of Uvalde (the “City”),
PETITION FOR WRIT OF MANDAMUS Page 1

Uvalde Consolidated Independent School District (“UCISD” or the “District”), and the Uvalde
County Sheriff’s Office (“UCSO” or the “Sheriff’s Office”) seeking a writ of mandamus to compel
the disclosure of public information under the Texas Public Information Act (“the Act”).
DISCOVERY LEVEL
1. Pursuant to TEX. R. CIV. P. 190.1, discovery is expected to be conducted under
Level 2.
JURISDICTION AND VENUE
2. This Court has jurisdiction over this action pursuant to Section 552.321 of the Act,
which allows a requestor of public information to file suit in a district court for a writ of mandamus
to compel a governmental body to make information available for public inspection if the
governmental body refuses to supply the public information.
3. Venue is proper in Uvalde County, Texas under Section 552.321(b) of the Act,
because the main office of each Defendant is located in Uvalde County.
PARTIES
4. Plaintiff The Texas Tribune (“Texas Tribune”) is a news media organization
primarily engaged in disseminating information to the public. The Texas Tribune is incorporated
under the laws of Texas. The Texas Tribune employs dozens of journalists in Texas and distributes
its product throughout the state.
5. Plaintiff ABC News (“ABC News”) is a news media organization primarily
engaged in disseminating information to the public. ABC News is incorporated under the laws of
Delaware as American Broadcasting Companies, Inc. d/b/a ABC News. ABC News employs
several journalists in Texas and distributes its product throughout the state.

6. Plaintiff CBS News (“CBS News”) is a news media organization primarily engaged
in disseminating information to the public. CBS News is a division of CBS Broadcasting Inc.,
which is incorporated under the laws of Delaware. CBS News employs several journalists in Texas
and distributes its product throughout the state.
7. Plaintiff Cable News Network, Inc. (“CNN”) is a news media organization
primarily engaged in disseminating information to the public. CNN is incorporated under the laws
of Delaware. CNN employs several journalists in Texas and distributes its product throughout the
state.
8. Plaintiff Dow Jones & Co. (“Dow Jones”) is a news media organization primarily
engaged in disseminating information to the public. Dow Jones & Co. is incorporated under the
laws of Delaware. Dow Jones & Co. employs several journalists in Texas and distributes its
product throughout the state.
9. Plaintiff The E.W. Scripps Company (“Scripps”) is a news media organization
incorporated under the laws of Ohio and the parent company to Media Convergence, Inc., d/b/a
Newsy, which is incorporated under the laws of Delaware. Newsy operates in Texas and distributes
its product throughout the state.
10. Plaintiff Gannett Co., Inc. (“Gannett”) is a news media organization primarily
engaged in disseminating information to the public. Gannett is incorporated under the laws of
Delaware. Gannett subsidiaries own and operate a number of media properties in Texas, including
the Austin-American Statesman, The Abilene Reporter-News, Corpus Christi Caller-News, The
El Paso Times, San Angelo Standard-Times, Times Record News (Wichita Falls), the Amarillo
Globe-News, and the Lubbock Avalanche-Journal, as well as USA Today.

11. Plaintiffs Graham Media Group, Houston and Graham Media Group, San Antonio
(collectively “Graham”) are news media organizations primarily engaged in disseminating
information to the public. Graham Media Group, Houston and Graham Media Group, San Antonio
are incorporated under the laws of Delaware. Graham Media Group, Houston owns and operates
KPRC (Houston). Graham Media Group, San Antonio owns and operates KSAT (San Antonio).
12. Plaintiff Hearst Newspapers, LLC, (“Hearst”) is a news media organization
primarily engaged in disseminating information to the public. Hearst is incorporated under the
laws of Delaware. Hearst owns and operates a number of media properties in Texas, including the
San Antonio Express-News and Houston Chronicle.
13. Plaintiff NBC News (“NBC News”) is a news media organization primarily
engaged in disseminating information to the public. NBC News is a division of NBCUniversal
Media, LLC, which is incorporated under the laws of Delaware. NBC News employs several
journalists in Texas and distributes its product throughout the state.
14. Plaintiff The New York Times Co. (“New York Times”) is a news media
organization primarily engaged in disseminating information to the public. The New York Times
Co. is incorporated under the laws of New York. The New York Times Co. employs several
journalists in Texas and distributes its product throughout the state.
15. Plaintiff Pro Publica, Inc. (“ProPublica”) is a news media organization primarily
engaged in disseminating information to the public. ProPublica is a 501(c)(3) nonprofit
incorporated under the laws of Delaware. ProPublica employs several journalists in Texas and
distributes its product throughout the state.
16. Plaintiff Sinclair Broadcast Group, Inc. (“Sinclair”) is a news media organization
primarily engaged in disseminating information to the public. Sinclair Broadcast Group is

incorporated under the laws of Maryland. Sinclair Broadcast Group owns, operates and/or provides
services to a number of media properties in Texas, including WOAI-TV (San Antonio), KABB
(San Antonio), KMYS (San Antonio), KEYE-TV (Austin), KFOX-TV (El Paso), KDBC-TV (El
Paso), KBTV-TV (Beaumont/Port Arthur), KVII-TV (Amarillo), and KTXS-TV (Sweetwater).
17. Plaintiff TEGNA Inc. (“TEGNA”) is a news media organization primarily engaged
in disseminating information to the public. TEGNA Inc. is incorporated under the laws of
Delaware. TEGNA Inc. owns and operates a number of media properties in Texas, including
WFAA (Dallas), KHOU (Houston), KENS (San Antonio), KVUE (Austin) KAGS (Bryan/College
Station), KCEN (Waco), KYTX (Tyler), KIII (Corpus Christi), KWES (Midland/Odessa), KBMT
(Beaumont), and KIDY/KXVA (San Angelo).
18. Plaintiff TelevisaUnivision (“TelevisaUnivision”) is a news media organization
primarily engaged in disseminating information to the public. TelevisaUnivision is incorporated
under the laws of Delaware. TelevisaUnivision owns and operates a number of media properties
in Texas, including KWEX-DT (San Antonio), KAKW-DT (Austin), KXLN-DT (Houston), and
KUVN-DT (Dallas-Fort Worth).
19. Plaintiff The Washington Post (“Washington Post”) is a news media organization
primarily engaged in disseminating information to the public. The Washington Post is incorporated
under the laws of Delaware under the entity name WP Company LLC d/b/a The Washington Post.
The Washington Post employs journalists in Texas and distributes its product throughout the state.
20. Defendant City of Uvalde (the “City”) is a “governmental body” for purposes of
the Act. The City comprises the Uvalde Police Department and Uvalde Mayor’s Office, among
other agencies. The City may be served at 101 E. Main Street, Uvalde, Texas 78801. Plaintiffs
request that the clerk issue a citation to be served on the City at the above address.

21. Defendant Uvalde Consolidated Independent School District (“UCISD” or the
“District”) is a “governmental body” for purposes of the Act. The District may be served at 1000
N. Getty Street, Uvalde, Texas 78801. Plaintiffs request that the clerk issue a citation to be served
on the District at the above address.
22. Defendant Uvalde County Sheriff’s Office (“UCSO” or the “Sheriff’s Office”) is a
“governmental body” for purposes of the Act. The Sheriff’s Office may be served at 339 King
Fisher Lane #1, Uvalde, Texas 78801. Plaintiffs request that the clerk issue a citation to be served
on the Sheriff’s Office at the above address.
NATURE OF ACTION
23. This is a suit arising under the Texas Public Information Act regarding numerous
public information requests related to the murder of 19 children and 2 teachers at Robb Elementary
School in Uvalde, Texas, and the ensuing failure to disclose public records concerning this
abhorrent tragedy.
24. In response to these requests, Defendants have declined to release a broad swath of
information related to the events at Robb Elementary, claiming these records are exempt from
disclosure under various exceptions contained in the Public Information Act.
25. Plaintiffs seek a writ of mandamus ordering Defendants to produce all responsive
records, pursuant to § 552.321.
STATEMENT OF FACTS
26. On May 24, 2022, 19 students and 2 teachers were murdered — and 17 others were
injured — inside Robb Elementary School in Uvalde, Texas, by an 18-year-old gunman.
27. After more than 77 minutes in which the gunman slaughtered his helpless victims,
he was shot and killed. There is no ongoing criminal investigation into the gunman.

28. In the immediate aftermath of the tragedy, and continuing throughout the ensuing
three months, Defendants have consistently resisted releasing any meaningful information in
response to the Requests regarding the events of that day — despite the awful reality that some
376 members of law enforcement responded to the tragedy, including dozens of officers from the
Uvalde Police Department, UCISD Police Department, and the Uvalde County Sheriff’s Office. 1
29. The obfuscation and inaction have only prolonged the pain of victims, their families
and the community at large, all of whom continue to cry out for transparency regarding the events
of that day. 2
30. The Uvalde community and citizens of Texas deserve answers and the opportunity
to heal from this horrific tragedy. It is impossible to resuscitate the community’s trust in law
enforcement or public officials while the facts of that fateful day continue to be hidden, protected
from scrutiny and accountability. 3
The City of Uvalde has not accounted for the role of its police officers
31. Defendant the City of Uvalde has not provided clarity regarding the actions of
Uvalde Police Department officers, even as the City has paid lip service to the idea of transparency.
1
According to the House Committee Report, 25 officers from the Uvalde Police Department responded to the scene
at Robb Elementary, along with 16 members of the Uvalde County Sheriff’s Office, and 5 officers from the UCISD
Police Department. See TEXAS HOUSE OF REPRESENTATIVES, INVESTIGATIVE COMMITTEE ON THE ROBB ELEMENTARY
SHOOTING, Interim Report 2022, at 65 (2022).
2
See, e.g., Laura Romero and Samira Said, Uvalde families demand answers from City Council during heated hearing,
ABC NEWS, June 30, 2022, https://abcnews.go.com/US/uvalde-families-demand-answers-city-
council/story?id=86045264 (“We’re looking for some answers that nobody seems to be getting and it’s just making
Uvalde PD and everybody else look even more guilty,” said Berlinda Arreola, grandmother of Amerie Jo Garza, one
of the students who died); Claire Bryan, 4 grievances filed against Uvalde school superintendent in aftermath of Robb
Elementary shooting, SAN ANTONIO EXPRESS-NEWS, July 23, 2022,
https://www.expressnews.com/news/local/article/Uvalde-school-superintendent-grievances-17390946.php (reporting
that “five people called on the board to be more transparent and to hold the superintendent accountable” during public
comments).
3
Claire Bryan, 4 grievances filed against Uvalde school superintendent in aftermath of Robb Elementary shooting,
SAN ANTONIO EXPRESS-NEWS, July 23, 2022, https://www.expressnews.com/news/local/article/Uvalde-school-
superintendent-grievances-17390946.php (quoting a Uvalde parent stating: “I told him the longer this lasts, the longer
the pain is going to last for these people — even myself. It causes pain when we remember nothing has been done.
Something needs to happen.”).

32. Twenty-five police officers from the Uvalde Police Department responded to Robb
Elementary on May 24, 2022, and several of those were among the first to arrive at the school, just
minutes after the shooter entered.
33. Beginning on May 25, 2022, Plaintiffs submitted dozens of Public Information Act
requests to Defendants, for the purpose of informing the public about the events at Robb
Elementary. See Exh. A. Collectively, Plaintiffs’ requests seek the following categories of
information:
• Recordings of 911 calls, radio traffic, computer-aided dispatch (CAD) notes,

call slips and other communications reporting and responding to the incidents
at 715 Old Carrizo Rd., 552 Diaz St., and several other local addresses, on May
24, 2022 and prior;
• Recordings of body camera footage and dashboard camera footage from

responding officers;
• Police reports and incident reports related to the events at Robb Elementary,
along with several addresses and individuals;
• Rosters, calendars, communications, training materials, use-of-force reports

and personnel records related to certain current and former Uvalde Police
officers;
• Ballistics reports and evidence logs related to events at Robb Elementary on

May 24, 2022;
• Police reports and any recordings of calls regarding a suspicious person or

vehicle in the area of Robb Elementary between May 9 and May 23, 2022;
• Surveillance footage from inside Robb Elementary, and schematics and floor
plans of the school;
• Text, email and other communications sent to or from certain City of Uvalde
officials, including Mayor of Uvalde Don McLaughlin, UPD Chief of Police
Daniel Rodriguez and Lieutenants Javier Martinez and Donald Page, City
Councilpersons, City Attorney and other City staff;
• Investigative file for an alleged school-shooting plot in 2018; and
• Any contracts between the City and unions representing police officers.

34. On June 16, 2022, the City submitted a letter to the Attorney General asserting its
belief that the City may withhold responsive records pursuant to TEX. GOV’T CODE §§ 552.101,
552.103, 552.107, 552.108, 552.1175, 552.130, 552.136, and 552.152. See Exh. B. In response,
Plaintiffs submitted a brief to the Attorney General on July 12, 2022. See Exh. C. On August 12,
2022, the Attorney General issued an Open Records ruling that allowed the City to withhold certain
information under § 552.108 and other limited exceptions but rejected the City’s assertion that it
may withhold all responsive information under §§ 552.108 and 552.103. See Tex. Att’y Gen.
OR2022-24126, attached as Exh. D. The Attorney General also rejected the City’s request to
withhold certain information under §§ 552.108(b)(1), 552.108(a)(1), 552.101, 552.117(a)(2), and
552.152. Although Plaintiffs do not believe the City has met its burden with regard to any
exceptions, it is worth noting that to date Plaintiffs have received no documents in response to the
AG ruling.
35. In response to Plaintiffs’ requests and the community’s demand for answers, the
Mayor of Uvalde, Don McLaughlin, has stated that the City and its Police Department “strive for
transparency.” Yet the City of Uvalde has not provided Plaintiff with any meaningful information
in response to their requests.
36. The City’s lack of transparency has created a vacuum of reliable information that
has repeatedly led to the release of misinformation. State officials initially misstated the number
of deaths and the amount of time that officers were in the school, along with mischaracterizing the
speed of officers’ response to the shooter. They also incorrectly stated that officers had engaged
the shooter on the way into the school. None of this information was true.
37. Upon seeing these initial misstatements, the City could have proactively provided
facts regarding the events of that day, but instead City officials chose to continue withholding

information. The lack of reliable information led to further misstatements regarding whether a
teacher left an exterior door unlocked, whether an interior door was properly maintained and
locked at the time of the shooting, and whether officers had an opportunity to shoot at the attacker
on his way into the school. The volume of misinformation has prolonged the frustration of families
and led to accusations of a “cover up” among government agencies.
38. Mayor McLaughlin has acknowledged this torrent of misinformation, and he has
publicly expressed his frustration with the Texas Department of Public Safety for releasing
allegedly self-serving details about its investigation. At a public meeting of the Uvalde City
Council on June 21, 2022, Mayor McLaughlin publicly accused DPS of leaking information, and
stated the City would respond by releasing information to set the record straight. “The gloves are
off. If we know it, we will share it,” he said. 4 Despite this promise, the City has declined to share
information in its possession with the public.
39. To explain the City’s lack of transparency, Mayor McLaughlin has repeatedly said
that the City is withholding information upon the request of 38th Judicial District Attorney,
Christina Mitchell Busbee, who has stated that all information should be withheld until any
potential prosecution is complete—acknowledging that process will likely takes years. Mayor
McLaughlin has suggested, incorrectly, that the City could be subject to criminal prosecution or a
gag order for releasing information prior to the convening of a grand jury.
40. On June 28, 2022, Plaintiffs sent a letter to Mayor McLaughlin, explaining that City
officials are not required by the Texas Public Information Act (or any other law) to await the
completion of an investigation before releasing public information. See Exh. E. In fact, as the letter
pointed out, many jurisdictions release footage from police body cameras and other information
4
William Melhado, Uvalde mayor accuses state of leaking records to make local police look bad, TEX. TRIBUNE, June
21, 2022, https://www.texastribune.org/2022/06/21/uvalde-shooting-mayor-pete-arredondo/.

within 10 or 30 days as a matter of policy.
41. Mayor McLaughlin has stated he will honor the District Attorney’s request to
indefinitely withhold information, but he has also refused to commit to releasing information upon
the conclusion of that investigation, saying only that the City will “evaluate release of City records”
at that time. 5
42. The City does not have unilateral authority under the law to withhold documents
based only on the request of a District Attorney, nor does it have power to forever withhold public
information following a completed investigation.
Defendants UCISD and UCSO have refused to release any information regarding school
safety and the conduct of responding officers
43. Similarly, Defendants UCISD and the UCSO have refused to release information
that could shed light on the safety preparations at Robb Elementary and the actions of officers and
sheriff’s deputies who responded to the scene.
44. Numerous reports have raised questions about UCISD’s safety protocols and the
maintenance of locks at Robb Elementary. In addition, officers from the UCISD Police Department
were some of the first to respond to the incident, and several responding officers have stated they
believed UCISD’s Chief of Police, Pete Arredondo, was acting as the on-scene incident
commander during the response.
45. Beginning on May 25, 2022, Plaintiffs submitted numerous PIA requests to UCISD
seeking information regarding the District’s safety protocols, maintenance reports, and the
response of its officers. See Exh. F. Collectively, Plaintiffs’ requests seek the following categories
of information:
5
Uvalde mayor says records related to school shooting will not be released, KENS5, June 21, 2022,
https://www.kens5.com/article/news/special-reports/uvalde-school-shooting/uvalde-records-robb-elemenetary-
school-shooting-investigation-texas/273-3af6c04e-de3c-45f0-a3e3-f184950e9552

• Records of any and all calls for service made to the Uvalde CISD Police
Department from January 2018 to May 25, 2022;
• Records and recordings of any and all 911 calls made to the Uvalde CISD Police
Department on May 24, 2022;
• Evidence logs or other documents that account for evidence collected related to
the shooting at Robb Elementary on May 24, 2022;
• Records showing which UCISD Police Department personnel were on duty on

May 24, 2022, along with their location and duty assignment;
• Recordings of any and all body-worn camera videos from Uvalde CISD Police
officers responding to Robb Elementary School from May 24, 2022;
• All footage from interior and exterior security cameras at Robb Elementary
School on May 24, 2022;
• Text messages sent or received by UCISD Police Chief Pete Arredondo, and
phone records, including call logs for the phone used by Chief Arredondo on
May 24, 2022;
• The personnel file of Chief Arredondo;
• Recordings of any and all threats reported to the UCISD Police Department
from January 1, 2018 to May 25, 2022;
• The most recent floor plans of Robb Elementary School;
• All use-of-force reports, probable cause affidavits and/or Page 1 reports

regarding any and all arrests made by the UCISD Police Department from
January 1, 2018 to May 25, 2022;
• Any and all maintenance records, maintenance record requests, and/or work
orders for door locks at Robb Elementary School over the past five years;
• Emails, memos, and any other records that mention “magnets,” “door stops,”
or “locks” to keep doors open at Robb Elementary School;
• All work orders for classrooms 111 and 112 at Robb Elementary School over
the past five years;
• All current policies and procedures, as well as the general manual for the
UCISD Police Department;

• Any current Memoranda of Understanding (MOUs) or Memoranda of
Agreement (MOAs) between UCISD and any other law enforcement agency;
• All available student records for Salvador Ramos, and any correspondence or
police reports that mention him;
• Personnel file of Cecilia Martinez Gonzalez;
• Notices of claim or other correspondence received by UCISD since May 24,

2022, that reflect contemplated or expected legal actions against employees of
UCISD or UCISD more broadly;
• Communications, including emails, texts, voicemails, and other messages sent

to or from UCISD police officers, UCISD’s superintendent and deputy
superintendent, UCISD executive director of communications, and the principal
of Robb Elementary between May 27 and June 27, 2022; and
• Records related to the termination of Chief Arredondo, including

correspondence between the District and Arredondo.
46. On July 7, 2022, UCISD submitted the first of at least four letters to the Attorney
General (including letters sent on July 11, August 4, August 26), which collectively assert the
District’s belief that it may withhold records responsive to these requests, pursuant to TEX. GOV’T
CODE §§ 552.101, 552.103, 552.1315, and 552.108, along with sections of the Family Code. 6 See
Exh. G. In response, Plaintiffs submitted a brief to the Attorney General on July 29, 2022. See
Exh. H.
47. Beginning on May 25, 2022, Plaintiffs submitted numerous PIA requests to UCSO
seeking information regarding the Sheriff’s Office response to the events at Robb Elementary and
its previous interactions with the shooter. See Exh. I. Collectively, Plaintiffs’ requests seek the
following categories of information:
• Copies of all incident and corresponding reports related to calls made to Robb
Elementary School;
6
While UCISD received requests at the same time as the other Defendants, UCISD filed two “catastrophe notices”
with the Attorney General, which tolled its deadline to respond by a total of two weeks.

• Recordings of the 911 calls and sheriff's dispatch radio logs and traffic;
• Copies of body camera, dashboard and other unit camera footage;
• Ballistics reports and evidence logs related to events at Robb Elementary on May
24, 2022;
• Use-of-force reports and policies;
• Any current Memoranda of Understanding (MOUs) or Memoranda of Agreement

(MOAs) between UCISD and any other law enforcement agency;
• Any contracts between the City and unions representing police officers;
• Any recordings of calls or reports of interactions between law enforcement and

Salvador Ramos and Adriana Martinez Reyes;
• Text, email and other communications sent to or from Sheriff Nolasco and Sheriff’s
Office deputies from May 24 to May 26, 2022; and
• Any and all 911 calls originating from the 1500 block of Hood Street since May 1,
2017.
48. On June 16, 2022, UCSO submitted a letter to the Attorney General asserting its
belief that the Sheriff’s Office may withhold responsive records pursuant to TEX. GOV’T CODE
§§ 552.108, 552.111, 441.084, 552.109, 552.117, and 552.102. See Exh. J. In response, Plaintiffs
submitted a brief to the Attorney General on July 29, 2022. See Exh. K.
49. Like UCISD, UCSO also has not accounted for the role of the Sheriff and its
deputies in response to the tragedy. The Sheriff’s Office has not released any documents in
response to Plaintiffs’ requests and its actions on May 24 remain shrouded in secrecy.
50. At least 16 members of the Sheriff’s Office responded to Robb Elementary,
including one deputy who joined the team of Border Patrol agents that stormed the classroom and
killed the shooter. In addition, sheriff’s deputies had previously responded to a call regarding a

disagreement between the shooter and his mother. 7
51. Neither the UCISD nor the UCSO have provided meaningful information in
response to Plaintiffs’ requests.
52. UCISD Superintendent, Hal Harrell, made his first public appearance before the
Uvalde community on July 19, 2022, when he acknowledged the District had not properly
responded to the community’s questions and concerns. “In hindsight, this meeting should have
happened earlier. I apologize that it did not,” Harrell said. “Trying to find the right time, the right
balance out of respect, I did not do well.” 8 A subsequent board meeting was cancelled without
explanation.
53. At a board meeting on August 22, 2022, the Uvalde community continued to call
for transparency and accountability. The meeting was attended by approximately 50 people, and
at least five attendees called on the District to be more transparent and to hold the superintendent
accountable. 9
54. Uvalde County Sheriff, Ruben Nolasco, has said even less regarding his actions
and the performance of his deputies. Sheriff Nolasco did not appear before the Senate Special
Committee to Protect All Texans, and he initially ignored requests to testify before the House
Committee investigating the response. Sheriff Nolasco only agreed to testify after the Committee
chairman issued a notice of deposition seeking to compel his testimony, and his office refused to
provide certain records that were requested by the House Committee.
55. Defendants UCISD and UCSO also appear to be withholding information at the
7
TEXAS HOUSE OF REPRESENTATIVES, INVESTIGATIVE COMMITTEE ON THE ROBB ELEMENTARY SHOOTING, Interim
Report 2022, at 34 (2022).
8
Camille Phillips, Uvalde families tell school leaders they’ve lost their trust, TEXAS PUBLIC RADIO, July 19, 2022,
https://www.tpr.org/education/2022-07-19/uvalde-families-tell-school-leaders-theyve-lost-their-trust
9
superintendent-grievances-17390946.php

request of the District Attorney, despite the fact that much of the information they possess would
not have any impact on a potential criminal investigation into the shooter, who is deceased.
The House Committee Report Raises Additional Questions that Can Only
Be Answered By Complete Transparency
56. On July 17, 2022, the Texas House of Representatives’ Investigative Committee on
the Robb Elementary Shooting released its Interim Report (the “House Report”). 10 The House
Report provided the first window into the actions of responding officers from all law enforcement
agencies, including those of Defendants.
57. Release of the House Report demonstrated the immediate impact transparency can
have on government officials, as agencies—including Defendants—that had previously taken no
action in response to the tragedy suddenly reacted to the House Report.
58. On the same day the House Report was released, the City of Uvalde released edited
body camera footage recorded by seven of its officers. 11 City officials have not explained why
they chose to release this set of recordings—in apparent defiance of the District Attorney’s request
to withhold all information pending prosecution—but have chosen to withhold other recordings
and documents that will clearly have no effect on any potential prosecution.
59. On the same day, the City of Uvalde placed Uvalde Police Department Lieutenant
Mariano Pargas on administrative leave, pending an independent review of all UPD officers. Lt.
Pargas was acting chief on May 24, and the House Report stated that Lt. Pargas and other officers
were aware of the 911 calls coming from the classrooms as officers stood in the hallway for more
than 70 minutes.
10
Report 2022 (2022).
11
Marcelino Benito, Uvalde PD body camera paints picture of chaos from multiple agencies , KHOU11, July 17,
2022, https://www.khou.com/article/news/special-reports/uvalde-school-shooting/uvalde-video/body-camera-
footage-uvalde-school-shooting/285-71e79210-0076-488d-ba5d-75dde4ab516d

60. While the House Report and the City’s seven body cameras shed some much-
needed light on the actions of Defendants, it also raised additional questions that can only be
answered by a full transparent accounting of all of their actions.
61. For instance, Sheriff Nolasco’s testimony to the Committee did little to clarify his
own actions, and those of his deputies. According to the House Report, Sheriff Nolasco testified
that he was en route to Robb Elementary when a man in a vehicle flagged him down and told him
about the shooting on Diaz Street (where the attacker shot his grandmother). However, as noted in
the Report, “[o]ther information provided to the Committee has suggested that Sheriff Nolasco
learned about the shooting on Diaz Street by other means, and perhaps earlier than he has
acknowledged.” 12 The Committee noted that it had requested records of the Sheriff’s mobile
phones in order to confirm Sheriff Nolasco’s account but had yet to receive those records.
62. One week after the release of the House Report, on July 25, 2022, Uvalde County
commissioners voted unanimously to conduct an independent review of the Sheriff’s Office.
However, commissioners stated that investigation is unlikely to commence for at least six
months. 13 In the meantime, Sheriff Nolasco has declined to comment to reporters.
63. Defendant UCISD responded to the House Report by suspending the principal of
Robb Elementary, Mandy Gutierrez, who was criticized in the House Report for not properly
maintaining a classroom door lock, only to reinstate her several days later when Ms. Gutierrez
stated that the lock did, in fact, function properly. 14
12
Report 2022, at 48 fn.145 (2022).
13
Guillermo Contreras, Uvalde County OKs review of Sheriff’s Office over mass shooting, SAN ANTONIO EXPRESS-
NEWS, Aug. 16, 2022, https://www.expressnews.com/news/local/article/Uvalde-school-shooting-sheriff-
17375195.php
14
Bonnie Petrie and Dan Katz, Uvalde’s Robb Elementary School Principal Mandy Gutierrez reinstated days after
suspension, TEXAS PUBLIC RADIO, July 29, 2022, https://www.tpr.org/government-politics/2022-07-29/uvaldes-robb-
elementary-school-principal-mandy-gutierrez-reinstated-days-after-suspension.

64. The revelations in the House Report have not resolved the concerns of the Uvalde
community but have only intensified their call for full transparency and accountability.
65. At the special meeting called by UCISD on July 19, 2022, numerous parents
complained they had yet to receive answers regarding the District’s safety measures and the role
of its responding officers, who continue to be employed by the District for the upcoming school
year. “So I ask you: What are you going to do about your failures?” Rachel Martinez, the mother
of four children, asked district officials. “Are you going to take responsibility? Are you going to
make this right?” 15
66. More than a month later, those concerns remained unresolved. At a board meeting
on August 22, 2022, parents urged the board to hold its meetings in public, and to promote
accountability. “It causes pain when we remember nothing has been done. Something needs to
happen,” said Uvalde parent Adam Martinez. 16
67. Similarly, at the Uvalde County Commissioners meeting on July 25, 2022, parents
of the victims questioned the lack of transparency and criticized the Sheriff and District Attorney
for not attending the meeting to answer their questions. “We don’t trust these officers to make
decisions for our county, for our city or our schools and everything like that,” said Brett Cross,
guardian of 10-year-old Uziyah Garcia, one of the 19 slain students. “We need justice. Nobody
has given it to us. Nobody is accepting accountability.” 17
15
Uriel J. Garcia and Jaden Edison, “What are you going to do about your failures?”: Uvalde parents demand answers
at school board meeting, TEX. TRIBUNE, July 18, 2022, https://www.texastribune.org/2022/07/18/uvalde-school-
shooting-parents-officials/
16
superintendent-grievances-17390946.php
17
Guillermo Contreras, Uvalde County OKs review of Sheriff’s Office over mass shooting, SAN ANTONIO EXPRESS-
NEWS, Aug. 16, 2022, https://www.expressnews.com/news/local/article/Uvalde-school-shooting-sheriff-
17375195.php

68. On August 24, 2022, the Uvalde school board agreed in executive session to
terminate Chief Arredondo’s employment with the District. More than 100 people attended the
meeting and those who were allowed to speak during a brief public comment period called for the
deliberations to be conducted in public. The board instead made its decision behind closed doors.18
69. While the audience at the school board meeting applauded the firing of Chief
Arredondo, the Uvalde community continues to demand transparency. After the applause, there
were shouts of “We’re not done,” along with continuing questions about how officials failed in
their preparation and response. “Why did [Superintendent Harrell] not know there were issues with
doors and keys and locks and people not following policy at the campus level?” asked Diana
Olvedo-Karau, a lifelong Uvalde resident. 19
The Requested Records Are Public Information
70. Under Texas law, information about the affairs of government is presumed to be
public. The Preamble to the Texas Public Information Act makes clear: “The people, in delegating
authority, do not give their public servants the right to decide what is good for the people to know
and what is not good for them to know.” TEX. GOV’T CODE § 552.001(a). Instead, the declared
public policy of the state of Texas is that “each person is entitled, unless otherwise expressly
provided by law, at all times to complete information about the affairs of government and the
official acts of public officials and employees.” Id.
71. To effectuate that policy, the provisions of the Public Information Act “shall be …
liberally construed in favor of granting a request for information.” Id. at §§ 552.001(a)-(b)
18
Brian Lopez and William Melhado, Uvalde school board fires Chief Pete Arredondo over shooting response, after
he calls vote a “public lynching,” TEXAS TRIBUNE, Aug. 24, 2022, https://www.texastribune.org/2022/08/24/uvalde-
school-police-chief-pete-arredondo-termination-board-vote/.
19
Brian Lopez, “We’re not done”: Uvalde residents say the fight for accountability won’t stop with Pete Arredondo’s
firing, TEXAS TRIBUNE, Aug. 25, 2022, https://www.texastribune.org/2022/08/25/pete-arredondo-firing-aftermath/.

(emphasis added).
The Attorney General’s ruling does not constrain the trial court
72. The Attorney’s General ruling that Defendants City of Uvalde and Uvalde County
Sheriff’s Office may withhold certain records does not deny this court of jurisdiction or otherwise
constrain the court from ruling on whether the requested information may be withheld. Nor does
the lack of an Attorney General ruling deny the trial court of jurisdiction to determine whether
Defendant UCISD may withhold records. See Thomas v. Cornyn, 71 S.W.3d 473, 483 (Tex.
App.—Austin 2002, no pet.) (“A requestor may bring a mandamus action regardless of whether
an attorney general's opinion has been requested or despite the issuance of an adverse attorney
general's opinion that favors the withholding of the information.”); Kallinen v. City of Houston,
462 S.W.3d 25 (Tex. 2015).
73. Attorney General opinions “are not controlling on the courts.” Holmes v. Morales,
924 S.W.2d 920, 924 (Tex. 1996). Trial courts must independently determine whether a
governmental body seeking to withhold information has met its burden of demonstrating that an
exception to withholding applies. While Defendants attempt to justify their withholding of public
information by claiming a litany of exceptions, Plaintiffs address only a few of those exceptions
here, in order to demonstrate how Defendants fail to meet their burden.
The “Law Enforcement” exception does not justify withholding responsive information
74. Defendants have withheld responsive records under two TPIA exemptions
contained in §552.108 (the “law-enforcement exception”)—even though §552.108 was not
intended to shield from disclosure the actions of law enforcement. See TEX. ATT'Y GEN. ORD 71
(1986). (“The public has an obvious interest in having access to information concerning the
qualifications and performances of governmental employees, particularly employees who hold

positions as sensitive as those held by members of [law enforcement].”).
75. Defendants cannot meet their burden to show that the relevant information would
undermine an ongoing investigation. To qualify for an exception to disclosure under
§552.108(a)(1), Defendants must show that release of information would “interfere with
prosecution.” City of Fort Worth v. Cornyn, 86 S.W.3d 320, 327 (Tex. App.—Austin 2002, no
pet.). The exception only applies to investigations that are criminal in nature not internal
investigations or those of an administrative nature. Morales v. Ellen, 840 S.W.2d 519 (Tex. App.—
El Paso 1992, writ denied) (statutory predecessor to section 552.108 not applicable to internal
investigation that did not result in criminal investigation or prosecution).
76. Clearly the shooter himself cannot be prosecuted since he is deceased. As a result,
Defendants cannot withhold information related to the shooter—including previous incident
reports, school records, disciplinary history, etc.—under this law enforcement exception.
77. To qualify for an exception to disclosure under §552.108(b)(1), Defendants must
show that the information, “if released, would permit private citizens to anticipate weaknesses in
a police department, avoid detection, jeopardize officer safety, and generally undermine police
efforts to effectuate the laws of this State.” City of Fort Worth v. Cornyn, 86 S.W.3d 320 (Tex.
App.—Austin 2002, no writ).
78. But the weaknesses have already been exposed; the Texas House Report devoted
77 pages to the failures of law enforcement, and officials from DPS have testified to the proper
procedures and policies. Section 552.108(b)(1) is not applicable to policies and procedures that are
generally known.
Common-Law Privacy does not apply to any responsive records
79. Defendants also seek to withhold all responsive records under §552.101 and a

common-law right to privacy, which the Attorney General found does not justify withholding of
the requested records. See Exh. D.
80. The common-law right to privacy encompasses highly intimate or embarrassing
facts about a person such that its disclosure would be “highly objectionable to a person of ordinary
sensibilities.” Industrial Foundation of the South v. Texas Industrial Accident Board, 540 S.W. 2d
668, 683 (Tex. 1976).
81. As previously noted, the shooter is deceased, and, as such, he does not have any
recognizable privacy interest. TEX. ATT'Y GEN. OR2011-03167 (2011) (“because privacy is a
personal right that lapses at death, the common-law right to privacy does not encompass
information that relates only to a deceased individual”).
82. Defendants also claim a common-law privacy exception related to
“emotional/mental distress.” However, the common-law right to privacy does not include events
or occurrences that may cause emotional or mental stress, so it does not apply to witnesses or
victims. King v. Paxton, 576 S.W.3d 881, 901 (Tex. App.—Austin 2019, pet. denied) (“to broadly
construe common-law privacy to encompass stressful interactions with the police ‘would allow
the exception to swallow the rule’”).
The “litigation exception” does not apply to the responsive records
83. Defendants also seek to withhold all responsive records under §552.103(a), on the
grounds that litigation was reasonably anticipated at the time the Requests were made. The
Attorney General ruled that this exception does not justify withholding of the requested records.
See Exh. D.
84. In order to claim this exception, Defendants bear the burden of showing “concrete
evidence” that litigation involving a specific matter was realistically contemplated and is more

than mere conjecture. Open Records Decision No. 452 at 4 (1986). In order to meet this burden,
Defendants must show that (1) litigation was pending or reasonably anticipated on the date the
governmental body received the request for information, and (2) the requested information is
related to that litigation. See Univ. of Tex. Law Sch. v. Tex. Legal Found., 958 S.W.2d 479, 481
(Tex. App.—Austin 1997, no pet.); Heard v. Houston Post Co., 684 S.W.2d 210, 212 (Tex. App.—
Houston [1st Dist.] 1984, writ ref'd n.r.e.); Open Records Decision No. 551 at 4 (1990).
85. Defendants cannot satisfy the first prong of this test, because the two Notice of
Representation letters on which they rely were received on June 1, 2022, after Plaintiffs submitted
their TPIA requests. Further, the Attorney General has repeatedly ruled that Letters of
Representation do not constitute concrete evidence of litigation, even when the letter contains a
demand for preservation of evidence. See, e.g., TEX. ATT'Y GEN. OR2008-08934; OR2011-02078.
CLAIM FOR RELIEF: REQUEST FOR WRIT OF MANDAMUS
86. Because Defendants have refused to supply public information, Plaintiffs seek a
writ of mandamus pursuant to Section 552.321(a) of the Act compelling Defendants to produce
the requested public records.
87. Although the TPIA allows Plaintiffs to request reasonable attorney’s fees, because
Plaintiffs are pursuing these records in the public interest for the community of Uvalde and the
state at large, Plaintiffs have chosen not to seek fees in this matter.
CONDITIONS PRECEDENT
88. Pursuant to TEX. R. CIV. P. 54, all conditions precedent have been performed or
have occurred.

PRAYER
Upon final hearing, Plaintiffs pray that this Court issue a writ of mandamus requiring
Defendants to make the requested public information available. Plaintiffs pray for such other and
further relief, whether at law or in equity, to which they may show themselves to be justly entitled.
Dated: August 29, 2022

Respectfully submitted,
/s/ Laura Lee Prather

Laura Lee Prather
State Bar No. 16234200
Laura.Prather@haynesboone.com
William Reid Pillifant
State Bar No. 24126157
Reid.Pillifant@haynesboone.com
Haynes Boone, LLP
600 Congress Ave., Ste. 1300
Austin, TX 78701
(512) 867-8400
Counsel for Plaintiffs

EXHIBIT A
Received
May 25, 2022
Esmeralda Casarez
From: Clarissa Rodriguez

Sent: Tuesday, May 31, 2022 10:08 AM
To: Esmeralda Casarez
Subject: FW: Texas Tribune media request - 911 calls to/from 1500 Hood Street block
Clarissa M. Rodriguez
Partner
Denton, Navarro, Rocha. Bernal, & Zech , P.C.
2517 N. Main
San Antonio, TX 78212
210/227-3243
210/225-4481 (f)
CONFIDENTIALITY NOTICE
This transmission is intended for the individual or entity to which it is addressed, and may be information that is
PRIVILEGED AND CONFIDENTIAL. If you are not the intended recipient, or the employee or agent responsible for
delivering the message to the intended recipient, and have received this information in error, you are hereby notified that
any dissemination , distribution, or copying of this communication is prohibited. If you have received this communication in
error, please notify us immediately by replying to the message and deleting it from your computer. Thank you.
From: Sorayda Sanchez <ssanchez@uvaldetx.gov>

Sent: Friday, May 27, 2022 4:37 PM
To: Clarissa Rodriguez <cmrodriguez@rampagelaw.com>
rP/r~,
(1/~~(1/~
City Secretary
Cl'n:QFUVALOE -
1Jwt'i •
/t,i,t;J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssa11c/1ez(ii),uvaldet.x.gov
From: Ren Larson

To: Juan Hernandez <ihernandez@uvaldetx.gov>; Sorayda Sanchez <ssanchez@uvaldetx.gov>
Cc: Susan Anderson <sanderson@uvaldetx.gov>
Subject: Re: Texas Tribune media request - 911 calls to/from 1500 Hood Street block
1
Fire Marshal Hernandez,
Thank you for your quick reply. I know that this has been a distressing week and so much is being requested of
Uvalde's residents and those who work in the city.
It looks like you looped in Susan Anderson, I'm including ssanchez@uvaldetx.gov on the "to" line -- please let me know if
this is correct.
Sorayda, good afternoon, it is nice toe-meet you. My name is Ren Larson and I'm a journalist with The Texas Tribune
and ProPablica. I'm seeking records 011 all 911 calls from and to the 1500 block of Hood Street over the past five years.
Please let me know if you would like me to file a separate request, or if the below email will work for you.
I am here to help narrow down the request in ways that are useful. Please let me know if you have any questions on the
requests. I'm available by phone at - - or email a
Sincerely,
Ren
On Fri, May 27, 2022 at 2:53 PM Susan Anderson <sanderson@uvaldetx.gov> wrote:
All public information requests go through our city secretary, Sorayda Sanchez. I am copying her in this email.
From: Juan Hernandez <jhernandez@uvaldetx.gov>

To: Susan Anderson <sanderson(@uvaldetx.gov>
Here another one
From: Ren Larson >

Sent: Wednesday, May 25, 2022 4:45 PM
To: Juan Hernandez <jhernandez@uvaldetx.gov>
Subject: Texas Tribune media request - 911 calls to/from 1500 Hood Street block
r Dear Fire Marshal Hernandez and Uvalde Fire Marshal Department,
My name is Ren Larson and I'm a data journalist with The Texas Tribune. I'm contacting you to request any and all 911
calls originating from the 1500 block of Hood Street since May 1, 2017 that your agency received.
I request these under Texas' Public Information Act on behalf of the Texas Tribune, ProPublica and myself jointly.
2
If you plan to send any of the responsive records to the Attorney General for an exemption ruling, I ask that you
i contact me before to discuss the objection to the request.
I seek this information for non-commercial journalistic purposes. I ask that you use your discretion to waive any search,
1 review or duplication fees that result from this request, as allowed in the Texas Public Information Act. If this is not
possible, and the costs exceed $25, please inform me in writing of the costs involved broken down by the charge type
and amount before fulfilling the request.
If you deny any part of this request, please state in writing the specific reason and share the appeal procedures
available under the law.
I request this information in a machine readable, spreadsheet format, such as a .csv or .xlsx file. Please let me know if
there are any questions you have about this request and whether there are any amendments that can be made to
ensure the records will be produced with less friction.
Please feel free to contact me a o~ . Thank you for your public service. I look
forward to working together.
Sincerely,
Ren
Ren Larson
Data Journalist - Texas Tribune+ ProPublica Investigative Unit
919 Congress Ave., Sixth Floor

Austin, TX 78701
3
www.texastribune.org
M (512) 910-4651 F (512) 716-8601

@renlarson
THE TEXAS TRIBUNE

Ren Larson
Data Journalist - Texas Tribune+ProPublica Investigative Unit
@renlarson
4
Esmeralda Casarez

Subject: FW: PUBLIC RECORDS REQUEST--Body Camera Footage
Partner
Denton, Navarro, Rocha, Bernal, & Zech, P.C.
2517 N. Main
210/227-3243
210/225-4481 (f)
PRIVILEGED AND CONFIDENTIAL. If you are not the intended recipien t, or the employee or agent responsible for
any d issemination, distribution, or copying of this communication is prohibited. If you have received this communication in
From: Sor ayda Sa nchez <ssanchez@ uvaldetx.gov>

To: Clarissa Rodr iguez <cmrodriguez@rampagelaw .com>
Subject: FW : PUBLIC RECORDS REQUEST--Body Camera Footage
@J{'~,
~~~~~
City Secretary
O'l'YOFUVAWE ~-
/!:'¢f,4~ •,.t,1:/f.l
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
F ax: (830) 278-2234
Email: ssa11che'lfii>.u1,aldetx.gov
From: Daniel Rodriguez <drodriguez@uvaldetx.gov>

Sent: M onday, M ay 30, 2022 8:49 PM
To: Sorayda Sanchez <ssanchez@uvaldetx.gov>
Subject: Fwd: PUBLIC RECORDS REQUEST--Body Camera Footage
1
Sent from my iPhone
Begin forwarded message:
From: "Caan, Niccole" >

Date: May 25, 2022 at 10:59:09 AM CDT
To: Daniel Rodriguez <drodriguez@uvaldetx.gov>
Subject· PURI IC RECORDS REQI IEST--Body Camera Footage
Dear Chief Rodriguez:
So very sorry for the loss of precious members of your community.
Under the Texas Public Information Act, Tex. Gov't Code Sec. 1701.661 I am requesting an
opportunity to inspect or obtain copies of public records of any body camera or dash camera video
starting at 11 :20 a.m. on 5/24/22 from Robb Elementary School involving Salvador Ramos.
If there are any fees for searching or copying these records, please inform me if the cost will exceed
$ 25. However, I would also like to request a waiver of all fees in that the disclosure of the
requested information is in the public interest because I am a journalist working for a news
organization and this information will contribute significantly to the public's understanding of the
Robb Elementary School shooting.
The Texas Public Information Act requires that you "promptly produce" the requested records
unless, within 10 days, you have sought an Attorney General's Opinion. If you expect a significant
delay in responding to this request, please contact me with information about when I might expect
copies or the ability to inspect the requested records.
If you deny any or all of this request, please cite each specific exemption you feel justifies the refusal
to release the information and notify me of the appeal procedures available to me under the law.
Thank you for considering my request.
Sincerely,
Niccole Caan
Niccole Caan
2
Esmeralda Casarez

Sent: Tuesday, June 7, 2022 10:54 AM
To: dnrbzsat
Subject: FW: PUBLIC RECORDS REQUEST--911 CALLS
{p/f~,
(lf~~(lf~
City Secretary
crrv c.w ,uv.MJ>l! _
1;:;,1/41.; •./4~~1
City of Uvalde
P.0.Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssanchez@uvaldetx.gov

Subject: FW: PUBLIC RECORDS REQUEST--911 CALLS
Z,a«tet i<odwJ«eJ
Chief of Police
Uvalde Police Depa rtment
(830) 278-9147 ext. 848
(830) 900-4145 eel
From: Caan, Niccol

Sent: Wednesday, May 25, 2022 10:53 AM
Subject: PUBLIC RECORDS REQUEST--911 CALLS
5
Dear Chief Rodriguez:
So very sorry for the loss of precious people in your community. Please forward to the correct individual:
Under the Texas Public Information Act, Tex. Gov't Code §552.001 et seq. , I am requesting an opportunity to
inspect or obtain copies of public records:
1. All 911 calls from Robb Elementary School in reference to the school shooting starting about 11 :20 a.m . on
Ma 24 2022.
Digital copies are preferred as they save money and are easy to send.
If there are any fees for searching or copying these records, please inform me if the cost will exceed $ 25. However,
I would also like to request a waiver of all fees in that the disclosure of the requested information is in the public
interest because I am a journalist working for a news organization and this information will contribute significantly to
the public's understanding of the Robb Elementary School shooting.
The Texas Public Information Act requires that you "promptly produce" the requested records unless, within 10
days, you have sought an Attorney General's Opinion. If you expect a significant delay in responding to this
request, please contact me with information about when I might expect copies or the ability to inspect the requested
records.
If you deny any or all of this request, please cite each specific exemption you feel justifies the refusal to release the
information and notify me of the appeal procedures available to me under the law.
Sincerely,
Niccole Caan
Niccole Caan
6
Esmeralda Casarez

Sent: Tuesday, May 31 , 2022 10:26 AM
Subject: FW: NBC News request: Prior incidents at 1511 Hood St
Partner
Denton , Navarro, Rocha, Bernal, & Zech, P.C .
251 7 N. Main
210/227-3243
210/225-4481 (f)
any dissemination, distribution, or copying of this communication is prohibited . If you have received this communication in

Subject: FW: NBC News request: Prior incidents at 1511 Hood St
{M'~,
(?/~~(?/~
City Secretary
. CllYOFUVALOE .-
//,+:;-b/4 •X.r,,1-;f
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: s.m11che1,(a.,.u11altletx.gov

Sent: Monday, May 30, 2022 8:47 PM
Subject: Fwd: NBC News request: Prior incidents at 1511 Hood St
Sent from my iPhone
From: "Duarte, Nicole (NBCUniversal)"

Date: May 25, 2022 at 12:45:39 PM CDT
Cc· "@NIK UNI Miami 6ureau Desk" ----i;.►-------------------
Subject: NBC News request: Prior incidents at 1511 Hood St
Good afternoon,
NBC News would like to request any incident reports for Salvador Ramos' former home at 1511 Hood St.
We've heard anecdotal reports from neighbors that police were often called to the home.
Even though Ramos was not charged, can you please tell us how many time police were called?
Thank you!
2
Esmeralda Casarez

Subject: FW: TX PIA Request - 911/Calls for Service/Body Came Footage
Partner
Denton, Navarro, Rocha. Bernal , & Zech, P.C.
2517 N. Main
210/227-3243
210/225-4481 (f)
any dissemination . distribution, or copying of this communication is prohibited. If you have received this communication in

Subject: FW: TX PIA Request - 911/Ca lls for Service/Body Came Footage
{fJt~,
(?/~!¥.(?/~
City Secretary
· OTYOF'UVAWE -
't/414'. ,/,9r(J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: sst111d1ez(ii)uvaldetx.gov

Subject: Fwd: TX PIA Request - 911/Calls for Service/Body Came Footage
Sent from my iPhone
Begin forwa rded message:
From: "Ghisolfi, Caroline"

Date: May 25, 2022 at 1:24:07 PM CDT
To: Gabriella Mata <gmata@uvaldetx.gov>
Cc: Daniel Rodriguez <dradrigqez@uvaldetx gov>
Subject: TX PIA Request - 911/Calls for Service/Body Came Footage
To Whom It May Concern:
Pursuant to the Texas Publ ic Information Act, I hereby request the following records:
• all logs, data, transcripts, media files, and recordings of all emergency (911) and non-emergency
calls for service (CFS) received from Robb Elementary School at 715 Old Carrizo Rd, Uvalde, on
Tuesday, May 24.
• All body camera footage for the Tuesday, May 24 shooting incident at Robb Elementary School
at 715 Old Carrizo Rd, Uvalde, recorded on Tuesday, May 24.
The requested documents will be made available to the genera l public, and this request is not being
made for commercial purposes.
In the event that there are fees, I would be grateful if you would inform me of the total charges in
advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if
available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your
response to this request within 10 business days, as the statute requires.
Sincerely,
Caroline Ghisolfi
Data Reporter
Au,stin Amtrican-~tatt,man
2
Esmeralda Casarez

Sent: Tuesday, May 31, 2022 11 :34 AM
Subject: FW: TX PIA Request - 911/Calls for Service logs at 552 Diaz St
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
any dissemination, distribution, or copying of this communication is prohibited. If you have received this communication in
From : Sorayda Sanchez <ssanchez@uvaldetx.gov>

(§I{'~,
{?J~!K{?J~
City Secretary
- CITY o.g.ovA!JlE.;-
• ~,rft:«. •/rd'IIJ
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ss1111che'lfa'luvaldetx.glJv
From : Gabriella M ata <gmata@uvaldetx.gov>

To: Sorayda Sanchez <ssanchez@uva ldetx.gov>
17
Good morning,
Please see email below.
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: {830)278-9147 ext. 812
Fax: (830)591-2552
&,rmata(@uvaldetx.gov
CONFIDENTIALITY NOTICE: This email message and any included attachments are for the sole use of the intended
recipient(s), and may contain confidential and/or privileged information. Do not read, copy, forward, or print this email
message or any attachments unless you are the intended recipient. If you are not the inti::ncJed recipient, please notify the
sender and destroy all copies and printouts of this email message and/or attachments
From: Ghisolfi, Caroline

To: Gabriella Mata <gmata@ uvaldetx.gov>
Subject: TX PIA Request - 911/Calls for Service logs at 552 Diaz St
Pursuant to the Texas Public Information Act, I hereby request the following records:
• All logs, data, transcripts, media files, and recordings of all emergency (911) and non-emergency calls for service
(CFS) received between Jan 1, 2012, and May 25, 2022, at 552 Diaz St., Uvalde.
The requested documents will be made available to the general public, and this request is not being made for
commercial purposes.
In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling
my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this
request within 10 business days, as the statute requires.
Sincerely,
18
Caroline Ghisolfi
Data Reporter
~uitin )\mtrican--jtatt~man
19
Esmeralda Casarez

To: Esmeraloa Casarez
Subject: FW: TX PIA Request - Communications with Robb Elementary School
Partner
Denton, Navarro, Rocha, Bernal , & Zech, P.C .
2517 N. Main
210/227-3243
210/225-4481 (f)

{(j{'~,
(;/~~(;/~
City Secretary
OW 0.F UVALDE -
7/2~6/4. ,/1~,iM
City of Uvalde
P.O. Box 799
Uvalde, Te.xm; 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssrmcliez(ii)uvaldetx.gav
From: Gabriella Mata <gmata@uvaldetx.gov>

24
Good morning,
T ~yo-vv)
Cio.,h,v~/\1~
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: {830)591-2552
gmata(@,uvaldetx.gov
message or any attachments unless you are the intended recipient. If you are not the intended reuipient, please notify the

To: Gabriella Mata <grnata@uvaldetx.gov>
Subject: TX PIA Request - Communications with Robb Elementary School
• All communication records (including call transcripts, text messages and emails) between any individual
associated w ith Robb Elementary School in Uvalde, Texas, and any Uvalde Police Department staff member.
Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to t his
Sincerely,
25
Caroline Ghisolfi
Data Reporter
26
Esmeralda Casarez

Subject: FW: Open Records Request - May 25, 2022
Note date received
Clarissa M. Rodrig uez

Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
This transmission is intended for the individual or entity to which it is addressed , and may be information that is

Subject: FW: Open Records Request - May 25, 2022
~~,
(?/~ ~(?/~
City Secretary
CITY OE WAWE .-
//4,;,{t(; ;/4',r/ &J
City of Uvalde
P. O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssa11cl1ez@µvaldetx.gov

Sent: Monday, M ay 30, 2022 8 :42 PM
Subject: Fw d: Open Records Request - May 25, 2022
Sent from my iPhone
From : "Morris, M ike"

Date: M ay 25, 2022 at 4:33: 50 PM CDT
To: City Hall <cityhall@uvaldetx.gov>, Daniel Rodriguez <drodriguez@uvaldetx.gov>
Subject: Open Records Request May 25, 2022
Good afternoon,
Under the Texas Public Information Act, I respectfully request:
1. Records listing all Uvalde Police Department calls for service to 552 Diaz Street
in Uvalde from Jan. 1, 2012 to May 25, 2022.
2. Records of all accompanying incident reports (or equivalent records) produced in

connection with those calls for service.
3. Recordings of all 911 calls placed by callers at 552 Diaz Street in Uvalde from
Jan. 1, 2012 to May 25, 2022 (if the city or city agencies maintain said records) .
I respectfully request that the records be produced in electronic I digital fonnat and
delivered via email.
Thank you ,
Mike Morris
Houst on Chronicle
2
Esmeralda Casarez

Subject: FW: Texas Public Information Act request
Partner
251 7 N. Main
210/227-3243
210/225-4481 (f)
PRIVILEGED AND CONFIDENTIAL If you are not the intended recipient, or the employee or agent responsible for

Subject: FW: Texas Publ ic Information Act request
{p/f~,
(t/~~(t/~
City Secretary
OTT. OF.UVALOE -
11¥/t/4 , /4,ttj
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 2 78-2234
Email: ss,111c/1erfa)u1·altletx.gov

Sent: Monday, May 30, 2022 8 :36 PM
Subject: Fwd: Texas Public Information Act request
1
Sent from my iPhone
From: "Merchant, Nomaan"

Date: May 26, 2022 at 9:35:46 AM CDT
Subject· RE· Texas Public lr:iformation Act reque
Hi Chief, good morning. Would it be possible for you or a member of your agency to
confirm r eceipt of th is request under the Texas Public Information Act?
Thank you.
Nomaan
From: Merchant, Nomaan

Sent: Wednesday, May 25, 2022 9 :18 AM
To: drodriguez@uvaldetx.gov
Subject: Texas Public Information Act request
Dear Chief Rodriguez,
I am so sorry for your communit y's loss and pain and pray for healing during this
terrible time.
I am writing to submit a request under the Texas Public Information Act for records
of any calls for service t o 552 Diaz St, Uvalde, Texas, between January 1, 2016,
and May 23, 2022. Please note that I have limited my request to the day before
yesterday's shooting so as not to request records that may interfere with the
ongoing investigation of the shooting.
The Texas Attorney General has deemed the following categories of data "basic
information" automatically releasable under TPIA. Please release, unredacted, any
and all information that corresponds to the following categories, as listed on p. 97
of the Office of the Attorney General's 2020 Public Information Handbook:
(a) the name, age, address, race, sex, occupation, alias, social security number,
police
department identification number, and physical condition of the arrested person;
(b) the date and t ime of the arrest;
(c) the place of the arrest
(d) the offense charged and the court in which it is filed;
(e) the details of the arrest; ·
(f) booking information;
(g) the notation of any release or transfer;
(h) bonding information;
(i) the location of the crime ;
U) the identification and description of the compla inant;
2
(k) the premises involved;
(l) the time of occurrence of the crime;
(m) the property involved, if any;
(n) the vehicles involved, if any;
( o) a description of the weather; .
(p) a detailed description of the offense; and
( q) the names of the arresting and investigating officers.
I ask that you waive any charges associated with the production of this request as
the u11derlyi11g docu111e11ts a,e "i11 tile public interest," according to Sec. 552.26/(a)
of the Texas Government Code. I am an Associated Press reporter primarily
engaged in newsgathering and whose reporting appears commonly in Texas media.
I have no commercial interest in these documents, which will help inform the public
about ongoing governmental operations.
~ c o n s i d e r a t i o n . I can be reached anytime at or
Nomaan
AP ASSOCIATED PRESS
NOMAAN MERCHANT
Reporter
---
The information contained in this communication is intended for the use of the designated recipients
named above. If the reader of this communication is not the intended recipient, you are hereby notified
that you have received this communication in error, and that any review, dissemination, distribution or
copying of this communication is strictly prohibited. If you have received this communication in error,
please notify The Associated Press immediately by telephone at +1-212-621-1500 and delete this email.
Thank you.
3
Esmeralda Casarez

Subject: FW: Texas Tribune Media request - 911 calls from/to 151 1 Hood Street
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
PRIVILEGED AND CONFIDENTIAL. If you are not tt1e intended recipient, or the employee or agent responsible for
delivering the message to the intended redpient, and have received this information in error, you are hereby notified that

Subject: FW: Texas Tribune Media request- 911 calls from/to 1511 Hood Street
{p/{'~,
(?J~!K(?J~
City Secretary
C:tlY Of.U\IAWli -
f'~✓t,/4 , ~/rd#}
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssanc/1ez(tiJJ111aldetx.gov

Subject: Fwd: Texas Tribune Media request - 911 calls from/to 1511 Hood Street
1
~!I~
) RM ATION REQUEST PORM
·. . f;
You
• Pr-
od
• Re
Di1
• Re
the E-Ma il (optional):
• Re,
cha
opp
Public Information Records Re quest
stat, (Note: Minutes are no t Otlicial unless Pnssed and Approved by 6 overni 11~ body of the c ity o f Uvalde]
• Ch~ Detailed Descr.iption of Records: _ __ _ _ _ _ __ _ __
•
ofteu lit no c.nargeJ, receive copies oflhe infonnation or both;
A waiver or reduction of charges if the govemmental body
determines that access to the infonnation primarily benefits the
general public;
lb4 pOhCJ. ~e! S ~bJ/;
• Receive a copy of the communication from the governmental
body asking the Office of the Attorney General for a ruling on
whether the infonnation can be withheld under one of the
accepted exceptions, or if the communication discloses the
requested io fonnation, a redacted copy;
• Lodge a written complaint about overcharges for public
information with the Office of the Attorney General.
Complaints of otheF possible violations may be fi led with the
county or district attorney of the county where the
governmental body, other than a state agency, is located. If the
complaint is against t!1e county or district attorney, the
complaint must be 61.ed with the Office of the Attorney
General.
Procedures to Obtain Information: :l,'ispQKf. '°'1 ¥7hlilli! HU(AS qµvm ~ i1 I
✓ Submit a request by mail , fax, e-mail or in person according to
a governmental body's reasonable procedures .
Number of Copies Requested ; (ol'-L) I
✓ Include enough description and detail about the infonnation Date Requested F'or: ---'5
""-'\-....Q,__5..,__________
requested lo enable the governmental body to accurately
identify and l ocate the information requested. In fo rmation to be 1·clc ascd:
✓ Cooperate v.1th the governmental body's reasonable effons to • You may revie w it promptly, and if it cannot be produced within l 0
clarify the type or amount ofinfom1ation requested.
work ing d ays the public information o fficer w ill n oti(y you in writing of
Cost of Records: the reason abl e date and tlmc when it wi'II be ava ilable.
Standard paper copy $. 10 per page
Nonstandard copy. • Keep all appointments to i!lspect records and to pick up copies. Failure to
A. Diskette $1.00 each keep appo intments may result in losing the opportllnity to inspect the
B. Magnetic Tape actual cost
C. Data Cartridge actual cost i nform ation at the time re quested.
D. Tape Cartridge actual cost • Information that may be withheld due to an exception of t he referral by
E. Rewritable CD $1.00 each
the Office of th e Attorney General; y our request will be referred withi n 10
F. Non-rewritable CD $1.00 each
G. Digital Video Disc $3.Q0 each busine ss days. 'I11e Office o f the Attorney General .must issue a decis ion
H. JAZ drive actual cost no later than the 45 th work ing day from the day after the Attorney General
I. Other electronic media actual cost
J. VHS videocassette $2.50 each received the '.·equest t,>r a. dlc;f>L_~
K. Audio cassette Sl.00 each
L. Oversize paper copy (e.g. 11 x 17", green bar, bluebar, not
Requester S1gnature: ~~
including maps and photographs using specialty paper)
S.50 per page
Date of Request: $/a:5" .
M . Specialty paper{e.g.: Mylar, blueprint, blueline, map,
. .
photographic) actual cost
Programming Labor Charge $28.50 per hour Si gnat

Labor Charge for locating, compili.n g, and reproducing public
Name:
information. $15.00 per hour
[A labor charge shall not be billed with requests that arc for 50 T itle: ~:::::~::=',P----"-L.. w. _;e."""'JJ.\, -11,- . . ._ ·1-
or fewer pages of paper records, wt less recotds are in separate
building.] Revised 0712018 Date Received: (
-~-+-~~-~~~~- ----- - ---
Esmeralda Casarez

Subject: FW: Texas Public Information Act Request
Partner
Denton , Navarro, Rocha, Bernal, & Zech, P.C.
2517 N. Main
210/227-3243
210/225-4481 (f)
PRIVILEGED AND CONFIDENTIAL. ff you are not the intended recipient, or the employee or agent responsible for
delivering the message to the lntended recipient, and have received this information in error, you are hereby notified that
error., please notify us immediately by replying to the message and deleting it from your computer. Thank you.

[qf~,
(?/~~(?/~
City Secretary
CttY.OF.UVAl.OE _
1/,.,vf/4 •;l,..r(t.J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssmu:lte'lfa1uvaldetx.gov

1
T~ f:101.IV_,
4~~ fvlr;.f0v
Records Clerk
City of Uvalde
Police Depa, tment
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: (830)591-2552
gmata(@uvaldetx.gov
message or any attachments unless you are the intended recipient. If you are not the intended recipient, please notify the

Sent: Tuesday, May 24, 2022 11:55 PM
To: Gabriella Mata <gmata@uvaldetx.gov>; Clarissa Chavez <cchavez@uvaldetx.gov>
Subject: Fwd: Texas Public Information Act Request
FYI. Got a records request.
Sent from my iPhone
From: "Bleiberg, Jake"

Date: May 24, 2022 at 8:43:44 PM MST
Subject: Texas Public Information Act Request
Hello Chief Daniel Rodriguez:
I'm Jake Bleiberg, a reporter w ith The Associated Press. First off, I'm am so terribly sorry for the tragedy
in Uvalde. My deepest condolences to you and your community.
I'm writing to request records under the Texas Public Information Act, Tex. Gov't Code Ann.§ 552.001 et
2
seq. (the "Act"), and under the common law right of access. I am making this request in my capacity as a
full-time journalist w ith The Associated Press.
Pursuant to the Act, I am requesting a copy of the following public records:
_ any recordings of any 911 or other emergency calls placed between 11:00 a.m. and 1 p.m. on May 24,
2022 related to a shooting or other emergency at Robb Elementary School;
_ any recordings of any 911 or other emergency calls placed on May 24, 2022 from 707 S. High Street in
_ any recordings of any 911 or other emergency calls placed in May 2022 mentioning Salvador Ramos;
_ any reports from arrests of ot her int eractions between police and Salvador Ramos from prior to May
24, 2022.
I would like to receive t he information in electronic format. I note that under the Act, "if public
information exists in an electronic or magnetic medium, a requester may request a copy either on paper
or in an electronic medium," if the following three requirements are met: (1) the governmental body has
the technological ability to produce a copy of the requested information in the requested medium, (2)
such body is not required to purchase any softwa re or hardware to accommodate the request, and (3)
provision of a copy of the information in the requested medium would not violate any copyright
agreements between the body and a third party. Tex. Gov't Code Ann.§ 552.228(b).
I ask that you waive any and all fees associated with this request pursuant to Tex. Gov't Code Ann. §
552.267. I am making the request as an AP reporter and this request is made as part of
newsgathering. Release of the information will primarily benefit the general public because it will
contribute significantly to the public understanding of government. If you deny this request for a fee
waiver, please advise me in advance of the estimated charges if they are to exceed $50. I remind you a
public body may not collect fees exceeding those that "reasonably include ... all costs related to
reproducing the public information." Tex. Gov't Code Ann. § 552.261.
If this request is denied in whole or part, I ask that you justify all deletions by reference to specific
exemptions of the Act, and inform me of appeals procedures available to me under the law. I also
expect you to release all segregable portions of otherwise exempt material. I reserve the right to appeal
your decision to w ithhold any information or to deny a waiver of fees.
Under the Act, this request must be acted upon as soon as possible "under the circumstances, that is,
within a reasonable time, without delay." Tex. Gov't Code Ann. § 552.221.
I would appreciate your handling this request as quickly as possible, and I look forward to hearing from
you.
Thank you,
Jake Bleiberg
Jake Bleiberg
The Associated Press
3
The information contained in this communication is intended for the use of the designated recipients
named above. If the reader of this communication is not the intended recipient, you are hereby notified
that you have received this communication in error, and that any review, dissemination, distribution or
copying of this communication is strictly prohibited. If you have received this communication in error,
please notify The Associated Press immediately by telephone at nd delete this email.
Thank you.
4
Esmeralda Casarez

Subject: FW: Record Request
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
error. please notify us immediately by replying to the message and deleting it from your computer. Thank you.

(fj/f~,
(lf~!Y.(1/~
City Secretary
(Jh' Of UVAt.OI:: ~-
. ~ ,mftl: ,~t,;~~
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssancl1e1.@µvaldetx.gov

8
Records Clerk
City of Uvalde
Polite Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: {830)591-2552
gmata(@uvaldetx.gov
From: Frances Robles >

Subject: Record Request
Hello.
*I would like make a public record request for police reports for prior calls for service to
552 Diaz St. and
1511 Hood St. Lot 9
* I would like any recordings of 911 calls made from those addresses.
*I would like any police reports that mention Salvador Ramos in any capacity (complainant, victim, witness,
etc.)
*I would like any police reports that mention Adriana Martinez Reyes in any capacity (complainant, victim,
witness, etc.)
t hank you
My phone number is below if you have any questions.
9
Frances Robles
10
Esmeralda Casarez

Subject: FW: Washington Post records request
Partner
Denton, Navarro, Rocha, Bernal , & Zech , P .C.
2517 N. Main
210/227-3243
210/225-4481 (f)
error, please notify us immediately by replying to the message and deleting it from your computer. T hank you.
From: Sorayda Sanchez <ssanchez@uva ldetx.gov>

{ff{'~,
(?J~~(?J~
City Secretary
Cfl'YOF VVAU)I): -
· 1/:,,rtf/.. •/2.m,f
City of Uvalde
P.O.Box 799
Uvalde, Texas 78802
Phone: (830) 2 78-3315 ext. 142
Fax: (830) 278-2234
Email: sstm dier@.1uvaldetx.gov

11
Records Clerk
City of Uvalde
Police Depa, tment
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: (830)591-2552
gmata@u valdetx. gov
CONFIDENT/AL/TY NOTICE This email message and any included attachments are for the sole use of the intended
From: Boburg, Shawn

To: Gabriella Mata <grnat a@uvaldetx.gov>
Subject: Washington Post records request
Hello:
I'm a reporter at The Washington Post, writing to request t he following records:
1. Calls for service, from 2010 to the present, to 552 Diaz St., Uvalde and 1511 Hood St., Uvalde.
2. Any incident or arrest reports for Adriana M . Reyes ( d a b - ) or Salvador Ramos (dab
5/16/2004)
Please send the records to me at this e-mail address. Please send each record to me as soon it becomes
available, if one or more records takes longer to produce.
You may reach me at
Thank you,
Shawn Boburg
12
Esmeralda Casarez

Subject: FW: Open Records Request
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Subject: FW: Open Records Reque·st
City of Uvalde
P.O. Box799
Uvalde, Texas 78802
Phone: (830) 278-3315 exL 142
Fax: (830) 278-2234
Email: ss,md,er.w.~uvaldetx.gov
From: Gabriella M ata <gmata@uvaldetx.gov>

Sent: Tuesday, M ay 31, 2022 9:39 AM
Subject: FW: Open Records Request
14
Good morning,
T ~~O'vl-'~
~~~ Mo.;fo.,,
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: {830)278-9147 ext. 812
Fax: {830)591-2552
gmata(a),uvaldetx.u.ov
recipient(s). and may contain confidential and/or privileged information. Do not read, copy, forward, or print this email
message or any attachments unless you are the intended recipient. If you are not lfJe intended recipient, please notify the
From: Mabell Dieppa

Subject: Open Records Request
Dear Ms. Mata:
My name is Mabell Dieppa and I work for Univision network. I am submitting this Open
Records Request under the Public Information Act. Pursuant to section 552.234 of the
Government Code, Effective September 1, 2019, I am presenting this request in writing,
via electronic mail, to you, identified by the Uvalde Police Department as the
governmental body's public information officer or the officer's designee for this purpose.
At least one student made a 9-1-1 call and her name is Ameri Jo Garza and she was in
Fourth Grade.
15
Because of public interest in this case, we are requesting that you provide this calls as
soon as possible. If you need additional information , don't hesitate to contact me via e-
mai I or by phone at:
Our prayers are with the Uvalde community and all those affected by this shooting.
God Bless!
Mabell
Mabell Dieppa I Senior Entertainment Producer

IO
TelevisaUnivlsion. Inc. httpl/televisaunivision.com
16
Esmeralda Casarez

To: Esmeral da Casarez
Subject: FW: ABC News / public records request
Clarissa M. Rodriguez .
Partner
Denton, Navarro, Rocha, Bernal , & Zech, P.C.
2517 N. Main
210/227-3243
210/225-4481 (f)
any dissemination, distribution , or copying of this communication is prohibited . If you have received this communication in
From: Sorayda Sanchez <ssanchez@uva ldetx.gov>

Subject: FW: ABC News/ public records reque st
{g/{'~,
~~~~~
City Secretary
• C:ll'Y. 05l WA_lP,E ,-

- t/4,£/4 •:lr.r,1/J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ss1111che,ffe),uvaldetx.gov
From: Gabriella Mata <gm ata@uvaldetx.gov>

Subject: FW: ABC News/ public records request
20
Good morning,
T~ !:J o-vv)
c;~ ~ fvf ~
Records Clerk
City of IJ.11alde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: {830)591-2552
gmata(a),uvaldetx.gov
From: Levine, Mike

Subject: Re: ABC News/ public records request
Hello Gabriella, I'm adding these records to my request:
-- any and all police reports from the past 5 years that are related to the property at 1511 Hood St., Lot 9, in
Uvalde
-- any and all 9-1-1 calls from the past 5 years that were made from 1511 Hood St., Lot 9, or related to that
address
-- any and all police reports from the past 5 years that are related to Marisabelle Ramos (sister to Salvador
Ramos)
-- any and all police reports from the past 5 years that are related to Adriana Reyes (mother to Salvador
Ramos)
-- any and all police reports from the past 5 years that are related to the elder Salvador Ramos (father to
Salvador Ramos DOB 5/16/04)
21
Thank you.
From: Levine Mike

To: gmata@uvaldetx.gov <gmata @uvaldetx.gov>
Subject: ABC News / public records request
Hello Gabriella,
I hope you 're doing ok and hanging in -- my condolences to the entire Uvalde community. My name is Mike
Levine, and I'm a reporter with ABC News. I am submitting the following public records request:
Under the Texas Public Information Act, Tex. Gov't Code §552.001 et seq., I am req uesting copies of:
-- any and all police reports from the past 5 years that are related to the property at 552 Diaz Street in Uvalde
-- any and all 9-1-1 calls from the past 5 years that were made from 552 Diaz Street or related to 552 Diaz
Street
-- any and all 9-1-1 calls from the past 5 yea rs that were made by or about Salvador Ramos (DOB 5/16/04)
-- any and all police reports or other records from t he past 5 years that were/are related to Salvador Ramos
(DOB 5/16/04)
$200. However, I would also like to request a waiver of all fees in that the disclosure of the requested
information is in t he public interest. This information is not being sought for commercial purposes.
The Texas Public Information Act requires that you " prompt ly produce" the requested records unless, within
10 days, you have sought an Attorney General's Opinion. If you expect a significant delay in responding to this
request, please contact me with information about when I might expect copies or t he ability to inspect the
requested records.
If you deny any or all of this request, please cite each specific exemption you feel justifies t he refusal to
release the information and notify me of the appeal procedures available to me under the law.
Thank you for considering my request,

Mike Levine
ABC News
22
I
Esmeralda Casarez

Subject: FW: CNN records request -- Salvador Ramos (DOB: May 16, 2004)
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

{§/{'~,
(?f~!K(?f~
City Secretary
. OTYOFUVAI:OE ,_
l/4._,,t;t:, •.X.u,..1
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssu,tcltei@),uvaltlt?tx.gov
From : Gabriella Mata <gmata@uvaldetx.gov>

30
Good morning,
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: (830)591-2552
umata(@uvaldetx.gov
CONFIDENTIALITY NOTICE This email message and any included attachments are for the sole use of the intended
mossage or any attachments unless you are the intended recipient. If you are not lhe intended recipient, please notify the
From: Clarissa Chavez <cchavez@uvaldetx.gov>

Sent: Thursday, May 26, 2022 9:41 AM
To: Alexandra T. Wegrzyn <alexandra@tarskilaw.com>; Sorayda Sanchez <ssanchez@uvaldetx.gov>
Cc: Gabriella Mata <gmata@uvaldetx.gov>
Subject: FW: CNN records request -- Sa lvador Ramos (DOB: May 16, 2004)
From: Devine, Curt

To: Clarissa Chavez <cchavez@uvaldetx.gov>
Hi - I just wanted to follow up on this. Can the records request below be processed? I just want to make sure I should
not submit this another way. Thank you again .
Curt Devine
CNN, Washington
31
From: Devine, Curt
Date: Wednesday, May 25, 2022 at 11:12 AM
To: drodriguez@uva ldetx.gov <drodriguez@uvaldetx.gov>, cchavez@uvaldetx.gov <cchavez@uva ldetx.gov>,
jazamora@uvaldetx.gov <jazamora@uvaldetx.gov>
Subject: CNN records request -- Salvador Ramos (DOB: May 16, 2004)
Hi Chief Rodriguez and colleagues,
My name is Curt Devine and I'm with the news network CNN. We wanted to submit the following records request for
any documents of prior interactions with Salvador Ramos or his home. Given the public interest, if there is any way this
request can be expedited, that is helpful.
PUBLIC RECORDS REQUEST:
Pursuant to the Texas Public Information Act, CNN requests access to and copies of any documents related to Sa lvador
Ramos (DOB: May 16, 2004) held by Uvalde Police. This should include any incident reports, declarations, calls for
service or affidavits related to this individual.
Additionally, CNN requests any documents related to 552 DIAZ ST, UVALDE, TX. This should include any calls for service
(including logs), incident reports, declarations, or affid avits related to this address, including but not limited to anything
that mentions Sa lvador or Ramos.
If you have any questions about this request, don't hesitate to contact me.
Thank you,
Curt Devine
CNN, Washington
32
Esmeralda Casarez

Sent: Wednesday, June 1, 2022 1:41 PM
Subject: FW: Public records request related to Uvalde shooting
Partner
Denton, Navarro, Rocha, Bernal, & Zech, P.C .
2517 N. Main
210/227-3243
210/225-4481 (f)

Subject: FW: Public records request related to Uvalde shooting
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City Secretary
CHY Of. tNALOE -
-,4,,1. . x.¥✓.J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssa1tcl1ez(a),uvaltletx.gov
From: Lee, Joyce <Joyce.Lee@washpost.com>

To: Susan Anderson <sanderson@uvaldetx.gov>; Sorayda Sanchez <ssanchez@uvaldetx.gov>
Cc: Swaine, Jon <Jon.Swaine@washpost.com>
Subject: Re: Public records request related to Uvalde shooting
16
Hi Susan -
Thank you so much for your guidance so far during a difficult t ime.
I' m sorry to bug again - we were hoping to look at a copy of the school plans - not necessarily for publishing but because
we want to be able to map out the movement of the shooter and law enforcement officers, which has been a bit difficult
in the absence of internal video footage.
Does the city have a copy of tfie building plans or even a permit for the building, or do you know who else I might reach
out to for a copy?
Many thanks in advance,
Joyce Sohyun Lee

The Washington Post
C: 202-236-2832
From: Susan Anderson <sanderson @uv ald etx.gov>

Date: Friday, May 27, 2022 at 3:05 PM
To: Lee, Joyce >, Sorayda Sanchez <ssanch ez@uvaldetx.gov>
Cc: Swaine, Jon
Subject: RE: Public records request related to Uvalde shooting
I am passing this on to our city secretary.
From: Lee, Joyce >

To: Susan Anderson <sanderson@uvaldetx.gov>; Sorayda Sanchez <ssanchez@uvaldetx.gov>
Cc: Swaine, Jon
Thank you, Susan!
Just to clarify - is t his an official denial of my Texas PIA request. If so, can you please provide and officia l denial in writing,
including my appeal rights?
From: Susan Anderson <sa nderson@uvaldetx.gov>

To: Lee, Joyce Sorayda Sanchez <ssanchez@uvaldet x.gov>
Cc: Swaine, Jon
The Texas Department of Public Safety has not ended their investigation yet.
From: Lee, Joyce

Sent: Friday, May 27, 20221 :53 PM
To: Susan Ande <..........................____,---._______________........._>; Sorayda Sanchez <ssanchez@ uvaldetx.gov>
Cc: Swaine, Jon
17
Hi Susan,
I wanted to, if possible, inquire abo ut these t hree request s? I figure these all fall under t he investigation but wanted t o
ask in case.
1. I was wondering if there are any traffic cameras w ithin a two mi le radius of the school? And if so, can I request
video fi les to review?
2. Any foot age from internal cameras inside of Robb Elementary School on May 24
3. Any drone video belonging t o Uvalde's police officers and sheriff s deputies
Thank you very much,

Joyce
From: Lee, Joyce

To: Susan Ande =-=:...:;..;..;;;.~ ""'--';;.;..;:;:c.;.;;;;..;;:;._;.'-,;.=...;;.>, Sorayda Sanchez <ssanchez@uvaldetx.gov>
Cc: Swaine, Jon
Hi Susan,
Just to follow up - thanks for your work on this. Is this an official denial of my Texas PIA request. If so, can you please
provide and official denial in writing, including my appeal rights?
Best,
Joyce
From: Susan Ande rson <san d erson @uvald etx.gov>

Date: Thursday, May 26, 2022 at 6:55 PM
To: Lee, Joyce Sorayda Sanchez <ssanchez@uvaldetx.gov>
Cc: Swaine, Jon
I
;~AUTION:·EXTERNAl SENO~R
Joyce,
Because this is an ongoing investigat ion, we cannot send you the it ems you requested at this t ime. Please understand
that, because of the nature of th is event, the Texas Department of Public Safety is in charge of this investigatio n. Below
is the link to their contacts.
Susan
https ://www.dps.texas.gov/section/media-a nd-comm un ications-o ff ice/contact-us Idps.t exas. gov)
From: Lee, Joyce

To: Sorayda Sanchez <ssanchez@uvaldetx.gov>; Susan Anderson <sanderson@uvaldetx.gov>
Cc: Swaine, Jon
Subject: Re: Public records request related to Uva lde shoot ing
Hi Susan,
18
I wanted to add to this request any drone footage from t he scene owned by the county or city.
Thank you so much again for all your help during this difficult time.
Best,
Joyce
From: Lee, Joyce _ _ _ _ _ _ _ _ __ _ _ _ _ __ _ _ _ _ _ _ __ __

Date: Wednesday, May 25, 2022 at 12:30 PM
To: ssanchez@uvaldetx.gov <ssanchez@uvaldetx.gov>, sanderson@uvaldetx .gov <sanderson@uvaldetx.gov>
Cc: Swaine, Jon
Hi Susan,
Just following up on our phone ca ll. Here' s the origina l request I sent in . Thank you so much again and please let me
know if there's another form I can fill out.
Best,
Joyce
From: Lee, Joyce

To: ssanchez@uvaldetx.gov <ssanchez @uva ldetx.gov>
Cc: d rodriguez @uvaldetx.gov <drodriguez@uvaldetx.gov>, Swaine, Jon
sh eriff@uvald ecou nty.com <sheriff@uvaldecounty.com>
Subject: Public records request related to Uvalde shooting
Hello,
My name is Joyce Lee, and I am a reporter with The Washington Post's Visual Forensics team. I' m writing to request the
following:
1. Any and all 911 calls made between 11 a.m. - 4 p.m. to the Uvalde Police Department and the Uvalde Sheriff's
Department
2. Any and all body camera video and dash camera video belonging to officers from the police department and
sheriff' s department who responded to the shooting at Robb Elementary School
3. Any audio communications or radio traffic between law enforcement officers in the hours of 10 a.m . - 6 p.m.
related to t he incident
I can be reached at if it 's easier to stay in touch over phone.
Many, many thanks in advance during this difficult time,
Joyce Sohyun Lee

The Washington Post
19
[I PROPUBLICA ICITHE TEXAS TRIBUNE.
May 25, 2022
Lexi Churchill
Research Reporter
ProPublica, Texas Tribune
To whom it may concern,
This is a request under the Texas Public Information Act. On behalf of ProPublica, The Texas
Tribune and myself, jointly, we respectfully request the following public records:
Copies of all 911 audio related to calls to 552 Diaz Street Uvalde, Texas 78801 on May 24,
2022. This should include the initial 911 call audio as well as audio of all transmission calls
made within the department and as well as from the department to an outside caller.
In the event some of the requested records cannot be immediately released, I ask that your
office still release whatever portion of my request is ready and public under Texas law,
In order to help to determine my status to assess fees, you should know that I am a reporter
for ProPublica and the Texas Tribune, two nonprofit news organizations, and this request is
made as part of news gathering and not for a commercial use.
I request a waiver of all fees for this request. Disclosure of the requested information to me
is in the public interest because it is likely to contribute significantly to public
understanding of the operations or activities of the government. If a waiver of fees is not
possible, please provide a detailed list that breaks down each charge in advance of fulfilling
our request.
If you denY, any part of this request, please cite in writing each s pecific reason that you
believe justifies your refusal to release the information and notify me of appeal procedures
In principle, I am willing to consider ways in which the request might reasonably be

narrowed. Let me know if clarifying this request might speed the release of the information.
Please feel free to contact me about any aspect of this request, via email at
or by phone at . Thank you in advance for
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter, ProPublica/Texas Tribune Investigative Unit
Research Reporter
[I PROPUBLICA THE TEXAS TRIBUNE
May 25, 2022
Lexi Churchill
Research Reporter
Copies of all incident and corresponding reports related to calls made to 552 Diaz
Street Uvalde, Texas 78801 on May 24, 2022.
Please note that if you plan to ask the attorney general to withhold these documents, I still
request a copy of all required basic information in the offense report which includes, as
defined in Section 552.108(c) of the Texas Government Code:
(a) the name, age, address, race, sex, occupation, alias, social security number, police
(b) the date and time of the arrest;
(c) the place of the arrest;
(e) the details of the arrest;
(i) the location of the crime;
(j) the identification and description of the complainant;
(I) the time of occurrence of the crime;
(o) a description of the weather;
(q) the names of the arresting and investigating officers.
In the event some of the requested records cannot be immediately released. I ask that your
office stm release whatever portion of my request is ready and public under Texas Jaw,
our request.
If you deny any part of this request, please cite in writing each specific reason that you

or by phone a . Thank you in advance for
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
uJl PROPUBLICA THE TEXAS TRIBUNE
May 25, 2022
Lexi Churchill
Research Reporter
Copies of all body camera footage taken during calls to 552 Diaz Street Uvalde, Texas 78801
on May 24, 2022.
office stm release whatever portion of my request is ready and public under Texas law.
our request.
~ PROPUBLICA THE TEXAS TRIBUNE
May 25, 2022
Lexi Churchill
Research Reporter
Copies of all body camera footage taken during calls to Robb Elementary School (715 Old
Carrizo Rd, Uvalde, TX 78801) on May 24, 2022.
office stm release whatever portion of my request is ready and public under Texas law.
I request a waiver of all fees for this request. Disc.losure of the requested information to me
our request.
----- 0 r by phone at
,...;.------------------
. Thank you in advance for
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
[I PROPUBLICA THE TEXAS TRIBUNE
May 25, 2022
Lexi Churchill
Research Reporter
Copies of all 911 audio related to calls to Robb Elementary School (715 Old Carrizo Rd,
Uvalde, TX 78801) on May 24, 2022. This should include the initial 911 call audio as well as
audio of all transmission calls made within the department and as well as from the
department to an outside caller.
office still release whatever portion of my request js ready and public under Texas law.
In order to help to determine my status to assess fees, you should know that 1 am a reporter
our request.

your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
fii PROPUBLICA THE TEXAS TRIBUNE
May 25, 2022
Lexi Churchill
Research Reporter
Tribune and myself, jointly, we respectfully request the following public r ecords:
Copies of all incident and corresponding reports related to calls made to Robb
Elementary School (715 Old Carrizo Rd, Uvalde, TX 78801) on May 24, 2022.
U) the identification and description of the complainant;
(I) the time of occurrence of the crime;
office stm release whatever portion of my request is ready and public under Texas law,
our request.

or by phone a . Thank you in advance for
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
Esmeralda Casarez

Sent: Thursday, June 2, 2022 8:17 PM
Subject: Fwd: NBC News Inquiry
Please advise them of status.
Sent from my iPhone
From: Vince DiPiazza <vdipiazza@uvaldetx.gov>

Date: June 2, 2022 at 7:07:17 PM CDT
Subject: Fwd: NBC News Inquiry
Get Outlook for Android
From: Cusumano, Anthony (NBCUniversal)

Sent: Thursday, June 2, 2022 6:36:00 PM
To: Santana, Cristian (NBCUniversal) >; Obregon, Natalie (NBCUniversal)
>; Daniel Rodriguez <drodriguez@uvaldetx.gov>; Vince DiPiazza
<vdipiazza@uvaldetx.gov>
Cc: @NBC UNI Miami Bureau Desk <miamidesk@nbcuni.com>; @NBC UNI News NetDesk Internal
<netdeskinternal@nbcuni.com>; Calvin, Amy (NBCUniversal) ~ >
Subject: RE: NBC News Inquiry
Good Evening,
Following up on this request as we've yet to receive a reply.

Please advise on the status of this public records request.
Thank you,
Anthony Cusumano
Assignment Manager - South Region
NBC Network News
1
From: Cusumano, Anthony (NBCUniversal) < >
To: Santana, Cristian (NBCUniversal) >; Obregon, Natalie (NBCUniversal)
< >; drodriguez@uvaldetx.gov; vdipiazza@uvaldetx.gov
<netdeskinternal@nbcuni.com>; Calvin, Amy (NBCUniversal) >
Good Morning,
Following up again on the request from NBC Network News for any 911 calls, surveillance video from
Robb Elementary School, and any body camera video that may have been captured by your officers
responding to Tuesday's shooting at Robb Elementary.
Also adding City Manager Vince DiPiazza here for awareness and any help.
Thank you,
Anthony Cusumano
Assignment M anager - South Region
k Ne
From: Santana, Cristian (NBCUniversal)

Sent: Saturday, May 28, 2022 9:49 AM
To: Cusumano, Anthony (NBCUniversal) ; Obregon, Natalie
(NBCUniversal) ; drodriguez@uvaldetx.gov
Cc: @NBC UNI M iami Bureau Desk <miamidesk@nbcuni.com>; @NBC UNI News NetDesk Internal
<netdeskinternal@nbcuni.com>; Calvin, Amy (NBCUniversal) >
Good morning,
Just following up these requests from myself and my colleagues.
Cristian Santana
NBC News
2
From: Cusumano, Anthony (NBCUniversal) >
To: Obregon, Natalie (NBCUniversa l) drodriguez@uvaldetx.gov
<netdeskinternal@nbcuni.com>; Santana, Cristian (NBCUniversal)
Calvin, Amy (NBCUniversal) >
Good Afternoon,
NBC News is checking in on this request once again. Any status update you can offer at this time?
Thanks very much,
Anthony Cusumano
Assignment Manager - South Region
From: Obregon, Natalie (NBCUniversal) >

<netdeskinternal@nbcuni.com>; Santana, Cristian (NBCUniversal)
Calvin, Amy (NBCUniversal)
Subject: Re: NBC News Inquiry
Hello - I wanted to follow up on my colleague's request.

NBC News would like to formally request a copy of any 911 calls, surveillance video from Robb
Elementary School, or any body camera video that may have been captured by your officers yesterday.
We know this is a very difficult time for your community and you have our condolences.
Natalie
--
Natalie Valdes Obregon
NBC News
From: "Santana, Cristian (NBCUniversal)"

Date: Tuesday, May 24, 2022 at 6:04 PM
To: "drodriguez@uvaldetx.gov" <drodriguez@uvaldetx.gov>
Cc: "@NBC UNI Miami Bureau Desk" <miamidesk@nbcuni.com>, "@ NBC UNI News NetDesk
3
Subject: NBC News Inquiry
Good evening,
Cristian from NBC News here and we're reaching out with heavy hearts in hope of obtaining more
information on this afternoon's deadly shooting.
Is there a regular Public information officer on duty that we can follow up with for a further
investigation?
As it relates to 911 calls, is it the police that would release them to the public? Or is t here another
entity?
Cristian Santana
NBC News
4
7/11/22, I:UO PM NY Times Mail . Fwd: Rerord Request
Frances Robles
Fwd: Record Request

1 message
Frances Robles Thu, May 26, 2022 at 3:09 PM

To: gmatas@uval e x.gov
Frances Robles
iebt Ni'W !!lork Q!,mes
- - - Forwarded messa e - -
From: Frances Robles
Date: Wed, May 25, 20 a
To: <gmata@uvaldetx.gov>
Hello.
*I would like make a public record request for police reports for prior calls for service to
552 Diaz St. and
1511 Hood St. Lot 9
"I would like any recordings of 911 calls made from those addresses.
l!I would like any police reports that mention Salvador Ramos in any capacity (complainant, victim,
witness, etc.)
l!I would like any police reports that mention Adriana Martinez Reyes in any capacity (complainant,
victim, witness, etc.)
thank you
My phone number is below if you have any questions.
Frances Robles
~be Nt'\11 !iJork llt11llt',
https ://mail .google.coro/tnail/u/0/?ik.=faf2ca80b8&view=pt&search=all&permthid=thread-a% 3Ar608l 3909S::!988476710% 7Cmsg•a%3Ar 379285292382l 940703&si.. . 1/l

•
--_ l ce1ve · _ •
., . .
8/26/22, 3:51 PM NY Times Mail - press request from The New York Times for recordings of police/EMS scanner and 911 calls from 5/24/2022
m

Frances Robles
press request from The New York Times for recordings of police/EMS scanner and
911 calls from 5/24/2022
1 message
Robin Stein Thu, May 26, 2022 at 1:39 PM

To: gmata@uvaldetx.gov
Cc: "Robles, Frances"
Good morning,
I hope you are well. I'm writing from The New York Times with a records request related to the Robb Elementary School
shooting on May 24, 2022.

Might you be able to spare a moment to jump on a quick phone call to discuss this request.. The best way to reach me is
my cell phone
Under the Texas Open Records Law, we are requesting an opportunity to inspect or obtain copies of the following public
records & materials:
1. Recording and transcripts of any/all 911 calls received between 11:00pm and 1:15pm involving the shooting incidents.
2. Recording of the dispatch audio feeds utilized or monitored by your agency, partner law enforcement agencies, EMS &
fire departments between 11:00pm and 1:15pm
If there are any fees for searching or copying these records, please inform us if the cost will exceed $75. However, we
would also like to request a waiver of all fees in that the disclosure of the requested information is in the public interest
and will contribute significantly to the public’s understanding of policing and community relations ,which is a focus of our
newsgathering at The New York Times. This information is not being sought for commercial purposes.
Thanks so much in advance for your time & assistance.
Best,
Robin Stein
New York Times Video Unit
https://mail.google.com/mail/u/0/?ik=faf2ca80b8&view=pt&search=all&permthid=thread-f%3A1733911395842013260%7Cmsg-f%3A1733911395842013260&sim… 1/1
Esmeralda Casarez

Subject: FW: KPRC-TV Public Information Request
Attachments: Public-lnformation-Request-Form-10-01-19.pdf
Partner
2517 N. Main
210/227 -3243
210/225-4481 (f)
any dissemination, distribution , or copying of this communication is prohibited. If you have received this communication in

Subject: FW: KPRC-TV Public Information Request
{p/{1~
(l/~9£(1/~
City S ecretary
CITY Ofl.NAUY£ -
tll#/4. ./,. d{J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssanc/1ez(il),J1val,letx.go11
From: Joel Eisenbaum

Sent: Thursday, May 26, 2022 12:00 PM
To: Daniel Rodriguez <drodriguez@uvaldetx.gov>; izamora@uvaldetx.com; City Hall <cityhall@uvaldetx.gov>
Subject: KPRC-TV Public Information Request
1
Hello,
My sincerest condolences to your community.
ENCLOSED please find the Texas Public Information Act Request Form.
We are seeking public information, docs, material held by the City of Uvalde and Uvalde Police Department.
an you,
Joel Eisenbaum
--
Investigative Reporter
KPRC-TV Houston
2
TEXAS PUBLIC INFORMATION ACT INFORMATION REQUEST FORM
For guidance regarding your rights as a requestor and the public information procedures adopted by
this governmental body, you may review the governmental body's notice required under section 552.205 of
the Government Code. You can find additional Public Information Act resources on the Office of the Attorney
General's website at http://www.texasattorneygeneral.gov/open-government.
Requestor Contact Information
First Name: Joel Last Name: Eisenbaum
Company/Organization: KPRC-TV
Mailing Address:- - -
City: - State: TX Zip Code: 77074
E-mail Address: Phone N umber:
Prefen-ed Manner of Written Communication: E-mail
Description of the Information Requested

(Note: Describe the information as precisely as you can.)
5/24/2022 calls for service and associated transcripts related to Robb ES incident
5/24/2022 911 audio calls and transcripts regarding the Robb ES incident
5/24/2022 any and all available body/dash cam video regarding the Robb ES incident
/ 1/2021 to Present: calls for service and associated reports for 552 Diaz St.
Date Range (optional): From: to:
Under the Public In formation Act, some categories of information do not have to be released.
Exceptions to disclosure fall into two general categories: 1) mandato1y exceptions that make infonnation
confidential and require a governmental body to withhold information, and 2) discretionary exceptions
that allow but do not require a governmental body to withhold infonnation. You may find
information about mandatory and discretionary exceptions HERE.
fn most instances, a governmental body is required to request a decision from the Attorney General in order to
withhold information from a requestor. However, a requestor may perm it a governmental body to redact
information without requesting an Attorney G eneral decision. You are not required -to agree to the redaction of
any information responsive to your request, but doing so may streamline the handling of yo ur request. If you
agree to redactions in this request, then you may request the redacted information in a future information request.
• Do you agree to the redaction of information that is subject to mandatory exceptions, provided such
redactions are clearly labeled on the informat ion you received? Yes [i)
• Do you agree to the redaction of info1mation that is subject to discretionary exceptions, provided such
redactions are clearly labeled on the information you receive'? Yes [3
INFORMATION PREFERENCES:
• How would you like to have the information provided? Cooies

• If available, do you wish to receive an electronic copy of the information? Yes
Please Note: lf the information requested is unclear or if a large amount of information is requested you may be
contacted to discuss clarifying or narrowing your request. There may be charges associated with production of the requested
information. You may find more information regarding the charges under the Public Information Act HERE.
Rev. 10/1/2019
Esmeralda Casarez

Subject: FW: Victor from ABC
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Sent; Friday, May 27, 2022 5 :00 PM
{p/{1~,
~~9£~~
City Secretary
on O.F UVAWt -
7/4-J;{,I, •.:t..,~1:1
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 exL 142
Fax: (830) 2 78-2234
Email: ssa11ch ezia)J.1va/detx.gov
From: Susan Anderson <sanderson@uvaldetx.gov>

Sent: Friday, May 27, 2022 2 :06 PM
1
From: Ordonez, Victor M .
To: Susan Anderson <s n uvald t . v>
Cc: Lloyd, Whitney T.
Subject: Re: Victor from ABC
Any news on this? Now that we know more about what happened in the school, we are trying to build out a map for our
viewers to go with the timeline we were given by law enforcement today.
Also adding my colleague Whitney.
Best wishes,
Victor Ordonez
ABC News Specialized Units
Get Outlook for iOS

Sent: Friday, May 27, 2022 8:17:22 AM
To: Ordonez, Victor M . < >
Subject: RE: Victor from ABC
Thank you.
From: Ordonez, Victor M .

To: Susan Anderson <sanderson@uvaldetx.gov>
Absolutely. Wishing you and your city the best,
Victor Ordonez
Get Outlook for iOS

Sent: Thursday, May 26, 2022 6:34:55 PM
To: Ordonez, Victor M . < >
Than k you for your understanding. Crazy situation.
2
From: Ordonez, Victor M.
Understood. I'll pass this information to my editors. Thank you, please let m e know when you have more information.
Best wishes,
Victor Ordonez
Get Outlook for iOS

To: Ordonez, Victor M. <
Our lawyers are saying that until the Texas Department of Public Safety finishes their investigation, we can't release this
information.

Hi,
Is there any chance you can direct me to who is holding t he schematics back for the school?
Our lawyers are telling me these are suppose to be public.
All the best,
Victor Ordonez
Get Outlook for iOS

To: sanderson@uvaldetx.gov <sanderson@uvaldetx.gov>
Subject: Victor from ABC
Victor Ordonez
3
Get Outlook for iOS
4
Esmeralda Casarez

Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
PRIVILEGED AND CONFI DENTIAL. If you are not the intended recipient, or the employee or agent responsible for

To: Clarissa Rodriguez <cmrodriguez@rarnpagelaw.com>
(9/(~,
(t/~~(t/~
City Secretary
O'NOEUVALOE -
t/,'ftl'i. . ) .,w.i
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax.: (830) 278-2234
Email: ssam:he:.(iimvflldetx.go1•

Sent: Friday, May 27, 2022 8:24 AM
Subject: RE: Washington Post records request
I'm going to be t ied up much of the morning.
From: Sorayda Sanchez

Sent: Friday, May 27, 2022 8 :12 AM
To: Vince DiPiazza <vdipiazza@uvaldetx.gov>
Subject: Re: Washington Post records request
Good Morning Mr. DiPiazza,

Yes. I agree, we need to meet sooner. I will call Alex and see if we can meet sometime today. We spoke earlier
this week about these requests. She was going to call the AGs office to obtain an opinion. 1 will follow up with
her on that.
-Sory
On May 26, 2022, at 5: 11 PM, Vince DiPiazza <vdipiazza(a),uvaldetx.gov> wrote:
Sorayda,
Sorry about this request. I'm not going to tell them I think it will be irrelevant, but I we're probably going
to have to deal with it.
Alex wants to get together and meet on these requests, but she didn't think we needed to do t hat until
Tuesday. l'm thinking we may need to that sooner. What do you think?
Vince
From: Brown, Emma [

To: Vince DiPiazza <vdipiazza@uvaldetx.gov>
Subject: Washington Post records request
Dear Mr. Di Piazza,
First, I am so sorry for what your community has been forced to endure this week.
I am thinking about Uvalde and its people.
I am a representative of the Washington Post, a news media organization

primarily engaged in the dissemination of information that is urgency
needed to inform the public of actual or alleged government activity, so please
process this request in an expedited manner.
Pursuant to Texas Public Information Act (Tex. Gov't Code § 552), I hereby
request the following:
2
All emails and text messages sent to or.from Uvalde Police ChiefDaniel Rodriguez
and.Mayor Don McLaughlin between 11 a.m. on May 24, 2022 and 11 a.m. on
May 26.. 2022.
If you regard these documents as potentially exempt from the public record act's
disclosure requirements, I request that you nonetheless exercise your
discretion to disclose them. As required, please release all segregable, non-exempt
portions of documents, preferably via em ·
To permit me to reach an intelligent and informed decision whether to contest any

denied material, please describe any withheld records (or portions thereof) and cite
the legal justification for any exemption claims, as required by Texas law.
While I am aware that you may be entitled to charge some reasonable fees to
process this request, I hereby request that you waive all such fees. Waiver of fees is
in the public interest because the fu1nishing of the information sought by this
request will primarily benefit the public and is likely to contribute significantly to
public understanding of the operations or activities of the government. If, however,
you decide not to waive fees and expect them to exceed $100, please advise me as
to the estimated cost of fulfilling the request (including copying charges).
I look forward to hearing your prompt response to my request, as required by

Texas law.
Sincerely,
Emma Brown
Esmeralda Casarez

Subject: FW: PIR from San Antonio Express-News
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Subject: FW: PIR from San Antonio Express-News
~~,
(?/~~(?/~
City Secretary
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: sstmcl1e~@u valdetx.gov
From: Bryan, Claire

To: City Hall <cityhall@uvaldetx.gov>
Subject: PIR from San Antonio Express-News
Hello,
Under the Texas Public Information Act, Tex. Gov't Code §552.001 I am requesting copies of floorplans and/or a map of
Robb Elementary School. The San Antonio Express-News reporters need to review the maps in order to ensure our
reporting of the school shooting that occurred on Tuesday May 24111 is accurate.
If there are any fees for searching or copying these records, please inform me if the cost will exceed $100. However, I'd
like to request a waiver of all fees in that the disclosure of the requested information is in the public interest and will
contribute significantly to reporting on this national event.
I'd like to request that you email me the requested documentation a t -.___ _ _ _ _ _ _ __
Please let me know if you have any questions for me. Thank you in advance.
Best,
Claire Bryan
Claire Bryan
Education Reporter
ian.Antonio&press-News
ExpressNews.com; mySA.com;
2
Esmeralda Casarez

Subject: FW: CNN public records request -- body-cam video and other recordings
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
PRIVILEGED AND CONFIDENTIAL. If you are not the intended redpient, or the employee or agent responsible for

@Jr~ ,
(l/~ 9£~~
City Secretary
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 exl 142
Fax: (830) 278-2234
E mail: ssanche:@uvuldetx. gov
From: Clarissa Chavez <cchavez@uva ldetx.gov>

To: Alexandra Tarski <alexandra@tarskilaw.com>; Sorayda Sanchez <ssanchez@uvaldetx.gov>; Vince DiPiazza
<vdipiazza@uvaldetx.gov>
1
Cc: Gabriella Mata <gmata@uvaldetx.gov>
Subject: RE: CNN public records request -- body-cam video and other record ings
Yes Gabriella and are available any time you need us.
From: Alexandra Tarski <alexandra@tarskilaw.com>

To: Sorayda Sanchez <ssanchez@uvaldetx.gov>; Vince DiPiazza <vdipiazza@uva ldetx.gov>
Cc: Clarissa Chavez <cchavez@uvaJdetx.gov>; Gabriella Mata <gmata@ uvaldetx.gov>
Subject: Re: CNN public records request -- body-cam video and other recordings
Ladies and Gentlemen,
Can we meet either this afternoon or tomorrow morning to discuss further the city 's response on these requests?
Sent from my iPhone
On May 26, 2022, at 11 :40 AM, Sorayda Sanchez <ssanchez(a1nvaldetx.gov> wrote:
Good Morning,
We are not releasing any information related to the school shooting, as that could possibly hinder the
ongoing investigation. Alex will be contacting the AG's Office and preparing a statement for us to
provide on these types of requests.
{P/f~,
(?J~!Y.(?J~
City Secretary
CITY QJWVAl.011 -
1/4,///. ./ ,vWJ
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: s.wmche:(ii>u valdetx.gov
From: Clarissa Chavez <cchavez@uvaldetx.gov>

To: Alexandra T. Wegrzyn <alexandra@tarskilaw.com >; Sorayda Sanchez <ssanchez@uvaldetx.gov>
Cc: Gabriella Mata <gmata @uva ldetx.gov>
From: Devine, Curt

2
Cc: Daniel Rodriguez <drodriguez@ uvaldetx.gov>; Jessica Zamora <iazamora@uvaldetx.gov>
Subject: CNN public records request -- body-cam video and other recordings
Hello - CNN would like t o submit this additiona l public records request related to the Robb Elementary
shooting. Thank you for your assistance.
- -- - - PUH181t-1ti-t,ICP-1RfeORDS REQUEST:
Pursuant to the Texas Public Informat ion Act, CNN requests access to and copies of any body-worn
camera video or dash-cam video or other video recorded at or near Robb Elementa ry School on May 24,
2022 between 11:15am and 1:15pm held by t he department.
Additionally, CNN request s recordings of radio t ransmissions from or received by officers during this
time related to the shooting.
If t he department is already compiling this material to release to other requestors and t he parameters
of those requests is slightly different, CNN will likely agree to alter the parameters of t his request for the
sake of efficiency.
Thank you,
Curt Devine
CNN, Washington
3
Esmeralda Casarez

Subject: FW: NBC Records Request
Partner
Denton, Navarro, Rocha, Bernal, & Zech , P.C.
2517 N. Main
210/227-3243
210/225-4481 (f)
error, please notify us immediately by replying to the message and deleting it from your computer. Thank you .

Subject: FW: NBC Records Request
(p/{1~,
~~!K~~
City Secretary
CITY OF.UVAI.DE -
U'('t(,¼ ..;;J(<J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssa11cl1ez(@,uvaldet.x.gov

Subject: Fwd: NBC Records Request
1
Sent from my iPhone
From: "Parks, Eva (NBCUniversal)"

Date: May 26, 2022 at 10:14:31 AM CDT
To: City Hall <cityhall@uvaldetx.gov>, Daniel Rodriguez <drodriguez@uvaldetx.gov>
Cc· "Friedman, Scott (NBC! lniversal)" - 1 - - - - - - - - -- - - - - - - - - -
Subject: NBC Records Request
Our deepest and sincerest condolences to your city and community.

We have an open records request to file.
NBC is requesting police Computer-aided dispatch (CAD) reports from Tuesday, May 24, 2020.
In an effort to minimize any work for your staff, we can send someone in to pick them up in person
today if that's easier.
Please let us know.
Thanks
Eva
Eva Parks
Investigative Producer
- Dallas-Fort Worth
NBCDFW.COM I NBCDFW I @nbcdfw

"'~ ! 6=.
B~\ j f!JP&I
~"T NBCUniversal Local
2
Esmeralda Casarez

Subject: FW: Open records request
Clarissa M . Rodriguez
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
delivering the message to the intended recipient, and have received this information in error, you are hereby notified
that any dissemination, distribution, or copying of this communication is prohibited. If you have received this
communication in error, please notify us immediately by replying to the message and deleting it from your computer.
Thank you.
-----Original Message-----
Regards,
Sorayda A. Sanchez
City Secretary
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
36
Good morning,
Thank you,
Gabriella Mata
Records Clerk
City of Uvalde
Po .
964 W. Main St
Uva lde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: (830)591-2552
gmata@uvaldetx.gov
message or any attachments unless you are the intended recipient. If you are not the intended recipient, please notify
the sender and destroy all copies and printouts of this email message and/or attachments
From: Wagschal, Gerry
Subject: Open records request
Hello my name is Gerry Wagschal And I am a senior producer for ABC News. I am currently doing research int o the past
of Salvador Ramos, 18, the alleged mass murderer. I wanted to obtain for abc news Any police reports, documents, or
videotape evidence in connection with Salvador Ramos in your possession or w ith his address including the police report
from the actual shooting at the school.
I am willing to pay Any cost of up toS00 dollars relating to t his search and retrieval. Tha nk you
Gerry Wagschal
Senior producer
-
Sent from my iPhone
37
Esmeralda Casarez

Subject: FW: Houston Chronicle TPIA request
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
PRIVILEGED AND CONFIDENTIAL. lf you are not the intended recipient, or the employee or agent responsible for
Fro m : Sorayda Sanchez <ssanchez@uvaldetx.gov>

{!1/)prdJ,
(?f~ !K(?f~
City Secretary
· CHYOFUVAWE ~-
74wid .l-.r,.~i
City of Uvalde
P. O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (8.10) 278-2234
Email: ss,md,er{a)uvaldetx.g"v

41
Good morning,
T ~y01-½
c;oJ?,y~ fvl o..fo-,
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: (830)591-2552
message or any attachments unless you are the intended reciµient. If you are not the intended recipient, please notify the
From: Foxhall, Emily

Subject: Houston Chronicle TPIA request
Hi Gabriella -- I'm writing to request under the Texas Public Information Act copies of recordings of all 911 calls
placed on May 24 between 10 a.m. and 3 p.m .. I would also like to receive the call slips associated with those
recordings. I prefer to receive these records electronically. Please let me know if there is anything I can do to
expedite this request.
Thank you,
Emily Foxhall
42
Esmeralda Casarez

Subject: FW: press request from The New York Times for recordings of police/EMS scanner and
911 calls from 5/24/2022
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Subject: FW: press request from The New York Times for recordings of police/EMS scanner and 911 calls from 5/24/2022
fir~ ,
r;/~ !5.r;I~
City Secretary
OTYQf.'. iUVAWt --
. 'f/,;.,_/J •j,..m..
l
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssa11cl1ez@,ul!a/detx.gov

Subject: FW: press request from The New York Times for recordings of police/EMS scanner and 911 calls from 5/24/2022
43
Good morning,
Reeeff!ls~rk
City of Uvalde
Police Department
964 W. Main St
Uvalde1 Texas 78801
Work: {830)278-9147 ext. 812
Fax: (830)591-2552
gmata(a),uvaldetx. gov
rectpfent(s), and may contain confidential and/or privileged information. Do not read, copy, forward, or print this email
From: Robin Stein >

Cc: Robles, Frances
Subject: Re: press request from The New York Times for recordings of police/EMS scanner and 911 calls from 5/24/2022
Apologies! I'm re-sending because I initially wrote pm instead of am.
1. Recording and transcripts of any/all 911 calls received between 11:00am and 1:15pm involving the shooting
incidents.
2. Recording of the dispatch audio feeds utilized or monitored by your agency, partner law enforcement agencies,
EMS & fire departments between 11:00am and 1:15pm
On Thu, May 26, 2022 at 1:39 PM Robin Stein wrote:

Good morning,
44
Might you be able to spare a moment to jump on a quick phone call to discuss this request.. The best way to reach me
is my cell phone _ _
Under the Texas Open Records Law, we are requesting an opportunity to inspect or obtain copies of the following
public records & materials:
incidents.
2. Recording of the dispatch audio feeds utilized or monitored by your agency, partner law enforcement agencies, EMS
& fire departments between 11:00am and 1:15pm
and will contribute significantly to the public's understanding of policing and community relations ,which is a focus of
our newsgathering at The New York Times. This information is not being sought for commercial purposes.
Best,
Robin Stein
; New York Times Video Unit
45
£1 PROPUBLICA J:ITHE TEXAS TRIBUNE
May 26, 2022
Lexi Churchill
Research Reporter
Electronic Copies of all communications to and from Uvalde Chief of Police Daniel
Rodriguez including but not limited to emails, text messages, voicemail recordings,
electronic messages (such as on Slack, Microsoft Teams, Facebook messenger, Whats
app, Signal etc.), call logs, call recordings and meeting recordings from May 24, 2022
to May 26, 2022. This should include communications from both professional, as well
as personal phones, computers and email addresses when used for government
work.
office still release whatever portion of my reQuest is ready and public under Texas law.
our request.
If you deny any part of th is request, please cite in w riting each s pecific reason that you

or by phone at Thank you in advance for
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
uJl PROPUBLICA THE TEXAS TRIBUNE
May 26, 2022
Lexi Churchill
Research Reporter
Electronic Copies of all communications to and from all Uvalde Police Department
officers including but not limited to emails, text messages, voicemail recordings,
electronic messages (such as on Slack, Microsoft Teams, Facebook messenger, Whats
app, Signal etc.), call logs, call recordings and meeting recordings from May 24, 2022
to May 26, 2022. This should include communications from both professional, as well
as personal phones, computers and email addresses when used for government
work.
office stm release whatever portjon of my request is ready and public under Texas law.
our request.

r by phone at . Thank you in advance for
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
Esmeralda Casarez

To: dnrbzsat
Subject: FW: TPIA RE: Calls for service, 911 calls
{[it~,
(l/~9£(?/~
City Secretary
<..m Of UVALDE _
12..-rl.l. •.h Jr.f.J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234

Subject: FW: TPIA RE: Calls for service, 911 calls
'DMid 6Rodtw)«eJ,
Chief of Police
Uvalde Police Department
(830) 278-9147 ext. 848
(830) 900-4145 eel
From: Macias, Tina [

Cc: information@tarskilaw.com; Cobb, Jennifer ; Merced.es, Cheryl
Rogalski, Jeremy >
Subject: TPIA RE: Calls for service, 911 calls
Good afternoon:
I'm Tina Macias, an investigative producer for KHOU llNews in Houston. First , let me extend my condolences for the
terrible tragedy at Robb Elementary School and for everything your department and city has been through this week.
We're also looking for answers and have several records requests below. We understand some records may be available
sooner than others, so please provide information on a rolling basis, when they become available.
Under the Texas Public Information Act, we are requesting t he following information:
• Records of any and all calls for service made to the Uvalde Police Department on May 24, 2022.
• Records and recordings of any and all 911 calls made to the Uvalde Police Department on May 24, 2022.
• Recordings of any and all body-worn camera videos from Uvalde Police officers from May 24, 2022.
• Records of any and all calls for service regarding Robb Elementary School, 715 Old Carrizo Rd or Uva lde High
School, 1 Coyote Trail from January 1, 2022 to May 25, 2022.
• Records of any and all calls for service regarding 552 Diaz St reet from January 1, 2020 to May 25, 2022.
The Texas Public Information Act requires that you "promptly produce" t he requested records unless, within 10 days,
you have sought an Attorney General's Opinion. If you expect a delay in producing these records, please contact me
w ith information about when I might expect the request to be fulfilled.
In advance, I stipulate t o the redaction of any information protected under the Act or by a Texas Attorney General's
opinion, but please include an explanation of redactions when completing this request.
Additionally, if this informat ion is available electronically, I prefer to receive it that way, sent via e-mail
to
If you require any additional information or clarification to fulfil l this request please feel free to contact me.
Thanks,
Tina
Tina Macias
KHOU*ll.
SUND$ ,01 MOIISTOH
AT!GNA~ I
I I khou.com
2
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Esmeralda Casarez

Subject: FW: NBC Open Records Request #2
Importance: High
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Importance: High
{p/{1~ ,
(?/~ 9£(?/~
City Secretary
QTY QlHJ\IAlDE -
7/..-alli . /,,[<~
City of Uvalde
P. O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 exL 142
Fax: (830) 278-2234
Email: ssanc/1e;,@)1valdetr:. 'f{m'
From: Parks, Eva (NBCUniversa l) <Eva.Parks@nbcuni.com>

1
To: Daniel Rodriguez <drodriguez@ >· · < - l@uvaldetx.gov>
Cc: Friedman, Scott (NBCUniversal)
Subject: NBC Open Records Request #2
Importance: High
This is an open records request filed under the Texas Public Information Act.
NBC is requesting the following:

CAD Reports and Police reports filed at:
552 Diaz Street
820 High Street
Please search 2021 to May 23, 2022.
The Texas Public Information Act requires that you "promptly produce" the requested records unless, within
request, please contact me with information about when I might expect copies or the ability to inspect the
requested records.
If you deny any or all of this request, please cite each specific exemption you feel justifies the refusal to
Sincerely,
Eva
Eva Parks
I
NBC 5 Dallas-Fort Worth
~to
I* ·11 . ,=
i.l 'fU
.fkT NBCUniversal Local
2
Esmeralda Casarez

Subject: FW: NBC Open Records Request
Partner
2517 N. Main
210/227-3243
210/ 225-4481 (f}
any d issemination, distribution , or copying of this communication is prohibited. If you have received this communication in

Subject: FW: NBC Open Records Request
~~,
r;/~ 9£r;/~
City Secretary
. CITY OF UVAWE __
//,,,.,,/,~ ,/,;,,~tJ
City of Uvalde
P.O. Box799
Uvald.e, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: s.sa11chetfa'i.11valdetx.gov
From: Parks, Eva (NBCUniversal)

To: Daniel Rodriguez <drodriguez >· · < · l@uvaldetx.gov>
Cc: Friedman, Scott (NBCUniversal)
Subject: NBC Open Records Request
1

911 calls made on 5/24/2022
CAD Reports from 552 Diaz Street and Robb Elementary on 5/24/2022
l Q days, yo11 have s011ght ao Attorney General's Opinion If you expect a significtmt delay in responding to-tl=i,i~s- -
requested records.
If you deny any or all of this request, please cite each specific exemption you feel j ustifies the refusa l to
Sincerely,
Eva
Eva Parks
I

~~ l ,=_
00_,) [ ~~
~tT NBCUniversal Local
2
Esmeralda Casarez

Subject: FW: Public Information Act Request -- Calls for Service
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

To: Clarissa Rodriguez <cmrodriguez@rampagelaw .co m>
Subject: FW: Public Information Act Request -- Calls for Service
~~,
(lf~!K(lf~
City Secretary
cm Of UVAtDE -
f /,w~ . ;/4,,.,,_i
City of Uvalde
P.O. Box 799
Uvalde, Te.ws 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssnnche?f@m1a/detx.gov
From: Eaton, Emilie

To: Daniel Rodriguez <drodriguez@uvaldetx.gov>; City Ha ll <cityhall@ uvaldetx.gov>
Subject: Public Information Act Request -- Calls for Service
1
Good morning,
Can you please forward this Open Records Request to the appropriate folks? Thank you very much .
Under Chapter 552 of Texas Government Code, the Texas Public Information Act, I respectfully request a copy of the
following records.
All list of calls for service of 911 calls, and any corresponding police reports, to and from the following addresses:
Uvalde, TX 78801
209 N First Street, #3A

Uvalde, TX 78801
1511 Hood Street #9

Uvalde, TX 78801
820 S. High Street

Uvalde, TX 78801
If you have any questions about this request, feel free to contact me at or
Thank you very much.
Best,
Emilie
Emilie Eaton
San Antonio Express-News
2
Esmeralda Casarez

Subject: FW: CBS News FOIA request - Uvalde Texas
Attachments: CBS News Public-lnformation-Request-Form- 10-01 -1 9.pdf
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
This transmission ls intended for the individual or entity to which it is addressed, and may be information that is

Subject: FW: CBS News FOIA request - Uvalde Texas
«~,
(?/~~(?/~
City Secretary
CIT)' QF.UVALOt _
tl #a ._1,,_,4J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax.: (830) 278-2234
Email: sstmchez@ul'ai,fot.x.gov
From: Petrie, Andrew< >

To: City Ha ll <cityhall@uvaldetx.gov>; Daniel Rodriguez <drodriguez@uvaldetx.gov>; 'Ericka.Miller@dps.texas.gov'
<Ericka.Miller@dps.texas.gov>; 'MediaAndCommunicationsOffice@dps.texas.gov'
1
<MediaAndComrnunicationsO · · · ords@oag.t e · , county.co m
Cc: @CND National Desk Staff .
· Campa, Mary Helen
Subject: CBS News FOIA request - Uvalde Texas
Please see attached FOIA from CBS News regarding the incident at Robb Elementary in Uvalde, Texas.
2
this governmental body, you may review the governmental body's notice required under section 552.205 of
General's website at ht1p://www.texasattorneygenernl.gov/opeu-government.
First Name: Andrew Last Name: Petrie
Company/Organization: CBS News
Mailing Address:
City: Zip Code: -
Phone Number:
PrefeITed Manner of Written Communication: E-mail 13
(Note: Describe the infonnation as precisely as you can.)
We are seeking records regarding the police response and reaction to the shooting at Robb
i=lementary in Uvalde, Texas - police reports regarding decision making, information
~athered at the scene, radio communication during this event, body camera and any video
surveillance from or near the school during the incident.
Date Range (optional): From: 5/23/2022 to: 5/27/2022
Under the Public lnfomrntion Act, some categories of infom1ation do not have to be released .
Exceptions to d isclosure fall into two general categories : 1) mandatory exceptions that make infonnation
that allow but do not require a governmental body to withhold information. You may fi nd
In most instances, a governmental body is required to request a decision from the Attorney General in order to
withhold infomiation from a requestor. However, a requestor may permit a governmental body to redact
infonnation without requesting an Attorney General decision. You are not required to agree to the redaction of
any inform ation responsive to your request, but doing so may streamline the handling of your request. lf you
agree to redactions in this request, then you may request the redacted infom1ation in a future infonnation request.
redactions are c learly labeled on the information you received? Yes El
• Do you agree to the redaction of information that is subject to discretionary exceptions, provided such
redactions are clearly labeled on the information you receive? Yes [ii
• How would you like to have the inform ation provided? Cooies
• If available, do you wish to receive a n e lectro nic copy of the information? Yes L3
Please Note: If th e information requested is unclear or if a large amount of infom1ation is requested you may be
information. You may fi nd more infom1ation regarding the charges under the Public Information Act HERE.
Rev. I0/ tn019

Esmeralda Casarez

Subject: FW: TX PIA Request - Arrest Records for 5/24/2022
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
any dissemination, distribution, or copying of this communication is prohibited. If you have received this communication ln
From : Sorayda Sanchez <ssanchez@ uvaldetx.gov>

Subject: FW: TX PIA Request - Arrest Records for 5/24/2022
{pj[1~ 1
(I/~ !K.(11'~
City Secretary
(ITY OF. UVALDE ·-
. 1/;"~/,fl. •J,,.,,M
City of Uvalde
P. O. B ox 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ss,inchez@uvaldetx.gov
From : Daniel Rodriguez <drodriguez@uvaldetx.gov>

Subject: Fwd: TX PIA Request - Arrest Records for 5/24/2022
20
Sent from my iPhone
From: "Ghisolfi, Caroline"

Date: May 27, 2022 at 1:46:20 PM CDT
Cc· Daniel Bodrig11ez <dcodrig11ez@11valdetx gov>
Subject: TX PIA Request • Arrest Records for 5/24/2022
Good afternoon,
• All reports, photos (including but not limited to mugshots), videos, supplemental memos and
other records related to any individual arrested or detained on May 24, 2022.
The requested documents will be made available to the general public, and this request is not being
Sincerely,
Caroline Ghisolfi
--
Data Reporter
Au$tin Anttrican-~tate$man
21
Esmeralda Casarez

Subject: FW: TX PIA Request - Rosters and Communications with CBP
Partner
2517 N . Main
210/227-3243
210/225-4481 (f)
PR IVILEGED AND CONFIDENTIAL. If you are not the intended recipient, or the employee or agent responsible for
any dissemination, distribution, or copying of this communication is prohibited If you have received this communication in

Subject: FW: TX PIA Request - Rosters and Communications with CBP
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ss,1nchez(fi.1uvaldetx.gov

Subject: Fwd: TX PIA Request - Rosters and Communications with CBP
22
Sent from my iPhone
From : "Gh isolfi, Caroline"

Date: May 27, 2022 at 1:41:13 PM CDT
Cc· Daniel Rodriguez <dradrig11ez@11vaJdetx gov>
Subject: TX PIA Request - Rosters and Communications with CBP
Good afternoon,
• Rosters, calendars and any other documents detailing all on-duty and off-duty officers employed
by the Uvalde Police Department for May 24, 2022.
• All communication records (including call transcripts, text messages and emails) between any
individual employed by the Uvalde Police Department and any individual employed by U.S.
Customs and Border Protection between 11 a.m. and 4 p.m. on May 24, 2022.
Sincerely,
Caroline Ghisolfi
--
Data Reporter
Au$lin American-~tate%man
23
u)1 PROPUBLICA THE TEXAS TRIBUNE
May 27, 2022
Lexi Churchill
Research Reporter
Copies of the mostcurrent Robb Elementary School Floor plans.
office still release whatever portion of my request is ready and public under Texas law,
our request.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
Cl PROPUBLICA THE TEXAS TRIBUNE
May 27, 2022
Lexi Churchill
Research Reporter
Copies of all car and unit camera footage taken by Uvalde Police officers during calls
to Robb Elementary School (715 Old Carrizo Rd, Uvalde, TX 78801) on May 24, 2022.
office still release whatever portion of my request is ready and public under Texas Jaw,
understanding of the operations or activities of the government. If a waiver offees is not
our request.
If you deny any part of th is request, please cite in writing each specific reason that you
------ or by phone at
.------------------
. Thank you in advance for
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
Esmeralda Casarez

Subject: FW: Public Information Act request: 911 and police records
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Sent: Friday, May 27, 2022 4 :12 PM
Subject: FW: Public Information Act request: 911 and police records
Good Afternoon Clarissa,

Below one of many PIA requests I have received.
(pj['~,
(?f~~(?f~
City Secretary
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssa1Jchev.,ii)J1 valtletx.gov
From: Gloria Resma <gresma@uvaldetx.gov>

To: Alexandra Wegrzyn <awegrzyn@uvaldetx.gov>; Sorayda Sanchez <ssanchez@ uvaldetx.gov>
Subject: Fw: Public Information Act request: 911 and police records
1
Thank you,
GlorCcv V&vv Re-1--wuit. 1
Executive Assistant
101 E. Main Street
Uvalde, Texas 78801
830-278-3315 ext. 141
From: Eaton, Joshua (Contractor-NBCUniversal)

Cc: Carroll, Susan (NBCUniversal) Gloria Resma <gresma@uvaldet x.gov>
Subject: Re: Public Information Act request: 911 and police records
We would like to amend the below Texas Public Information Act request a third time to include the following additional
records:
• all personnel and/or disciplinary records for former Uvalde Police Department Assistant Chief of Police Pedro
"Pete" Moreno Arredondo
If some of the records we are requesting are not available, or are not releasable under Texas law, please provide those
records that are available and releasable.
If you have any questions, please feel free to contact us at 0. . . . . .
Thank you for your time and help.
Sincerely,
Joshua Eaton
cc: Gloria Resma, Susan Carroll
Joshua Eaton
Researcher I NBC News
From: Eaton, Joshua (Contractor-NBCUniversal) >

Date: Thursday, May 26, 2022 at 3:33 PM
To: cityhall@uvaldetx.gov <cityhall@uvaldet x.gov>
2
Cc: Carroll, Susan (NBCUniversal) < , gresma@uvaldetx.gov
<gresma@ uvaldetx.gov>
We would like to amend the below Texas Public Information Act request a second t ime to include the following
additional records:
• All body-worn camera and in-car camera footage, including both audio and video, from Uvalde Police
Department officers responding to the shooting at Robb Elementary School on 05/24/2022
• Any records related to the Uvalde Police Department SWAT team's visits to Uvalde CISD schools and the Uvalde
Classical Academy on Feb. 11, 2020, as described in t his Facebook post :
If you have any questions, please feel free t o contact us at
Thank you for your t ime and help.

0-
https://www.facebook.com/uvaldepd/photos/a.984027511630606/2986614501371887 /? rdr.
Sincerely,
Joshua Eaton
Joshua Eaton
From: Eaton, Joshua {Contractor-NBCUniversal) <

To: cityhall@uvaldetx.gov <cityhall@uvaldetx.gov>
Cc: Carroll, Susan (NBCUniversal) < >, gresma@uvaldetx.gov
<gresma@uvaldetx.gov>
We would like to amend the below Texas Public Information Act request to include the following additional records:
• all 911 call logs that include calls for service to 1511 Hood St., Lot 9, Uvalde, TX 78801 from 05/24/2017 -
05/24/2022 (if these dates are not readily available, please provide all readily available dates)
• all incident reports (or similar reports) for 1511 Hood St., Lot 9, Uva lde, TX 78801 from 05/24/2017 -
r--
05/24/2022 (if these dates are not readily avai lable, please provide all readily available dates)
If you have any questions, please feel free to contact us at
Than k you for your time and help.
3
Sincerely,
Joshua Eaton
Joshua Eaton
From: Eaton, Joshua (Contractor-NBCUniversal) <

To: cityhall@uvaldetx.gov <cit yhall@uvaldetx.gov>
Cc: Carroll, Susan (NBCUniversal) >, gresma@uvaldetx.gov
<gresma@uvaldet x.gov>
Subject: Public Information Act request: 911 and police records
This is a request for records under the Texas Public Information Act by Joshua Eaton and Susan Carroll for NBC News.
We request the following 911 records:
• all 911 call logs for 05/24/2022

• all 911 call recordings for 05/24/2022
• all 911 call logs that include calls for service to Robb Elementary School, 715 Old Carrizo Rd, Uvalde, TX 78801,
from 05/24/2017 - 05/24/2022 (if these dates are not readily available, please provide all readily available
dates)
• all 911 ca ll logs that include calls for service to 552 Diaz St, Uvalde, TX, 78801, from 05/24/2017 - 05/24/2022 (if
these dates are not readily available, please provide all readily available dates)
We also request the following police records:
• all Uvalde Police Department dispatch recordings for 05/24/2022

• all incident reports (or similar reports) for the shooting at Robb Elementary School on 05/24/2022
• all incident reports (or similar reports) for 552 Diaz St, Uvalde, TX, 78801, from 05/24/2017 - 05/24/2022 (if
these dates are not readily available, please provide all readily ava ilable dates)
• all arrest and/or criminal history records for Salvador Rolando Ramos (DOB 05/16/2004), Rolando Va lley Reyes,
Marisa belle Ramos and Adriana M. Reyes
We believe all these records are mainta ined by the Uvalde Police Department.
Please provide these records to us on a rolling basis as your office processes them, rather than waiting to provide any
records until al l records are processed.
We are full-time editorial employees of NBC News. We are requesting these records as part of the news-gathering
process, not for commercial purposes.
We are wi lling to pay up t o $100 in fees. If you charge more than $100, please inform us in advance.
4
Please provide all responsive records as an email attachment t If you cannot provide t hem
as an email attachment, please mail a thumb drive (preferable) or a hard copy to:
--
lfyou have any questions, please feel free to contact us a or
Thank you f-or your time afld help.
Sincerely,
Joshua Eaton
Joshua Eaton
5
Received
May 31, 2022
Mike Baker < >
NYT request, 5/31
Mike Baker < > Tue, May 31, 2022 at 10:22 AM

Pursuant to state open records law, The New York Times requests the following information
• All text, email and other electronic correspondence sent to or from Mayor McLaughlin on May 24 between 11 a.m. and 2 p.m.
• All text, email and other electronic correspondence sent between Daniel Rodriguez and Mayor McLaughlin since May 24 at 11 a.m.
• Any written reports or summaries Mayor McLaughlin has received related to the events of May 24.
Thank you.
--
Mike Baker | The New York Times

Esmeralda Casarez

Subject: FW: WOAI/KABB-TV OPEN RECORDS REQUEST - INCIDENT REPORT FOR 5/24 ROBB
ELEMENTARY SHOOTING
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
delivering the message to the intended recipient. and have received this information in error, you are hereby notified that

To: Sorayda Sanchez <ssanchez@uvaldetx.gov>; Clarissa Rodriguez <cmrodriguez@rampagelaw.com>
Subject: Fwd: WOAI/KABB-TV OPEN RECORDS REQUEST- INCIDENT REPORT FOR 5/24 ROBB ELEMENTARY SHOOTING
This is the first of four requests I received late last night from the same person.
Vince
From: Leslie Acosta <laacosta@sbgtv.com>

Sent: Friday, May 27, 2022, 23:34
To: Vince DiPiazza <vdipiazza@uvaldetx.gov>; Daniel Rodriguez <drodriguez@uvaldetx.gov>
Cc: Bryan Eckert
Subject: WOAI/KABB·TV OPEN RECORDS REQUEST - INCIDENT REPORT FOR 5/24 ROBB ELEMENTARY SHOOTING
Good evening,
WOAI/KABB-TV would like to request the following public information from the City of Uvalde under
the Texas Public Information Act, Texas Government Code, Chapter 552.
We would like to request the incident report for the May 24th shooting at Robb Elementary School,
located at 715 Old Carrizo Rd.
1
We would like you to waive any fees associated with th is request, as this information benefits the
public.
If you have any questions, you can contact myself or my managing editor Bryan Eckert copied
above.
Please send the report to
We can also pick up a physical copy 1f needed.
Thank you,
Leslie Acosta
Assignment Editor
News 4 WOAI l KABB
2
Esmeralda Casarez

Subject: FW: WOAI/KABB-TV OPEN RECORDS REQUEST - BODY & DASH CAM VIDEO FOR
RESPONSE TO ROBB ELEMENTARY SHOOTING 5/24
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)
any dissemination, distribution, or copying of this communication is prohibited . If you have received th is communication in

Subject: Fwd: WOAI/KABB-TV OPEN RECORDS REQUEST - BODY & DASH CAM VIDEO FOR RESPONSE TO ROBB
ELEMENTARY SHOOTING 5/24
#2 of 4
From: Leslie Acosta

Sent: Friday, May 27, 2022 11:33:09 PM
To: Vince DiPiazza <vdipiazza@uvaldetx.gov>; Daniel Rodriguez <drodriguez@uvaldetx .gov>
Cc: Bryan Eckert
Subject: WOAI/KABB-TV OPEN RECORDS REQUEST - BODY & DASH CAM VIDEO FOR RESPONSE TO ROBB ELEMENTARY
SHOOTING 5/24
Good evening ,
We would like to request the releasable body and dash cam video from initial responding units to
the May 24th shooting at Robb Elementary School, located at 715 Old Carrizo Rd.
1
We would like you to waive any fees associated with this request, as this information benefits the
public.
above.
Please send these videos via email to through WeTransfer

https ://wetra n sfer. com/
We can also pick up a hard copy If needed.
Thank you,
Leslie Acosta
Assignment Editor
News 4 WOAI KABB
GW35
2
Esmeralda Casarez

Subject: FW: WOAI/KABB-TV OPEN RECORDS REQUEST - 911 CALLS FOR ROBB ELEMENTARY
SHOOTING 5/24/2022
Partner
Denton, Navarro, Rocha, Bernal , & Zech , P.C.
2517 N. Main
210/227-3243
210/225-4481 (f)
error, please notify us immediately by replying to the message and deleting it from your computer. Thank you

Subject: Fwd: WOAI/KABB-TV OPEN RECORDS REQUEST - 911 CALLS FOR ROBB ELEMENTARY SHOOTING 5/24/2022
From: Leslie Acosta

Cc: Bryan Eckert <
Subject: WOAI/KABB-TV OPEN RECORDS REQUEST - 911 CALLS FOR ROBB ELEMENTARY SHOOTING 5/24/2022
Good evening,
We would like to request 911 calls from May 24,2022 between the hours of 10:30 a,m. and 1 p.m.
related to the shooting at Robb Elementary School located at 715 Old Carrizo Rd.
We would like you to waive any fees associated with th is request, as this information benefits the
public.
above.
Please send these record ings via email to
Thank you,
Leslie Acosta
Assignment Editor
News 4 WOAI I KABB
2
Esmeralda Casarez

Subject: FW: WOAI/KABB-TV OPEN RECORDS REQUEST - 911 CALLS FOR 500 BLOCK OF DIAZ
ST. 5/24/2022
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Subject: Fwd: WOAI/KABB-TV OPEN RECORDS REQUEST - 911 CALLS FOR 500 BLOCK OF DIAZ ST. 5/24/2022
#4of4
From: Leslie Acosta < >

Cc: Bryan Eckert >
Subject: WOAI/KABB-TV OPEN RECORDS REQUEST - 911 CALLS FOR 500 BLOCK OF DIAZ ST. 5/24/2022
Good evening,
We would like to request 911 calls from May 24,2022 between the hours of 10:30 a.m. and 1 p.m.
related to the shooting in the 500 block of Diaz St.
We would like you to waive any fees associated with this request, as this information benefits the
public.
1
above.
Please send these recordings via email t
Thank you,
Leshe Acosta
Assignment Editor
News 4 WOAI I KABB
2
Esmeralda Casarez

Subject: FW: CNN records request -- dispatch recordings
Partner
Denton, Navarro, Rocha , Bernal , & Zech , P.C .
251 7 N. Main
San Antonio, TX 782 12
210/227-3243
210/225-4481 (f)

Subject: FW: CNN records request -- dispatch recordings
~F',
(lf~~(lf~
City Secretary
(ITY Of.UVALDE -
'f;{,.,Nf/4 •7.-,mJ
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 2 78-2234
Email: ssa11cl1ez(ii).m,aldetx.gov
From: Daniel Rodriguez <d rodriguez@uvaldetx.gov>

Subject: Fwd: CNN records request - dispatch recordings
1
Sent from my iPhone
From: "Devine, Curt" <

Date: May 30, 2022 at 11:29:54 AM CDT
To: Clarissa Chavez <cchavez @uvaldetx.gov>
Cc; Daniel Rodriguez <d.[QQf!guez@uvaldet=!(.gO'v'>, Jessica Zamora <jazamora@uvaldetx.gov>
Subject: CNN records request -- dispatch recordings
Hello - CNN would like to submit an addit ional public records request. Thank you very much for your
assistance.
Public Records Request:
Pursua nt to the Texas Public Information Act, CNN requests access to and copies of any dispatch
recordings or audio t ransmissions from M ay 24, 2022 between 11am and 2pm related to the shooting at
Robb Elementary. This should include any recordings of 911 calls made by people at the school during
this time.
Additionally, CN N requests any logs or documents associated w ith these recordings, such as CAD
reports.
If the department is already compiling th is material to release to other requestors and the pa rameters
of those requests is slightly different, CNN will likely agree to alter t he parameters of th is request for t he
sake of efficiency.
If you have any questions about this request, don' t hesitate to contact me.
Thank you,
Curt Devine
CNN, Washington
2
Esmeralda Casarez

Subject: FW: CNN public records request -- Pedro Arredondo file
Partner
Denton, Navarro, Rocha , Bernal, & Zech, P.C.
2517 N. Main
210/227~3243
210/225-4481 (f)

Subject: FW: CNN public records request -- Pedro Arredondo file
{{le~,
~~~~~
City Secretary
OTYOF UVAlOE _
f /,,,u{;). •,½.,,.~
City of Uvalde
P.O.Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: sst1nche'{{ii).uvaldetx.gov

Subject: Fwd: CNN public records request -- Pedro Arredondo file
14
Sent from my iPhone
From: "Devine, Curt" ~

Date: May 31, 2022 at 11:28:37 AM COT
Cc: DaAiel Rodriguez <drodriguez@uvaldet,cgov►, Jessica Zamora <jazal'flora@uvaldetl<.gov:>
Subject: CNN public records request -- Pedro Arredondo file
Hello - CNN would like to submit an additional public records request. Thank you very much for your
assistance.
Public Records Request:
Pursuant to the Texas Public Information Act, CNN requests access to and copies of records within the
personnel file of Pedro "Pete" Arredondo, who we understand previously served for about 16 years in
the Uvalde Police Department. This should include but not be limited to any offers of employment or
notices of resignation/transfer/termination, documents showing qualifications (such as a CV, resume or
list of certifications/ trainings) letters, and/or any disciplinary records or reprimands.
Given the immense public interest and ongoing policy discussions relat ed to events in which this
individual was involved, we would greatly appreciate it if this request can be expedited.
Thank you,
Curt Devine
CNN, Washington
15
Esmeralda Casarez

Partner
2517 N. Main
2 10/227-3243
210/225-4481 (f)

To: Clarissa Rodriguez <cmrodriguez@rampagelaw.com >
{§}{'~,
~~!>£~~
City Secretary
OTYO.FUVAU)F. _
· f /,-.,.1tf:d •$ ,m>
City of Uvalde
P.O. Box799
Uvalde, Texas 78802
Phone: (830) 2 78-3315 ext. 142
Fax: (830) 278-2234
Email: ssllnchert,ii).uva/detx.g"v
From : Daniel Rodriguez <drodriguez@uvaldetx.gov>

To: So rayda Sanchez <ssanchez@uvaldetx.gov>
Subject: Fwd: NBC Open Records Request #3
18
Sent from my iPhone
From: "Parks, Eva (NBCUniversal)"

Date: May 27, 2022 at 6:01:50 PM CDT
To: Daniel Rodriguez <drodriguez@uvaldetx.gov>, City Hall <cityhall@uvaldetx.gov>
Cc: "Friedman, Scott (NBCUniversal)" - - - -f--- - - - - - - - - - - - - - - -
Subject: NBC Open Records Request #3

The employment file for former Uvalde police officer, Pete Arredondo.
The Texas Public Information Act requires that you "promptly p roduce" the requested records
unless, within 10 days, you have sought an Attorney General's Opinion. If you expect a
significant delay in responding to this request, please contact me with information about when
I might expect copies or the ability to inspect the requested records.
If you deny any or all of this request, please cite each specific exemption you feel justifies the
refusal to release the information and notify me of the appeal procedures available to me
under the law.
Sincerely,
Eva
Eva Parks
I

x.~ •
BEl
ll<f.,;
I
I
Jj
.tflT NBCUnlversal Local
19
Esmeralda Casarez

Subject: FW: Amended Records Request from The New York Times re: 5/24/2022 shooting
incidents Involving Salvador Ramos
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Subject: FW: Amended Records Request from The New York Times re: 5/24/2022 shooting incidents Involving Salvador
Ramos
{p/{'~,
(?/~~(?/~
City Secretary
City of Uvalde
P.O. Box 799
Uvalde, Texas 78801
Phone: (830) 278-3315 ext 141
Fax: (830) 278-2234
Email: ssa11cliez(ii;,uvaltfetx.gov

Subject: FW: Amended Records Request from The New York Times re: 5/24/2022 shooting incidents Involving Salvador
Ramos
Good morning,
l;ci13,ruX,Cd,, Mcitii,
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: (830)591-2552
gmata(a),uvaldetx. gov
CONFIDENT/AL/TY NOTICE: This email message and any included attachments are for the sole use of the intended
From : Robin Stein

Cc: David Goodman

Subject: Amended Records Request from The New York Times re: 5/24/2022 shooting incidents Involving Salvador
Ramos
Good Morning,
I hope t his note finds you well. I'm writing again from The New York Times to add additional items to the public records
request I sent via email on Thursday, May 26
Here is our amended request (Please note #1 and #2 were included in our original request, which is pasted below):
1. Recordings and transcripts of any/all 911 calls received between 11:00am and 1:15pm involving Salvador
Ramos and the shooting incidents on May 24, 2022 in Ulvade, TX.
2
2. Recordings and transcripts of the dispatch audio feeds ut ilized or monitored by your agency, partner law
enforcement agencies, EMS & fire departments between 11:00am and 1:15pm on May 24, 2022.
3. Any/all audio-visual recordings and transcripts of footage or audio feeds captured by Uva lde peace
officers' body worn cameras and vehicle dash cams responding to the shooting incidents involving Salvador
Ramos on May 24, 2022.
4. Any/all audio-visual recordings and transcripts of footage or audio feeds captured by any other city or county
CCTV cameras or employee recordings involving the shooting incidents involving Salvador Ramos on May 24,
2022.
5. Any/all incident records and reports documenting dispatch and law enforcement communications, including
CAD notes created or monitored by law enforcement officers or dispatchers in response to the shooting incidents
involving Salvador Ramos on May 24, 2022.
If there are any fees for searching or copying these records, please inform us if the cost will exceed $75.
However, we would also like to request a waiver of all fees in that the disclosure of the requested information is in the
public interest and will contribute significantly to the public's understanding of policing and community relations ,which
is a focus of our newsgathering at The New York Times. This information is not being sought for commercial purposes.
We would request a response in writing, w ithin the 10 days described by law, if you intend to deny t his request. Also, if
you expect a significant delay in fulfilling this request, please contact me with information about when I might expect
copies or the ability to inspect the requested records. If you deny any or all of this request, please cite each specific
exemption you feel justifies the refusal to release the information and notify me of the appeal procedures available to
me under the law.
Might you be able to spare a moment to jump on a quick phone call to discuss this request? The best way to reach me is
my cell phone
Best,
Robin Stein
Visual lnvesligationsNideo Unit
3
On Thu, May 26, 2022 at 1:39 PM Robin Stein wrote:
Good morning,
Might you be able to spare a moment to jump on a quick phone call to discuss this request? The best way to reach me
is my cell phone - -.
Under the Texas Open Records Law, we are requesting an opportunity to inspect or obtain copies of the following
public records & materials:
incidents.
2. Recording of the dispatch audio feeds utilized or monitored by your agency, partner law enforcement agencies, EMS
& fire departments between 11:00am and 1:15pm
and will contribute significantly to the public's understanding of policing and community relations ,which is a focus of
our newsgathering at The New York Times. This information is not being sought for commercial purposes.
Best,
Robin Stein
New York Times Video Unit
4
Rights of Rcquestor
You have tile rigJ,t to:
• Prompt access to information that is not confidential or
otherwise protected;
• Received treatment equal to all requestors, including
accommodation in accordance with the Americans
Disabilities Act (ADA) requirements;
• Receive certain kinds of information without exceptions, like
the voting of public, officials, and other infonnation; E-Mai l (optional)
• Receive a written statement of estimated charges, when
cltarges will exceed S40, in advance of work begin started and
opportunity to modify the request in response to the itemized
Public Information Records Request
statement; (Note: Minutes are not. Official unless Passed and Approved by Govcrni11{l body of the cir)' of Uvalde]
°' \\wg\\s
• Choose whether to inspect the requested infonnation (most Detail.ed Description of Records: _____ _ _ _ _ __ _
often at no charge); receive copies of the information orboth;
• A waiver oi' reduction of charges if the governmental body
determines that.access to the infmmation primarily benefits the
vc lA±e.c\ :\o
general public;
body asking the Office oftbe Attorney General for a ruling on
whether the information c1.1n be withheld under one of th~
requested information, a redacted copy;
iufonnation with the Office of the Attorney General.
Complaints of other possible violations may be filed with the
governmental body, other than a state agency, is located. If the t (
complaint is against the county or district attorney, the \.\'/la Am. f\.·~Vv'.'&
complaint must be filed with the Office of the Attorney
General,
Procedures to Obtain Information:
✓ Submit a request by mail, fax, e-mail or in·person according to
a governmental body's reasonable procedures.
Number of Copies Requested: _ _\ _ _ _ _ __ _ _ __ _
✓ Include enough description and detail about the information
requested to enable the governmental body to accurately
Date Requested For: _ _ h. . ':\:
I, 111
-:S___,_..;:;.....J...-1- i ....:1.... _ _ _ _ _ __ __
......:::..=;...;;;;..;:.....
identify and locate the information requested. Information to be released:

✓ Cooperate with the govemmen4}1 body's reasonable effor!S to • Yo u may review it promptly, and ifit cannot be produced within 10
clarify the type or amount ofinformation requested.
working days the public information officer will notify you in wri ting of
Cost of Records: the reasonnble date and time when it will be available.
Standard paper copy $.10 per page
Nonstandard copy. • Keep all appointments to inspect records and to pick up copies. Failure to
A. Diskette $1.00 each keep appo in tments may result in losing the opportunity to inspect the
C. Data Cartridge actual cost infonnation at the time requested.
D. Tape Cartridge actual cost • information that may be withheld due to an exception of the referrnl by
the Oflice of the Attorney General; your request will be referred within I 0
G. Digital Video Disc $3.00 each business days. The Office of the Attorney Gene.rat must issue a decision
H. JAZ drive actual cost no late•· than the 45 11' working day from the day after the Attorney General.
J. VHS videocassette $2.50 each received the request for a d ·~i°J0 A },_
K. Audio cassette $LOO each Requestor Signature: · ,l.J "'-
L. Oversize paper copy (e.g. t lx17", greenbar, bluebac, not
including maps and photographs using specialty paper) 3 \ \ 1,.;2...
Date of Request: __ :5 ·-'--'"-'-4,-""-"----- - -- - - - -- --
$.50 per page
M. Specialty paper (e.g.: Mylar, blueprint, blueline, map,
photographic)
Programming Labor Charge -·

actual cost
$2850 per hour

Public
Signature:
lnfor7~~n
~ , . l e - ;1,r/i
~ecords-keeper Authority:
Labor Charge for locating, compiling, and reproducing public

information. SJ 5.00 per hour Name: ~d»t-\ e.U, M ~
[A labor charge shall l).ot be billed with requests that are for 50 Title: ~0£.aS=-"C,""--\..L.......,.r:.....:.K.....__ _ _ _ __ _ __
or fewer pages of paper records, unless records llfC in separate
building.] Revised 0712018 Date Received: 5' /; f / 2.o2.2.
~!'/~
PUBL IC INFORMATION REQUEST FORM
..---------- - - - -----------,
Rights of Requestor Requestors Name:
You have the right to:
• Prompt access to information that is not confidential or Address:
otherwise protected;
acoommodation in accordance wiUi the Americans with
1sa 1 1t1es Act (ADA) requirements;
• Receive certain kinds ofinfonnation without exceptions, like
the voting of public, official~, and other information;
• Receive a written statemeut of estimated charges, when
charges will exceed $40, in advance ofwo.rk begin started and
opportunity to modify the request in response lo the itemized
statement; (Note: Minutes are not Official unless !'asset! and Approved by Governing body of the city of Uvai~eJ
• Choose whether to inspect the requested information (most
Detailed Desc ription of Records: _ _ ___ _ _ _ ____
often at no charge), receive copies of the information or both;
• A waiver or reduction of charges if the governmental body
determines that access to the information primarily benefits the
,;Ca c" oe(Al ~0v.\-:
general public;
whether the information can be withheld under one of the
requested information, a redacted copy;
information with the Office of the. Attorney General.
Complaints of other poss ible violations may be filed with the
governmental body, other than a state agency, is located. If the \ .
complaint is against the county or district a11orney, the \\'.1o P.Dn A-1?·?~6-.L
complaint must be filed with the Office of the Attorney
General.
✓ Submit a request by mail, fax, e-mail or in person according to
a governmental bO:dy's reasonable procedures.
Number o f Copies Requested: ___\_ _ _ _ __ _ __ __
✓ Include enough description and detail about the information Date Req uested For: _ ::5
___,f'--"2'-"1-'--4\. .=i_
c ?..._ _ _ _ _ _ _ __
requested to enable the governmental body to accurately
identify and locate the information requested. Info r mati on to b e J'elea scd:
✓ Cooperate with the governmental body's reasonable efforts to • You ma y rev iew il promptly, and if it c annot be pro duced within l 0
clarify the type or amount of infunnation requested.
wo rking days the publ ic in forma tio n o ffic er will notify you in writing or
Cost of Records: che r e asonable date a nd time when it will be available.
Standard paper copy $.IOper page
Nonstandard copy. • Kee p all appointments to inspect rec ords and to pick up c opies. Fallure to
A. Diskette $1.00 each keep appointme nts may result in losing the opportunity to inspect the
C. Data Cartridge actual cost in for mation at the time requested.
D. Tape Cartridge actual cost • In formation t hat may be wi thhe ld d ue to an exception of the referral by
E. Rewritable CD $ 1.00 each
the Office of the Attorney G enera l; your request wil l be r eferred within l 0
G. Digital Video Disc $3.00 each busine ss days . ] lie Office o f the Attomey General must issue a decisi on
Ji JAZ drive actual cost no la.t e r t han t he 45 11, woJ'king day from the day after t he Attorne y Ge neral
J. VHS videocassette $2.50 each recei ved the re quest for a~~
K. Audio cassette $ J.00 each
L. Oversize paper copy (e.g. 11x 17", greenbar, bluebar, not Requestor Signature: - ~.,-----'---'~~- ---- - - - - - - - --
including maps and photographs using specialty paper) Date of Request: _ S:
.,J-..1\_.
::,<4\,.4\.,,..
2,,..::..
7-_ _ _ _ _ _ _ _ __
$.30 per page
M, Specialty paper (e.g.: Mylar, blueprint. bluelinc, map, \J.,,•,\ \ fl ~~ V\) \ "'\>-u-t,c,,i,-., GV e, YY\ jq,-{\
photographic) actual cost Public Information _Record:~eepe1· Authority:
Programming Labor Charge -- $28.50 per hour Signature: jj~ ~
Labor Charge for locating, compili ng, and reproducing public
infor:mation. $15.00 per hour Name : ~b..-,t-l14'. M~+---
(A labor charge shall not be billed with requests that are for SO
or fewer pages o f paper records, unless records are in separate
TitJe: 1-.t
y,rt.it.S CJtcle-
building.) Revised 07120LB D ate R eceived: S / 5 l / 2...a 2. 2.
Esmeralda Casarez

Subject: FW: PIR
Attachments: 22.5-31 _uvaldepd.docx
Partner
Denton, Navarro, Rocha, Bernal, & Zech, P.C .
2517 N. Main
210/227 -3243
210/225-4481 (f)

Subject: FW: PIR
{q{'~,
~~~~~
City Secretary
CITYOft!VAWE -
tt,,.14,f., •..h-..
City of Uvalde
P.O.Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssar,cl,e'lf[i;)1va/,letx.go11
From : Gabriella Mata <gmata@uvaldetx.gov>

Subject: FW: PIR
1
Good afternoon,
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: (830)591-2552
recipient(s) , and may contain confidential and/or privileged information. Do not read, copy, forward, or print this email
message or any attachments unless you are the intended recipient. If you are not the intended recipient, please notify (/Jr::
From: Findell, Elizabeth

Subject: PIR
Hello,
Please see the attached public information request. Let me know t hat you received it, and if you need any clarification.
Thank you,
Elizabeth
Eliza beth Findell

TEXAS REPORTER
2
--
Recent stories
3
THE WALL STREE'f JOURNAL.
May 31, 2022
Public Information
I fvalde Police Department
To Whom it May Concern,
I'm writing under the Texas Public Information Act to respectfully request the following records:
• Any list or spreadsheet documenting all 911 calls received Tuesday, May 24, 2022
• Recordings of all 911 calls received from 11 a.m. to 1 p.m. Tuesday, May 24, 2022
• Copies of any/all memos or office-wide communications from UPD command staff to the
department from May 24 to May 28, 2022
• Copies of any/all incident reports involving 820 S. High Street from Jan . 1, 2018 to May 24, 2022
• Copies of any/all incident reports involving Celia Martinez Gonzales (DOB - ) from Jari. 1,
2018 to May 24, 2022
• Copies of any/all memos or communications from UPD command staff to City Manager Vince
DiPiazza, Mayor Don Mclaughlin or members of Uvalde City Council or Commissioners' Court
from May 24 to May 28, 2022
I request the information electronically, if possible. Please notify me of any fees exceeding $40
associated with producing the records so that I may modify my request if needed. I am not seeking any
home addresses, email addresses or other personal information exempt from disclosure under TPIA.
Should you choose to appeal or deny any portion of this request, I ask that you provide any segregable
portions of otherwise TPIA-exempt material.
Please contact me if you need any clarification.
Thank you,
Elizabeth Findell
--· I
Esmeralda Casarez

Subject: FW: TX PIA Request - Records requests and relevant documentation
Partner
Denton, Navarro, Rocha, Bernal, & Zech . P.C.
2517 N. Main
210/227-3243
210/225-4481 (f)
T his transmission is intended for the individual or entity to which it is addressed, and may be information that is

Sent: Tuesday, M ay 31, 2022 3:31 PM
To: Clarissa Rodriguez <cmrodriguez@rampagelaw .com>
Plr~ ,
(lf~ ~ (lf~
City Secretary
,CITY QF- UVAU)£ ,-
f/4,/,j{; . h✓-rtd
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
E mail: ssm1cl1eefii.1uvaldetx.gov

Sent: Tuesday, M ay 31, 2022 2:55 PM
1
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: (830)591-2552
gmata(a)u valdetx.gov

To: Gabriella Mata <gmata@uvaldetx.gov>; Daniel Rodriguez <drodriguez@uvaldetx.gov>
Subject: TX PIA Request - Records requests and relevant documentat ion
Good afternoon,
• A log or list of all records reque sts submitted to this agency from Tuesday, M ay 24, 2022, to the present date.
• The content (including email attachments, data files, media files and documents) of all records requests
provided related to the shooting at Robb Elementary School at 715 Old Carrizo Rd, Uvalde, on Tuesday, May 24,
2022.
The requested documents w ill be made available to the general public, and this request is not being made for
Sincerely,
2
Caroline Ghisolfi
Data Reporter
3
Esmeralda Casarez

Subject: FW: KVUE REQUEST RE: ROBB ELEMENTARY SCHOOL SHOOTING - 5/31/2022
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Subject: FW: KVUE REQUEST RE: ROBB ELEMENTARY SCHOOL SHOOTING - 5/31/2022
{fl{'~,
(jl~~(jl~
City Secretary
CITY OF UVALDE -
· 7l"'ra .X,.,,,,,J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssanclte:r[ii>,uvaldetx.gov

Subject: Fwd: KVUE REQUEST RE : ROBB ELEMENTARY SCHOOL SHOOTING - 5/31/2022
Sent from my iPhone
From : "Ellis, Joseph"

Date: May 31, 2022 at 11:22:18 AM CDT
Subject· Kl/I IE REQI !EST RE· ROBB ELEMENTARY SCHOOL SHOOTING - 5/31/20
KVUE in Austin, Texas respectfully requests your assistance w ith this request for public information .
Please provide the following:
Records of any and all calls for service made to the Uvalde Police Department on May 24, 2022.
((an Excel spreadsheet would be ideal, otherwise a listing of calls showing the date, time,
reason/nature of call, etc))
Records and recordings of any and all 911 calls made to the Uvalde Police Department on May
24, 2022.
Recordings of any and all body-worn camera videos from Uvalde Police officers responding to
Robb Elementary School from May 24, 2022.
Records of any and all calls for service regarding Robb Elementary School, 715 Old Carrizo Rd or
Uvalde High School, 1 Coyote Trail from January 1, 2022 to May 25, 2022.
Records of any and all calls for service regarding 552 Diaz Street from January 1, 2020 to May 25,
2022.
Please provide the requested records as soon as possible. As you know there is a high level of public
interest in the requested records. KVUE requests a waiver or reduction of fees associated with this
request, as allowed un the Texas Public Information Act, when a request is made in the public interest.
KVUE is an ABC News affiliate and intends to use the requested information for news purposes to help
satisfy the vast public interest.
Please communicate with me via email and/or phone only regarding this request. Please DO NOT
communicate with me via regular US mail regarding this request.
Thank you,
Joe Ellis • Executive Producer, Investigations and News Projects

--1
KVUES
2
Esmeralda Casarez

Subject: FW: KHOU Request RE: Robb Elementary Shooting
Partner
2517 N. Main
210/227-3243
210/225-4481 (f}

Subject: FW: KHOU Request RE: Robb Elementary Shooting
{p/{'~,
(t/~!K.(tf~
City Secretary
cnt OF UVALOJi -
ll,v~u ./4"/;j
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssancherfii)u valdetx.gov

Subject: Fwd: KHOU Request RE: Robb Elementary Shooting
11
Sent from my iPhone
From: " Macias, Tina'

Date: May 31, 2022 at 1:21:20 PM CDT
Cc. it'lformatio fl@tarskilav • .eom . KIIOU lfl\>'
Subject: KHOU Request RE: Robb Elementary Shooting
Good afternoon:
I'm Tina Macias, an investigative producer for KHOU llNews in Houston. Please accept the request
below and let me know if you have any questions. We understand some records may be available
sooner t han others, so please provide information on a rolling basis, when they become available.
Under the Texas Public Information Act, we are requesting the following information:
• Records and recordings of any and all dispatch communication from May 24, 2022.
• Records that detail names, certifications, hire date and disciplinary history for any and all
officers who responded to the Robb Elementary School shooting on May 24, 2022.
• Any and all search warrants from May 24, 2022 to present with any of the keywords: "Robb
Eleme ntary," "school shooting," "Salvador Ramos."
• Any and all records of internet and social media postings and/or messages, writings, and or
journals attributed to Salvador Ramos.
The Texas Public Information Act requires that you "promptly produce" the requested records unless.
w ithin 10 days, you have sought an Attorney General's Opinion. If you expect a delay in producing these
records, please contact me with information about when I might expect t he request to be fulfilled.
In advance, I stipulate to the redaction of any information protected under the Act or by a Texas
Attorney General's opinion, but please include an explanat ion of redactions when completing this
request.
Additionally, if this information is avai lable electronically, I prefer to receive it that way. sent via e-mail
t
If you require any additional information or clarification to fulfill this request please feel free to contact
me.
Thanks,
Tina
Tina Macias
KHOU*ll.
UAN0S JOI MOUUOM
A TEGNA ~ I
I I
12
Dear Custodian of Records:
Under the Texas Public Information Act, Tex. Gov't Code §552.001 et seq. , I am requesting:
1. The 911 audio. transcript, and call log for any and all 911 calls placed from Robb Elementary
School located at 715 Old Carrizo Rd, Uvalde, TX 78801 on May 24, 2022.
2. The dispatch log for all Uvalde Police Department officers responding to the shooting at Robb
Elementary School on May 24, 2022.
3. The names, job title, and rank of all Uvalde Police Department officers responding to the
shooting at Robb Elementary School on May 24, 2022.
4. All allegations and/or complaints made against any Uvalde Police Department officer that
responded to the shooting at Robb Elementary School on May 24, 2022. Please restrict your
search to any allegation/complaint made between January 1, 2021 and the date this request is
filled.
5. All Uvalde Police Department training materials, including all slideshows, videos, handbooks, or
any other material, used to train law enforcement officers to respond to an active shooting
situation.
If there are any fees for searching or copying these records, please inform me if the cost will exceed $10.
The release of the information is for non-commercial purposes. I am a reporter for Insider, a news
organization based in New York City, whose mission is journalism in the public interest. This request is for
news gathering purposes. I, or my colleagues at Business Insider or Insider, will use the records to inform
the public through our reporting. I therefore request a waiver of all fees and charges pursuant to Texas
Public Information Act.
In conducting your search, please use the most recent technologies and tools available.
If any part of our request is determined by your organization to be exempt from disclosure, please release
any segregable non-exempt portions. If your organization determines that such segregation is impossible,
please indicate why this is technically the case. If my request is denied in whole or part, I ask that you
j ustify all deletions by reference to specific exemptions of the Texas Public Information Act. If you claim
such an exemption to my request under Texas Public Information Act, please cite in writing the specific
statutory exemption.
Please produce these records in the electronic format (such as excel file (.xlsx) or other database form, or
as .pdfs) and share them with me via email at if possible.
The Texas Public Information Act requires that you "promptly produce" the requested records unless,
within 10 days, you have sought an Attorney General's Opinion. If you expect a significant delay in
responding to this request, please contact me with information about when I might expect copies or the
ability to inspect the requested records.
Sincerely,
Hannah Beckler
Esmeralda Casarez

Subject: FW: NYT request, 5/31
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

{§/(~I
(?J~~(?J~
City Secretary
- (lTY <?~BVAU)l.i r-
• '!l'm4'/4 ,.h ,mJ
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
E mail: s.rn11cl1eefil)uvaldetx.gav

Good afternoon,
T ~yo-vv.,
CiCU?-v~ tvl~
Records Clerk
City ef Uwhle
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: {830)278-9147 ext. 812
Fax: (830)591-2552
CONFfDENTIALITY NOTICE. This email message and any included attachments are for the sole use of the intended
recipient(s), and may contain confidential and/or privileged information. Do not read, copy, fotward, or print this email
From: Mike Baker

Subject: NYT request, 5/31
Pursuant to state open records law, The New York Times requests the following information
• All text, ema il and other electronic correspondence sent to or from Mayor McLaughlin on May 24 between 11 a.m.
and 2 p.m.
• All text, ema il and other electronic correspondence sent between Daniel Rodriguez and Mayor McLaughlin since May
24 at 11 a.m.
• Any written reports or summaries Mayor McLaughlin has received related to the events of M ay 24.
Thank you.
Mike Baker ! The New York Times
2
Esmeralda Casarez

Subject: FW: NBC Dallas - Open Records Request
Partner
2517 N . Main
210/227-3243
210/225-4481 (f)
This transmission is intended for the individual or entity to which it is addressed, and may be information that is .

Subject: FW: NBC Dallas - Open Records Request
{q{'~,
f?J~
City Secretary
~f?J~
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ss11nc/1erf[i.1uvaldetx.gov
From: Friedman, Scott (NBCUniversal)

To: City Hall <cityhall@uvaldetx.gov>; Daniel Rodriguez <drodriguez@uvaldetx.gov>
Subject: NBC Dallas - Open Records Request
4
Our sympathies for everything that your city is going through right now. As the public asks for more information about
what occurred last week, we respectfully submit the following request for records under the Texas Public Information
Act.
We are requesting:
• Recordings of all 9-1-1 calls received by the Uvalde Police Department in regards to the shooting at Robb
Elementary School from 11:00am CT to 3:00pm CT on 5/24/22
• Recordings of all police radio audio on all channels that Uvalde Police Officers used to communicate on between
9:00am CT to 3:00pm CT on 5/24/22. This would include record ings of all radio traffic during that time frame
regardless of the location of the call.
• Recordings of all police radio audio on any mutual aid channels/ interoperable channels used by Uvalde Police
officers between 9:00am CT to 3:00pm CT on 5/24/22
• All GPS data reports showing the location of all Uvalde Police Department vehicles from 9:00amCT to 3:00pm CT
on 5/24/22 this would not just patrol units but any special response, command, or SWAT vehicles during that
time frame.
• All computer aided dispatch (CAD) reports or other logs detail ing all calls for service and unit locations from
9:00am CT to 3:00pm CT on 5/24/22
• All text messages between all Uvalde Police Department employees from 11:00am CT to 5:00pm CT on 5/24/22
on any department/city issued device.
I can be reached directly at
Thank you,
Scott Friedman
Scott Friedman
Senior Investigative Reporter
NBC 5 I KXAS··TV I Dallas-Fort Worth
NBCDFW.com
l!t.W.W obcdfw,e2rn1mvestiaatioos
£1 Foflow tr.s ,an 1\vrtt-tr D L1~t !JS :on F.aabac>k
5
THE
TEXAS
TRIBUNE
May 31, 2022
Carla Astudillo
Data Visuals Developer
Texas Tribune
This is a request under the Texas Public Information Act. On behalf of The Texas Tribune
and myself, jointly, we respectfully request the following public records:
Electronic copies maintained by the Uvalde Police Department of any and all Use of
Force forms filled out for all use of force incidents from January 1, 2017 - May 23,
2022. This should include, but not be limited to, date and time of the incident,
place/address incident occurred, the subject's race, officer's race, type of force used,
whether there was a subject injury and whether there was officer injury.
I would prefer the request be fulfilled electronically as PDFs or spreadsheets, by

e-mail attachment if available or CD-ROM if not.
office stm release whatever portion of my request is ready and puh!ic under Texas Jaw.
for the Texas Tribune, a nonprofit news organization, and this request is made as part of
news gathering and not for commercial use.
possible, please provide a detailed list that breaks down each charge in advance of fu lfilling
our request.
In p rinciple, I am willing to consider ways in which the request might reasonably be

or by phone at Thank you in advance for your
cooperation.
Sincerely,
Carla Astudillo
Texas Tribune
THE
TEXAS
TRIBUNE
May 31, 2022
Carla Astudillo
Texas Tribune
Electronic copies maintained by the Uvalde Police Department of any and all Use of
Force forms filled out for all use of force incidents on May 24, 2022. This should
include, but not be limited to, date and time of the incident, place/address incident
occurred, the subject's race, officer's race, type of force used, whether there was a
subject injury and whether there was officer injury.

e•mail attachment if available or CD·ROM if not.
office stiH release whatever portion of my request is ready and public under Texas law,
I request a waiver of all fees for this request. Disclosure of the reques ted information to me
our request.
available und er the law.

r by phone a . Thank you in advance for your
cooperation.
Sincerely,
Carla Astudillo
Texas Tribune
THE
TEXAS
TRIBUNE
May 31, 2022
Carla Astudillo
Texas Tribune
All current policies maintained by the Uvalde Police Department regarding use of
force. This should include, but not be limited to, any guidelines on circumstances
during which force might be deemed appropriate, reporting requirements and the
expectations of other officers that are present.
office still release whatever portion of my request is ready and public under Texas law.
our request.

or by phone at . Thank you in advance for your
cooperation.
Sincerely,
Carla Astudillo
Texas Tribune
THE
TEXAS
TRIBUNE
May 31, 2022
Carla Astudillo
Texas Tribune
Electronic copies of the most recent collective bargaining agreement/collective

agreement between the Uvalde Police Department and the local police
union/fraternal order/benevolent association, or other similar organization.

e-mail attachment if available or CD-ROM if not.
our request.

cooperation.
Sincerely,
Carla Astudillo
Texas Tribune
i)i PROPUBLICA CITHE TEXAS TRIBUNE
May 29, 2022
Lexi Churchill
Research Reporter
Copies of all 911 logs from May 24, 2022. These should include, but are not limited to the
date, time, duration of the call, caller name and notes from the call.
office stm release whatever portion of my reQuest is ready and public under Texas law,
our request.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
Cl PROPUBLICA THE TEXAS TRIBUNE
May 31, 2022
Lexi Churchill
Research Reporter
Tribune and myself, jointly, we respectfully request the following public records:_
Electronic Copies of all ballistic reports related to the May 24, 2022 Uvalde school shooting
that took place in Robb Elementary School at 715 Old Carrizo Rd, Uvalde, TX 78801.
office stm release whatever portion of my request is ready and public under Texas law,
our request.
narrowed. Le( me know if clarifying this request might speed the release of the information.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
Esmeralda Casarez

Subject: FW: CBS News Inquiry
Importance: Hig h
Partner
Denton , Navarro, Rocha, Bernal , & Zech, P.C.
2517 N. Main
210/227-3243
21 0/225-4481 (f)
any dissemination, distribution, or copying of this communication is prohibited. ff you have received this communication in

Subject: FW: CBS News Inquiry
Importance: High
{P/{'~,
(If~ 9£(1)'~
City Secretary
CITYO.FUV'ALDE -
'1/4/ft¼ . /4,.,,✓.,
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ssmiclleefii>)1valtletx.gov
From: Jennifer Potter <ipotter@uvaldetx.gov>

6
Subject: FW: CBS News Inqu iry
Importance: High
From: Giraldo, Luis

Sent: Sunday, May 29, 2022 9:13 PM
To: Daniel Rodriguez <drodriguez@uva ldetx.gov>; Jennifer Potter <jpotter@uvaldetx.gov>;
vromero@uvaldecounty.com; ezamorauc6@uvaldecounty.com ; dvaldez@uvaldecounty.com
Cc: @CND National Desk Staff
Subject: CBS News Inquiry
Importance: High
Hello,
My name is Luis Giraldo. I work for CBS News.

I apologize for casting such a wide net, but I am seeing reports out there t hat have what appears to be audio of 911
dispatchers commun icating w ith potential officers about incoming calls during the Robb Elementary shooting.
Can one of you provide CBS News with that audio? Or can you connect me with the point of contact handling these
records?
If these t apes have not been released, when does the city plan on releasi ng them?
Is Uvalde County or the city going to be handling the records request ?
I appreciate your hel p on this. Thank you. Our continued thoughts are with your commun ity.
Luis Giraldo
-
CBS News
7
' '
. '· , . . . .
'
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·,.
.' '·.
. . . .. '· ·•
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. ..
•
. .
, . . . ' .
. · · . ·. · · ·.· · ·. Received · · · · ·.. ·. · ·.

' ' . .. .' ', '
. ' ' ' . . .
.. . . ....·June ·l '·• 2022

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7/111'.!2, 1~24PM NY Times Mail - Record Request
m Record Request
Frances Robles
1 message
Frances Robles > Wed, Jun 1, 2022 at 11:13 AM

I would like to make a public record request for all incoming and outgoing text messages on the phone belonging to Chief
Daniel Rodriguez for May 24, 2022.
Thank you.
Franc es Ro bles
l!i~t ~.-w flork ii!inics
https ://maiLgoogle.com/mail/u/0/?ik=faf2ca80b8&view=pt&search=all&permthid=lhread-a% 3Ar2007S16558127149405% 7Cmsg-a%3Ar-54576173970713 781 0S&s. .. 1/l

7/lln2, 12:23 PM NY T11DesMail • Record request
Frances Robles
Record request
1 message
Frances Robles Wed, Jun 1, 2022 at 11 :15 AM

To: gmata@uval etx.gov
I would like to make a record request for the text messages on the phones of Lt. Javier Martinez and Sgt Donald
Page for May 24, 2022n
Thank you.
Franc es Ro bles
i!tl1e%,w Mork mittl\'.!l
https ://mail .google.coro/tnail/u/0/?ik.=faf2ca80b8&view=pt&search=all&J)ermthid=thread-a% 3Ar50191539478909 519 35% 7Cmsg. a%3Ar-1438224384704 l 6008&si. . l/ l

7/11/'.!2, 12:59 PM NY Times Mail - Record Request
m Record Request
Frances Robles
1 message
Frances Roble Wed, Jun 1, 2022 at 11 :30 AM

To: ssanchez@uva
Hello,
I would like to make a public record request for Mayor Don McLaughlin's incoming and outgoing text messages for May
24, 2022.
Thank you.
Frances Rob les

eb<New j otlc Shnt$
https ://mail .google.coro/tnail/u/0/?ik=faf2ca80b8&view=pt&search=all&permthid=thread-a% 3Ar8401466884971371O37% 7Cmsg-a%3Ar114283 9529136254262&si. . 1/l

Esmeralda Casarez

Subject: FW: KPRC TPIA REQUEST 6/1/22
Attachments: 060122_Uvalde Fire Marshal Request.pdf
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

~~,
(1/~!¥.(lf~
City Secretary
Cln: OJ WAWt _
'//,,qt4 .)i;.,.,1.;
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: s.wmchezf,a),uvaltletx.gov

From: Juan Hernandez <jhernandez@uvaldetx.gov>
Sent: Wednesday, June 1, 2022 11:59 AM
From: Ana Lastra <

To: Juan Hernandez <jhernandez@uvaldetx.gov>
Subject: KPRC TPIA REQUEST 6/1/22
Hello-
Please see t he attached Texas Publ ic Information Act request form . Let me know if you need any ot her information or
clarity on t his request.
Thanks,
Ana Lastra
Executive Producer
KPRC 2 News
2
this go,•emmental body, you may review the governmental body's notice required under section 552.205 of
General's website at http://www.texasattorneygeneral.gov/open-govemment.
First Name: Ana Last Name: Lastra
Company/Organization: KPRC
Mailing Address:
City: - State: - Zip Code: 77074
E-mail Address: Phone Number:
Preferred Manner of Written Communication : E-mail

i:ire inspection reports and accompanying documents (such as maps, supplemental
documents, etc.) for Robb Elementary at 715 Old Carrizo Road. Date range for these records
Jan. 1, 2019 thru June 1. 2022.
Under the Public Information Act, some categories of infornrntion do not have to be released.
Exceptions to disclosure faJI into two general categories: I) mandatory exceptions that make information
that allow but do not require a governmental body lo withhold information. You may find
infonnation about mandatory and discretionary exceptions HERE.
withhold information from a requestor. However, a requestor may permit a governmental body to redact
information without requesting an Attorney General decision. You are not required to agree to the redaction of
any information responsive to your request, but doing so may streaml ine the handling of your request. If you
redactions are clearly labeled on the infonnation you received? Yes [:;)
redactions are clearly labeled on the information you receive? No
lNFORMATION PREFERENCES:

• If available, do you wish to receive an electronic copy of the information? Yes
Please Note: If t he information requested is unclear or i f a large amount of information is requested you may be
contacted to discuss clarifying o r narrowing your request. There may be charges associated with production of the requested
information. You may find more information regarding the charges under the Public Information Act HERE.
Rev. 10/1/2019
Esmeralda Casarez

Subject: FW: KPRC-TV TPIA Request 6/1/22
Attachments: 060122_Uvalde PD Request.pdf
Partner
2517 N. Main
210/227 -3243
21 0/225-4481 (f)

Subject: FW: KPRC-TV TPIA Request 6/1/22
~~,
(?/~~(?/~
City Secretary
cm QF.WALDE _._
(i'~t~ •,/4/Y(.)
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: s.~uncl1ez(ii';,u1•a/detx.gov

To: Sorayda Sanchez <ssanchez@uvaldetx.gov>; Clarissa M. Rodriguez (cmrodriguez@rampagelaw.com )
1
<cmrodriguez@rampagelaw.com>
Subject: FW: KPRC-TV TPIA Request 6/1/ 22
From: Ana Lastra

To: City Hall <cityhall@uvaldetx.gov>; Vince DiPiazza <vdipiazza@uvaldetx.gov>; Daniel Rodriguez
<drodriguez@uvaldetx.gov>; Joe A. Cardenas <jcar@uvaldetx.gov>
Subject: KPRC-TV TPIA Request 6/1/22
Good afternoon - See the attached Texas Public Information Act request form.
Please let me know if you have any questions in regards to my request.
Thank you,
Ana Lastra
Executive Producer
KPRC 2 News
2
For guidance regarding your rights as a requestor and the public infonnation procedures adopted by
this governmental body, you may review the governmental body's notice required under section 5S2.205 of
General's website at http://www.texasattorneygeneral.gov/open-government.
First Name: Ana Last Name: Lastra
Company/Organiz.ation:
Mailing Address
City: - State: -
E-mail Address: Phone Number:
Preferred Manner of Written Communication: E-mail El
All police reports. including supplemental reports, filed in response to the May 24, 2022 Robb Elementary School shootings. Th is may
nclude reports filed after the date of the incident.
All police reports, including supplemental reports. filed in response to the shooting at 552 Diaz SI. on May 24, 2022. This may include
eports filed after the date of the incident.
'The GPS location history for all Uvalde Police Department squads or vehicles owned/operated by police between 10:30 a.m. to 2 p.m. on
May 24, 2022. The location history should include the squad number and corresponding officers who were in those vehicles.
Under the Public Inforn1ation Act, some categories of information do not have to be released.
Exceptions to disclosure fall into two general categories: 1) mandatory exceptions that make information
confidential and require a governmental body to w ithhold information, and 2) discretionary exceptions
that allow but do not require a governmental body to withhold information. You may find
withhold information from a requestor. However, a requestor may permit a governmental body to redact
information without requesting an Attorney General decision. You are not required to agree to the redaction of
any information responsive to your request, but doing so may streamline the handli ng of your request. If you
redactions are clearly labeled on the information you received? Yes [3
redactions are clearly labeled on the infonnation you receive? No El

• If available, do you wish to receive an electronic copy of the information? Yes [3
Please Note: If th e information requested is unclear o r if a large amount of infonnation is requested you may be
information. You may find more infom1ation regarding the charges under the Public Infonnation Act HERE.
Rev. 10/1 /2019

1').-/0S
Esmeralda Casarez

Subject: FW: TX PIA Request - Personnel File
Partner
Denton, Navarro, Rocha, Bernal, & Zech , P.C .
2517 N. Main
210/227 -3243
210/225-4481 (f)

{pj['~,
(lf~!K(lf~
City Secretary
C!lY O.F UVAWR .-
't/4i";£, •,i,.i~IJ
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ss11ncher/ii.luvaldetx.gov
From: Gabriella Mata <gmat a@uvaldetx.gov>

13
Records Clerk
City of Uvalde
Pollce Department
964 W. Main St
Uvalde, Texas 78801
Work: {830)278-9147 ext. 812
Fax: {830)591-2552
gmata(iauvaldetx.gov
From: Ghisolfi, Carolin

Cc: Daniel Rodriguez <drodriguez@uvaldetx.gov>
Subject: TX PIA Request - Personnel File
Good afternoon,
• All files relating to former Officer Pete Arredondo including but not limited to personnel files, disciplinary
records, performance reviews, and any complaints filed against him or any other Human Resources files.
In the event t hat there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling
14
Sincerely,
caroline Ghisolfi
Data Reporter
- - -~ - - - - - - - - - - - - - - - - -- - - - -
ft U$1in Amtrimn-~tatcjman
15
Esmeralda Casarez

Subject: FW: TPIA from KHOU RE: Emails and contracts
Partner
Denton , Navarro, Rocha, Bernal, & Zech , P.C .
2517 N. Main
210/227-3243
210/225-4481 (f)

{p/{'~,
(?J~9f.(?J~
City Secretary
CJ.TY OFUVAWE ,_
· 'f/4rlfl •:/4.;-td
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssa11cliez((i,.1111a/detx.gov

To: Sorayda Sanchez <ssanchez@uvaldetx.gov>; Clarissa M. Rodriguez (cmrodriguez@rampagelaw.com )
<cmrodriguez@rampagefaw.com>
Here's a Pl request that just came in.
Vince
From: Macias, Tina

To: Mayor <mayor@uvaldetx.gov>; Vince DiPiazza <vdipiazza@uvaldetx.gov>; City Hall <cityha ll@uvaldetx.gov>
Cc: information@tarskilaw.com; KHOU Investigates
Subject: TPIA from KHOU RE: Emails and contracts
Good afternoon:
I'm Tina Macias, an investigative producer for KHOU 11News in Houston. Please accept the request below and let me
know if you have any questions. We understand some records may be available sooner than others, so please provide
information on a rolling basis, when they become available.
Under the Texas Public Information Act, we are requesting the following information:
• Any and all emails and/or text messages t o/from Mayor Don McLaughlin to/from UCISD Police Ch ief Pet
Arredondo from May 24, 2022 to June 1, 2022.
• Any and all emails and/or text messages to/from Mayor Don McLaughlin with any of the following
keywords: "Arredondo", "UCISD", "school", "shotting", "Robb", "Salvador Ramos" from May 24, 2022 to
June 1, 2022.
• Any and all city contracts involving The Eisenberg Group.
The Texas Public Information Act requires that you "promptly produce" the requested records unless, within 10 days,
you have sought an Attorney General's Opinion. If you expect a delay in producing these records, please contact me
with information about when I might expect the request to be fulfilled.
In advance, I stipulate to the redaction of any information protected under the Act or by a Texas Attorney General's
opinion, but please include an explanation of redactions when completing this request .
Additionally, if this information is available electronically, I prefer to receive it that way, sent via e-mail
t
If you require any additional information or clarification to fulfill this request please feel free to contact me.
Thanks,
Tina
Tina Macias
KI-IOU*ll.
STAND$ JOI IIOUUON
ATIGNA~ I
I I
2
Esmeralda Casarez

Sent: Wednesday, June 1, 2022 11 :30 AM
Partner
2517 N . Main
210/227-3243
210/225-4481 (f)

Se nt: Wednesday, June 1, 2022 11:29 AM
(9/f~,
r;l~ !K(?I~
City Secretary
CITY OF.lJVAWE -
.f/,14;{4, •Y,,,,)ft)
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 exL 142
Fax: (830) 278-2234
E mail: ssancheefii)uvaldetx.gov

7
Good morning,
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: {830)278-9147 ext. 812
Fax: {830)591-2552
CONFIDENTIALITY NOTICE This email message and any included attachments are tor the sole use of the intended

I would like to make a public record request for all incoming and outgoing text messages on the phone
belonging to Chief Daniel Rodriguez for May 24, 2022.
Thank you.
Frances Robles
8
Esmeralda Casarez

Subject: FW: Record request
Partner
2517 N. Main
210/227 -3243
210/225-4481 (f)
PRIVI LEGED AND CONFIDENTIAL. If you are not the intended recipient, or the employee or agent responsible for

{pj{'~,
r;/~9£(?/~
City Secretary
cm Of tJVAtoF. -
1/,..,/£ •Jr.,~i,
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
Email: ss,mclzet@µvaldet.x.gov

3
T ~yo-t-v)
c;~~rv1tufev
Records Clerk
City of Uvalde
Police Depa, tment
964 W. Main St
Uvalde, Texas 78801
Work: {830)278-9147 ext. 812
Fax: {830)591-2552
gmata@,uvaldetx.gov
CONFIDENTIALITY NOTICE.: Tni.s email message and any included attachments are for the sole use of the intended
recipient(s), and may t;9ntain corifJ:!,f!J)f/f:t{andlor privileged information. Do not read, copy, forward, or print this email
message or any attacihments unle$Jij ou a,re th,Jintended recipient. If you are not the intended recipient, please notify the
sender and destroy alli'copies and printouts of this email message and/or attachments

Subject: Record request
I would like to make a record request for the text messages on the phones of Lt. Javier Martinez and Sgt.
Donald Page for May 24, 2022n
Thank you.
Frances Robles
4
Esmeralda Casarez

Partner
Denton, Navarro , Rocha, Bernal, & Zech, P.C.
2517 N. Main
2 10/227-3243
210/225-4481 (f)

{pit~,
(IJ'~!K.(11'~
City Secretary
. Cl1'Y Of.UVAW:E -
. fl,,,t¼ .:lr.tt-1.1
City of Uvalde
P.O. Box 799
Uvalde, .Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssa11cl1ez(Q)1waldet.x.gov

To: Sorayda Sanchez <ssanchez@uva ldetx.gov>
1
Hello,
I would like to make a public record request for Mayor Don McLaughlin's incoming and outgoing text
messages for May 24, 2022.
Thank you.
Frances Rob l es
2
Esmeralda Casarez

Subject FW: Open records request - KSAT
Partner
2517 N. Main
210/227-3243
210/225-4481 (f)

Subject: FW: Open records request - KSAT
From: Dillon Collier I

Cc: Vince DiPiazza <vdipiazza@uvaldetx.gov>
Subject: Open records request - KSAT
Good morning,
This request is made under the Texas Public Information Act, Chapter 552, Texas Government Code,
which guarantees the public's access to information in the custody of governmental agencies. I
respectfully request the following information:
Please provide a copy of any documents related to the May 31, 2022 swearing in of City Councilman Pete
Arredondo, including but not limited to who took part in the swearing in, the oath of office read and where
this swearing in took place.
Thanks, Dillon Collier
5
Dillon Collier
KSAT 12 TV
6
fl PROPUBLICA THE TEXAS TRIBUNE
June 1, 2022
Lexi Churchill
Research Reporter
Electronic Copies of all current and ongoing Memorandum of Understanding (MOU) and or
Memorandum of Agreement (MOA) documents between the Uvalde Police Department and
other law enforcement agencies, including but not limited to the Department of Public Safety,
the Uvalde Sheriff's department and Uvalde CISD Police.
Please see this DPS MOU as an example for reference.
our request.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
Received
June 2, 2022
8/26/22, 3:35 PM Fwd: NY Times records request - 2018 investigative file - June 2, 2022 - NY Times Mail
- - - Forwarded message ---------

From: Nicholas Bogel-Burroughs >
Date: Thu, Jun 2, 2022 at 1:39 PM
Subject: NY Times records request - 2018 investigative file - June 2, 2022
To: <Gmata@uvaldetx.gov>
Hello all,
Under Texas's public records laws, I am requesting:

• The full investigative file from the investigation and arrest of two students on April 25, 2018, in which the students were
accused of plotting to carry out a mass shooting.
I understand that while some records in this case may not be available because it involved juveniles, much of the investigative
file should be available to the public with redactions of the students' names.
Thank you for your time and for your help with the request amid what I understand to be a flood of requests.
Best,
Nick
Nicholas Bogel-Burroughs
The New York Times
https://mail.google.com/mail/u/1/#inbox/FMfcgzGqQJhCddhRgNDqJcRbWTfBZJWS?compose=DmwnWsCRjWtdwxNDMWWZjVMfHKKThzqdMSnVfh... 1/1
Esmeralda Casarez

Subject: Fwd: TX PIA Request - CAD and Radio Transmissions
Sent from my iPhone

Subject: FW: TX PIA Request - CAD and Radio Transmissions
~~,
(IJ'~!K(IJ'~
City Secretary
(IIYQf: tl\!Al.DE .,,_
Yt:.dtf/4 •/2'.;;I'.,
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234

Subject: FW: TX PIA Request - CAD and Radio Transmissions
Good afternoon,
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: {830)278-9147 ext. 812
Fax: {830)591-2552
CONFIDENTIALITY NOTICE: This email message and any included attachments are for the sole use of
the intended recipient(s), and may contain confidential and/or privileged information. Do not read, copy,
forward, or print this email message or any attachments unless you are the intended recipient. If you are
not the intended recipient, please notify the sender and destroy all copies and printouts of this email
message and/or attachments

To: Gabriella Mata <gmat a@uvaldetx.gov>
Cc: Daniel Rodriguez <drodriguez@uvaldetx.gov>
Subject: TX PIA Request - CAD and Radio Transmissions
Good afternoon,
• CAD and radio transmissions relating to the May 24, 2022, Robb Elementary school shooting in
Uvalde, TX, received between 11 a.m. and 3 p.m. on May 24, 2022.
Sincerely,
Caroli ne Ghisolfi
--
Data Reporter
J\t1$fin American·~tatt$man
2
Esmeralda Casarez

Subject: FW: Open records request - KSAT
Partner
2517 N . Main
210/227-3243
210/225-4481 (f)
any d issemination, distribution, or copying of this communication is prohibited. If you have received this communication in

Subject: Fwd: Open records request- KSAT
Sent from my iPhone
From: Dillon Collier

To: Vince Di Piazza <vdipiazza@uvaldetx.gov>
Cc: City Hall <cityhall@uvaldetx.gov>
Subject: Open records request - KSAT
Good afternoon,
This request is made under the Texas Public Information Act, Chapter 552, Texas
Government Code, which guarantees the public's access to information in the custody of
governmental agencies. I respectfully request the following information:
From May 6, 2022 to present, please provide a copy of all emails and text messages sent
between the Uvalde city manager, mayor and city council members, both current and incoming
7
as of May 31, 2022, regarding the swearing-in of council members on May 31, 2022. Please also
provide a copy of all video and audio recordings of these swear-ins taking place on May 31,
2022.
Thanks, Dillon Collier
Dillon Collier
8
~!!'~
PUBLIC INFORMATION RE U
Rights or Requestor -, , Requestor
You have. the right w:
• Prompt access to information that is not confidential or Addres
otherwise pro tected;
accommodation in accordance with the Americans with
Disabilities Act (ADA) requirements;
• Receive certain kinds ofin(ormation without exceptions. like
the voting of public, officials, and other infom1ation;
• Receive a written statement of estimated charges. when
charges will exceed $40, in advance of work begin slarted and
opportunity to modify the requcsl in response to the itemized
Public Information Records Request
statement;
• Choose whether to inspect the requeS"ted information (most Detailed Description of Records: ____ _ _ ______ __,
often at no charge). receive copies o f the infonnation or both;
• A waive.r or reduction of charges if the governmental body Ret\AE'S-h~-'--._ _ __ _ _ _ _ _ __
detennines that access 10 the information primarily benefits the
general public;
d ~A.t &.t c ..~ ~

• Receive a copy of the communica1ion from the governmental
whether the infonnalion can be withheld under one of the
tM&~eb.
~~ = ~~~~-
requested information, a mlacted copy;
• Lodge a wrillcn complaint about overcharges for public
information with the Office of the Attorney General.
Complaints of other possible violations may be filed with the '.Fj l,O 11 - ::Z,0 2. 0
governmental body, other than a state agency. is located . If the
complaint is against the county or d istrict attorney, the
complaint must be filed with the Office of the Auomey
General.
✓ Submit a request by mail, fail, e-mail or in person according 10
a governmental body's reasonable procedures. Number of Copies Requested: {,- -+--""~-:;1'-::.I....-J"-"'-~ ~~ -
✓ Include enough description and detail about the information
requested 10 enable the governmental body to accurately
Datc Requested For: --9u--~~
Information to be rdl"ll~l."d:
I 2JZ>2.v
identify and locate the information requested.
✓ Cooperate with the governmental body's reasonable efforts to • You muy review it promplly, and if it cannot be produced within 10
clarify the type or amount of information requested.
working <lays the public intormati()O l)litccr will nulify you in wrili ug of
Cost of Records: the reasonable Jatc and time when ii wilt be available.
Standard paper copy S. IO per page
Nonstandard copy. • K~ep all appointmcnls to ins pect rccl1rds and to pick up copic!i. fnilurc to
A. Diskette $1 .00 each keep appointments may result in losing the oppm1unity 10 inspect t he
8- Magnetic Tape actual cost
C. Data Cartridge actual cost information al the time requested.
D. Tape Cartridge actual cost • In formatio n that may be withh,."ld due to an exception of the referral by
the Oflice of the Altomcy General: your request will be referrt.'d within 10
G. Digital Video Disc $3.00 each busines:; days . The Office uf Lhe At!Mney General musl issut.> a dedsion
H. JAZ drive actual COSI
no lm er i han the 45'h working day from the day ofie r th<)' Altomey Gcncrnl
I. Other electronic media •· actual cost
J. VHS videocassette $2.50 each received the ~cqucst for a d ~ /'),. ,,, {)
K.
L.
Audio cassette $LOO each
Oversize paper copy (e.g. 11 x 17'' , greenbar, b!uebar, not
Requcstor Signature: ~ ~
including maps and photographs using specialty paper)
S.50 per page
Date of Request: ~ 4 ,N2-:: L I 2a:L2
M. Specialty paper (e.g.: Mylar. bluq,rint, blueline, map,
photographic) actual cost cco ds- epc
Programming Labor Charge $28.50 per hour Signature: Jt.JWLMl'IIV
Labor Charge for locating, compiling, and reproducing public
infonnation. SIS.00 per hour Name: &b s...:---'-=-~~Vl_O_~Ji:c::a::..:c~~.:..u:~-- -- - -
[ A labor charge shall not be billed with requests that arc for 50
or fewer pages of paper records, unless records are in separate
£1:nJ.-~..e.,m__m
Til'lc: ______ _ __ _
building.] Revised 0712018 D,atc Received: Lt I iii.o 2-'2,..
8/26/22, 3:35 PM Fwd: NY Times records request - 2018 investigative file - June 2, 2022 - NY Times Mail
- - - Forwarded message ---------

From: Nicholas Bogel-Burroughs
Date: Thu, Jun 2, 2022 at 1:39 PM
Subject: NY Times records request - 2018 investigative file - June 2, 2022
To: <Gmata@uvaldetx.gov>
Hello all,
Under Texas's public records laws, I am requesting:

• The full investigative file from the investigation and arrest of two students on April 25, 2018, in which the students were
accused of plotting to carry out a mass shooting.
I understand that while some records in this case may not be available because it involved juveniles, much of the investigative
file should be available to the public with redactions of the students' names.
Thank you for your time and for your help with the request amid what I understand to be a flood of requests.
Best,
Nick
Nicholas Bogel-Burroughs
The New York Times
1/1
Received
June 3, 2022
. ·'
' '
Esmeralda Casarez

Sent: Friday, June 3, 2022 1:33 PM
To: dnrbzsat
Subject: FW: Public records request re: Notice of Claims
{§/{'~,
~~ !K.~~
City Secretary
OTYQF..UVAWE -
t/,.,alU, •./4.r/.tJ
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234

Sent: Friday, June 3, 2022 11:35 AM
Subject: FW: Public records request re: Notice of Claims
Good morning,
T ~ f i o - t N>
C~~ Mo.A:ov
Records Clerk
City of Uvalde
Police Department
964 W. Main St
Uvalde, Texas 78801
Work: (830)278-9147 ext. 812
Fax: {830)591-2552
gmata(Zv.uvaldetx.gov
5
CONFIDENTIALITY NO TICE This email message and any included attachments are for the sole use of the intended
recipient(s}, and may contain confidential and/or privileged information. Do not read, copy, forward, or print this email
message or ar,y attachments unless yot1 aie the intended 1ecipient. If you a,e not tlie intended recipient, please notify the
From: Levine, Mike

Sent: Friday, June 3, 2022 11:33 AM
Subject: Public records request re: Notice of Claims
Hello,
My name is Mike Levine, and I'm a reporter with ABC News. I am submitting the following public records
request ...
Under the Texas Public Information Act, Tex. Gov't Code §552.001 et seq., I am requesting copies of any all
notices of claim or other correspondence received by the police department since May 24, 2022, that reflect
contemplated or expected legal actions against employees of the department or the department more
broadly for the tragic events on May 24 at Robb Elementary School.
information is in the public interest. This information is not being sought for commercial purposes.
requested records.

Mike Levine
ABC News
6
Esmeralda Casarez

To: dnrbzsat
Subject: FW: Public Records Request
~~,
( I f ~ ~ (If~
City Secretary
OTYQFUVALO'E --
~:t/U. •,t,IYAJ
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
From: Jones, Nate <Nate.Jones@washpost.com>

To: Susan Anderson <sanderson@uvaldetx.gov>; Sorayda Sanchez <ssanchez@uva ldetx.gov>
Subject: Public Records Request
June 3, 2022
VIA EMAIL
sanderson@uvaldetx.gov
ssanchez@uvaldetx.gov
Re: Request under the Texas Public Information Act (Tex. Gov't Code § 552)
Dear Information Officer:
I am a representative of the Washington Post, a news media organization primarily engaged in

the dissemination of information that is urgency
needed to inform the public of actual or alleged government activity, so please process this
request in an expedited manner.
3
Pursuant to Texas Public Information Act (Tex. Gov't Code§ 552) I hereby request the
following:
All contracts between the city of Uvalde (or any Uvalde agency) and any public relations firm
(broadly defined) or law firm created after the May 24, 2022, shooting at Robb Elementa,y
School.
If you regard these documents as potentially exempt from the public record act's disclosure
requirements, I request that you nonetheless exercise your discretion to disclose them. As
required, please release all segregable, non-exempt portions of documents, preferably via email
to
To permit me to reach an intelligent and informed decision whether to contest any denied
material, please describe any withheld records (or portions thereof) and cite the legal
justification for any exemption claims, as required by Texas law.
While I am aware that you may be entitled to charge some reasonable fees to process this
request, I hereby request that you waive all such fees. Waiver of fees is in the public interest
because the furnishing of the information sought by this request will primarily benefit the public
and is likely to contribute significantly to public understanding of the operations or activities of
the government. If, however, you decide not to waive fees and expect them to exceed $100,
please advise me as to the estimated cost of fulfilling the request (including copying charges).
I look forward to hearing your prompt response to my request, as required by Texas law.
Sincerely,
Isl
Nate Jones
Nate Jones
FOIA Director
-
The Washington Post
4
Esmeralda Casarez

To: dnrbzsat
Subject: FW: OPEN RECORDS REQUEST TX CODE 552/ UVALDE PD
{pj{'~,
(l/~~(1/~
City Secretary
an O•.EtWAL.0£ ·-
tt,w/U ,/4mv
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext. 142
Fax: (830) 278-2234
Email: ssanche;f@,uvaldetx.gov
From: Mone, John

Subject: OPEN RECORDS REQUEST TX CODE 552/ UVALDE PD
Ms. Sanchez:
I've filed a request in person, but I am adding this in addition to, per email, regarding matters pertaining to the Uvalde
Police Department.
*I am requesting any and all criminal incident reports regarding the major event response to Robb Elementary on May
24, 2022.
*I am requesting any and all copies of Uvalde Police Department body cam footage from May 24, 2022 from officers
deployed to respond to the mass shooting at Robb Elementary.
This is for editorial purposes to better understand the tragic events that took place that day.
Regards,
John Mone
John Mone
National Correspondent
Texas
◄i► NEWSY scrippsnetworks.com
1
2
Esmeralda Casarez

Sent: Monday, June 6, 2022 11:13 AM
To: dnrbzsat
Subject: FW: OPEN RECORDS REQUEST TX CODE 552/ UVALDE PD/ Addition
~~,
(?/~~(?/~
City Secretary
cm Of UVALOE -
lZwlJ/4 ,h .m..1
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 2 78-3315 ext 142
Fax: (830) 278-2234
From: Mone, John

Subject: Re: OPEN RECORDS REQUEST TX CODE 552/ UVALDE PD/ Addition
Ms. Sanchez:
Since it has come to my attention that the 9-1-1 calls are routed to and overseen by the Uvalde Police Department, I am
also adding a request to include 9-1-1 call recordings from May 24, 2022 from 1115 Central Time to 1600 Centra l Time.
Regards,
John Mone
John Mone
National Corr~sponcent
Texas
◄t► NEWSY
1
From: Mone, John
Date: Friday, June 3, 2022 at 4:15 PM
To: ssanchez@uvaldetx.gov <ssanchez@uvaldet x.gov>
Subject: OPEN RECORDS REQUEST TX CODE 552/ UVALDE PD
Ms. Sanchez:
I've filed a request in person, but I am adding this io addition to, per email, regarding matters pertaining to the Uvalde
Police Department.
*I am requesting any and all criminal incident reports regarding the major event response to Robb Elementary on May
24, 2022.
*I am requesting any and all copies of Uvalde Police Department body cam footage from May 24, 2022 from officers
deployed to respond to the mass shooting at Robb Elementary.
This is for editorial purposes to better understand the tragic events that took place that day.
Regards,
John Mone
John Mone
National Correspondent
Texas
◄t► NEWSY
2
Esmeralda Casarez

Sent: Monday, June 6, 2022 11:10 AM
To: dnrbzsat
Subject: FW: CNN information request// Uvalde Police Department+ more
(9/{'~,
(?/~~(?/~
City Secretary
. CITI'. Qf.UVALD.E _
'f/4,J{). .J,.nr.1
City of Uvalde
P.O.Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 exL 142
Fax: (830) 278-2234
Email: ssanche'li@uvaldetx.gov
From: Flores, Rosa

To: Sorayda Sanchez <ssanchez@uvaldetx.gov>; City Hall <cityha ll@uvaldetx.gov>
Cc: Nieves, Rosalina >; Flores, Rosa
Subject: Re: CNN information request// Uva lde Police Department+ more
Hi, Ms. Sanchez.
I'd like to amend my request to add the following 2 items. (I balded it to make it easy.)
Pursuant to the Texas Public Information Act, Chapter 552 of the Government Code, (the "Act"), Cable News
Network, Inc. ("CNN") requests access to and copies of the following in relation to the Uvalde School Shooting
on May 24, 2022:
1. Cellphone text messages sent and received by Uvalde CISO Police Chief Pete Arredondo on May 24, 2022.
2. Cellphone call log sent and received by Uvalde CISD Police Chief Pete Arredondo on May 24, 2022.
3. 911 call logs on May 24, 2022.
4. 911 audio calls on May 24, 2022.
5. Initial police report for the Uvalde School Shooting on May 24, 2022.
6. Incident police log for the Uvalde School Shooting scene on May 24, 2022. (This is the a request for the log
at the scene)
7. Uvalde Fire Department logs on May 24, 2022.
8. Uvalde Fire Department radio and incident command logs on May 24, 2022.
9. Uvalde Fire Department incident reports on the Uvalde School Shooting on May 24, 2022.
10. Uvalde Police Department dispatch call logs on May 24, 2022.
1
11. Cellphone text messages sent and received by Uvalde Police Chief Daniel Rodriguez on May 24, 2022.
12. Cellphone call log sent and received by Uvalde Police Chief Daniel Rodriguez on May 24, 2022.
CNN agrees to pay reasonable duplication fees for the processing of this request in an amount not to exceed
$25. Please notify me prior to your incurring any expe nses in excess of that amount.
If CNN's request is denied in whole or part, we ask that you justify all deletions by reference to the specific
exemptions of the Act. CNN will also expect you to release all segregable portions of otherwise exempt
- -ffl1tl'Pmt1t-:-f~'ll-rl~tnt1~H-tt>'""'~ d s i o n to withhold any informati,-- - - - - - - - - - -
I would appreciate your communicating with me by telephone at or by email

at rather than by mail, if you have questions regarding this req uest.
As I have made this request in the capacity as a journalist and this information is of timely value, I would
appreciate your expediting the consideration of this request in every way possible. In any event, I look
forward to your reply within five (5) working days, as the Act requires.
Thank you for your assistance. I look forward to hearing from you soon.
Best,
Rosa
Rosa Flores
CNN Correspondent
Houston. TX
From: Flores, Rosa

Date: Friday, June 3, 2022 at 6:06 PM
To: ssa nchez @uval < · > · yhall@uvaldet < · · · >
Cc: Nieves, Rosa lina , Flores, Rosa >
Subject: CNN information request// Uvalde Police Department
M s. Sanchez:
Pursuant to the Texas Public Information Act, Chapter 552 of the Government Code, (the "Act"), Cable News
Network, Inc. ("CNN") requests access to and copies of the following in relation to the Uvalde School Shooting
on May 24, 2022:
1. Cellphone text messages sent and received by Uvalde Police Chief Pete Arredondo on May 24, 2022.
2. Cellphone call log sent and received by Uvalde Police Chief Pete Arredondo on May 24, 2022.
3. 911 call logs on May 24, 2022.
4. 911 audio calls on May 24, 2022.
5. Initial police report for the Uvalde School Shooting on May 24, 2022.
6. Incident police log for the Uv_alde School Shooting scene on May 24, 2022. (This is the a request for the log
at the scene)
2
7. Uvalde Fire Department logs on May 24, 2022.
8. Uvalde Fire Department radio and incident command logs on May 24, 2022.
9. Uvalde Fire Department incident reports on the Uvalde School Shooting on May 24, 2022.
10. Uvalde Police Department dispatch call logs on May 24, 2022.
CNN agrees to pay reasonable duplication fees for the processing of this request in an amount not to exceed
$25. Please notify me prior to your incurring any expenses in excess of that amount.
If CNN 's request is denied in whole or part, we ask that you justify all deletions by reference to the specific
exemptions of the Act. CNN will also expect you to release all segregable portions of otherwise exempt
material. CNN reserves the right to appeal your decision to withhold any information.
I would appreciate your communicating with me by telephone at or by email

at rather than by mail, if you have questions regarding this request.
As I have made this request in the capacity as a journalist and this information is of timely value, I would
appreciate your expediting the consideration of this request in every way possible. In any event, I look
forward to your reply within five (5) working days, as the Act requires.
Thank you for your assistance. I look forward to hearing from you soon.
Best,
Rosa
Rosa Flores
CNN Correspondent
lfouston, TX
3
Esmeralda Casarez

Sent: Monday, June 6, 2022 12:54 PM
To: dnrbzsat
Subject: FW: ORR - CBS News Dallas
(pj{)~dA,
~~gy:-~~
City Secretary
OTY QF..UVALDE .,._
'/,l,,,;£1,. . /4.1<;,1.J
City of Uvalde
P.O. Box 799
Uvalde, Texas 78802
Phone: (830) 278-3315 ext 142
Fax: (830) 278-2234
From: New, Brian A

Sent: Monday, June 6, 2022 12:43 PM
To: City Hall <cityhall@uvaldetx.gov>; Vince DiPiazza <vdipiazza@uvaldetx.gov>
Subject: ORR - CBS News Dallas
Please let me know if there is a different email I need to send this ORR to for the Uvalde Police Department.
This request is made under the Texas Public Information Act, Chapter 552, Texas Government Code which guarantees
the public access to information in the custody of government agencies.
I request copies the following documents/ files pertaining to the shooting at Robb Elementary School on May 24 th,
2022 ...
Copy of incident report

911 call log
911 call audio
Full investigative report
In the interest of expediency, and to minimize the research and/or duplication burden on your staff, please comrnur.iicate with
me by t e l e p h o n ~ or email rather than postal mail. I would be happy to clarify ;r.ny questions
related to my request.
If any part of my request is taking longer to fulfill than the rest, I respectfully ask that you make available what is r.fJ~u1~~b.!e ~»
it becomes ready.
1
If you deny any part of t he request, please cite each specific exemption you feel justifies the refusal to release the information
and notify me of the appeal procedures available to me under t he law.
Thank you for your cooperation and t ime.
Brian New
KTVT - Dallas/ Fort Worth
I
sees DALLAS - FT. WORTH
2
6/15/22, 11:43 AM Mail - Levine, Mike - Outlook
Public records request re: BWC video, 9-1-1 calls, etc.

Levine, Mike < >
Thu 6/9/2022 1:58 PM
To: gmata@uvaldetx.gov <gmata@uvaldetx.gov>
Hello,
My name is Mike Levine, and I'm a reporter with ABC News. On behalf of ABC News, I am submitting the
following public records request...
Under the Texas Public Information Act, Tex. Gov’t Code §552.001 et seq., I am requesting copies of any
and all video or audio recordings, including but not limited to surveillance video, patrol-car video and/or
body-worn camera video, from any Uvalde police department personnel or other city officials who went
to Robb Elementary School on May 24, 2022, to assist with the unfolding situation there. I am also
requesting copies of all calls made to 9-1-1 on that day related to the situation at Robb Elementary,
including but not limited to all calls made from inside the school.
The Texas Public Information Act requires that you “promptly produce” the requested records unless,
within 10 days, you have sought an Attorney General’s Opinion. If you expect a significant delay in


Mike Levine
ABC News
https://outlook.office.com/mail/deeplink?Print 1/1
From:
To:
Date: Friday, August 26, 2022 3:14:08 PM

From: Bleiberg, Jake
Cc: information@tarskilaw.com; dnrbzsat@rampagelaw.com; mayor@uvaldetx.gov

Hello:
I’m writing to request records under the Texas Public Information Act, Tex.
Gov't Code Ann. § 552.001 et seq. (the “Act”), and under the common law
right of access. I am making this request in my capacity as a full-time
journalist with The Associated Press.
Pursuant to the Act, I am requesting a copy of the following public

records:
__ any body-camera footage or dashboard camera footage from the May

24, 2022 shooting at Robb Elementary School;
__ any reports by police officers related to the May 24, 2022 shooting at
Robb Elementary School, including any supplementary materials for those
reports;
__ any emails or other written communication related to the May 24, 2022
shooting at Robb Elementary School that representatives of the city of
Uvalde – including the mayor, city councilors, city police chief, city
attorney or other city staff – sent to or received from representatives of
the Texas Department of Public Safety, the office of Gov. Greg Abbott, the
FBI, the officer of the U.S. attorney general, the office of District Attorney
Christina Mitchell Busbee.
I would like to receive the information in electronic format. I note that

under the Act, “if public information exists in an electronic or magnetic
medium, a requester may request a copy either on paper or in an
electronic medium,” if the following three requirements are met: (1) the
governmental body has the technological ability to produce a copy of the
requested information in the requested medium, (2) such body is not
required to purchase any software or hardware to accommodate the
request, and (3) provision of a copy of the information in the requested
medium would not violate any copyright agreements between the body
and a third party. Tex . Gov't Code Ann . § 552.228(b) .
I ask that you waive any and all fees associated with this request pursuant
to Tex. Gov't Code Ann . § 552 .267 . I am making the request as an AP
reporter and this request is made as part of newsgathering . Release of
the information will primarily benefit the general public because it wi ll
contribute significantly to the public understanding of government. I f you
deny this request for a fee waiver, please advise me in advance of the
estimated charges if they are to exceed $50. I remind you a public body
may not collect fees exceeding those that "reasonably include ...al l costs
related to reproducing the public information ." Tex. Gov't Code Ann . §
552.261.
If this request is denied in whole or part, I ask that you justify al l deletions
by reference to specific exemptions of the Act, and inform me of appea ls
procedures avai lable to me under the law. I also expect you to release al l
segregable portions of otherwise exempt material. I reserve the right to
appea l your decision to withhold any information or to deny a waiver of
fees.
Under the Act, this request must be acted upon as soon as possible "under
the circumstances, that is, within a reasonable time, without delay." Tex .
Gov't Code Ann . § 552 .221.
I wou ld appreciate your hand ling this request as quickly as possible, and I
look forward to hearing from you .
Thank you,
Jake Bleiberg
Jake Bleiberg
[;)1 PROPUBLICA l'.'ITHE TEXAS TRIBUNE
June 27, 2022
Lexi Churchill
Research Reporter
This is a request under the Texas Public Information Act. On behalf of ProPublica, The
Texas Tribune and myself, jointly, we respectfully request the following public records:
Electronic copies of all communications sent to and sent from Uvalde Mayor Don
McLaughlin Jr. between May 27, 2022 to June 27, 2022.
“All communications” should include but are not limited to:

● Emails (this should include all attachments and email responses)
● Text messages
● Voicemail recordings
● Electronic messages sent from platforms including but not limited to Slack,
Microsoft Teams, Facebook, Instagram, Twitter, Whats app, Signal
● Call logs or call history
● Call recordings
● Zoom recordings
● Zoom chats
● Recordings in the voice memos app
● Meeting recordings
● Handwritten notes
This should include communications from both professional, as well as personal

devices and accounts when acting in a government role as defined by 552.002 (a).
If possible, please exclude all subscription or listserv emails.
In order to help to determine my status to assess fees, you should know that I am a
reporter for ProPublica and the Texas Tribune, two nonprofit news organizations, and this
request is made as part of news gathering and not for a commercial use.
our request.

narrowed. Let me know if clarifying this request might speed the release of the
information.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
[Di PROPUBLICA P THE TEXAS TRIBUNE
June 27, 2022
Lexi Churchill
Research Reporter
Electronic copies of all evidence logs and or other documents that account for
evidence collected related to the school shooting at Robb Elementary (715 Old
our request.

information.
your cooperation.
Sincerely,
Lexi Churchill
[D1 PROPUBLICA l'.'ITHE TEXAS TRIBUNE
June 29, 2022
Lexi Churchill
Research Reporter
Copies of all body camera footage taken during calls to Robb Elementary School (715 Old
Carrizo Rd, Uvalde, TX 78801) on May 24, 2022. This footage may include the shooter
Salvador Ramos, 18, and or Uvalde CISD Police Chief Pete Arredondo or CISD Police officers
Mike Hernandez, Ruben Ruiz, Ruby Gonzalez and Adrian Gonzalez.
In the event some of the requested records cannot be immediately released, I ask that your office
still release whatever portion of my request is ready and public under Texas law.
In order to help to determine my status to assess fees, you should know that I am a reporter for
ProPublica and the Texas Tribune, two nonprofit news organizations, and this request is made as
part of news gathering and not for a commercial use.
I request a waiver of all fees for this request. Disclosure of the requested information to me is in the
public interest because it is likely to contribute significantly to public understanding of the
operations or activities of the government. If a waiver of fees is not possible, please provide a
detailed list that breaks down each charge in advance of fulfilling our request.
If you deny any part of this request, please cite in writing each specific reason that you believe
justifies your refusal to release the information and notify me of appeal procedures available under
the law.
In principle, I am willing to consider ways in which the request might reasonably be narrowed. Let
me know if clarifying this request might speed the release of the information.
cooperation.
Sincerely,
Lexi Churchill
From:
To:
Date: Friday, August 26, 2022 3:14:14 PM

From: Bleiberg, Jake
Sent: Thursday, August 04, 2022 5:01 PM
To: drodriguez@uvaldetx.gov; information@tarskilaw.com; jazamora@uvaldetx.gov
Cc: dnrbzsat@rampagelaw.com

Hello:
I’m writing to request records under the Texas Public Information Act, Tex.
Gov't Code Ann. § 552.001 et seq. (the “Act”), and under the common law
right of access. I am making this request in my capacity as a full-time
journalist with The Associated Press.
Pursuant to the Act, I am requesting a copy of the following public

records:
__ any police reports regarding calls for service to Robb Elementary School
from May 9, 2022 to May 23, 2022;
__ any police reports regarding reports of a suspicious person or vehicle in

the area of Robb Elementary School from May 9, 2022 to May 23, 2022;
__ any recordings of of calls to 911, to dispatch or to any other branches

of the Uvalde Police Department regarding reports a suspicious person or
vehicle in the area of Robb Elementary School from May 9, 2022 to May
23, 2022;
I would like to receive the information in electronic format. I note that

under the Act, “if public information exists in an electronic or magnetic
medium, a requester may request a copy either on paper or in an
electronic medium,” if the following three requirements are met: (1) the
governmental body has the technological ability to produce a copy of the
requested information in the requested medium, (2) such body is not
required to purchase any software or hardware to accommodate the
request, and (3) provision of a copy of the information in the requested
medium would not violate any copyright agreements between the body
and a third party. Tex. Gov't Code Ann. § 552.228(b).
I ask that you waive any and all fees associated with this request pursuant
to Tex. Gov't Code Ann. § 552.267. I am making the request as an AP
reporter and this request is made as part of newsgathering. Release of
the information will primarily benefit the general public because it wi ll
contribute significantly to the public understanding of government. If you
deny this request for a fee waiver, please advise me in advance of the
estimated charges if they are to exceed $50. I remind you a public body
may not collect fees exceeding those that "reasonably include ...al l costs
related to reproducing the public information." Tex. Gov't Code Ann. §
552.261.
If this request is denied in whole or part, I ask that you justify al l deletions
by reference to specific exemptions of the Act, and inform me of appea ls
procedures avai lable to me under the law. I also expect you to release al l
segregable portions of otherwise exempt material. I reserve the right to
appea l your decision to withhold any information or to deny a waiver of
fees.
Under the Act, this request must be acted upon as soon as possible "under
the circumstances, that is, within a reasonable time, without delay." Tex.
Gov't Code Ann. § 552.221.
I wou ld appreciate your hand ling this request as quickly as possible, and I
look forward to hearing from you.
Thank you,
Jake Bleiberg
Jake Bleiberg
EXHIBIT B
DNRB*;
Denton Navarro Rocha Bernal &Zech, RC
attorneys & counselors at law • rampajeiaw.com
San Antonio I Austin I Rio Grande Valley I Texas Gulf Coast

2517 N. Main Avenue I San Antonio, Texas 78212-4685
V 210-227-3243 I F 210-225-4481
June 16, 2022
The Honorable Ken Paxton, Attorney General Via Hand Delivery

Office of the Attorney General
Open Records Division
P.O. Box 12548
Austin, Texas 7871 1-2548
Re: Request for Attorney General Decision Under Tex. Gov’t Code Ann. § 552.301
Requestors: Exhibit A (UV 22-001 through UV 22-148)
Entity: City of Uvalde (hereinafter, the “City”)
Date received: May 25, 2022 1 through June 7, 2022
Texas.gov ID No: 66151040
Dear Attorney General Paxton:
Our law firm represents the City of Uvalde (“City”) in the above-referenced matters.
During the time period of May 25, 2022, through June 8, 2022, the City received numerous public
information requests as listed in Exhibit A, attached hereto and incorporated by reference.
In the City’s letter to the Attorney General dated June 9, 2022, regarding the subject matter
of the requests, the City claimed that the requested information is excepted from disclosure. See
Exhibit B. This correspondence will serve as the City’s brief in its request for a decision from the
Attorney General. Pursuant to Section 552.301 of the Public Information Act (the “Act”), the City
hereby requests a decision from the Attorney General regarding whether the requested information
is excepted from disclosure under the Act. See Tex. Gov’t Code Ann. §552.301(a), (b) (West
2012).
Further, I hereby certify that the City’s administrative offices were closed on May 30, 2022,
in observance of the Memorial Day holiday. See Exhibit C. As such, this calendar day is not
included in the statutory time frame that the City must comply with in requesting this decision
from the Attorney General pursuant to Section 552.301 of the Act.
1 City offices are open Monday through Friday 8:00 am - 5:00 pm. Any requests received after these hours or on a
weekend are considered received the next business day.
The Honorable Ken Paxton, Attorney General
June 16, 2022
Page 2
Background
There are 148 requests for information related to the May 24, 2022, mass shooting at the
Rob Elementary School in Uvalde, Texas. Please refer to Exhibit A.
The City has made a good faith effort to relate each request to information that it holds.
Open Records Decision No. 561 at 8 (1990).
The City has not voluntarily released any information to a member of the public.
Information provided to the Texas Rangers was in the form of an intergovernmental transfer of
records for law enforcement purposes. As such, the transfer of records is not considered a release
of information to a member of the public.
The City asserts that Exhibits G01-G382, which consists of the Requested Information, is
subject to exception from disclosure pursuant to Sections 552.101, 552.103, 552.107, 552.108,
552.1175, 552.130, 552.136, and 552.152 of the Texas Government Code.
Briefing to the Attorney General3
Section 552.108 of the Act: Certain Law Enforcement, Corrections, and Prosecutorial
Information
Sections 552.108(a)(1) and (b)(1) of the Act. Sections 552.108(a)(1) and (b)(1) state, in
pertinent part, the following:
“(a) Information held by a law enforcement agency or prosecutor that deals with
the detection, investigation, or prosecution of crime is excepted from the
requirements of Section 552.021 if:
(1) release of the information would interfere with the detection,

investigation, or prosecution of crime;” [and]
(b) An internal record or notation of a law enforcement agency or prosecutor that

is maintained for internal use in matters relating to law enforcement or prosecution
is excepted from the requirements of Section 552.021 if:
(1) release of the internal record or notation would interfere with law
enforcement or prosecution. . . .”
Tex. Gov’t Code Ann. § 552.108 (West 2012).
2 Exhibits GO1-G38 are representative samples of the information responsive to the requests.
3 Exceptions that apply to specific categories of information are noted with the briefing.
June 16, 2022
Page 3
The Public Information 2022 Handbook published by the Office of the Attorney General
states that “[i]nformation relating to a pending criminal investigation or prosecution is one example
of information that is excepted under sections 552.108(a)(1) and 552.108(b)(1) of the Act because
release of such information presumptively would interfere with the detection, investigation, or
prosecution of a crime.” Texas Attorney General Public Information 2022 Handbook, at
91 (2022). Furthermore, your office has previously stated that when a police file relates to a
pending criminal investigation or prosecution, the release of that police file would interfere with
the detection, investigation, or prosecution of crime. Tex. Att’y Gen. ORL-08338 (2005); Tex.
Att’y. Gen. ORL-3062 (2000).
The City of Uvalde Police Department has confirmed that the incident is currently pending
investigation by the Texas Rangers, the Uvalde County District Attorney, and the Federal Bureau
of Investigation. The City has received notices of objection to the disclosure of the responsive
information. See Exhibit D. In consideration of the objections, the City believes that releasing
the Responsive Information may interfere with the ongoing investigation. Therefore, the City asks
to withhold the Requested Information from the Requestors pursuant to Sections 552.108(a)(1)
and 552.108(b)(1) of the Act.
Section 552.101 of the Act; Information Confidential Under Common Law or Constitutional
Privacy Doctrine - Common-Law Privacy
Section 552.101 of the Act excepts from disclosure “information considered to be

confidential by law, either constitutional, statutory, or by judicial decision.” Tex. Govt. Code
Ann. § 552.101 (West 2012). The Texas Supreme Court recognizes that Section 552.101 of the
Act applies to the common-law tort of invasion of privacy through the disclosure of private facts.
See Industrial Found, v. Texas Indus. Accident Bd., 540 S.W.2d 668 (Tex. 1976). Specifically,
the Texas Supreme Court holds that common-law privacy protects information that (1) contains
highly intimate [. . . ] facts, the publication of which would be highly objectionable to a reasonable
person, and (2) is not of legitimate concern to the public. See id. at 683. If the information qualifies
as highly intimate, there is a presumption that the information is not of legitimate concern to the
public unless the requestor of the information can show otherwise. See id. at 685. The Attorney
General’s office has also recognized that information regarding drug overdoses, acute alcohol
intoxication, obstetrical/gynecological illnesses, convulsions/seizures, or emotional/mental
distress is protected by common-law privacy. See Tex. Att’y Gen. ORD-262 (1980).
When considered in light of the previous guidance of the attorney general and the nature
of the responsive information, the Requested Information may fall within the protected class of
emotional/mental distress. Consequently, the City believes that the exception may apply to this
category of information.
Section 552.103 of the Act: Litigation or Settlement Negotiations Involving the State or a
Political Subdivision
Section 552.103(a) of the Texas Government Code, the “litigation exception,” excepts
from disclosure information relating to litigation to which the state or a political subdivision is or
June 16, 2022
Page 4
may be a party. The City has the burden of providing relevant facts and documents to show that
the section 552.103(a) exception is applicable in a particular situation. The test for meeting this
burden is a showing that (1) litigation is pending or reasonably anticipated on the date the
governmental body receives the request for information and (2) the information at issue is related
to that litigation. University of Tex. Law Sch. v. Texas Legal Found., 958 S.W.2d 479, 481 (Tex.
App.-Austin 1997, no pet.); Heard v. Houston Post Co., 684 S. W.2d 210, 212 (Tex. App.-Houston
[1st Dist.] 1984, writ refd n.r.e.); Open Records Decision No. 551 at 4 (1990).
Your office has previously determined that the reasonably anticipated prong of the test is
determined on a case-by-case basis. Open Records Decision No. 452 at 4 (1986). Additionally, a
claim letter is a factor the Attorney General will consider in determining from the totality of the
circumstances presented whether the governmental body has established that litigation is
reasonably anticipated. Texas Attorney General Public Information 2022 Handbook, at 8 1 (2022).
The City believes it meets both prongs of this test, making the information excepted from
disclosure under section 552.103(a). The City has received Letters of Representation from legal
counsel, which include evidence preservation demand and corresponding spoliation of evidence
language, attached as Exhibit E. A demand for evidence preservation is a recognized procedural
standard in preparation of filing suit. Under the standard, the notice letters may be considered as a
factor in conjunction with the nature of the incident in determining if this exception is applicable.
The documents responsive to this request, Exhibits G01-G38, relate to the anticipated litigation
and may be utilized in the lawsuit.
Section 552.101 of the Act and Chapter 1701 of the Occupations Code (Exhibit G02)
Body worn cameras are subject to Subchapter N of Chapter 1 70 1 of the Occupations Code.
A member of the public must provide the following information when submitting a written request
to a law enforcement agency for information recorded by a body worn camera:
(1) the date and approximate time of the recording;

(2) the specific location where the recording occurred; and
(3) the name of one or more persons known to be a subject of the recording.
Occ. Code § 1701.661(a).

confidential by law, either constitutional, statutory, or by judicial decision.” Tex. Govt. Code Ann.
§ 552.101 (West 2012). The City is required to comply with the requirements of the Occupations
Code. For requests that did not provide the requisite information under section 1701.661(a), the
City contends that it is not permitted to release the Requested Information pursuant to Section
552.101 of the Act and Chapter 1701 of the Occupations Code.
June 16, 2022
Page 5
Section 552.101 of the Act: Information Confidential Under Common Law or Constitutional
Privacy Doctrine - Common-Law Privacy

confidential by law, either constitutional, statutory, or by judicial decision.” Tex. Govt. Code
Ann. § 552.101 (West 2012). The Texas Supreme Court recognizes that Section 552.101 of the
Act applies to the common-law tort of invasion of privacy through the disclosure of private facts.
See Industrial Found, v. Texas Indus. Accident Bd., 540 S.W.2d 668 (Tex. 1976). Under the
common-law right of privacy, an individual has a right to be free from the publicizing of private
affairs in which the public has no legitimate concern. Id. at 682. The court of appeals has
concluded public citizens’ dates of birth are protected by common-law privacy pursuant to section
552.101. Paxton v. City of Dallas, No. 03-13-00546-CV, 2015 WL 3394061, at *3 (Tex. App. -
Austin May 22, 2015, pet. Denied) (meme. Op.).
The Requested Information contains birth dates. Therefore, the City believes that it must
withhold the dates of birth from the Requestor pursuant to Section 552.101.
Section 552.101 of the Act and the Common Law Right to Privacy (Exhibits G18, G19, G20)
In addition to protecting from disclosure information that is confidential by law, Section

552.101 applies to information that is protected under the common law right to privacy . The Texas
Supreme Court holds that common-law privacy protects information that (1) contains highly
intimate or embarrassing facts, the publication of which would be highly objectionable to a
reasonable person, and (2) is not of legitimate concern to the public. See Industrial Found, v. Texas
Indus. Accident Bd., 540 S.W.2d 668 (Tex. 1976). If the information qualifies as highly intimate
or embarrassing, there is a presumption that the information is not of legitimate concern to the
public unless the requestor of the information can show otherwise. See id. at 685.
The attorney general has determined that the compilation of an individual’s criminal
history is highly embarrassing information, the publication of which would be highly objectionable
to a reasonable person and not of legitimate concern to the public. See OR201 8-06345, citing U.S.
Dep ’t ofJustice v. Reporters Comm, for Freedom of the Press, 489 U.S. 749, 764(1989) (finding
significant privacy interest in compilation of individual’s criminal history by recognizing
distinction between public records found in courthouse files and local police stations and compiled
summary of criminal history information).
The Requested Information contains a compilation of an individual’s criminal history and

therefore, the City believes that it must withhold the Requested Information.
Section 552.107 of the Act: Certain Legal Matters (Exhibit G30)
Section 552.107 of the Act excepts from disclosure “information that ... an attorney of a
political subdivision is prohibited from disclosing because of a duty to the client under the Texas
Rules of Evidence or the Texas Disciplinary Rules of Professional Conduct.” Tex. Gov’t Code
Ann. § 552.107 (West 2012). In Open Records Decision Number 676, the Texas Attorney General
June 16, 2022
Page 6
interpreted Section 552.107 of the Act to protect the same kind of information protected under
Texas Rule of Evidence 503. Tex. Att’y Gen. ORD No. 676 at 4 (2002). Essentially, Section
552.107 protects from disclosure information that reveals client confidences to the attorney and
information that reveals legal advice, opinions, and recommendations from the attorney. Tex.
Att’y. Gen. ORD No. 574 (1990) (attorney notes documenting client confidences or the attorney’s
legal advice or opinion to the client may be withheld); Tex. Att’y. Gen. ORD No. 163 (1994)
(memorandum containing legal advice and recommendations to an ACC official, in the context of
an attorney-client relationship with ACC may be withheld).
The Attorney General has stated that the standard for demonstrating the attorney-client
privilege under the Act is the same as the standard used in discovery under Texas Rule of Evidence
503. Tex. Att’y Gen. ORD No. 676 at 4 (2002). The government must meet five elements to
demonstrate the elements of the attorney-client privilege. First, the governmental body must
demonstrate that the information constitutes or documents a communication. Id. at 7. Second, the
communication must have been made for the purpose of facilitating the rendition of professional
legal services to the client governmental body. Id. Third, the governmental body must demonstrate
that the communication was between or among clients, client representatives, lawyers, and lawyer
representatives. Id. at 8. Fourth, the governmental body must show that the communication was
confidential and was not “intended to be disclosed to third persons other than those to whom
disclosure is made in furtherance of the rendition of professional legal services to the client or
those reasonably necessary for the transmission of the communication.” Id. at 10. Fifth, the
governmental body must demonstrate that the communication has remained confidential. Id.
The City asserts that portions of the Requested Information constitute a communication for
purposes of the Act because the information consists of electronic messages communicated
between the City and the counsel for the City.
The City argues that the portion of the Requested Information consists exclusively of
communications that were made for the purpose of facilitating legal counsel to the City. These
communications consist of legal advice, legal strategy, legal analysis, opinions, and legal
recommendations.
The communications in the portion of Requested Information are between the City staff
and Counsel. The “client” as defined by Rule 503 is the City of Uvalde and the following
individuals are individuals included in the confidential communications and are considered by the
City to be representatives of the client.
City Representatives:
Vice DiPiazza (City Manager)

Donald McLaughlin (Mayor)
Paul Tarski (City Attorney)
The following are attorneys, paralegals, and/or staff of legal counsel retained by the City.
Each of the individuals listed is either a lawyer authorized to engage in the practice of law, or a
June 16, 2022
Page 7
non-lawyer employed to assist the firm’s layers in the rendition of professional legal services;
therefore, each person is either a “lawyer” or “representative of the lawyer” as those terms are
defined in Rule 503 of the Texas Rules of Evidence.
Legal Counsel for the City:
Clarissa Rodriguez (lawyer)
The City asserts that the portion of the Requested Information constitutes privileged
communications, as defined by Texas Rule of Evidence 503, because these communications were
not intended to be disclosed to third persons other than those to whom disclosure is made in
furtherance of rendition of professional legal services to the client or those reasonably necessary
for the transmission of the communication. As indicated, the portion of the Requested Information
contains legal advice, facts obtained on the request of counsel to provide legal advice, legal
strategy, opinion, analysis, and legal recommendations, all of which was provided by counsel to
the City staff in furtherance of the rendition of professional legal services to the City and was not
intended to be disclosed to third persons. Finally, the portion of the Requested Information has
remained confidential and has not been waived through disclosure to a third party or otherwise.
As such, the portion of the Requested Information constitutes confidential communications
between the City and Counsel and may not be disclosed. The City, therefore, requests that the
portion of the Requested Information be withheld under Section 552.107 of the Act.
For the above stated reasons, the City respectfully requests that your office issue an opinion
that the marked portion of the Requested Information, should be excepted from disclosure pursuant
to Section 552.107 of the Act.
Section 552.108 of the Act: Certain Law Enforcement, Corrections, and Prosecutorial
Information (Exhibits G25, G28)
Sections 552.108(b)(1) state, in pertinent part, the following:

is maintained for internal use in matters relating to law enforcement or prosecution
is excepted from the requirements of Section 552.021 if:
(1) release of the internal record or notation would interfere with law
enforcement or prosecution. ...”
Tex. Gov’tCode Ann. § 552.108 (West 2012).
The attorney general previously held that release of routine investigative procedures,
techniques that are commonly known, and routine personnel information would not interfere with
law enforcement and crime prevention. See Open Records Decision Nos. 216 at 4 (1978), 133 at
3 (1976). However, the Court have ruled that the release of some categories of internal records
could interfere with law enforcement such as those that would divulge a police department's
June 16, 2022
Page 8
methods, techniques, and strategies for preventing and predicting crime. See A & T Consultants,
Inc., 904 S.W.2d at 678.
Examples of these types of documents include police officer training guides, policy and
procedure manuals, shift change schedules, security details, and blueprints of secured facilities.
See, e.g. Tex. Atfy Gen. LR2002-0159 (2002) (shift rosters); Tex. Att'y Gen. LR2001-32 (2001)
(policy and procedure manuals); Tex. Atfy Gen. ORD-413 (1984) (security details at execution);
Open Records Decision No. 531 (1989) (detailed guidelines regarding a police department’s use
of force policy [...]).
Portions of the responsive information fall within the categories of information that the
attorney general has previously found to excepted from release. Additionally, the City believes
that this information may be subject to the objection to disclosure notices.
Section 552.1175 of the Act: Confidentiality of Addresses, Telephone Numbers, Social

Security Numbers, and Personal Family Information of Peace Officers, County Jailers,
Security Officers, and Employees of the Texas Department of Criminal Justice (Exhibits
G08, G25, G27, G33)
Section 552.1175 excepts from public disclosure certain personal information of peace
officers including a peace officer’s home address, home telephone number, emergency contact
information, date of birth, social security number, and family member information.
A peace officer as defined by Article 2.12, Code of Criminal Procedure includes marshals
or police officers of an incorporated city, town, or village, and those reserve municipal police
officers who hold a permanent peace officer license issued under Chapter 1701, Occupations Code.
Tex. Crim. Proc. Code. Ann. art. 2.12(3).
Portions of the Requested Information contains some of the above information regarding a
peace officer. The City believes that the information must be withheld from public disclosure
because it is information that meets the criteria for Section 552.1 175.
Section 552.130 of the Act: Confidentiality of Certain Motor Vehicle Records
As previously noted, Section 552.101 of the Act excepts from disclosure “information
considered to be confidential by law, either constitutional, statutory, or by judicial decision.” Tex.
Govt. Code Ann. § 552.101 (West 2012). The Attorney General’s office has previously
recognized that certain motor vehicle records are confidential under Section 552.130 of the Act.
See Tex. Att’y Gen. GR2000-4847. Specifically, Section 552.130 states, in pertinent part, the
following:
(a) Information is excepted from the requirements of Section 552.021 if the information
relates to:
June 16, 2022
Page 9
(1) a motor vehicle operator's or driver's license or permit issued by an agency of

this state or another state or country;
(2) a motor vehicle title or registration issued by an agency of this state or another
state or country; or
(3) a personal identification document issued by an agency of this state or another

state or country or a local agency authorized to issue an identification document.
(b) Information described by Subsection (a) may be released only if, and in the manner,
authorized by Chapter 730, Transportation Code.
(c) Subject to Chapter 730, Transportation Code, a governmental body may redact
information described by Subsection (a) from any information the governmental body
discloses under Section 552.021 without the necessity of requesting a decision from the
attorney general under Subchapter G.
Tex. Gov’t Code Ann. § 552.130 (West 2012)
The Requested Information includes driver license and license plate numbers and other
motor vehicle information. Therefore, the City believes it must redact the information prior to
disclosure pursuant to Section 552.130 of the Act.
Section 552.136: Confidentiality of Credit Card, Debit Card, Charge Card, and Access
Device Numbers (Exhibit G24)
Section 552.136 of the Government Code provides as follows:
(a) In this section, “access device” means a card, plate, code, account number, personal
identification number, electronic serial number, mobile identification number, or
other telecommunications service, equipment, or instrument identifier or means of
account access that alone or in conjunction with another access device may be used
to:
(1) obtain money, goods, services, or another thing of value; or
(2) initiate a transfer of funds other than a transfer originated solely by paper
instrument.
(b) Notwithstanding any other provision of this chapter, a credit card, debit card, charge
card, or access device number that is collected, assembled, or maintained by or for
a governmental body is confidential.
The Requested Information includes information that falls within this exception to
4
disclosure. Therefore, the City believes the information should be withheld from public disclosure.
June 1 6, 2022
Page 10
Section 552.152 of the Act: Confidentiality of Information Concerning Public Employee or

Officer Personal Safety (Exhibits G08, G25, G27, G28, G33)
Information in the custody of a governmental body that relates to an employee or officer

of the governmental body is excepted from the requirements of Section 552.021 if, under the
specific circumstances pertaining to the employee or officer, disclosure of the information would
subject the employee or officer to a substantial threat of physical harm.
In this instance, there are requests for information that fall within this exception to
disclosure. Under the current circumstances, there is reason to believe that a substantial threat of
physical harm exists for certain employees or city officials. The information is under review to
determine whether the information reaches the threshold for this exception. See Exhibit F The
City requests that you issue a ruling regarding this category of information.
For the above stated reasons, the City respectfully requests that your office issue a ruling
regarding the responsive information, attached as Exhibits G01-G38.
Should you have any questions or concerns, please do not hesitate to contact me by
telephone at (210) 227-3243.
Very truly yours,
Denton Navarro Rocha Bernal & Zech

A Professional Corporation
CYNTHIA TREVINO
CT/ec
Enclosures: as stated.
cc: Exhibit A - Requests

(w/o enclosures)
EXHIBIT C
July 12, 2022
Via Email and Certified Mail / Return Receipt Requested
The Honorable Ken Paxton

P.O. Box 12548
Austin, Texas 78711-2548
Attn: Justin Gordon, Division Chief, Open Records Division
Re: Public Information Requests received by the City of Uvalde regarding events at Robb
Elementary School in Uvalde, Texas, on May 24, 2022. (UV 22-001, -002, -143, -003,
-004, -014, -016, -005, -006, -018, -007, -008, -009, -010, -011, -013, -015, -017, -019,
-020, -021, -022, -023, -024, -025, -136, -028, -030, -031, -033, -034, -036, -037, -039,
-042, -043, -044, -046, -047, -142, -048, -049, -052, -055, -057, -058, -059, -060, -138,
-067, -075, -077, -093, -080, -083, -086, -088, - 089, -090, -091, -095, 096, -098, -099,
-100, -101, -102, -103, -132, -105, -107, -110, -112, -113, -111, -115, -116, -119, -122,
-126, -130)
We are a coalition of media organizations (collectively “Requestors”) who write in reference to

numerous Public Information Requests (the “Requests”) served upon the City of Uvalde Police
Department, the City of Uvalde Fire Marshal, and other City of Uvalde officials regarding the
murder of 19 students and 2 teachers at Robb Elementary School in Uvalde, Texas, on May 24,
2022. See Exh. A. Collectively, our Requests seek the following categories of information:
• Recordings of 911 calls, radio traffic, computer-aided dispatch (CAD) notes, call slips and
other communications reporting and responding to the incidents at 715 Old Carrizo Rd.,
552 Diaz St., and several other local addresses 1;
• Recordings of body camera footage and dashboard camera footage from responding
officers,
• Police reports and incident reports related to the events at Robb Elementary, along with
several addresses and individuals 2;
• Rosters, calendars, communications, training materials, use-of-force reports and personnel
records related to certain current and former Uvalde Police officers;
1
These addresses include: 616 High St.; 707 S. High St.; 820 High St.; 1511 Hood St., Lot 9; 209 N. First St., #3A;
223 Evans St.; 1805 Bowie St.; 1511 Hood Street; 434 Bates St.; 1212 Laredo St.; 1 Coyote Trail.
2
These requests include some or all of the above addresses, and individuals including: Salvador Ramos, Salvador
Ramos Sr., Adriana Ramos, and Marisabelle Ramos.
Haynes and Boone, LLP 600 Congress Avenue | Suite 1300 | Austin, TX 78701
T: 512.867.8400 | haynesboone.com
Page 2
• Surveillance footage from inside Robb Elementary, and schematics and floor plans of the
school; and
• Text, email and other communications sent to or from certain City of Uvalde officials,
including but not limited to the Mayor and Chief of Police.
On June 16, 2022, the City of Uvalde (“City”) submitted a letter to the Attorney General asserting
its belief that the City may withhold responsive records pursuant to Tex. Gov’t. Code §§ 552.101,
552.103, 552.107, 552.108, 552.1175, 552.130, 552.136, and 552.152. See Exh. B.
As explained in detail below, the exceptions asserted do not provide a legal basis for withholding
the information sought by Requestors.
Section 552.108
§§ 552.108(a)(1) and (b)(1) - Ongoing Investigation does not apply to all responsive records
The City claims that all responsive records are excepted from disclosure under §§ 552.108(a)(1)
and 552.108(b)(1) of the Act, on the grounds that release of the requested information could
interfere with a pending investigation. Section 552.108 (the “law enforcement” exception) is a
discretionary exception that allows an agency to withhold certain law enforcement records, but it
does not require any information to be kept confidential. See Tex. Att’y Gen. Op. KP-0186 (2018).
The City’s decision to invoke the law enforcement exception has only prolonged the frustration of
victims and their families, who continue to cry out for transparency regarding the events of that
day. 3 Furthermore, the City’s reliance on this exception is inconsistent with both the purpose and
scope of the exception.
Section 552.108 was intended to ensure justice in criminal prosecutions — it was not intended to
shield law enforcement from accountability. While some officials may prefer to keep such
information secret, the Attorney General has long recognized the importance of transparency in
enforcing the law. “The public has an obvious interest in having access to information concerning
the qualifications and performances of governmental employees, particularly employees who hold
positions as sensitive as those held by members of [law enforcement].” Tex. Att’y Gen. ORD 71
(1986).
3
Laura Romero and Samira Said, Uvalde families demand answers from City Council during heated hearing, ABC
NEWS, June 30, 2022, https://abcnews.go.com/US/uvalde-families-demand-answers-city-council/story?id=86045264
(“We’re looking for some answers that nobody seems to be getting and it’s just making Uvalde PD and everybody
else look even more guilty,” said Berlinda Arreola, grandmother of Amerie Jo Garza, one of the students who died).
Page 3
A law enforcement agency claiming § 552.108 has the burden of establishing that the records at
issue fall within the exception, and it may not “arbitrarily relegate information to that category.”
Tex. Atty. Gen. Op. ORD 287 (1981) (an agency claiming the law enforcement exception “must
reasonably explain . . . how and why release of [the information] would unduly interfere with law
enforcement.”) To qualify for withholding under § 552.108(a)(1), information must be related to
the prosecution of crime. City of Fort Worth v. Cornyn, 86 S.W.3d 320, 327 (Tex. App.—Austin
2002, no pet.) (stating the provision must be read “in reference to the type of information that
would ‘interfere with prosecution’”). It is the governmental agency’s burden to produce evidence
that a criminal investigation is ongoing. A vague or tangential relationship to law enforcement is
not sufficient. See Tex. Att’y Gen. ORD–287 (1981) (“In one sense, any information that a law
enforcement agency possesses may someday become useful to it in the discharge of its law
enforcement duties”).
In this case, there is no pending criminal investigation into the shooter. He is, after all, dead. The
City of Uvalde relies, in part, on a letter issued by Uvalde County District Attorney Christina
Mitchell Busbee stating that an investigation is ongoing. However, District Attorney Mitchell has
publicly stated: “I’m not investigating anything.” 4 Law enforcement officials have repeatedly
stated that the shooter acted alone. He is now deceased. And there are no indications that anyone
else is being investigated in connection with the shooting. As a result, any investigative
information related to the shooter — including ballistics reports, toxicology reports, disciplinary
history and other records regarding Salvador Ramos — do not qualify for the exception. These
documents, which would otherwise be public information, should not be exempted from disclosure
because an investigation into other aspects of the tragedy is ongoing. See Tex. Att’y Gen. ORD
287 (1981) (stating that “the ‘law enforcement’ exception was not intended by the legislature to
shield from public view information in the hands of police units that ... would ordinarily be
available to the public if possessed by a different governmental unit”). The purpose of the
exception contained in § 552.108(a)(1) is not to provide categorical cover to every document
related to a crime. Id. These records must be immediately released.
The City of Uvalde also relies on letters from the Texas Department of Public Safety (“DPS”) the
Uvalde Police Department, and the 38th Judicial District Attorney confirming active investigations.
See Exh. C. But those letters alone do not demonstrate a criminal prosecution, nor do they mandate
wholesale cloaking of all public records in secrecy. An investigation that is purely administrative
in nature and does not specifically involve the investigation or prosecution of crime does not
trigger the exception. OR2021-06928; City of Fort Worth v. Cornyn, 86 S.W.3d 320 (Tex. App.—
4
John Paul Barajas, Uvalde County District Attorney: ‘I’m not investigating anything’, June 16, 2022,
https://www.ksat.com/news/local/2022/06/17/uvalde-county-district-attorney-im-not-investigating-anything/.
Page 4
Austin 2002, no pet.) (stating the exception must be read “in reference to the type of information
that would ‘interfere with prosecution’”); Morales v. Ellen, 840 S.W.2d 519 (Tex. App.—El Paso
1992, writ denied) (statutory predecessor to section 552.108 not applicable to internal investigation
that did not result in criminal investigation or prosecution). When an investigation concerns only
the conduct of a law enforcement officer, the exception does not apply. Thomas v. Cornyn, 71
S.W.3d 473, 489–90 (Tex. App.—Austin 2002, no pet.). The City has not presented any evidence
or even any suggestion that its investigation is criminal in nature, and thus, has failed to meet its
burden to withhold information under § 552.108(a)(1).
Even if criminal prosecution could result from these investigations, there is no evidence that the
release of information would “interfere” with such a prosecution. Law enforcement agencies
throughout the state have released investigative information — including video and audio
recordings — without compromising the potential for prosecution. 5
In this case, DPS admits that release of certain information would not interfere with its
investigation. In a July 8, 2022 letter to Rep. Dustin Burrows, DPS stated that release of the 77-
minute surveillance video from Robb Elementary “would bring clarity” to the public, and would
not harm the agency’s investigative efforts. See Exh. D. Uvalde Mayor Don McLaughlin has also
said he supports release of the video. See Exh. D at 2. However, DPS declined to release the video,
citing a request by District Attorney Busbee.
The Attorney General is not bound by a prosecutor’s unsupported assertion that disclosure would
interfere with the investigation or prosecution of crime. See Tex. Att’y Gen. OR2017-16049
(disagreeing with County Attorney’s contention that disclosure would interfere with ongoing
investigation of criminal case). In this case, the District Attorney’s claim is especially tenuous and
5
Recently, the Haltom City Police Department, the Austin Police Department, the Houston Police Department, and
the La Marque Police Department, among many others, have released body camera footage of critical incidents, even
as those incidents were being investigated. See, e.g., 'This was an ambush situation': Video released of suspect
shooting at Haltom City officers in neighborhood, WFAA, July 4, 2022,
https://www.wfaa.com/article/news/local/video-released-gunman-ambush-shooting-haltom-city-officers/287-
513d74e5-84d3-42c4-8d96-31e554387b12; Shannon Ryan, APD releases body camera footage of officer-involved
shooting in southeast Austin, FOX7, June 9, 2022, https://www.fox7austin.com/news/apd-body-camera-footage-
officer-involved-shooting-southeast-austin; Anna Bauman, HPD releases body camera footage from May officer-
involved shooting in north Houston, June 17, 2022, https://www.houstonchronicle.com/news/houston-
texas/houston/article/Police-release-body-camera-footage-from-May-17249840.php; Bodycam footage of fatal La
Marque PD involved shooting released, ABC13, Dec. 21, 2020, https://abc13.com/joshua-feast-shot-by-police-
officer-jose-santos-la-marque-department-chief-kirk-jackson/8949216/.
Page 5
contradictory, since she has previously stated that she is “not investigating anything.” 6 DPS is the
primary investigative agency, and its determination that release of the surveillance video would
not interfere with the investigation should be accorded great weight.
Similarly, DPS officials have publicly detailed other aspects of their investigation, making clear
that the release of certain recordings and reports would not interfere with the investigation. On
June 21, 2022, Col. Steve McCraw, the Director of DPS testified for nearly four hours at a public
hearing conducted by the Texas Senate Special Committee to Protect All Texans. 7 Col. McCraw
appeared voluntarily – without a subpoena – and testified in open session. At that hearing, which
was broadcast nationally on C-SPAN2 and streamed online by numerous local and national media
outlets, Col. McCraw presented a detailed timeline that included color-coded quotes from body-
camera footage, surveillance footage and audio recordings, along with placards that included
excerpts from selected transcripts of those recordings. Col. McCraw stressed that his testimony
was based on recordings from the scene —not witness statements — saying the families of victims
could take his testimony as “facts” that were unlikely to change. Col. McCraw also offered his
own conclusions regarding the events at Robb Elementary, calling the police response an “abject
failure” and stating that “terrible decisions were made by the on-scene commander.” 8 Col.
McCraw’s comments suggest that key witnesses have already provided their version of events to
investigators, and there is no legitimate concern that the release of information will compromise a
full accounting of the events on that day. 9
Further, DPS has shared its investigative materials with the Advanced Law Enforcement Rapid
Response Training (“ALERRT”) group, for the purpose of producing a public report that detailed
and critiqued the performance of law enforcement. See Exh. E. This report was initiated by DPS,
which briefed officials from ALERRT and provided them with access to a variety of investigative
materials. See Exh. E at 1. The resulting 24-page report states that it “was created using school
video, third party video exterior of school, body cameras, radio logs, verbal testimony of officers
on scene, and verbal statements from investigators.” See Exh. E at 1. The report details the exact
6
7
Col. Steven McCraw, Hearing before Senate Special Committee to Protect All Texans, June 21, 2022,
https://tlcsenate.granicus.com/MediaPlayer.php?view_id=52&clip_id=16906.
8
Lucien Bruggeman, Uvalde shooting hearing: Police response was 'abject failure', ABC NEWS, June 21, 2022,
https://abcnews.go.com/US/live-updates/texas-hearing/?id=85516525.
9
Uvalde Schools Police Chief Pedro “Pete” Arredondo — the incident commander criticized by McCraw — has
previously stated that he was “in contact with DPS every day.” Aaron Cooper, Shimon Prokupecz and Eric Levenson,
Uvalde school district police chief declines to answer CNN questions in first public comments in a week, CNN, June
1, 2022, https://www.cnn.com/2022/06/01/us/uvalde-shooting-police-chief-pete-arredondo/index.html.
Page 6
movement of officers, and critiqued their response for violating procedures. See Exh. E at 3–9
(“Detailed timeline”); 10–12 (“Physical Site Assessment”); 13–20 (“Tactical Assessment”). Given
the public accounting of these details, the City cannot reasonably claim that providing these same
materials to the public would interfere with its investigation.
The City has not demonstrated, and cannot reasonably claim, that it would be detrimental to this
investigation for the public to review the same information that has already been presented publicly
by one of the investigating agencies.
§ 552.108(b)(1) - Certain Law Enforcement, Corrections, and Prosecutorial Information does not
apply to officer information or policies and procedures in this instance
The City also seeks to withhold responsive records related to “Officer information” and “policies”
pursuant to § 552.108(b)(1), which excepts from disclosure “internal records or notations” that
would “interfere” with investigation or prosecution. Section 552.108(b)(1) is intended to protect
“information which, if released, would permit private citizens to anticipate weaknesses in a police
department, avoid detection, jeopardize officer safety, and generally undermine police efforts to
effectuate the laws of this State.” City of Fort Worth v. Cornyn, 86 S.W.3d 320 (Tex. App.—
Austin 2002, no writ). A governmental body bears the burden of explaining how release of the
requested information would interfere with law enforcement and crime prevention. Open Records
Decision No. 562 at 10 (1990). Whether the release of particular records would interfere with law
enforcement is made on a case-by-case basis. Open Records Decision No. 409 at 2 (1984).
The City has not met its burden with regard to “Officer information,” since the City does not even
attempt to demonstrate how information related to particular officers would interfere with law
enforcement or crime prevention.
Also, as the City notes, this exception does not apply to routine investigative procedures,
techniques that are commonly known, and routine personnel information. Open Records Decision
No. 252 at 3. Many of the policies that were in place have become commonly known in recent
weeks. In his testimony before the Senate, DPS Director Col. Steve McCraw explained these
policies in specific detail and answered more than three hours of questions from members of the
committee, clarifying and expanding on the proper procedures for responding to such an incident,
the operational problems at Robb Elementary, and potential solutions that could be enacted by the
Texas Legislature. This testimony was viewed by hundreds of thousands of people online. 10
10
See, e.g., Texas official gives blistering testimony criticizing law enforcement response to Uvalde shooting, CBS
NEWS, https://www.youtube.com/watch?v=RYUgPNhkVs8 (showing more than 111,000 views); WATCH LIVE:
Page 7
Additionally, the report produced by ALERRT outlines the policies and procedures that should
have been followed during the response at Robb Elementary. See Exh. E. The report includes a
detailed description of the physical site. See Exh. E at 10–12 (“Physical Site Assessment”). It also
includes a detailed “Tactical Assessment” that outlines the weaknesses and failures of the response
effort. See Exh. E at 13–20.
Thus, the policies and procedures that are in place, and the way in which those policies were —
and were not — followed in the response at Robb Elementary, are now generally known, and
cannot properly be withheld on the basis of § 552.108(b)(1). 11
Section 552.101
Common-Law Privacy based on emotional/mental distress does not apply to any responsive
records
The City also seeks to withhold all responsive records under § 552.101 and a common-law right
to privacy, on the grounds that some information “may fall within the protected class of
emotional/mental distress.” See Exh. B at 3.
The common-law right to privacy encompasses highly intimate or embarrassing facts about a
person such that its disclosure would be “highly objectionable to a person of ordinary sensibilities.”
Industrial Foundation of the South v. Texas Industrial Accident Board, 540 S.W. 2d 668, 683 (Tex.
1976). The City relies on Open Records Decision 262, which states that common-law privacy may
apply to medical episodes that could be considered intimate or embarrassing, such as a “drug
overdose,” “acute alcohol intoxication,” “obstetrical / gynecological” illness,
“convulsions/seizures,” or “emotional/mental distress.” Tex. Att’y Gen. OR 262 at 2 (1980). The
common-law right to privacy does not include events or occurrences that may cause emotional or
mental stress, so it does not apply to witnesses or victims. King v. Paxton, 576 S.W.3d 881, 901
(Tex. App.—Austin 2019, pet. denied) (“to broadly construe common-law privacy to encompass
stressful interactions with the police ‘would allow the exception to swallow the rule’”).
While the shooter could possibly claim a medical episode that falls under the “emotional/mental
distress” protection of common-law privacy, he is deceased, and therefore has no privacy interest
to protect. Tex. Att’y Gen. OR2011-03167 (2011) (“because privacy is a personal right that lapses
at death, the common-law right to privacy does not encompass information that relates only to a
Texas Senate holds special hearing on police response to Uvalde school shooting, PBS NEWSHOUR,
https://www.youtube.com/watch?v=IAawESxplOQ (showing more than 50,000 views).
11
See, e.g., McCraw, Hearing before Senate Special Committee to Protect All Texans, June 21, 2022.
Page 8
deceased individual”). Thus, this exception cannot be used to justify the withholding of any
responsive information.
Common-Law Privacy does not apply to the criminal histories of the shooter or his family members
The City asserts that the criminal histories of Salvador Ramos, Adriana Ramos, and Salvador
Ramos, Sr. may be withheld as “highly embarrassing information” that is protected from disclosure
under common-law privacy.
As previously noted, Salvador Ramos is deceased, and, as such, he does not have any recognizable
privacy interest. Tex. Att’y Gen. OR2011-03167 (2011) (“because privacy is a personal right that
lapses at death, the common-law right to privacy does not encompass information that relates only
to a deceased individual”).
The Attorney General has ruled that a compilation of an individual’s criminal history “is generally
not of legitimate concern to the public.” Tex. Att’y Gen. OR2008-12058 (emphasis added).
However, the Texas Supreme Court has held that “[t]here may be circumstances in which the
special nature of the information makes it of legitimate concern to the public even though the
information is of a highly private and embarrassing nature.” Indus. Found. of the S. v. Tex. Indus.
Acc. Bd., 540 S.W.2d 668, 685 (Tex. 1976).
The deadliest school-shooting in Texas history must qualify as such an exception. Twenty-one
lives were lost to a gunman whose motivations remain a mystery. The public has a “legitimate
interest” in a comprehensive portrait of the shooter’s personal and familial history, including
information that might otherwise be considered private or embarrassing.
Section 552.103(a) – Litigation Exception does not apply to all responsive records
The City also seeks to withhold all responsive records under § 552.103(a), on the grounds that
litigation was reasonably anticipated at the time the Requests were made. In order to claim this
exception, the City bears the burden of showing “concrete evidence” that litigation involving a
specific matter was realistically contemplated and is more than mere conjecture. Open Records
Decision No. 452 at 4 (1986). In order to meet this burden, the City must show that (1) litigation
was pending or reasonably anticipated on the date the governmental body received the request for
information, and (2) the requested information is related to that litigation. See Univ. of Tex. Law
Sch. v. Tex. Legal Found., 958 S.W.2d 479, 481 (Tex. App.—Austin 1997, no pet.); Heard v.
Houston Post Co., 684 S.W.2d 210, 212 (Tex. App.—Houston [1st Dist.] 1984, writ ref'd n.r.e.);
Open Records Decision No. 551 at 4 (1990). The City cannot satisfy the first prong of this test.
Page 9
To support its argument, the City includes two Notice of Representation letters that it received on
June 1, 2022 from attorneys representing the families of victims. See Exh. E. The City points to
the preservation of evidence demand contained in one of these letters as a possible precursor to
litigation. See Exh. E at 4. However, the Attorney General has repeatedly ruled that Letters of
demand for preservation of evidence. See, e.g., Tex. Att’y Gen. OR2008-08934; OR2011-02078.
Further, the City received both Notices of Representation after the vast majority of the Requests
had been received. See Exh. F. In order to qualify for the exception, a governmental entity must
have concrete evidence of litigation at the time the request is received. Univ. of Tex. Law Sch. v.
Tex. Legal Found., 958 S.W.2d at 481. Because these Notices were not received until June 1, 2022,
the City cannot apply the exception to any Requests received prior to that date.
Chapter 1701 of the Occupations Code does not apply to all body camera recordings
The City seeks to withhold body camera footage under § 552.101 of the Act, in combination with
Chapter 1701 of the Occupations Code. Specifically, the City points to § 1701.661(a) of the
Occupations Code, which requires a requestor of body camera footage to include: (1) the date and
approximate time of the recording; (2) the specific location where the recording occurred; and (3)
the name of one or more persons known to be the subject of the recording. Tex. Occ. Code §
1701.661(a).
Requestors have complied with this statutory requirement. Several of the Requests specifically
mention the time, location, and at least one possible subject of the recording. See, e.g., Exh. A at
6 (request by Niccole Caan of KENS5-TV on May 25, 2022 for “body camera or dash camera
video starting at 11:20 a.m. on 5/24/22 from Robb Elementary School involving Salvador
Ramos”).
Because Requestors have complied with the requirements of the statute, and the City does not
assert any other exceptions related to body camera footage, that information must be released.
Section 552.107 – Attorney-Client Privilege does not apply to all talking points
The City seeks to withhold certain communications between City representatives and a private
attorney on the grounds of attorney-client privilege, pursuant to § 552.107. The City claims the
privilege with respect to “Talking Points” (G-30). As the City notes in its letter, in order to
withhold information under § 552.107, a governmental body must demonstrate that the
Page 10
communications were made for the purpose of facilitating the rendition of professional legal
services to the client governmental body. Tex. Att’y Gen. ORD 676 at 7 (2002).
The fact that an attorney is included on communications regarding “talking points” may not be
enough to invoke the exception. Tex. Att’y Gen. OR2007-06452 (2007). The Attorney General
has denied requests to withhold communications regarding talking when those communications
do not include advice, recommendations or opinions. Id. Should the Attorney General find that
some portion of the communications are exempt from disclosure under § 552.107, Requestors ask
that such portions be redacted, and the remaining responsive records be released in their entirety.
Section 552.1175 - Confidentiality of Addresses, Telephone Numbers, Social Security

Numbers, and Personal Family Information of Peace Officers does not allow for withholding
of responsive documents
The City also seeks to withhold certain confidential information under § 552.1175. According to
the City, this information is contained in the following exhibits: “SWAT information” (G-08),
“Officer information” (G-25); “Arredondo file” (G-27); and “Employee information” (G-33).
Section 552.1175(b) notes that the governmental body may only withhold such information if an
individual:
(1) chooses to restrict public access to the information; and

(2) notifies the governmental body of the individual’s choice on a form provided by
the governmental body, accompanied by evidence of the individual’s status.
The City has not provided any evidence to Requestors that the requirements of this section have
been met. In the event that the City has demonstrated the requirements for withholding have been
satisfied, Requesters note that the City may not withhold all information related to these categories
of information under this exception. The City may only redact specific information relating to
“home address, home telephone number, emergency contact information, date of birth, or social
security number of an individual to whom this section applies, or that reveals whether the
individual has family members.” Tex. Gov’t Code § 552.1175(b).
Page 11
Section 552.136 – Credit Card, Debit Card, Charge Card, and Access Device Numbers does
not allow for withholding of responsive documents
The City seeks to withhold information under § 552.136, on the grounds that such information
contains access numbers that are used to electronically access or transfer funds. The City states
that this information is contained among “Text messages” (G-24).
Requesters concede that these access numbers are made confidential by § 552.136. However,
Requesters also note that a governmental entity may redact such information without seeking a
determination by the Attorney General. Tex. Gov’t Code § 552.136(c).
The City states only that it “believes the information should be withheld from disclosure,” without
specifying whether it seeks to redact specific access numbers or withhold all text messages on the
basis of this exception. The City must redact specific access device numbers under the statute and
cannot use this exception to withhold any portions of text messages that do not contain access
numbers.
Section 552.152 - Information concerning public employee or officer personal safety does not
allow for withholding of responsive documents
The City also seeks to withhold information contained in several categories of responsive records
under § 552.152, which protects from disclosure “information [that] would subject the employee
or officer to a substantial threat of physical harm.”
The City states that the information “is under review to determine whether the information reaches
the threshold for this exception,” and points to Exhibit F of its briefing. Requestors note that they
were not provided with a copy of Exhibit F, and thus are unable to evaluate the City’s claims.
The Texas Supreme Court has recognized § 552.152 as a codification of the common law
protections against disclosure that threatened substantial bodily harm. Tex. Dep’t of Pub. Safety v.
Cox Tex. Newspapers, L.P., 343 S.W.3d 112, 118 (Tex. 2011). Under the common law protections,
the Texas Attorney General described the exception as covering only a “very narrow set of
situations in which release of the information” would cause someone to face “an imminent threat
of physical danger.” Tex. Att'y Gen. ORD 0169 at 6 (1979). It must be “more than a desire for
privacy or a generalized fear of harassment or retribution.” Id.
Under this standard, the City is required to show that the threat is specific and imminent. “[V]ague
assertions of risk will not carry the day.” Tex. Dep't of Pub. Safety v. Cox Tex. Newspapers, L.P.,
Page 12
343 S.W.3d at 119. Based on the information provided to Requestors, the City has failed to make
such a showing.
Requesters Consent to Certain Limited Redactions
Requesters acknowledge that portions of responsive information may be expressly confidential

under the Act. We consent to redaction of the following information: dates of birth, Social Security
numbers, PIN access numbers, motor vehicle license plate numbers, motor vehicle registration
numbers, driver’s license numbers, and the home address, home telephone number, and emergency
contact information of peace officers.
However, any redactions made by the City must include only the above information. The City may
not withhold records in their entirety, simply because a document or recording contains some
information deemed confidential under the law.
Conclusion
For all of these reasons, we respectfully request that you issue a determination concluding that the
documents and other materials sought by Requestors are not exempt from disclosure, and directing
the Uvalde Police Department, Uvalde Fire Marshal and the City of Uvalde to promptly disclose
the requested materials to Requestors.
Thank you for your consideration. If you have any questions or require any additional information
from us, please let us know.
Sincerely,
Laura Lee Prather

On behalf of:
ABC News CBS Stations Group of Texas

KTRK – Houston KTVT – Dallas
The Associated Press CNN
CBS News Cox Media Group
The Dallas Morning News
Page 13
Dow Jones & Company Sinclair Broadcast Group

Gannett KABB/WOAI – San Antonio
Austin American-Statesman KVII – Amarillo
The Abilene Reporter-News KDBC/KFOX – El Paso
Corpus Christi Caller-Times KEYE – Austin
The El Paso Times KBTV/KFDM – Beaumont
San Angelo Standard-Times KTXS – Abilene
Times Record News – Wichita Falls TEGNA
Amarillo Globe-News WFAA – Dallas
Lubbock Avalanche-Journal KHOU – Houston
USA Today KENS – San Antonio
Graham Media Group KVUE – Austin
KSAT – San Antonio KAGS – Bryan/College Station
KPRC – Houston KCEN – Waco
Gray Television KYTX – Tyler
KXII – Sherman KIII – Corpus Christi
KGNS – Laredo KWES – Midland/Odessa
KFDA – Amarillo KBMT – Beaumont
KWTX – Waco KIDY/KXVA – San Angelo
Hearst Newspapers TelevisaUnivision
Houston Chronicle KUVN – Dallas
San Antonio Express-News KXLN – Houston
NBC News KAKW – Austin
NBC Owned Television Stations KWEX – San Antonio
KXAS – Dallas-Fort Worth Texas Public Radio
The New York Times Company Texas Tribune
Pro Publica, Inc.
Scripps
EXHIBIT D
is
KEN PAXTON
AI'IOKXEV GF.NEKAI. OF TEXAS
August 12.2022
Ms. CynthhpTrevino
Counsepfir the City of Uvalde
DenpZ' Navarro Rocha Bernal & Zech, PC
25T 7 North Main Avenue
Xan Antonio. Texas 78212-4685
OR2022-24126
Dear Ms. Trevino:
You ask whether certain information is subject to required public disclosure under the
Public Information Act (the "Act”), chapter 552 of the Government Code. Your request
was assigned ID# 963676 (ORR Nos. 22-001 through 22-151, 22-154 through 22-158,
22-225, 22-227, 22-230. 22-233, 22-235, and 22-236)
The City of Uvalde (the "city”), which you represent, received 162 requests from 92
requestors for information pertaining to a specified incident. You state the city does not
have information responsive to portions of the requests.1 You claim a portion of the
submitted information was not properly requested pursuant to section 1701.661(a) of the
Occupations Code. You also claim the submitted information is excepted from disclosure
under sections 552.101, 552.103, 552.107, 552.108, 552.117, 552.1 175, 552.130, 552.136,
and 552. 1 52 of the Government Code.2 We have also received and considered comments
from the requestors, representatives of requestors, and interested third parties. See Gov’t
Code § 552.304 (permitting interested third party to submit to attorney general reasons why
requested information should or should not be released); see also id. § 552.305; Open
1 The Act does not require a governmental body to release information that did not exist when a request for
information was received or to prepare new information in response to a request. See Econ. Opportunities
Dev. Corp. r. Bustamante, 562 S.W.2d 266, 267-68 (Tex. Civ. App.—-San Antonio 1978, writ dism’d);
Open Records Decision Nos. 605 at 2 (1992), 452 at 3 (1986), 362 at 2 (1983).
’ Although the city raises section 552.1 175, we note section 552.1 17 is the correct exception to raise for
information the city holds in its capacity as employer.
Post Office lh>x 12548, Ausnn, Texas 78"r11 2548 • (512)463 2100 • www.texasattorneygeneral.gov
Ms. Cynthia Trevino - Page 2
Records Decision No. 542 (1990). We have considered the submitted arguments and
reviewed the submitted representative sample of information.1
Initially, we note some of the submitted information, is not responsive to some of the
requests at issue because it was created after the date the requests were received. This
ruling does not address the public availability of any information that is not responsive to
the requests and the city is not required to release such information in response to these
requests.
Next, we note the requestor in request 22-148 is a Texas State Senator. Section 552.008 of
the Government Code grants access to requested information, including confidential
information, to individual members, agencies, or committees of the Texas Legislature.
Section 552.008 provides:
(a) [The Act] does not grant authority to withhold information from
individual members, agencies, or committees of the legislature to use for
legislative purposes.
(b) A governmental body on request by an individual member, agency, or

committee of the legislature shall provide public information, including
confidential information, to the requesting member, agency, or committee
for inspection or duplication in accordance with this chapter ifthe requesting
member, agency, or committee states that the public information is
requested under this chapter for legislative purposes. A governmental body,
by providing public information under this section that is confidential or
otherwise excepted from required disclosure under law, does not waive or
affect the confidentiality of the information for purposes of state or federal
law or waive the right to assert exceptions to required disclosure of the
information in the future. The governmental body may require the
requesting individual member of the legislature, the requesting legislative
agency or committee, or the members or employees of the requesting entity
who will view or handle information that is received under this section and
that is confidential under law to sign a confidentiality agreement that covers
the information and requires that:
(1) the information not be disclosed outside the requesting entity, or

within the requesting entity for purposes other than the purpose for
which it was received;
(2) the information be labeled as confidential:
(3) the information be kept securely; or
’ We assume the ''representative sample” of records submitted to this office is truly representative of the
requested records as a whole. See Open Records Decision Nos. 499 (1988), 497 (1988). This open records
letter does not reach, and therefore does not authorize the withholding of, any other requested records to the
extent those records contain substantially different types of information than that submitted to this office.
(4) the number of copies made of the information or the notes taken
from the information that implicate the confidential nature of the
information be controlled, with all copies or notes that are not
destroyed or returned to the governmental body remaining
confidential and subject to the confidentiality agreement.
(c) This section does not affect:
(I ) the right of an individual member, agency, or committee of the

legislature to obtain information from a governmental body under
other law, including under the rules of either house of the legislature;
(2) the procedures under which the information is obtained under

other law; or
(3) the use that may be made of the information obtained under other
law.
Gov't Code § 552.008(a)-(b), (c). In this instance, the requestor is Texas State Senator
Roland Gutierrez ("Senator Gutierrez”). However, Senator Gutierrez does not state, and it
is not otherwise clear to this office, the request was made for legislative purposes.
Accordingly, we must rule on the applicability of section 552.008 in the alternative. If
Senator Gutierrez made this request for legislative purposes, then the city must make the
information responsive to his request available to him in accordance with section 552.008
of the Government Code. See id. § 552.008(b). We note section 552.008 permits a
governmental body to require a member of the legislature to sign a confidentiality
agreement for the protection of information obtained pursuant to this section. Id. In
addition, release of this information under section 552.008 does not waive or affect the
confidentiality of the information for the purposes of state or federal law or waive the right
of the department to assert exceptions to required public disclosure of this information to
future requestors. See id. But, if this request for information was not made for legislative
purposes, then the information responsive to his request need not be released under
section 552.008. and we will consider the submitted arguments against its public disclosure.
Next, we note the submitted information contains peace officers’ Texas Commission
on Law Enforcement ("TCOLE”) identification numbers.4 Section 552.002(a) of the
Government Code defines "public information” as information that is written, produced,
collected, assembled, or maintained under a law or ordinance or in connection with the
transaction of official business:
( 1 ) by a governmental body;
J The Texas Commission on Law Enforcement Officer Standards and Education was renamed the Texas
Commission on Law Enforcement by the 83rd Legislature. See Act of May 6, 2013, 83rd Leg., R.S., ch. 93,
§ LOI.
(2) for a governmental body and the governmental body:
(A) owns the information;
(B) has a right of access to the information; or
(C) spends or contributes public money for the purpose of writing,

producing, collecting, assembling, or maintaining the information:
or
(3) by an individual officer or employee of a governmental body in the

officer’s or employee’s official capacity and the information pertains to
official business of the governmental body.
Id. § 552.002(a). In Open Records Decision No. 581 (1990), this office determined certain
computer information, such as source codes, documentation information, and other
computer programming, that has no significance other than its use as a tool for the
maintenance, manipulation, or protection of public property is not the kind of information
made public under section 552.021 of the Government Code. We understand an officer's
TCOLE identification number is a unique computer-generated number assigned to peace
officers for identification in TCOLE’s electronic database, and may be used as an access
device number on the TCOLE website. Accordingly, we find the officers’ TCOLE
identification numbers in the submitted information do not constitute public information
under section 552.002 of the Government Code. Therefore, the TCOLE identification
numbers are not subject to the Act and need not be released to the requestors.
We note we have received comments from interested third parties asserting some of the
information at issue was previously released. The Act does not permit selective disclosure
of information to the public. See id. §§ 552.007(b), .021 ; Open Records Decision No. 463
at 1-2 (1987). Information that has been voluntarily released to a member of the public
may not subsequently be withheld from another member of the public, unless public
disclosure of the information is expressly prohibited by law or the information is
confidential under law. See Gov’t Code § 552.007(a); Open Records Decision Nos. 5 1 8 at
3 (1989), 490 at 2 (1988). Although the city seeks to withhold the information at issue
under sections 552.103 and 552.108 of the Government Code, these sections are
discretionary exceptions to disclosure that protect a governmental body's interests and may
be waived. See Dallas Area Rapid Transit v. Dallas Morning News, 4 S. W.3d 469. 475-76
(Tex. App.—Dallas 1999, no pet.) (governmental body may waive Gov't Code § 552.103):
Open Records Decision Nos. 665 at 2 n.5 (2000) (discretionary exceptions generally). 663
at 5 (1999) (waiver of discretionary exceptions), 177 at 3 (1977) (statutory predecessor to
Gov't Code § 552.108 subject to waiver). As such, sections 552.103 and 552.108 do not
expressly prohibit the release of information to the public nor do they make information
confidential under the Act. Therefore, to the extent the city previously released any of the
information at issue to a member of the public voluntarily, it may not now withhold any
such information from any of the requestors under section 552.103 or section 552.108 but
must, instead, release it.
We note portions of the submitted information are subject to section 552.022 of the
Government Code. Section 552.022(a) provides, in relevant part:
(a) [T]he following categories of information are public information and not
excepted from required disclosure unless made confidential under this
chapter or other law:
(1) a completed report, audit, evaluation, or investigation made of,

for, or by a governmental body, except as provided by
Section 552.108; [and]
(3) information in an account, voucher, or contract relating to the receipt or

expenditure of public or other funds by a governmental body[.]
Gov't Code § 552.022(a)(1), (3). The information we have indicated consists of completed
reports and evaluations subject to section 552.022(a)(1). The city must release the
completed reports and evaluations pursuant to section 552.022(aXl) unless they are
excepted from disclosure under section 552. 1 08 ofthe Government Code or expressly made
confidential under the Act or other law. See id. § 552.022(a)(1). Portions of the submitted
infonnation also consist of information in an account or contract relating to the expenditure
of funds by a governmental body subject to section 552.022(a)(3). The information subject
to section 552.022(a)(3), which we have marked, must be released unless it is made
confidential under the Act or other law. See id. § 552.022(a)(3). Although you raise
sections 552.103 and 552.108 of the Government Code for the entirety of the submitted
information, these sections are discretionary exceptions to disclosure and do not make
information confidential under the Act. See Dallas Area Rapid Transit, 4 S.W.3d at
475-76; ORDs 665 at 2 n.5. 663 at 5.
Therefore, none of the information subject to section 552.022, which we have marked, may
be withheld under section 552.103. Further none of the information subject to section
552.022(a)(3) may be withheld under section 552.108. However, we will consider your
arguments for the information not subject to section 552.022. Additionally, you raise
sections 552.101, 552.117, and 552.152 for this information. These sections make
information confidential under the Act. Accordingly, we will also consider the applicability
of these exceptions to the information subject to section 552.022.
Section 552.107(1) of the Government Code protects information coming within the
attorney-client privilege. When asserting the attorney-client privilege, a governmental
body has the burden of providing the necessary facts to demonstrate the elements of the
privilege in order to withhold the information at issue. Open Records Decision No. 676 at
6-7 (2002). First, a governmental body must demonstrate that the information constitutes
or documents a communication. Id. at 7. Second, the communication must have been made
"to facilitate the rendition of professional legal services” to the client governmental body.
Tex. R. Evid. 503(b)(1). The privilege does not apply when an attorney or representative
is involved in some capacity other than that of providing or facilitating professional legal
services to the client governmental body. In re Tex. Farmers Ins. Exch., 990 S.W.2d 337,
340 (Tex. App.—-Texarkana 1999, orig. proceeding) (attorney-client privilege does not
apply if attorney acting in a capacity other than that of attorney). Governmental attorneys
often act in capacities other than that of professional legal counsel, such as administrators,
investigators, or managers. Thus, the mere fact that a communication involves an attorney
for the government does not demonstrate this element. Third, the privilege applies only to
communications between or among clients, client representatives, lawyers, and lawyer
representatives. Tex. R. Evid. 503(b)(1). Thus, a governmental body must inform this
office of the identities and capacities of the individuals to whom each communication at
issue has been made. Lastly, the attorney-client privilege applies only to a confidential
communication, id., meaning it was “not intended to be disclosed to third persons other
than those: (A) to whom disclosure is made to further the rendition of professional legal
services to the client; or (B) reasonably necessary to transmit the communication." Id.
503(a)(5). Whether a communication meets this definition depends on the intent of the
parties involved at the time the information was communicated. Osborne v. Johnson. 954
S.W.2d 180, 184 (Tex. App. —Waco 1997, orig. proceeding). Moreover, because the client
may elect to waive the privilege at any time, a governmental body must explain that the
confidentiality of a communication has been maintained. Section 552.107(1) generally
excepts an entire communication that is demonstrated to be protected by the attorney-client
privilege unless otherwise waived by the governmental body. See Huie v. DeShazo, 922
S.W.2d 920, 923 (Tex. 1996) (privilege extends to entire communication, including facts
contained therein).
You claim Exhibit G30 is protected by section 552.107(1) of the Government Code. You
state Exhibit G30 consists of communications between the attorneys for the city and city
officials. You state the communications were made for the purpose of facilitating the
rendition of professional legal services to the city. You further state these communications
were intended to be confidential and have remained confidential. Based on your
representations and our review, we find you have demonstrated the applicability of the
attorney-client privilege to the information at issue. Thus, the city may withhold the Exhibit
G30 under section 552.107(1) of the Government Code.5
Section 552.108(bXl) of the Government Code excepts from disclosure the internal records
and notations of law enforcement agencies and prosecutors when their release would
interfere with law enforcement and crime prevention. Gov’t Code § 552. 1 08(b)( 1 ); see also
Open Records Decision No. 531 at 2 (1989) (quoting Ex parte Pruitt, 551 S.W.2d 706
(Tex. 1977)). A governmental body claiming section 552. 1 08(b)( 1 ) must explain how and
why the release of the requested information would interfere with law enforcement. See
Gov’t Code §§ 552.108(bXl), -301(e)(1)(A); see also Ex parte Pruitt, 551 S.W.2d 706.
Section 552.108(b)(1) is intended to protect “information which, if released, would permit
private citizens to anticipate weaknesses in a police department, avoid detection, jeopardize
officer safety, and generally undermine police efforts to effectuate the laws of this State."
See City ofFort Worth v. Cornyn, 86 S.W.3d 320 at 327 (Tex. App.—Austin 2002. no pet.).
This office has concluded section 552.108(b)(1) excepts from public disclosure information
relating to the security or operation of a law enforcement agency. See. e.g.. Open Records
Decision Nos. 531 (release of detailed use of force guidelines would unduly interfere with
law enforcement), 252 (1980) (section 552.108 of the Government Code is designed to
5 As our ruling is dispositive, we need not address your remaining arguments against disclosure of this
information.
protect investigative techniques and procedures used in law enforcement), 143 (1976)
(disclosure of specific operations or specialized equipment directly related to investigation
or detection of crime may be excepted). Section 552.108(b)(1) is not applicable, however,
to generally known policies and procedures. See, e.g., ORDs 531 at 2-3 (Penal Code
provisions, common law rules, and constitutional limitations on use of force not protected),
252 at 3 (governmental body failed to indicate why investigative procedures and techniques
requested were any different from those commonly known).
You state Exhibits G25 and G28, if released, would interfere with law enforcement or
prosecution of crime. We understand the information at issue contains highly specific
guidelines for police officers confronted by violence or threatened violence when affecting
an arrest or protecting the public safety. You argue release of the information at issue could
give criminals a tactical advantage and jeopardize officers’ safety. Based on your
representations and our review, we agree the release of some of the information at issue,
which we have marked, would interfere with law enforcement. Accordingly, the city may
withhold the information we have marked under section 552.108(b)(1) of the Government
Code? I lowcver. we find you have not demonstrated how release of any of the remaining
information al issue would interfere with law enforcement or crime prevention.
Accordingly, the city may not withhold any of the remaining information at issue under
section 552. 1 08(b)( 1 ).
Section 552. 1 08(a)( 1 ) of the Government Code excepts from disclosure “[information held
by a law enforcement agency or prosecutor that deals with the detection, investigation, or
prosecution of crime [if] release of the information would interfere with the detection,
investigation, or prosecution of crime[.]” Gov’t Code § 552.108(a)(1). A governmental
body claiming section 552.108 must explain how and why the release of the requested
information would interfere with law enforcement. See id. §§ 552.108(a)(1), .301(e)(1)(A);
see also Ex parte Pruitt, 55 1 S.W.2d 706 (Tex. 1977). Section 552. 108 may be invoked by
the proper custodian of information relating to a pending investigation or prosecution of
criminal conduct. See Open Records Decision No. 414 at 4-5 (1987). Where a
governmental body has custody of information that would otherwise qualify for exception
under section 552.108 as information relating to the pending case of a law enforcement
agency, the custodian of the records may withhold the information if it provides this office
with a demonstration the information relates to the pending case and a representation from
the law enforcement agency that it wishes to have the information withheld. You state, and
provide documentation demonstrating, the Texas Department of Public Safety (“DPS”)
objects to release of the remaining information because it relates to its ongoing criminal
investigation. We note the information at issue includes traffic tickets. Because copies of
the traffic tickets were provided to the individuals who were cited, we find release of the
traffic tickets will not interfere with the detection, investigation, or prosecution of crime.
See Gov't Code § 552.108(a)(1). We therefore conclude the traffic tickets may not be
withheld under section 552.108(a)(1). Nevertheless, based on DPS’s representation and
our review, we conclude the release of some of the information at issue would interfere
with the detection, investigation, or prosecution of crime. See Houston Chronicle Publ 'g
Co. v. City of Houston, 531 S.W.2d 177 (Tex. Civ.App.—Houston [14th Dist.] 1975)(court
information.
delineates law enforcement interests that are present in active cases), writ refd n.r.e. per
curiam, 536 S.W.2d 559 (Tex. 1976). Thus, section 552.108(a)(1) is applicable to the
information we have indicated. However, we find you have not demonstrated how release
of any of the remaining information at issue would interfere with law enforcement or crime
prevention. Accordingly, the city may not withhold any ofthe remaining information under
section 552.108(a)(1).
We note section 552.108 does not except from disclosure “basic information about an
arrested person, an arrest, or a crime.” Gov’t Code § 552. 1 08(c). Section 552. 1 08(c) refers
to the basic information held to be public in Houston Chronicle. See 53 1 S. W.2d at 1 86-88:
see also Open Records Decision No. 127 (1976) (summarizing types of information
considered to be basic information). Accordingly, with the exception of basic information,
the city may withhold the information we have indicated under section 552. 1 08(a)( 1 ) of the
Government Code on behalf of DPS.7 As previously noted, section 552. 1 08 is discretionary
in nature and does not make information confidential under the Act. See ORDs 665 at 2
n.5, 663 at 5, 177 at 3. Thus, the city has the discretion to release all or part of the
information at issue that is not otherwise confidential by law. Gov’t Code § 552.007.
(a) Information is excepted from [required public disclosure] if it is

information relating to litigation of a civil or criminal nature to which the
state or a political subdivision is or may be a party or to which an officer or
employee of the state or a political subdivision, as a consequence of the
person’s office or employment, is or may be a party.
(c) Information relating to litigation involving a governmental body or an

officer or employee of a governmental body is excepted from disclosure
under Subsection (a) only if the litigation is pending or reasonably
anticipated on the date that the requestor applies to the officer for public
information for access to or duplication of the information.
Id. § 552.103(a), (c). A governmental body has the burden of providing relevant facts and
documents to show the section 552.103(a) exception is applicable in a particular situation.
The test for meeting this burden is a showing (1) litigation was pending or reasonably
anticipated on the date the governmental body received the request for information, and (2)
the information at issue is related to that litigation. Univ, of Tex. Law Sch. v. Tex. Legal
Found., 958 S.W.2d 479, 481 (Tex. App.—Austin 1997, orig. proceeding); Heard v.
Houston Post Co., 684 S.W.2d 210, 212 (Tex. App.— Houston [1st Dist.] 1984.
writ ref d n.r.e.); Open Records Decision No. 551 at 4 (1990). A governmental body must
meet both prongs of this test for information to be excepted under section 552. 1 03(a). See
ORD 551.
information.
The question of whether litigation is reasonably anticipated must be determined on a

case-by-case basis. See Open Records Decision No. 452 at 4 (1986). To establish litigation
is reasonably anticipated, the governmental body must furnish concrete evidence that
litigation involving a specific matter is realistically contemplated and is more than mere
conjecture. Id. Concrete evidence to support a claim that litigation is reasonably
anticipated may include, for example, the governmental body’s receipt of a letter containing
a specific threat to sue the governmental body from an attorney for a potential opposing
party. Open Records Decision No. 555 (1990); see Open Records Decision No. 518 at 5
(1989) (litigation must be "realistically contemplated”). In addition, this office has
concluded litigation was reasonably anticipated when the potential opposing party hired an
attorney who made a demand for disputed payments and threatened to sue if the payments
were not made promptly, or when an individual threatened to sue on several occasions and
hired an attorney. See Open Records Decision Nos. 346 (1982), 288 (1981). In Open
Records Decision No. 638 (1996), this office stated a governmental body has met its burden
of showing that litigation is reasonably anticipated when it received a notice of claim letter
and the governmental body represents that the notice of claim letter is in compliance with
the requirements of the Texas Tort Claims Act ("TTCA”), Civ. Prac. & Rem. Code, ch.
101. On the other hand, this office has determined if an individual publicly threatens to
bring suit against a governmental body, but does not actually take objective steps toward
filing suit, litigation is not reasonably anticipated. See Open Records Decision No. 331
( 1 982). Further, the fact that a potential opposing party has hired an attorney who makes a
request for information does not establish litigation is reasonably anticipated. See Open
Records Decision No. 361 (1983).
You assert the remaining information at issue is excepted under section 552.103 of the
Government Code. Upon review, however, we find the city has not demonstrated the
information at issue is related to pending or reasonably anticipated litigation for purposes
of section 552.103. Consequently, we conclude the city may not withhold any of the
remaining information at issue under section 552.103 of the Government Code.
Section 552.102(a) of the Government Code excepts from disclosure “information in a

personnel file, the disclosure of which would constitute a clearly unwarranted invasion of
personal privacy.”8 Gov’t Code § 552.102(a). The Texas Supreme Court has held
section 552.102(a) excepts from disclosure the dates of birth of state employees in the
payroll database of the Texas Comptroller of Public Accounts. Tex. Comptroller of Pub.
Accounts r. Attorney Gen. of Tex., 354 S.W.3d 336 (Tex. 2010). Upon review, we find the
city must withhold the dates of birth of current and former employees under section
552. 1 02(a) of the Government Code.
Section 552.101 of the Government Code excepts from disclosure “information considered
to be confidential by law, either constitutional, statutory, or by judicial decision.” Gov’t
Code § 552.101. Section 552.101 encompasses the doctrine of common-law privacy,
which protects information that is (1) highly intimate or embarrassing, the publication of
which would be highly objectionable to a reasonable person, and (2) not of legitimate
s The Office of the Attorney Genera) will raise mandatory exceptions on behalf of a governmental body, but
ordinarily will not raise other exceptions. See Open Records Decision Nos. 481 (1987), 480 (1987), 470
(1987).
concern to the public. Indus. Found, v. Tex. Indus. Accident Bd., 540 S.W.2d 668. 685
(Tex. 1976). To demonstrate the applicability of common-law privacy, both prongs of this
test must be satisfied. Id. at 681-82. Types of information considered intimate and
embarrassing by the Texas Supreme Court are delineated in Industrial Foundation. Id. at
683. Additionally, this office has concluded some kinds of medical information are
generally highly intimate or embarrassing. See Open Records Decision No. 455 (1987).
This office has also found common-law privacy generally protects the identifying
information of juvenile offenders. See Open Records Decision No. 394 (1983): cf. Fam.
Code § 58.008(b). However, this office has found the public has a legitimate public interest
in the details of a crime. See Open Records Decision No. 400 at 4 (1983). See generally
Lowe v. Hearst Communications, Inc., 487 F.3d 246, 250 (5th Cir. 2007) (noting
“legitimate public interest in facts tending to support an allegation of criminal activity*'
(citing Cinel v. Connick, 15 F.3d 1338, 1345-46 (1994)). The Third Court of Appeals has
concluded public citizens’ dates of birth are protected by common-law privacy pursuant to
section 552. 101. Paxton v. City ofDallas, No. 03-1 3-00546-CV, 20 1 5 WL 339406 1 . at *3
(Tex. App.-—Austin May 22, 2015, pet. denied) (mem. op.). We also note information
belonging to an individual who has been de-identified may not be withheld under
common-law privacy as the de-identified individual’s privacy interests are protected.
Upon review, we find some of the information at issue satisfies the standard articulated by
the Texas Supreme Court in Industrial Foundation. Accordingly, the city must withhold
the dates of birth of identifiable public citizens and the information we have marked under
section 552.101 of the Government Code in conjunction with common-law privacy.
However, the city has failed to demonstrate any of the remaining information is highly
intimate or embarrassing and of no legitimate public interest. Thus, the city may not
withhold any of the remaining information under section 552. 101 of the Government Code
in conjunction with common-law privacy.
Section 552.101 of the Government Code also encompasses the doctrine of constitutional
privacy. Constitutional privacy consists of two interrelated types of privacy: (1) the right
to make certain kinds of decisions independently and (2) an individual's interest in avoiding
disclosure of personal matters. Open Records Decision No. 455 at 4 (1987). The first type
protects an individual’s autonomy within “zones of privacy” which include matters related
to marriage, procreation, contraception, family relationships, and child rearing and
education. Id. The second type of constitutional privacy requires a balancing between the
individual’s privacy interests and the public’s need to know information of public concern.
Id. The scope of information protected is narrower than that under the common law1
doctrine of privacy; the information must concern the “most intimate aspects of human
affairs.” Id. at 5 (citing Ramie v. City of Hedwig Village. Texas, 765 F.2d 490 (5th Cir.
1985)). Upon review, we find the city has failed to demonstrate any portion of the
remaining information falls within the zones of privacy or implicates an individual's
privacy interests for purposes of constitutional privacy. Therefore, the city may not
withhold any of remaining information under section 552.1 01 on the basis of constitutional
privacy.
Section 552.1 17(a)(2) of the Government Code excepts from public disclosure the home
address, home telephone number, emergency contact information, and social security
number of a current or honorably retired peace officer, as well as information that reveals
Ms. Cynthia Trevino - Page 1 1
whether the current or honorably retired peace officer has family members, regardless of
whether the current or honorably retired peace officer complies with sections 552.024 and
552.1175 of the Government Code. See Gov’t Code §§ 552.117(a)(2), 552.003(l-b))
(defining "honorably retired*’ for purposes of the Act). We note, for purposes of section
552.1 17. "family member” means a spouse, minor child, or adult child who resides in the
person's home. See id. § 552.117(c) (providing that “family member” has meaning
assigned by Fin. Code § 31.006(d)). Section 552.117(a)(2) applies to peace officers as
defined by article 2.12 of the Code of Criminal Procedure. Section 552.1 17 also protects a
peace officer' s personal cellular telephone number if a governmental body does not pay for
the cellular telephone service. See Open Records Decision No. 670 at 6 (2001) (section
552.1 17(a)(2) excepts from disclosure peace officer’s cellular telephone or pager number
if officer pays for cellular telephone or pager service). Accordingly, the city must withhold
the information we have marked under section 552.117(a)(2) of the Government Code.9
However, the city may not withhold the cellular telephone numbers at issue under section
552. 1 1 7(a)(2) if a governmental body pays for the cellular telephone service.
Section 552.1 17(a)(1) of the Government Code excepts from disclosure the home address
and telephone number, emergency contact information, social security number, and family
member information of a current or former employee or official of a governmental body
who requests this information be kept confidential under section 552.024 of the
Government Code. See Gov't Code § 552.117(a)(1). Section 552.117 is applicable to
cellular telephone numbers, provided the cellular telephone service is not paid for by a
governmental body. See Open Records Decision No. 506 at 5-6 (1988) (statutory
predecessor to section 552.1 17 not applicable to cellular telephone numbers provided and
paid for by governmental body and intended for official use). Whether a particular item of
information is protected by section 552.117(a)(1) must be determined at the time of the
governmental body's receipt of the request for the information. See Open Records Decision
No. 530 at 5 (1989). Thus, information may be withheld under section 552.1 17(a)(1) only
on behalf of a current or former employee or official who made a request for confidentiality
under section 552.024 prior to the date of the governmental body’s receipt of the request
for the information. Accordingly, if the individuals whose information is at issue timely
requested confidentiality pursuant to section 552.024 of the Government Code, the city
must withhold the information we have marked under section 552.117(a)(1) of the
Government Code; however, the cellular telephone numbers may only be withheld if a
governmental body does not pay for the cellular telephone service.
Section 552. 1 30 of the Government Code provides information relating to a motor vehicle
operator's or driver's license, motor vehicle title or registration, or personal identification
document issued by an agency of this state or another state or country is excepted from
public release. Gov't Code § 552. 130(a). Upon review, we find the city must withhold the
motor vehicle record information we have marked under section 552.130 of the
Government Code.
Section 552.1 37 of the Government Code excepts from disclosure “an e-mail address of a
member of the public that is provided for the purpose of communicating electronically with
" As our ruling is dispositive, we need not address your remaining argument against disclosure of this
information.
a governmental body,” unless the member of the public consents to its release or the e-mail
address is of a type specifically excluded by subsection (c). Id.
§ 552.1 37(a)-(c). Section 552.137 does not apply to an institutional e-mail address, the
general e-mail address of a business, an e-mail address of a person who has a contractual
relationship with a governmental body, an e-mail address of a vendor who seeks to contract
with a governmental body, an e-mail address maintained by a governmental entity for one
of its officials or employees, or an e-mail address provided to a governmental body on a
letterhead. See id. § 552.137(c). We are unable to determine whether some of the personal
e-mail addresses at issue, which are located within e-mails communicating official business
of the city, belong to city officials or employees. Thus, we rule conditionally. To the extent
the e-mail addresses within the remaining information are the personal e-mail addresses of
city employees, or to the extent subsection (c) applies, this information is not subject to
section 552.137 of the Government Code and may not be withheld on that basis. See Austin
Bulldog v. Leffingwell, 490 S.W.3d 240 (Tex. App.—Austin 2016, no pet.) (holding
personal e-mail addresses of government officials used to conduct official government
business are not e-mail addresses of “members of the public*’ for purposes of Gov’t Code
§ 552.137(a)). However, to the extent the e-mail addresses within the remaining
information are not the personal e-mail addresses of city employees and subsection (c) does
not apply, this information is subject to section 552.137 and must be withheld under section
552.137 of the Government Code, unless the owners of the e-mail addresses affirmatively
consent to their release.
The city seeks to withhold the identifying information of police officers and city employees
under section 552. 1 52 of the Government Code. Section 552. 1 52 provides.
Information in the custody of a governmental body that relates to an

employee or officer of the governmental body is excepted from [required
public disclosure] if, under the specific circumstances pertaining to the
employee or officer, disclosure of the information would subject the
employee or officer to a substantial threat of physical harm.
Gov’t Code § 552.152. The city argues the release of some of the remaining information
would subject the officers and employees to a substantial threat of physical harm. Upon
review, we find you have failed to demonstrate release of any of the remaining information
would subject an employee or officer to a substantial risk of physical harm. Therefore, the
city may not withhold any of the remaining information under section 552. 1 52 of the
Government Code.
In summary, the TCOLE identification numbers are not subject to the Act and need not be
released to the requestors. The city may withhold the Exhibit G30 under section 552. 107( 1 )
of the Government Code. The city may withhold the information we have marked under
section 552.108(b)(1) of the Government Code. With the exception of basic information,
the city may withhold the information we have indicated under section 552. 1 08(a)( 1 ) of the
Government Code on behalf of DPS. The city must withhold the dates of birth of current
and former employees under section 552.102(a) of the Government Code. The city must
withhold the dates of birth of identifiable public citizens and the information we have
marked under section 552.101 of the Government Code in conjunction with common-law
privacy. To the extent the cellular telephone numbers at issue are not paid for by a
Ms. Cynthia Trevino - Page 1 3
governmental body, the city must withhold the information we have marked under section
552.1 17(a)(2) of the Government Code. If the individuals whose information is at issue
timely requested confidentiality pursuant to section 552.024 of the Government Code, the
city must withhold the information we have marked under section 552.1 17(a)(1) of the
Government Code; however, the cellular telephone numbers may only be withheld if a
governmental body does not pay for the cellular telephone service. The city must withhold
the motor vehicle record information we have marked under section 552.130 of the
Government Code. To the extent the e-mail addresses within the remaining information
are not the personal e-mail addresses of city employees and subsection (c) does not apply,
this information is subject to section 552.137 and must be withheld under section 552.137
of the Government Code, unless the owners of the e-mail addresses affirmatively consent
to their release. The city must release the remaining information.
This letter ruling is limited to the particular information at issue in this request and limited
to the facts as presented to us; therefore, this ruling must not be relied upon as a previous
determination regarding any other information or any other circumstances.
This ruling triggers important deadlines regarding the rights and responsibilities of the
governmental body and ofthe requestor. For more information concerning those rights and
responsibilities, please visit our website at htt s://www.texasattornev«.'eneral. .’ov/oicn-
,.o\ cDinicni mcnibcrs-niihlic?what-cxnect-after-ruling-issued or call the OAG’s Open
Government Hotline, toll free, at (877) 673-6839. Questions concerning the allowable
charges for providing public information under the Public Information Act may be directed
to the Cost Rules Administrator of the OAG, toll free, at (888) 672-6787.
Sincerely.
Kelly McWethy
Assistant Attorney General
KM/eb
Ref: ID# 963676
Line. Submitted documents
c: 160Requestors
(w/o enclosures)
EXHIBIT E
June 28, 2022
Mayor Don McLaughlin

101 E. Main Street
Uvalde, TX 78801
Dear Mayor McLaughlin:
We are a coalition of local and national media organizations that have sought to inform the
public about the horrific tragedy at Robb Elementary School. We share your commitment to
ensuring that all the facts about this incident come to light. We also share the concerns you recently
expressed regarding the limited information that has emerged so far, and your desire to present the
public with a more comprehensive portrait of the events on that day. In many ways, this is entirely
within the City’s control.
We write to make you aware of provisions in the law that allow you and other City of Uvalde
officials to release additional information to the public. The Texas Public Information Act does
not require City officials to await the conclusion of any state or federal investigation in order to
make information public. And, as you know, the members of the Uvalde community are crying
out to know what happened that day and to have complete transparency and accountability sooner
rather than later. In the words of Berlinda Irene Arreola, the grandmother of 10-year-old victim
Amerie Jo Garza: “We need to get down to the bottom of everything that has happened and find
out the truth."
The sections of the TPIA invoked by the City (552.103, 552.108), and other provisions of the
Public Information Act, simply do not mandate withholding of information about the events that
transpired that fateful day at Robb Elementary. While some of these provisions may allow the City
to temporarily withhold certain information from the public, the Act does not require the City to
do so in direct contravention to the demands of the community.
Similarly, the Texas Occupations Code, which governs the release of law enforcement body
camera footage, does not require an agency to withhold those recordings during the course of an
investigation. Section 1701.660(b) of the Occupations Code specifically states that a law
enforcement agency “may release to the public a [body camera] recording . . . if the law
enforcement agency determines that the release furthers a law enforcement purpose.” And, in fact,
recognizing the rights and needs of the public to know, such disclosure has been made during
investigations throughout the state. Recently, the Austin Police Department, the Houston Police
Department, the La Marque Police Department and the Galveston County Sheriff’s Office, among
many others, have released body camera footage of critical incidents, even as those incidents were
being investigated. In fact, law enforcement agencies across Texas routinely release body camera
footage of officer-involved shootings and other critical incidents as a matter of policy – often
within 10 days or 30 days – during ongoing investigations.
June 28, 2022
Page 2
Texas law clearly gives the City of Uvalde, the Uvalde Police Department, the Uvalde County
Sheriff’s Office, and the Uvalde County and District Attorneys the discretion to release broad
swaths of information to the public now rather than waiting an indefinite amount of time for the
closure of an investigation involving a shooter who is already dead. Many police and prosecutors
across Texas routinely release such information.
We join you in calling for a full accounting of the tragic events at Robb Elementary. The
victims and their families deserve an accurate and complete picture about what occurred that day.
We hope that this letter assists you in evaluating the needs of your community during this difficult
time and prompts immediate disclosure of information requested and needed for a community to
heal.
Sincerely,
Laura Prather
On behalf of:
ABC News Graham Media

KTRK – Houston KSAT – San Antonio
Associated Press KPRC – Houston
CBS News Gray Television
CBS Stations Group of Texas KXII – Sherman
KTVT – Dallas KGNS – Laredo
CNN KFDA – Amarillo
Cox Media Group KWTX – Waco
Dallas Morning News Hearst Newspapers
Gannett Houston Chronicle
Austin American-Statesman San Antonio Express-News
The Abilene Reporter-News NBC News
Corpus Christi Caller-Times New York Times
The El Paso Times ProPublica
San Angelo Standard-Times Scripps
Times Record News – Wichita Falls Sinclair Broadcasting
Amarillo Globe-News KABB/WOAI – San Antonio
Lubbock Avalanche-Journal KVII – Amarillo
USA Today KDBC/KFOX – El Paso
KEYE – Austin
June 28, 2022
Page 3
KBTV/KFDM – Beaumont
KTXS – Abilene
TEGNA
WFAA – Dallas
KHOU – Houston
KENS – San Antonio
KVUE – Austin
KAGS – Bryan/College Station
KCEN – Waco
KYTX – Tyler
KIII – Corpus Christi
KWES – Midland/Odessa
KBMT – Beaumont
KIDY/KXVA – San Angelo
TelevisaUnivision
KUVN – Dallas
KXLN – Houston
KAKW – Austin
KWEX – San Antonio
Texas Tribune
Wall Street Journal
EXHIBIT F
May 27, 2022
Lexi Churchill
Research Reporter
An Electronic Copy of Uvalde CISD Police Chief Pete Arredondo’s personnel records.
our request.
information.
your cooperation.
Sincerely,
Lexi Churchill
Uvalde
Consolidated Independent School District
5®
i Texas Public Information Request Form
Date:
I
Name: ~MI o/x £o 1 1 ; er

Address: I
City: State: Zip:
Phone:
Fax:
E-mail:
I request the following documents from the Uvalde Independent School District
under the Texas Public Information Act, Texas Government Code, Chapter 552.
(Please be as specific as possible.)
P(-e e pr (A/ &Q- 6 O- H

' U. I (le eV
£> t\ !$ 4-u-A^A o> zVx 4 S /I re
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Please provide the information: (circle one)
Pickup Mail Fax E-mai
Co I <
Print
Signature
Contact Person Mikka Sanchez, Administrative Assistant to Superintendent

1000 N. Getty, Uvalde, TX 78801
Phone 830-278-6655
Fax 830-591-4971
Uvalde
Consolidated Independent School District
« Texas Public Information Request Form
Date: /Vi c. 2-^, 2 (2 Z-Z

Name: to f 0/ 1 r-e r
Address:
City: State: Zip:
Phone:
Fax:
E-mail:
I request the following documents from the Uvalde Independent School District
under the Texas Public Information Act, Texas Government Code, Chapter 552.
(Please be as specific as possible.)
a i^-e ( LL
< r-
H tUe
0 I ? t-e s p<- & C /< s s
Kci 1\Z Ac
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Please provide the information: (circle one)
Pickup Mail Fax E-mail
o /1 <
Print )
Signature
Contact Person Mikka Sanchez, Administrative Assistant to Superintendent

1000 N. Getty, Uvalde, TX 78801
Phone 830-278-6655
Fax 830-591-4971
June 1, 2022
Lexi Churchill
Research Reporter
Memorandum of Agreement (MOA) documents between the Uvalde CISD Police Department
and other law enforcement agencies, including but not limited to the Department of Public
Safety, the Uvalde Sheriff’s department and Uvalde Police Department.
our request.

information.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
6/8/22, 3:45 PM Mail - Levine, Mike - Outlook
Notices of Claim / ABC News public records request

Levine, Mike < >
Fri 6/3/2022 12:36 PM
To: Anne Marie Espinoza <amespinoza1075@uvaldecisd.net>
Hello Anne Marie,
My name is Mike Levine, and I'm a reporter with ABC News. I am emailing you to submit the following
public records request...
Under the Texas Public Information Act, Tex. Gov’t Code §552.001 et seq., I am requesting copies of any
all notices of claim or other correspondence received by UCISD since May 24, 2022, that reflect
contemplated or expected legal actions against employees of UCISD or UCISD more broadly for the tragic
events on May 24 at Robb Elementary School.
The Texas Public Information Act requires that you “promptly produce” the requested records unless,
within 10 days, you have sought an Attorney General’s Opinion. If you expect a significant delay in


Mike Levine
ABC News
https://outlook.office.com/mail/id/AAQkADE3YmI3ZTNkLWYyNDktNDY5ZS05MWNlLTVhNzM3NDkwMzFhOQAQAOMTGMEMu1hFown9rRrLmX4%3D 1/1
THE
TEXAS
TRIBUNE
Fwd: Records Request
Wed, Jun 22, 2022 at 10:59 AM
Forwarded
From: James Barragan

Date: Tue, Jun 14, 2022 at 1:57 PM
Subject: Records Request
To: <webmaster@uvaldecisd.net>, Anne Marie Espinoza <amespinoza1075@uvaldecisd.net>
To whom it may concern:
Pursuant to the Texas Public Information Act, §6252-1 7a et seq. (), I hereby request access to and copies of the following items:
• Phone records, including call logs, for the cell phone operated by UCISD police chief Pete Arredondo on May 24.
Under the Texas Public Information Act, §6252-1 7a et seq. the government is allowed to charge only the cost of copying materials.
Through this request, I am gathering information on the law enforcement response to the Uvalde shooting. This information is being sought on behalf of The Texas Tribune for
dissemination to the general public.
I am requesting that you waive all applicable fees associated with this request as I believe this request is in the public interest and is not for commercial use. Release of this
information is in the public interest because it will contribute significantly to public understanding of government operations and activities. If you deny this request for a fee waiver,
please advise me in advance of the estimated charges associated with fulfilling this request. Please send me a detailed and itemized explanation of those charges.
If my request is denied in whole or part, I ask that you justify all deletions by reference to specific exemptions of the act. I will also expect you to release all segregable portions of
otherwise exempt material. I, of course, reserve the right to appeal your decision to withhold any information or to deny a waiver of fees.
In the interest of expediency, and to minimize the research and/or duplication burden on your staff, please send records electronically if possible. If this is not possible, please notify
me before sending to the address listed below. Since time is a factor, please communicate with me by telephone or by email address. I can be reached at
Please contact me if you have any questions about my request. I look forward to your response within 10 business days, as state law requires.
James Barragán
Politics Reporter
--
James Barragán
Politics Reporter
7/21/22, 5:18 PM Mail - Brown, Emma - Outlook
All <r pia XZ P cn Teams call & Q © BE
c§] Print X Cancel
Re: Uvalde CISD/Brown, Emma

(PIA 0013)
Wed 6/29/2022 5:38 PM
To: Victoria Campbell

< vcampbell@wabsa.com >
Cc: Leandra Ortiz

< lortiz@wabsa.com >;Kacey Villafuerte
< kvillafuerte@wabsa.com >;Leah
Wingerson
< lwingerson@wabsa.com > ;Aurea Arellano
<aarellano@wabsa.com >;Endelia Diaz
<ediaz@wabsa.com>;Patricia Alejo
< palejo@wabsa.com >;Roxanna Ortiz
< rortiz@wabsa.com >
Ms. Campbell, thank you for your reply.

I would like to limit my request to
only district devices and emails.
Please let me know if you have any
further questions.
Emma
From: Victoria Campbell
<vcampbell@wabsa.com>
Sent: Tuesday, June 28, 2022 5:22 PM
To: Brown, Emma
Cc: Leandra Ortiz <lortiz@wabsa.com>;
Kacey Villafuerte <kvillafuerte@wabsa.com>;
Leah Wingerson <lwingerson@wabsa.com>;
Aurea Arellano <aarellano@wabsa.com>;
Endelia Diaz <ediaz@wabsa.com>; Patricia
Alejo <palejo@wabsa.com>; Roxanna Ortiz
<rortiz@wabsa.com>
Subject: Uvalde CISD/Brown, Emma (PIA
0013)
| CAUTION; EXTERNAL SENDER |

Good afternoon Ms. Brown,
In connection with the above-referenced

matter, attached please find
correspondence from attorney, Kacey M.
Villafuerte, for your review on behalf of
the District.
Should you have any questions or

concerns, please feel free to contact the
office.
Cordially,
\KG
VICTORIA CAMPRFLL
https://outlook.office.com/mail/id/AAQkADU2MzE3OTImLWZmYjEtNDZmZi05ZTdjLWM3MzRiMDFhZTgwNAAQALVHbDIQ8085qttSf6S83b8%3D 1/1
June 27, 2022
Lexi Churchill
Research Reporter
Electronic Copies of all communications sent to and sent from each of the following
Uvalde CISD employees from May 27 to June 27, 2022:
● Pedro M. Arredondo, CISD Chief of Police
● Mike Hernandez, CISD Detective
● Ruben Ruiz, CISD Police officer
● Ruby Gonzalez, CISD Police officer
● Adrian Gonzalez, CISD Police officer
● John H. Harrell Jr., Superintendent
● Michael Rodriguez, Deputy Superintendent
● Ann Marie Espinoza, Executive Director of Communications and Marketing
● Mandy Moreno Gutuierrez, Robb Elementary Principal
“All communications” should include but are not limited to:

● Emails (this should include all attachments and email responses)
● Text messages
● Voicemail recordings
● Electronic messages sent of platforms including but not limited to Slack,
Microsoft Teams, Facebook, Instagram, Twitter, Whats app, Signal
● Call logs or call history
● Call recordings
● Zoom recordings
● Zoom chats
● Recordings in the voice memos app
● Meeting recordings
● Handwritten notes
This should include communications from both professional, as well as personal

devices and accounts when used for government purposes as defined by 552.002 (a).
If possible, please exclude all subscription or listserv emails.
our request.

information.
your cooperation.
Sincerely,
Lexi Churchill
June 27, 2022
Lexi Churchill
Research Reporter
Electronic copies of all video footage taken by cameras on the inside and on the
outside of the Robb Elementary School property (715 Old Carrizo Rd, Uvalde, TX
78801) from 11:00 a.m. to midnight central standard time on May 24, 2022.
our request.

information.
your cooperation.
Sincerely,
Lexi Churchill
June 29, 2022
Lexi Churchill
Research Reporter
Copies of all 911, transmission and radio traffic audio related to calls to Robb Elementary
School (715 Old Carrizo Rd, Uvalde, TX 78801) on May 24, 2022.
our request.
information.
your cooperation.
Sincerely,
Lexi Churchill
June 29, 2022
Lexi Churchill
Research Reporter
Copies of all incident and corresponding reports related to calls made to Robb
Elementary School (715 Old Carrizo Rd, Uvalde, TX 78801) on May 24, 2022.
(j) the identification and description of the complainant;
(l) the time of occurrence of the crime;
our request.

information.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
EXHIBIT G
WALSH GALLEGOS
WG TREVINO KYLE & ROBINSON P.C.
July 7, 2022
P.O. Box 12548
Austin, TX 78711
Via CMRRR: 7019 2280 0001 1039 7071
Re: Request for Public Information Determination; Uvalde Consolidated

Independent School District
This law firm represents the Uvalde Consolidated Independent School District (the “District”),
and on its behalf, on June 28, 2022, we requested authorization to withhold information the District
believes is excepted from disclosure under the Public Information Act (the “Act”), chapter 552 of
the Government Code. The District received a request for public information on May 26, 2022, for
records showing what UCISD police department personnel were on duty on May 24, 2022 along
with their location and duty assignment J The District does not have responsive information
relating to the requests for footage from security cameras or dash or body camera footage. The
10th and 15th business days from the date of receipt of the request are June 28, 2022, and July 7,
2022, respectively.2
This letter sets forth the reasons we are seeking to withhold the information requested under
the Act. This letter is being sent to your office within 15 District Business days of the District
receiving the request for information. A copy of the requested information is included for your
review and consideration and is Bates-stamped |' The Requestor was advised
4
by way of separate letter of our seeking this opinion from your office.
1 See Exhibit 1 : Public Information Request.

2 See Exhibit 2: District Summer Schedule and Public Information Act Catastrophe Exemption Period. Please note
that the District was closed on May 30, 2022, for Memorial Day and July 4, 2022, in observance of Independence
Day. The District submitted a Catastrophe Notice and Catastrophe Notice Extension to your office pursuant to
section 552.2325 of the Government Code to be effective from June 5, 2022, to June 18, 2022, suspending its Public
Information Act deadlines for a total of 14 days. Please further note that the District was closed on June 3, 2022,
June 24, 2022, and July 1, 2022, because the District is closed on Fridays during the summer.
3 See Exhibit 3 : Information at Issue.
4 See Exhibit 4: Letter to Requestor.
6770 W. Expressway 83, Suite 301, Harlingen, Texas 78552 I MAIL: P.O. Box 532146, Harlingen, Texas 78553
T: 956.647.5122 | F: 956.647.5421 | www.WalshGallegos.com

July 7, 2022
Argument Letter (15-Day)
PIA 0024
The District’s Position
The District maintains the information responsive to the request is confidential and exempt
from disclosure under state law. The responsive documents being submitted to your office for
review are attached as Exhibit 3 and are numbered
A. Information Responsive to the Request Is Information Relating to Certain Law

Enforcement, Corrections and Prosecutorial Information protected under § 552.108
as Confidential.
The District contends that the documents attached are protected from disclosure under
section 552.108 of the Texas Government Code, which provides, in pertinent part:
(a) Information held by a law enforcement agency or prosecutor that deals with the
detection, investigation, or prosecution of crime is excepted from the requirements
of Section 552.021 if:

investigation, or prosecution of crimef.]
(c) This section does not except from the requirements of Section 552.021
information that is basic information about an arrested person, an arrest, or a crime.
Gov’t Code § 552.108(a)(1), (c).
Section 552.108 (b)(1) of the Government Code intended to protect “information which, if
released, would permit private citizens to anticipate weaknesses in a police department, avoid
detection, jeopardize officer safety, and generally undermine police efforts to effectuate the laws
of this State. ” See City ofFt. Worth v. Cornyn, 86 S.W.3d 320 (Tex. App.—Austin 2002, no writ).
To demonstrate the applicability of section 552.108, a governmental body must meet its burden of
explaining how and why release of the requested information would interfere with law
enforcement and crime prevention. Open Records Decision No. 562 at 10 (1990). This office has
5 See Exhibit 5: Correspondence with Law Enforcement Agencies.

July 7, 2022
PIA 0024
concluded section 552.108(b) excepts from public disclosure information relating to the security
or operation of a law enforcement agency. See, e.g., Open Records Decision Nos. 531 (1989)
(release of detailed use of force guidelines would unduly interfere with law enforcement), 456 at
2 (1987) (release of forms containing information regarding when and where off-duty police
officers will be working would unduly interfere with law enforcement), 252 (1980) (section
552.108 is designed to protect investigative techniques and procedures used in law enforcement),
143 (1976) (disclosure of specific operations or specialized equipment directly related to
investigation or detection of crime may be excepted).
B. Section 552.103: Litigation or Settlement Negotiations Involving the State or Political

Subdivision
Section 552.103 of the Government Code provides, in relevant part:
(a) Information is excepted from [required public disclosure] if it is information relating to

litigation of a civil or criminal nature to which the state or a political subdivision is or may
be a party or to which an officer or employee of the state or a political subdivision, as a
consequence of the person’s office or employment, is or may be a party.
(c) Information relating to litigation involving a governmental body or an officer or

employee of a governmental body is excepted from disclosure under Subsection (a) only if
the litigation is pending or reasonably anticipated on the date that the requestor applies to
the officer for public information for access to or duplication of the information.
Gov’t Code § 552.103(a), (c).
A governmental body has the burden of providing relevant facts and documents to show the
section 552. 103(a) exception is applicable in aparticular situation. The test for meeting this burden
is a showing that (1) litigation was pending or reasonably anticipated on the date the governmental
body received the request for information, and (2) the information at issue is related to that
litigation. See University ofTex. Law Sch. v. Tex. Legal Found. ,958S.W. 2d479, 481 (Tex. App.—
Austin 1997, no pet.); Heard v. Houston Post Co., 684 S.W.2d 210, 212 (Tex. App.—Houston [1st
Dist.] 1984, writ refd n.r.e.); Open Records Decision No. 551 at 4 (1990). A governmental body
July 7, 2022
PIA 0024
must meet both prongs of this test for information to be excepted under section 552.103(a). Your
office has previously determined that a governmental body need only establish the relatedness of
the information to the subject matter of the pending or anticipated litigation. Open Records
DecisionNo. 51 at 5 (1990).
Conclusion
Based upon the above exceptions, I hereby request, on behalf of the District, a Public
Information Act determination. The District is submitting with this Request a copy of the Public
Information Act request, the entirety of the information requested, and this written justification
pursuant to Section 552.301 of the Texas Government Code. The District reserves the right to
supplement this request as permitted by state law, if necessary.7
Sincere?
Kdc rafuerte
Enclosures: as stated
cc: (w/o enclosures)
Dr. John “Hal” Harrell, Superintendentfor Uvalde CISD

Ms. Beth Reavis, Assistant Superintendentfor Uvalde CISD
Mr. Joshua Eaton, Requestor
6 See Exhibit 6: Letters from Attorneys.

7 See Tex. Gov't Code Ann. 552.301(e).
July 11, 2022
Via Office of the Attorney General’s eFiling System

P.O. Box 12548
Austin, TX 78711
Re: Request for Public Information Determination; Uvalde Consolidated Independent School
District
This law firm represents the Uvalde Consolidated Independent School District (the “District”), and on
its behalf, on June 28, 2022, we requested authorization to withhold information the District believes is
excepted from disclosure under the Public Information Act (the “Act”), chapter 552 of the Government
Code. The District received a request for public information on May 27, 2022, for arrest reports, probable
cause affidavits, and page one reports for a specified time frame .1 The District does not have responsive
documents for the other requested information. The 10th and 15th business days from the date of receipt
of the request are June 29, 2022, and July 11, 2022, respectively.2
This letter sets forth the reasons we are seeking to withhold the information requested under the Act.
This letter is being sent to your office within 15 District Business days of the District receiving the
request for information. Because the responsive information is voluminous, the District has attached a
representative sample of the requested information and is Bates-stamped .3 The
Requestor was advised by way of separate letter of our seeking this opinion from your office.4
1 See Exhibit 1: Public Information Request.

June 24, 2022, July 1, 2022 and July 8, 2022 because the District is closed on Fridays during the summer.
3 See Exhibit 3: Information at Issue.
6770 West Expressway 83, Suite 301, Harlingen, TX 78552 | MAIL: P.O. Box 532146, Harlingen, TX 78553-2146
June 5, 2015
Page 2 of 6
The District maintains the information responsive to the request is confidential and exempt from
disclosure under state law. The responsive documents being submitted to your office for review are
attached as Exhibit 3 and are numbered .
A. Information Responsive to the Request Is Information Relating to Certain Law Enforcement,

Corrections and Prosecutorial Information protected under § 552.108 as Confidential.
The District contends that the documents attached as Exhibit 3 are protected from disclosure under
detection, investigation, or prosecution of crime is excepted from the requirements of
Section 552.021 if:
(1) release of the information would interfere with the detection, investigation, or
prosecution of crime[.]
...
(c) This section does not except from the requirements of Section 552.021 information that
is basic information about an arrested person, an arrest, or a crime.
Gov’t Code § 552.108(a)(1), (c).

Subdivision
(a) Information is excepted from [required public disclosure] if it is information relating to litigation
of a civil or criminal nature to which the state or a political subdivision is or may be a party or to

June 5, 2015
Page 3 of 6
which an officer or employee of the state or a political subdivision, as a consequence of the person’s
office or employment, is or may be a party.
...
(c) Information relating to litigation involving a governmental body or an officer or employee of a

governmental body is excepted from disclosure under Subsection (a) only if the litigation is pending
or reasonably anticipated on the date that the requestor applies to the officer for public information
for access to or duplication of the information.
Gov’t Code § 552.103(a), (c).
A governmental body has the burden of providing relevant facts and documents to show the section
552.103(a) exception is applicable in a particular situation. The test for meeting this burden is a showing
that (1) litigation was pending or reasonably anticipated on the date the governmental body received the
request for information, and (2) the information at issue is related to that litigation. See University of Tex.
Law Sch. v. Tex. Legal Found., 958 S.W.2d 479, 481 (Tex. App.—Austin 1997, no pet.); Heard v. Houston
Post Co., 684 S.W.2d 210, 212 (Tex. App.—Houston [1st Dist.] 1984, writ ref’d n.r.e.); Open Records
Decision No. 551 at 4 (1990). A governmental body must meet both prongs of this test for information to
be excepted under section 552.103(a). Your office has previously determined that a governmental body
need only establish the relatedness of the information to the subject matter of the pending or anticipated
litigation. Open Records Decision No. 51 at 5 (1990).
C. Section 552.101: Information Confidential by Section 58.007 of the Family Code

Section 551.101 of the Government Code excepts from public disclosure “information to considered to
be confidential by law, either constitutional, statutory, or by judicial decision.” Gov’t Code § 552.101.
Section 552.101 encompasses information protected by other statutes. Juvenile law enforcement records
relating to conduct that occurred on or after September 1, 1997, are confidential under section 58.007 of
the Family Code. For purposes of section 58.007, “child” means a person is ten years of age or older and
under seventeen years of age See Fam. Code § 51.02(2). The relevant language of section 58.007 reads as
follows:

June 5, 2015
Page 4 of 6
(c) Except as provided by Subsection (d), law enforcement records and files concerning a child and
information stored, by electronic means or otherwise, concerning the child from which a record or file could
be generated may not be disclosed to the public and shall be:
(1) if maintained on paper or microfilm, kept separate from adult files and records;
(2) if maintained electronically in the same computer system as records or files relating to adults, be
accessible under controls that are separate and distinct from controls to access electronic data concerning
adults; and
(3) maintained on a local basis only and not sent to a central state or federal depository, except as
provided by Subchapters B, D, and E.
...
(e) Law enforcement records and files concerning a child may be inspected or copied by a juvenile
justice agency as that term is defined by Section 58.101, a criminal justice agency as that term is defined
by Section 411.082, Government Code, the child, and the child's parent or guardian. Fam. Code § 58.007(c),
(e).
D. Section 552.101: Information Protected by Section 261.201 of the Family Code
Section 552.101 of the Government Code excepts from disclosure "information considered to be
confidential by law, either constitutional, statutory, or by judicial decision." Gov't Code § 552.101. This
section encompasses information protected by other statutes, such as section 261.201 of the Family Code,
which provides, in relevant part:
(a) [T]he following information is confidential, is not subject to public release under [the Act], and may be
disclosed only for purposes consistent with this code and applicable federal or state law or under rules
adopted by an investigating agency:
(1) a report of alleged or suspected abuse or neglect made under this chapter and the identity of the person
making the report; and
(2) except as otherwise provided in this section, the files, reports, records, communications, audiotapes,
videotapes, and working papers used or developed in an investigation under this chapter or in providing
services as a result of an investigation. Fam. Code § 261.201(a).
June 5, 2015
Page 5 of 6
E. Section 552.1315: Confidentiality of Certain Crime Victim Records
The 87th Legislature enacted section 552.1315 of the Government Code, which provides, in pertinent
part, as follows:
(a) Information is confidential and excepted from the requirements of Section of 552.021 if the
information identifies an individual as
…
(2) Any victim of any criminal offense, if the victim was younger than 18 years of age when any
element of the offense was committed.
Gov’t Code § 552.1315(a)(2)
F. Section 552.101: Information Protected by Common-Law Right to Privacy
Section 552.101 of the Government Code excepts from disclosure “information considered to be
confidential by law, either constitutional, statutory, or by judicial decision.” Gov’t Code
§ 552.101. This section encompasses the doctrine of common-law privacy. Indus. Found. v. Tex. Indus.
Accident Bd., 540 S.W.2d 668, 685 (Tex. 1976). Under the doctrine of common-law privacy, an individual
has a right to be free from the publicizing of private affairs in which the public has no legitimate concern.
Id. at 682. The Third Court of Appeals has concluded public citizens’ dates of birth are protected by
common-law privacy pursuant to section 552.101. See Paxton v. City of Dallas, No. 03-13-00546-CV, 2015
WL 3394061, at *3 (Tex. App—Austin May 22, 2015, pet. denied) (mem. op.). The submitted information
contains a private citizen’s date of birth. Thus, the District asserts the dates of birth in the submitted
information should be withheld under section 552.101 of the Government Code in conjunction with
common-law privacy.
In Industrial Foundation, the Texas Supreme Court stated information is excepted from disclosure if
(1) the information contains highly intimate or embarrassing facts, the release of which would be highly
objectionable to a reasonable person, and (2) the information is not of legitimate concern to the public. 540
S.W.2d at 685. To demonstrate the applicability of common-law privacy, both prongs of this test must be
demonstrated. See id. at 681-82. The type of information considered intimate and embarrassing by the Texas
Supreme Court in Industrial Foundation included information relating to sexual assault, pregnancy, mental
or physical abuse in the workplace, illegitimate children, psychiatric treatment of mental disorders,
attempted suicide, and injuries to sexual organs. Id. at 683.
June 5, 2015
Page 6 of 6
Conclusion
Based upon the above exceptions, I hereby request, on behalf of the District, a Public Information
Act determination. The District is submitting with this Request a copy of the Public Information Act
request, the entirety of the information requested, and this written justification pursuant to Section 552.301
of the Texas Government Code. The District reserves the right to supplement this request as permitted by
state law, if necessary.7
Sincerely,
WALSH GALLEGOS TREVIÑO

KYLE & ROBINSON P.C.
Kacey Villafuerte
Kacey M. Villafuerte
Enclosures as stated
cc: (w/out enclosures)
Dr. John “Hal” Harrell, Superintendent for Uvalde CISD

Ms. Beth Reavis, Assistant Superintendent for Uvalde CISD
Ms. Tina Macias
5718 Westheimer Rd
Houston, Texas 77057
7
See TEX. GOV’T CODE ANN. 552.301(e).
July 13, 2022

P.O. Box 12548
Austin, TX 78711
District
its behalf, on July 5, 2022, we requested authorization to withhold information the District believes is
Code. The District received a request for public information on June 1, 2022, for the personnel file of a
specified employee.1 The 10th and 15th business days from the date of receipt of the request are July 5,
2022, and July 13, 2022, respectively.2
This letter is being sent to your office within 15 District Business days of the District receiving the request
for information. A copy of the requested information is included for your review and consideration and is
Bates-stamped .3 The Requestor was advised by way of separate letter of our seeking
this opinion from your office.4
disclosure under state law. The responsive documents being submitted to your office for review are attached
as Exhibit 3 and are numbered .
1
See Exhibit 1: Public Information Request.
2
See Exhibit 2: District Summer Schedule and Public Information Act Catastrophe Exemption Period. Please note
3
See Exhibit 3: Information at Issue.
4
See Exhibit 4: Letter to Requestor.
Hon. Ken Paxton
July 13, 2022
PIA #0060
Page 2 of 5

as Confidential.
The District contends that the documents attached are protected from disclosure under

investigation, or prosecution of crime[.]
...
Gov’t Code § 552.108(a)(1), (c).

Subdivision

...
5
See Exhibit 5: Correspondence with Law Enforcement Agencies.
Hon. Ken Paxton
July 13, 2022
PIA #0060
Page 3 of 5

Gov’t Code § 552.103(a), (c).
section 552.103(a) exception is applicable in a particular situation. The test for meeting this burden
litigation. See University of Tex. Law Sch. v. Tex. Legal Found., 958 S.W.2d 479, 481 (Tex. App.—
Dist.] 1984, writ ref’d n.r.e.); Open Records Decision No. 551 at 4 (1990). A governmental body
Decision No. 51 at 5 (1990).
C. 552.130: Confidentiality of Certain Motor Vehicle Records
In the event you determine the submitted information may not be withheld in its entirety
under section 552.108 or section 552.103, the District will withhold motor vehicle record
information contained in the submitted information in accordance with section 552.130 of the
Government Code.
D. Section 552.101: Information Protected by Common-Law Right to Privacy or

Constitutional Right to Privacy

Hon. Ken Paxton
July 13, 2022
PIA #0060
Page 4 of 5
In addition, and to the extent documents contain information regarding privacy issues the
District would argue that such information is protected under the common law right to privacy in
conjunction with Section 552.101 of the Texas Government Code. This Office has previously
recognized the protection of certain information under the common law right to privacy in
conjunction with 552.101, which excepts from disclosure information considered to be
confidential by law, either constitutional, statutory or by judicial decision. This section
encompasses the doctrine of the common-law right of privacy. Under this theory, information
should be withheld if it contains highly embarrassing facts, the publication of which would be
highly objectionable to a reasonable person, and is not of a legitimate concern to the public.
Industrial Foundation of the South v. Texas Industrial Accident Board, 540 S.W.2d 668 (Tex.
1976). As a public entity, a public school district is required to ensure that is does not violate an
individual’s liberty interest; that is, the District must not release information that would stigmatize
to the point of burdening an employee with a “badge of infamy.” See Wells v. HICO ISD, 736
F.2d 243, 256, n. 16 (5th Cir. 1984) app. dism’d, 106 S.Ct. 11 (1985).
E. Section 552.136: Confidentiality of Credit Card, Debit Card, Charge Card and Access
Device Numbers.
(a) In this section, “access device” means a card, plate, code, account number, personal
identification number, electronic serial number, mobile identification number, or
other telecommunications service, equipment, or instrument identifier or means of
account access that alone or in conjunction with another access device may be used
to:
(1) obtain money, goods, services, or another thing of value; or
(2) initiate a transfer of funds other than a transfer originated solely by paper
instrument.
(b) Notwithstanding any other provision of this chapter, a credit card, debit card, charge
card, or access device number that is collected, assembled, or maintained by or for a
governmental body is confidential.
The District asserts that the documents submitted marked under Section 552.136 contains
information excepted from disclosure under the Act. The District therefore requests that the submitted
information be withheld.
F. Section 552.117: Confidentiality of Certain Addresses, Telephone Numbers, Social

Security Numbers, and Personal Family Information
Section 552.117 1(a) excepts from disclosure the home addresses, telephone numbers, emergency
contact information, social security number, and family member information of a current or former
employee or official of a governmental body who requests this information be kept confidential under
section 552.024 of the Government Code. Gov't Code § 552.117(a)(1).
Hon. Ken Paxton
July 13, 2022
PIA #0060
Page 5 of 5
The District asserts that a portion of the submitted information marked under section 552.117 are
confidential. The District therefore requests that the submitted information be withheld.
Conclusion
Sincerely,
Kacey Villafuerte
cc: Without enclosures:
Mike Baker, Requestor, via email

620 Eighth Avenue
New York, NY 10018
Dr. John “Hal” Harrell, Superintendent for Uvalde CISD, via email
Ms. Beth Reavis, Assistant Superintendent for Uvalde CISD, via email
7
July 13, 2022

P.O. Box 12548
Austin, TX 78711
District
its behalf, on July 5, 2022, we requested authorization to withhold information the District believes is
Code. The District received a request for public information on June 1, 2022, for maintenance records for
a specified District campus.1 The 10th and 15th business days from the date of receipt of the request are
July 5, 2022, and July 13, 2022, respectively.2
This letter is being sent to your office within 15 District Business days of the District receiving the request
for information. A copy of the requested information is included for your review and consideration and is
Bates-stamped .3 The Requestor was advised by way of separate letter of our seeking
this opinion from your office.4
disclosure under state law. The responsive documents being submitted to your office for review are attached
as Exhibit 3 and are numbered .
1
See Exhibit 1: Public Information Request.
2
See Exhibit 2: District Summer Schedule and Public Information Act Catastrophe Exemption Period. Please note
3
See Exhibit 3: Information at Issue.
4
See Exhibit 4: Letter to Requestor.
Hon. Ken Paxton
July 13, 2022
PIA #0061
Page 2 of 4

as Confidential.
The District contends that the documents attached are protected from disclosure under section
552.108 of the Texas Government Code, which provides, in pertinent part:

...
Gov’t Code § 552.108(a)(1), (c).

Subdivision

...
5
Hon. Ken Paxton
July 13, 2022
PIA #0061
Page 3 of 4

Gov’t Code § 552.103(a), (c).
section 552.103(a) exception is applicable in a particular situation. The test for meeting this burden
litigation. See University of Tex. Law Sch. v. Tex. Legal Found., 958 S.W.2d 479, 481 (Tex. App.—
Dist.] 1984, writ ref’d n.r.e.); Open Records Decision No. 551 at 4 (1990). A governmental body
Decision No. 51 at 5 (1990).
Conclusion

7
Hon. Ken Paxton
July 13, 2022
PIA #0061
Page 4 of 4
Sincerely,
Kacey Villafuerte
cc: Without enclosures:
Mike Baker, Requestor, via email

620 Eighth Avenue
New York, NY 10018
Dr. John “Hal” Harrell, Superintendent for Uvalde CISD, via email
Ms. Beth Reavis, Assistant Superintendent for Uvalde CISD, via email
August 4, 2022

P.O. Box 12548
Austin, TX 78711
Re: Request for Public Information Determination; Uvalde Consolidated Independent

School District
This law firm represents the Uvalde Consolidated Independent School District (the “District”), and
on its behalf, on July 27, 2022, this firm requested authorization to withhold information the
District believes is excepted from disclosure under the Public Information Act (the “Act”), chapter
552 of the Government Code. The District received a request for public information on June 20,
2022, and received clarification of that request on July 14, 2022, for specified maintenance request
and/or work order information.1 The 10th and 15th business days from the date of receipt of the
request are August 2, 2022, and August 9, 2022, respectively.2
The District seeks to withhold the requested information under sections 552.103 and 552.108 of
the Government Code. We have included the information at issue for your review.
The District contends the requested information is protected from disclosure under section 552.103
of the Government Code, which provides, in relevant part:
1
See Exhibit 1: Public information request and clarification. Please note that although the District sent its request for
clarification to the requestor via email on July 7, 2022, the District received a delivery failure message because the
email address to which the request for clarification was sent was not a valid email address. As such, this firm
contacted the requestor via telephone regarding the matter and sent the request for clarification to the requestor again
on July 14, 2022, via a valid email address provided by the requestor.
2
See Exhibit 2: District Summer Schedule and Public Information Act Catastrophe Exemption Period Notices. The
District was closed on June 24, 2022, July 1, 2022, July 8, 2022, July 15, 2022, July 22, 2022, and July 29, 2022,
because the District was closed on Fridays during the summer. Additionally, the District submitted a Catastrophe
Notice and Catastrophe Notice Extension to your office pursuant to section 552.2325 of the Government Code to
cover the time period from June 5, 2022, to June 18, 2022, suspending its Public Information Act deadlines for a
total of 14 days. Furthermore, the District was closed on July 4, 2022, in observance of Independence Day.
Crestview Towers, 105 Decker Court, Suite 700, Irving, TX 75062 | MAIL: P.O. Box 168046, Irving, TX 75016-8046
August 4, 2022
Page 2 of 4
(PIA 0082)

...

Gov’t Code § 552.103(a), (c). A governmental body has the burden of providing relevant facts and
documents to show the section 552.103(a) exception is applicable in a particular situation. The test
for meeting this burden is a showing that (1) litigation was pending or reasonably anticipated on
the date the governmental body received the request for information, and (2) the information at
issue is related to that litigation. See University of Tex. Law Sch. v. Tex. Legal Found., 958 S.W.2d
479, 481 (Tex. App.—Austin 1997, no pet.); Heard v. Houston Post Co., 684 S.W.2d 210, 212
(Tex. App.—Houston [1st Dist.] 1984, writ ref’d n.r.e.); Open Records Decision No. 551 at 4
(1990). A governmental body must meet both prongs of this test for information to be excepted
under section 552.103(a). Your office has previously determined that a governmental body need
only establish the relatedness of the information to the subject matter of the pending or anticipated
On June 1, 2022, the District received correspondence from attorneys consisting of letters of
representation and demands to preserve and protect information related to the shooting incident
that occurred on May 24, 2022, at Robb Elementary School, one of the District’s schools.3 Thus,
the District reasonably anticipates litigation and has reasonably anticipated such litigation since
June 1, 2022. The clarified request for information was received by the District on July 14, 2022,
and seeks information pertaining to requests to repair or service exterior school building doors at
Robb Elementary School. The question of whether and which exterior doors at Robb Elementary
School were fully functional at the time of the May 24, 2022, incident is a significant issue
surrounding the events that took place during the incident. As such, the requested information
relates to the anticipated litigation. Therefore, the District asserts the information submitted as
Exhibit 3 may be withheld under section 552.103(a) of the Government Code because the District
reasonably anticipated litigation at the time the request for information was received and the
requested information is related to the anticipated litigation.
The District also asserts the requested information is protected from disclosure under section
3
See Exhibit 4: Letters from Attorneys.
August 4, 2022
Page 3 of 4
(PIA 0082)

...
Gov’t Code § 552.108(a)(1), (c).
The District has confirmed that the Texas Department of Public Safety Rangers, Federal Bureau
of Investigation, and 38th Judicial District Attorney’s office are all conducting criminal
investigations of the incident that occurred on May 24, 2022, at Robb Elementary School. The
District is actively cooperating with the ongoing criminal investigations and has received
objections from the investigating law enforcement agencies that release of the requested
information will interfere with the ongoing criminal investigations.4 The District, therefore,
contends that the information submitted as Exhibit 3 should be withheld under Section 552.108 of
the Government Code.
By copy of this letter, the District hereby provides notice to the requestor of this communication
to your office asking for a decision under the Public Information Act, as provided by Government
Code section 552.301.
If you have any questions or require additional information, please feel free to contact me.
Sincerely,
Leah Wingerson
4
August 4, 2022
Page 4 of 4
(PIA 0082)
Enclosures
cc: Tina Macias, Requestor, w/o enclosures via email tmacias@khou.com and
tmmacias@gmail.com
KHOU – CBS 11
5718 Westheimer Rd.
Dr. John “Hal” Harrell, Superintendent, Uvalde CISD, w/o enclosures

Ms. Beth Reavis, Assistant Superintendent, Uvalde CISD, w/o enclosures
August 16, 2022

P.O. Box 12548
Austin, TX 78711

School District
on its behalf, on August 9, 2022, this firm requested authorization to withhold information the
552 of the Government Code. The District received a request for public information on July 26,
2022, for specified work order records.1 The 10th and 15th business days from the date of receipt
of the request are August 10, 2022, and August 17, 2022, respectively.2
the Government Code. We have included the information at issue for your review.3

...
1
See Exhibit 1: Public information request.
2
See Exhibit 2: District Summer Schedule. The District was closed on July 29, 2022, because the District was closed
on Fridays during the summer.
3
See Exhibit 3: Information at issue.
August 16, 2022
Page 2 of 3
(PIA 0150)

June 1, 2022. The request for information was received by the District on July 26, 2022, and seeks
information pertaining to maintenance requests for the classrooms at Robb Elementary School
involved in the May 24, 2022, incident. As such, the requested information relates to the
anticipated litigation. Therefore, the District asserts the information submitted as Exhibit 3 may be
withheld under section 552.103(a) of the Government Code because the District reasonably
anticipated litigation at the time the request for information was received and the requested
information is related to the anticipated litigation.
The District also asserts the information at issue is protected from disclosure under section 552.108
of the Texas Government Code, which provides, in pertinent part:

...
4
August 16, 2022
Page 3 of 3
(PIA 0150)
Gov’t Code § 552.108(a)(1), (c).
Sincerely,
Leah Wingerson
Enclosures
cc: France Robles, w/o enclosures via email frances.robles@nytimes.com

The New York Times
9 Gerome Ave.
Key West, Florida 33040

5
August 16, 2022

P.O. Box 12548
Austin, TX 78711

School District
2022, for certain maintenance records at a specified campus.1 The 10th and 15th business days from
the date of receipt of the request are August 10, 2022, and August 17, 2022, respectively.2
The District seeks to withhold the requested information under sections 552.103, and 552.108 of
the Government Code. We have included the information at issue for your review.3
The District contends the submitted information is protected from disclosure under section 552.103

...

1
See Exhibit 1: Public information request.
2
See Exhibit 2: District Summer Schedule. The District was closed on July 29, 2022 because the District is closed on
Fridays during summer.
3
See Exhibit 3: Information at issue.
August 16, 2022
Page 2 of 3
(PIA 0149)
The District also asserts the submitted information is protected from disclosure under section

...
4
August 16, 2022
Page 3 of 3
(PIA 0149)
Gov’t Code § 552.108(a)(1), (c).
Sincerely,
Enclosures
cc: Frances Robles, Requestor, w/o enclosures via email frances.robles@nytimes.com

9 Gerome Avenue
Dr. John “Hal” Harrell, Superintendent, Uvalde CISD, w/o enclosures, via email
Ms. Beth Reavis, Assistant Superintendent, Uvalde CISD, w/o enclosures, via email
5
August 18, 2022

P.O. Box 12548
Austin, TX 78711

School District
2022, and a clarification of that request on July 27, 2022, for information related to doors at a
specified campus.1 The 10th and 15th business days from the date of receipt of the request are
August 11, 2022, and August 18, 2022, respectively. 2
the Government Code. We have included a representative sample of the information at issue for
your review.3

...
1
See Exhibit 1: Public information request and clarification.
2
See Exhibit 2: District Summer Schedule. The District was closed on July 29, 2022, because the District was closed
on Fridays during the summer.
3
See Exhibit 3: Representative sample of information at issue.
August 18, 2022
Page 2 of 3
(PIA 0151)

June 1, 2022. The request for information was received by the District on July 27, 2022, and seeks
information pertaining to the security of doors at Robb Elementary School during the May 24,
2022, incident. The question of whether and which doors at Robb Elementary School were
securely closed and/or locked at the time of the May 24, 2022, incident is a significant issue
surrounding the events that took place during the incident. As such, the requested information
relates to the anticipated litigation. Therefore, the District asserts the information submitted as
Exhibit 3 may be withheld under section 552.103(a) of the Government Code because the District
reasonably anticipated litigation at the time the request for information was received and the
requested information is related to the anticipated litigation.
The District also asserts the information at issue is protected from disclosure under section 552.108
of the Texas Government Code, which provides, in pertinent part:

4
August 18, 2022
Page 3 of 3
(PIA 0151)
...
Gov’t Code § 552.108(a)(1), (c).
Sincerely,
Leah Wingerson
Enclosures
cc: Frances Robles, w/o enclosures via email frances.robles@nytimes.com

The New York Times
9 Gerome Ave.

5
EXHIBIT H
July 29, 2022

P.O. Box 12548
Re: Public Information Requests received by the Uvalde Consolidated Independent School
Districts regarding events at Robb Elementary School in Uvalde, Texas, on May 24, 2022.

Public Information Requests (the “Requests”) served upon the Uvalde Consolidated Independent
School District (the “District”) beginning on May 25, 2022. These Requests sought information
related to the killing of 19 students and 2 teachers at Robb Elementary School in Uvalde, Texas,
on May 24, 2022.
The Requestors include the Texas Tribune, Texas Public Radio, ABC News (via affiliate KTRK),
CNN, Graham Media Group (via affiliate KSAT), Pro Publica, TEGNA (via affiliates KVUE,
KHOU, and KENS), and the Washington Post.
On July 11, 2022, the District submitted a letter to the Attorney General asserting its belief that
the District may withhold responsive records pursuant to Tex. Gov’t. Code §§ 552.101, 552.103,
552.1315, and 552.108, along with sections of the Family Code. See Exh. A.
As your office is aware, many Public Information Act requests related to the Uvalde tragedy are
pending. Rather than reiterate all the arguments made in prior briefings to your office regarding
these materials, Requestors adopt by reference their previous briefing submitted in support of
release of similar materials, as contained in the enclosed briefing. See Exh. B.
Specifically, Requestors call your attention to the portions of that briefing that address § 552.108
(pp. 2–7), § 552.101 (pp. 7–8), and § 552.103 (pp. 8–9).
Page 2
Sincerely,
Laura Prather
on behalf of:
ABC News Hearst Newspapers

KTRK – Houston Houston Chronicle
Associated Press San Antonio Express-News
CBS News NBC News
CBS Stations Group of Texas NBC Owned Television Stations
KTVT – Dallas KXAS – Dallas-Fort Worth
CNN Newsy
Cox Media Group The New York Times Company
The Dallas Morning News Pro Publica, Inc.
Dow Jones & Co. TEGNA
The E.W. Scripps Company WFAA – Dallas
Gannett KHOU – Houston
Austin American-Statesman KENS – San Antonio
The Abilene Reporter-News KVUE – Austin
Corpus Christi Caller-Times KAGS – Bryan/College Station
The El Paso Times KCEN – Waco
San Angelo Standard-Times KYTX – Tyler
Times Record News – Wichita Falls KIII – Corpus Christi
Amarillo Globe-News KWES – Midland/Odessa
Lubbock Avalanche-Journal KBMT – Beaumont
USA Today KIDY/KXVA – San Angelo
Graham Media TelevisaUnivision
KSAT – San Antonio KUVN – Dallas
KPRC – Houston KXLN – Houston
Gray Television KAKW – Austin
KXII – Sherman KWEX – San Antonio
KGNS – Laredo Texas Public Radio
KFDA – Amarillo Texas Tribune
KWTX – Waco The Washington Post
EXHIBIT A
July 11, 2022

P.O. Box 12548
Austin, TX 78711
District
its behalf, on June 28, 2022, we requested authorization to withhold information the District believes is
Code. The District received a request for public information on May 27, 2022, for arrest reports, probable
cause affidavits, and page one reports for a specified time frame .1 The District does not have responsive
documents for the other requested information. The 10th and 15th business days from the date of receipt
of the request are June 29, 2022, and July 11, 2022, respectively.2
This letter is being sent to your office within 15 District Business days of the District receiving the
request for information. Because the responsive information is voluminous, the District has attached a
representative sample of the requested information and is Bates-stamped .3 The
Requestor was advised by way of separate letter of our seeking this opinion from your office.4
1 See Exhibit 1: Public Information Request.

3 See Exhibit 3: Information at Issue.
June 5, 2015
Page 2 of 6
disclosure under state law. The responsive documents being submitted to your office for review are
attached as Exhibit 3 and are numbered .
A. Information Responsive to the Request Is Information Relating to Certain Law Enforcement,

Corrections and Prosecutorial Information protected under § 552.108 as Confidential.
The District contends that the documents attached as Exhibit 3 are protected from disclosure under
detection, investigation, or prosecution of crime is excepted from the requirements of
Section 552.021 if:
(1) release of the information would interfere with the detection, investigation, or
prosecution of crime[.]
...
(c) This section does not except from the requirements of Section 552.021 information that
is basic information about an arrested person, an arrest, or a crime.
Gov’t Code § 552.108(a)(1), (c).

Subdivision
(a) Information is excepted from [required public disclosure] if it is information relating to litigation
of a civil or criminal nature to which the state or a political subdivision is or may be a party or to

June 5, 2015
Page 3 of 6
which an officer or employee of the state or a political subdivision, as a consequence of the person’s
office or employment, is or may be a party.
...
(c) Information relating to litigation involving a governmental body or an officer or employee of a

governmental body is excepted from disclosure under Subsection (a) only if the litigation is pending
or reasonably anticipated on the date that the requestor applies to the officer for public information
for access to or duplication of the information.
Gov’t Code § 552.103(a), (c).
A governmental body has the burden of providing relevant facts and documents to show the section
552.103(a) exception is applicable in a particular situation. The test for meeting this burden is a showing
that (1) litigation was pending or reasonably anticipated on the date the governmental body received the
request for information, and (2) the information at issue is related to that litigation. See University of Tex.
Law Sch. v. Tex. Legal Found., 958 S.W.2d 479, 481 (Tex. App.—Austin 1997, no pet.); Heard v. Houston
Post Co., 684 S.W.2d 210, 212 (Tex. App.—Houston [1st Dist.] 1984, writ ref’d n.r.e.); Open Records
Decision No. 551 at 4 (1990). A governmental body must meet both prongs of this test for information to
be excepted under section 552.103(a). Your office has previously determined that a governmental body
need only establish the relatedness of the information to the subject matter of the pending or anticipated
C. Section 552.101: Information Confidential by Section 58.007 of the Family Code

Section 551.101 of the Government Code excepts from public disclosure “information to considered to
be confidential by law, either constitutional, statutory, or by judicial decision.” Gov’t Code § 552.101.
Section 552.101 encompasses information protected by other statutes. Juvenile law enforcement records
relating to conduct that occurred on or after September 1, 1997, are confidential under section 58.007 of
the Family Code. For purposes of section 58.007, “child” means a person is ten years of age or older and
under seventeen years of age See Fam. Code § 51.02(2). The relevant language of section 58.007 reads as
follows:

June 5, 2015
Page 4 of 6
(c) Except as provided by Subsection (d), law enforcement records and files concerning a child and
information stored, by electronic means or otherwise, concerning the child from which a record or file could
be generated may not be disclosed to the public and shall be:
(1) if maintained on paper or microfilm, kept separate from adult files and records;
(2) if maintained electronically in the same computer system as records or files relating to adults, be
accessible under controls that are separate and distinct from controls to access electronic data concerning
adults; and
(3) maintained on a local basis only and not sent to a central state or federal depository, except as
provided by Subchapters B, D, and E.
...
(e) Law enforcement records and files concerning a child may be inspected or copied by a juvenile
justice agency as that term is defined by Section 58.101, a criminal justice agency as that term is defined
by Section 411.082, Government Code, the child, and the child's parent or guardian. Fam. Code § 58.007(c),
(e).
D. Section 552.101: Information Protected by Section 261.201 of the Family Code
Section 552.101 of the Government Code excepts from disclosure "information considered to be
confidential by law, either constitutional, statutory, or by judicial decision." Gov't Code § 552.101. This
section encompasses information protected by other statutes, such as section 261.201 of the Family Code,
which provides, in relevant part:
(a) [T]he following information is confidential, is not subject to public release under [the Act], and may be
disclosed only for purposes consistent with this code and applicable federal or state law or under rules
adopted by an investigating agency:
(1) a report of alleged or suspected abuse or neglect made under this chapter and the identity of the person
making the report; and
(2) except as otherwise provided in this section, the files, reports, records, communications, audiotapes,
videotapes, and working papers used or developed in an investigation under this chapter or in providing
services as a result of an investigation. Fam. Code § 261.201(a).
June 5, 2015
Page 5 of 6
E. Section 552.1315: Confidentiality of Certain Crime Victim Records
The 87th Legislature enacted section 552.1315 of the Government Code, which provides, in pertinent
part, as follows:
(a) Information is confidential and excepted from the requirements of Section of 552.021 if the
information identifies an individual as
…
(2) Any victim of any criminal offense, if the victim was younger than 18 years of age when any
element of the offense was committed.
Gov’t Code § 552.1315(a)(2)
F. Section 552.101: Information Protected by Common-Law Right to Privacy
Section 552.101 of the Government Code excepts from disclosure “information considered to be
confidential by law, either constitutional, statutory, or by judicial decision.” Gov’t Code
§ 552.101. This section encompasses the doctrine of common-law privacy. Indus. Found. v. Tex. Indus.
Accident Bd., 540 S.W.2d 668, 685 (Tex. 1976). Under the doctrine of common-law privacy, an individual
has a right to be free from the publicizing of private affairs in which the public has no legitimate concern.
Id. at 682. The Third Court of Appeals has concluded public citizens’ dates of birth are protected by
common-law privacy pursuant to section 552.101. See Paxton v. City of Dallas, No. 03-13-00546-CV, 2015
WL 3394061, at *3 (Tex. App—Austin May 22, 2015, pet. denied) (mem. op.). The submitted information
contains a private citizen’s date of birth. Thus, the District asserts the dates of birth in the submitted
information should be withheld under section 552.101 of the Government Code in conjunction with
common-law privacy.
In Industrial Foundation, the Texas Supreme Court stated information is excepted from disclosure if
(1) the information contains highly intimate or embarrassing facts, the release of which would be highly
objectionable to a reasonable person, and (2) the information is not of legitimate concern to the public. 540
S.W.2d at 685. To demonstrate the applicability of common-law privacy, both prongs of this test must be
demonstrated. See id. at 681-82. The type of information considered intimate and embarrassing by the Texas
Supreme Court in Industrial Foundation included information relating to sexual assault, pregnancy, mental
or physical abuse in the workplace, illegitimate children, psychiatric treatment of mental disorders,
attempted suicide, and injuries to sexual organs. Id. at 683.
June 5, 2015
Page 6 of 6
Conclusion
Based upon the above exceptions, I hereby request, on behalf of the District, a Public Information
Act determination. The District is submitting with this Request a copy of the Public Information Act
request, the entirety of the information requested, and this written justification pursuant to Section 552.301
of the Texas Government Code. The District reserves the right to supplement this request as permitted by
state law, if necessary.7
Sincerely,
WALSH GALLEGOS TREVIÑO

KYLE & ROBINSON P.C.
Kacey Villafuerte
Enclosures as stated
cc: (w/out enclosures)
Dr. John “Hal” Harrell, Superintendent for Uvalde CISD

Ms. Beth Reavis, Assistant Superintendent for Uvalde CISD
Ms. Tina Macias
5718 Westheimer Rd
7
EXHIBIT B
July 12, 2022

P.O. Box 12548
-004, -014, -016, -005, -006, -018, -007, -008, -009, -010, -011, -013, -015, -017, -019,
-020, -021, -022, -023, -024, -025, -136, -028, -030, -031, -033, -034, -036, -037, -039,
-042, -043, -044, -046, -047, -142, -048, -049, -052, -055, -057, -058, -059, -060, -138,
-067, -075, -077, -093, -080, -083, -086, -088, - 089, -090, -091, -095, 096, -098, -099,
-100, -101, -102, -103, -132, -105, -107, -110, -112, -113, -111, -115, -116, -119, -122,
-126, -130)

officers,
1
2
Page 2
school; and
552.103, 552.107, 552.108, 552.1175, 552.130, 552.136, and 552.152. See Exh. B.
Section 552.108
(1986).
3
Page 3
4
Page 4
5
Page 5
6
7
8
9
Page 6
10

Page 7
Section 552.101
records
11
Page 8
Acc. Bd., 540 S.W.2d 668, 685 (Tex. 1976).
Page 9
1701.661(a).
Ramos”).
Page 10

individual:

Page 11
numbers.
Page 12
such a showing.

Conclusion
Sincerely,
Laura Lee Prather

On behalf of:

Page 13

Pro Publica, Inc.
Scripps
EXHIBIT I
COPY
Sheriff Ruben Nolasco
From: Joyce
To: ssanchez@uvaldetx.gov
Cc: drodriguez@uvaldetx.gov; Swaine, Jon; sheriff@uvaldecounty.com
Subject: Public records request related to Uvalde shooting
Hello,
My name is Joyce Lee, and I am a reporter with The Washington Posts Visual Forensics team. I'm writing to request the
following:
1. Any and all 911 calls made between 11 a.m. - 4 p.m. to the Uvalde Police Department and the Uvalde Sheriff's
Department
2. Any and all body camera video and dash camera video belonging to officers from the police department and
sheriff's department who responded to the shooting at Robb Elementary School
3. Any audio communications or radio traffic between law enforcement officers in the hours of 10 a.m. - 6 p.m.
related to the incident
I can be reached at if its easier to stay in touch over phone.
Many, many thanks in advance during this difficult time,
Joyce Sohyun Lee

The Washington Post
1
o
UVALDE COUNTY SHERIFF’S OFFICE
o<
,0
June 16, 2022
The Washington Post

Attn: Joyce Lee
Email:
RE: Records Request
Dear Mrs. Lee,
Please be advised, the Uvalde County Sheriff s Office submitted a request for an opinion with
the Texas Attorney General on June 16, 2022, pursuant to Texas Government Code, Section
552.108. A part, portion or all of the information outlined in your request is excepted from
public disclosure under applicable law.
Your public records search for dash camera footage yielded no records found. The Uvalde
County Sheriff s Office does not maintain the 911 Dispatch Call Log Records or Audio
Recordings outlined in your request. Please contact the Uvalde Police Department.
Your request will be considered when a ruling is received from the Texas Attorney General.
If you require additional assistance, please call (830) 278-4111 ext. 203. Your patience and
understanding is appreciated. Thank you.
Sincerely,
Rovey Ramos, Records Clerk

Uvalde County Sheriffs Office
339 King Fisher Lane, Box 1 • Uvalde, Texas 78801 • Phone (830) 278-41 1 1 • Fax (830) 278-2986 • sheriff&uvaldecounty.com
®l)ctoasljingtan|Jost
MS
May 26, 2022
sheriff@uvaldecounty.com
Re: EXPEDITED FOIA Request for emails and text messages under the
Texas Public Information Act (Tex. Gov’t Code § 552)
Dear Information Officer:
I am so sorry for what you and your community have endured this week.
I am a representative of the Washington Post, a news media organization

primarily engaged in the dissemination of information that is urgency
needed to inform the public of actual or alleged government activity, so
please process this request in an expedited manner.
Pursuant to Texas Public Information Act (Tex. Gov’t Code § 552), I hereby
request the following:
All emails and text messages sent to orfrom SheriffRuben Nolasco between
11 a.m. on May 24, 2022 and 11 a.m. on May 26, 2022.
If you regard these documents as potentially exempt from the public record
act’s disclosure requirements, I request that you nonetheless exercise your
discretion to disclose them. As required, please release all segrcgable, non
exempt portions of documents, preferably via email to
To permit me to reach an intelligent and informed decision whether to

contest any denied material, please describe any withheld records (or
portions thereof) and cite the legal justification for any exemption claims,
as required by Texas law.
While I am aware that you may be entitled to charge some reasonable fees
to process this request, I hereby request that you waive all such fees. Waiver
of fees is in the public interest because the furnishing of the information
sought by this request will primarily benefit the public and is likely to
contribute significantly to public understanding of the operations or
activities of the government. If, however, you decide not to waive fees and
expect them to exceed $100, please advise me as to the estimated cost of
fulfilling the request (including copying charges).
I look forward to hearing your prompt response to my request, as required

by Texas law.
Sincerely,
Emma Brown
Q
UVALDE COUNTY SHERIFF’S OFFICE
Us
June 16, 2022
The Washington Post

Attn: Emma Brown
Email:
RE: Records Request
Dear Mrs. Brown,
Please be advised, the Uvalde County Sheriff s Office submitted a request for an opinion with
the Texas Attorney General on June 16, 2022, pursuant to Texas Government Code, Section
552.108. A part, portion or all of the information outlined in your request is excepted from
public disclosure under applicable law.
Your Request will be considered when a ruling is received from the Texas Attorney General.
Ifyou require additional assistance, please call (830) 278-4111 ext. 203. Your patience and
understanding is appreciated. Thank you.
Sincerely,
Rovey Ramos, Records Clerk

339 King Fisher Lane, Box 1 • Uvalde, Texas 78801 • Phone (830) 278-41 1 1 • Fax (830) 278-2986 • sheriff@uvaldccounty.com
May 27, 2022
Lexi Churchill
Research Reporter
Copies of all car and unit camera footage taken by Uvalde Sheriff’s officers during
calls to Robb Elementary School (715 Old Carrizo Rd, Uvalde, TX 78801) on May 24,
2022.
our request.

information.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
June 1, 2022
Lexi Churchill
Research Reporter
Memorandum of Agreement (MOA) documents between the Uvalde Sheriff’s office and other
law enforcement agencies, including but not limited to the Department of Public Safety, the
Uvalde Police department and Uvalde CISD Police.
our request.

information.
your cooperation.
Sincerely,
Lexi Churchill
Research Reporter
June 27, 2022
Lexi Churchill
Research Reporter
Electronic copies of all evidence logs and or other documents that account for
evidence collected related to the school shooting at Robb Elementary (715 Old
our request.

information.
your cooperation.
Sincerely,
Lexi Churchill
EXHIBIT J
Uvalde County
Please be advised that due to

the high volume of record
requests received, the Uvalde
County Sheriff's Office filed one
request for an opinion to the
of Texas that covers numerous
records requests. Not all the
exemptions outlined in the
request for an opinion may
apply to your submitted
records request.
339 King Fisher Lane, Uvalde Texas 78801 · (830) 278-4111 Office · (830) 278-2986 Fax · sheriff@uvaldecounty.com
Uvalde Count
:: 701 -C-
June 16, 2022

Via Certified Mail # 7016060000000256108-1
The Honorable Attorney General Ken Paxton

Office of the Attorney General of the State of Texas
Attention: Open Records Division
P.O . Box 12548
Re : Request for Open Records Decision

Public Information requests for records related to the May 24, 2022 Mass Shooting at Robb
Elementary School in Uvalde, Texas.
The Uvalde County Sheriffs Office received the above referenced requests for information from
multiple requestors on May 25, 2022, May 26, 2022, May 27, 2022, May 30, 2022, May 31, 2022,
June 1, 2022, June 2, 2022, June 3, 2022, June 6, 2022, and on June 8, 2022
. On May 30, 2022, our offices closed in observance of Memorial Day.
Therefore, we believe this request for a ruling on disclosure is timely made in accordance with
section 552.301 of the Government Code . The Uvalde County Sheriffs Office filed a Catastrophe
Notice on June 6, 2022 and an extension on June 13 , 2022 online to the Texas Attorney General.
We believe the requested information is excepted from required public disclosure pursuant to
section 55 2. 108( a) ( !) and 552. 108(b) (l) of the Government Code. Accordingly, we are
requesting a ruling regarding the release of these records
339 King Fisher lane, Uvalde Texas 78801 · (830) 278-4111 Office · (830) 278-2986 Fax · shenff@uvaldecounty.com
Law Enforcement Exception - Ongoing Investigation
The Texas Rangers are conducting an investigation into the May 24, 2022 shooting at Robb
Elementary in Uvalde, Texas . We believe the requested information is excepted from required
public disclosure pursuant to section 552 . l 08(a)(l) of the Government Code, which states :
detection, investigation, or prosecution of crime is excepted from the
( l) Release of the information would interfere with the detection, investigation,
or prosecution of crime.
(3) It is information relating to a threat against a peace officer or detention
officer collected or disseminated under Section 411.048; or
Because this is an ongoing investigation, the release of potential evidence would interfere with the
investigation and prosecution of this case. See Houston Chronicle Pub! 'g Co. v. City of Houston,
531 S.W.2d 177, 184-85 (Tex. Civ. App.-Houston [14th Dist.) 1975), writ ref'd n.r.e., 536
S.W.2d 559 (Tex. 1976) (per curium).·
Law Enforcement Exception - lnternal Record of Law Enforcement _
We believe the requested records are excepted from required public disclosure pursuant to section
552 .108(b)(l) of the Government Code, which states :

is maintained for internal use in matters relating to law enforcement or
prosecution is excepted from the requirements of Section 552 .021 if:
(I) Release of the internal record or notation would interfere with law
enforcement or prosecution.
Section 552 .108(b )( l) is intended to protect "information which, if released, would permit private
citizens to anticipate weaknesses in [a law enforcement agency], avoid detection, jeopardize
officer safety, and generally undermine [law enforcement] efforts to effectuate the laws of this
State." City of Ft. Worth v. Cornyn, 86 S.W.3d 320 (Tex. App.-Austin 2002, no pet.). Your
office has stated that under the statutory predecessor to section 552 . l 08(b ), a governmental body
may withhold information that would reveal law enforcement techniques or procedures. See. e.g. ,
Open Records Decision Nos . 531 ( 1989) (release of detailed use of force guidelines would unduly
interfere with law enforcement), 456 ( 1987) (release of forms containing information regarding
location of off-duty police officers in advance would unduly interfere with law enforcement), 413
(1984) (release of sketch showing security measures to be used at next execution would unduly
interfere with law enforcement), 409 (1984) (if information regarding certain burglaries exhibit a
pattern that reveals investigative techniques, information is excepted under predecessor to section
552 .108), 341 ( 1982) (release of certain information from the Texas Department of Public Safety
would unduly interfere with law enforcement because release would hamper departmental efforts
to detect forgeries of drivers' licenses), 252 (1980) (predecessor to section 552.108 is designed to
protect investigative techniques and procedures used in law enforcement), 143 ( 1976) (disclosure
of specific operations or specialized equipment directly related to investigation or detection of
crime maybe excepted).
552.111 - Use for Certain Emails involving internal discussions
Section 552 . l l l states that "[a]n interagency or intraagency memorandum or letter that would not
be available by law to a party in litigation with the agency is excepted from the requirements of
Section 552.02 l." Section 552 . 111 encompasses the deliberative process privilege. See Open
Records Decision No. 615 at 2 ( 1993 ). The purpose of this exception is to protect advice, opinion,
and recommendation in the decisional process and to encourage open and frank discussion in the
deliberative process. See Austin v. City of San Antonio, 630 S. W.2d 391, 394 ~
~ - proceeding) : Open Records Decision No . 538 at 1-2 (1990). -
411.084 - Use for Criminal History
Criminal history record information (CHRI) is confidential under section 4 l l .084(a) of the
Government Code. We do not believe the requestor is authorized to obtain the requested criminal
history record information so we believe the records are excepted from disclosure under section
Through formal decisions, the attorney general developed
the "special circumstances" test under common-law privacy to withhold certain information from
disclosure .367 "Special circumstances" refers to a very narrow set of situations in which the
release of information would likely cause someone to face "an imminent threat of hysical
danger."368
Section 552.109: Confidentiality of Certain Private Communications of an Elected Office

Holder
Section 552.109 of the Government Code excepts from required public disclosure :
Private correspondence or communications of an elected office holder relating to matters the
disclosure of which would constitute an invasion of privacy are excepted from the requirements of
Section 552.021.
Section 552.117: Confidentiality of Certain ~ one Numbers, Social Security

Numbers, and Personal Family Information~
The 87th Legislature passed five different bills, Senate Bills 56, 841 and 1134 and House Bills
1082 and 3607, amending section 552 .117 of the Government Code. Section 552 .117 excepts from
required public disclosure:
(a) Information that relates to the home address, home telephone number, emergency contact
information, or social security number of the following person or that reveals whether
the person has family members:
( 1) A current or former official or employee of a governmental body, except as
otherwise provided by Section 552 .024;
(4) A peace officer as defined by Article 2.12, Code of Criminal Procedure, or other
law, a reserve law enforcement officer, a commissioned deputy game warden,
or a corrections officer in a municipal, county, or state penal institution in this
state who was killed in the line of duty, regardless of whether the deceased
complied with Section 552 .024 or 552 .1175;
( 12) A current or former district attorney, criminal district attorney, or county or
municipal attorney whose jurisdiction includes any criminal law or child
protective services matters , regardless of whether the current or former attorney
complies with Section 552.024 or 552 .1175 ;
Informer's Privilege
As interpreted by the attorney general, section 552 . l Ol of the Government Code incorporates the
" informer's privilege." In Roviaro v. United States,3 79 the United States Supreme Court explained
the rationale underlying the informer's privilege :
The informer's privilege protects not only the informer's identity, but also any portion of the
informer's statement that might tend to reveal the informer's identity.383 Of course, protecting an
informer's identity and any identifying information under the informer's privilege serves no
purpose if the accused already knows the informer's identity. The attorney general has held that
the informer's privilege does not apply in such a situation.384
The informer's privilege facet of section 552. l O1 of the Government Code serves to protect the
flow of information to a governmental body; it does not serve to protect a third person.385 Thus,
because it exists to protect the governmental body's interest, this privilege, unlike other section
552 . l Ol claims, may be waived by the governmental body.386
Section 552.102: Confidentiality of Certain Personnel Information

Section 552 . l 02 of the Government Code provides as follows :
(a) Information is excepted from [ required public disclosure) if it is information in a personnel
file , the disclosure of which would constitute a clearly unwa1nnted invasion of personal
privacy, except that all information in the personnel file of an employee of a governmental
body is to be made available to that employee or the employee 's designated representative
as public information is made available under this chapter. The exception to public
disclosure created by this subsection is in addition to any exception created by Section
552 .024. Public access to personnel information covered by Section 552 .024 is denied to
the extent provided by that section.
A notice of our request fo r a ruling was sent to each requestor; please find enclosed copies of the
received requests, and a representative sample of the responsive records we wish to except from
required disclosure. Please feel free to contact me at (830) 278-41 l l ext. 203 if you have any
additional questions .
Sincerely,
4:14imot
Rovey Ramos , Records Clerk
EXHIBIT K
July 29, 2022

P.O. Box 12548
Re: Public Information Requests received by the Uvalde County Sheriff’s Office regarding
events at Robb Elementary School in Uvalde, Texas, on May 24, 2022.

Public Information Requests (the “Requests”) served upon the Uvalde County Sheriff’s Office (the
“Sheriff’s Office”) beginning on May 25, 2022. These Requests sought information related to the
killing of 19 students and 2 teachers at Robb Elementary School in Uvalde, Texas, on May 24,
2022.
The Requestors include the Texas Tribune, Texas Public Radio, the Dallas Morning News, ABC
News (via affiliate KTRK), CBS, CNN, Graham Media Group (via affiliate KSAT), Pro Publica,
TEGNA (via affiliate KHOU), and the Washington Post.
On June 16, 2022, the Sheriff’s Office submitted a letter to the Attorney General asserting its belief
that the Sheriff’s Office may withhold responsive records pursuant to Tex. Gov’t. Code
§§ 552.108, 552.111, 441.084, 552.109, 552.117, and 552.102. See Exh. A.
As your office is aware, many Public Information Act requests related to the Uvalde tragedy are
pending. Rather than reiterate all the arguments made in prior briefings to your office regarding
these materials, Requestors adopt by reference their previous briefing submitted in support of
release of similar materials, as contained in the enclosed briefing. See Exh. B.
Specifically, Requestors call your attention to the portions of that briefing that address § 552.108
(pp. 2–7), and § 552.101 (pp. 7–8).
July 28, 2022
Page 2
Sincerely,
Laura Prather
on behalf of:
ABC News Hearst Newspapers

KTRK – Houston Houston Chronicle
Associated Press San Antonio Express-News
CBS News NBC News
CBS Stations Group of Texas NBC Owned Television Stations
KTVT – Dallas KXAS – Dallas-Fort Worth
CNN Newsy
Cox Media Group The New York Times Company
The Dallas Morning News Pro Publica, Inc.
Dow Jones & Co. TEGNA
The E.W. Scripps Company WFAA – Dallas
Gannett KHOU – Houston
Austin American-Statesman KENS – San Antonio
The Abilene Reporter-News KVUE – Austin
Corpus Christi Caller-Times KAGS – Bryan/College Station
The El Paso Times KCEN – Waco
San Angelo Standard-Times KYTX – Tyler
Times Record News – Wichita Falls KIII – Corpus Christi
Amarillo Globe-News KWES – Midland/Odessa
Lubbock Avalanche-Journal KBMT – Beaumont
USA Today KIDY/KXVA – San Angelo
Graham Media TelevisaUnivision
KSAT – San Antonio KUVN – Dallas
KPRC – Houston KXLN – Houston
Gray Television KAKW – Austin
KXII – Sherman KWEX – San Antonio
KGNS – Laredo Texas Public Radio
KFDA – Amarillo Texas Tribune
KWTX – Waco The Washington Post
EXHIBIT A
Uvalde County
Please be advised that due to

the high volume of record
requests received, the Uvalde
County Sheriff's Office filed one
request for an opinion to the
of Texas that covers numerous
records requests. Not all the
exemptions outlined in the
request for an opinion may
apply to your submitted
records request.
339 King Fisher Lane, Uvalde Texas 78801 · (830) 278-4111 Office · (830) 278-2986 Fax · sheriff@uvaldecounty.com
Uvalde Count
:: 701 -C-
June 16, 2022

Via Certified Mail # 7016060000000256108-1
The Honorable Attorney General Ken Paxton

Office of the Attorney General of the State of Texas
Attention: Open Records Division
P.O . Box 12548
Re : Request for Open Records Decision

Public Information requests for records related to the May 24, 2022 Mass Shooting at Robb
Elementary School in Uvalde, Texas.
The Uvalde County Sheriffs Office received the above referenced requests for information from
multiple requestors on May 25, 2022, May 26, 2022, May 27, 2022, May 30, 2022, May 31, 2022,
June 1, 2022, June 2, 2022, June 3, 2022, June 6, 2022, and on June 8, 2022
. On May 30, 2022, our offices closed in observance of Memorial Day.
Therefore, we believe this request for a ruling on disclosure is timely made in accordance with
section 552.301 of the Government Code . The Uvalde County Sheriffs Office filed a Catastrophe
Notice on June 6, 2022 and an extension on June 13 , 2022 online to the Texas Attorney General.
We believe the requested information is excepted from required public disclosure pursuant to
section 55 2. 108( a) ( !) and 552. 108(b) (l) of the Government Code. Accordingly, we are
requesting a ruling regarding the release of these records
339 King Fisher lane, Uvalde Texas 78801 · (830) 278-4111 Office · (830) 278-2986 Fax · shenff@uvaldecounty.com
Law Enforcement Exception - Ongoing Investigation
The Texas Rangers are conducting an investigation into the May 24, 2022 shooting at Robb
Elementary in Uvalde, Texas . We believe the requested information is excepted from required
public disclosure pursuant to section 552 . l 08(a)(l) of the Government Code, which states :
detection, investigation, or prosecution of crime is excepted from the
( l) Release of the information would interfere with the detection, investigation,
or prosecution of crime.
(3) It is information relating to a threat against a peace officer or detention
officer collected or disseminated under Section 411.048; or
Because this is an ongoing investigation, the release of potential evidence would interfere with the
investigation and prosecution of this case. See Houston Chronicle Pub! 'g Co. v. City of Houston,
531 S.W.2d 177, 184-85 (Tex. Civ. App.-Houston [14th Dist.) 1975), writ ref'd n.r.e., 536
S.W.2d 559 (Tex. 1976) (per curium).·
Law Enforcement Exception - lnternal Record of Law Enforcement _
We believe the requested records are excepted from required public disclosure pursuant to section
552 .108(b)(l) of the Government Code, which states :

is maintained for internal use in matters relating to law enforcement or
prosecution is excepted from the requirements of Section 552 .021 if:
(I) Release of the internal record or notation would interfere with law
enforcement or prosecution.
Section 552 .108(b )( l) is intended to protect "information which, if released, would permit private
citizens to anticipate weaknesses in [a law enforcement agency], avoid detection, jeopardize
officer safety, and generally undermine [law enforcement] efforts to effectuate the laws of this
State." City of Ft. Worth v. Cornyn, 86 S.W.3d 320 (Tex. App.-Austin 2002, no pet.). Your
office has stated that under the statutory predecessor to section 552 . l 08(b ), a governmental body
may withhold information that would reveal law enforcement techniques or procedures. See. e.g. ,
Open Records Decision Nos . 531 ( 1989) (release of detailed use of force guidelines would unduly
interfere with law enforcement), 456 ( 1987) (release of forms containing information regarding
location of off-duty police officers in advance would unduly interfere with law enforcement), 413
(1984) (release of sketch showing security measures to be used at next execution would unduly
interfere with law enforcement), 409 (1984) (if information regarding certain burglaries exhibit a
pattern that reveals investigative techniques, information is excepted under predecessor to section
552 .108), 341 ( 1982) (release of certain information from the Texas Department of Public Safety
would unduly interfere with law enforcement because release would hamper departmental efforts
to detect forgeries of drivers' licenses), 252 (1980) (predecessor to section 552.108 is designed to
protect investigative techniques and procedures used in law enforcement), 143 ( 1976) (disclosure
of specific operations or specialized equipment directly related to investigation or detection of
crime maybe excepted).
552.111 - Use for Certain Emails involving internal discussions
Section 552 . l l l states that "[a]n interagency or intraagency memorandum or letter that would not
be available by law to a party in litigation with the agency is excepted from the requirements of
Section 552.02 l." Section 552 . 111 encompasses the deliberative process privilege. See Open
Records Decision No. 615 at 2 ( 1993 ). The purpose of this exception is to protect advice, opinion,
and recommendation in the decisional process and to encourage open and frank discussion in the
deliberative process. See Austin v. City of San Antonio, 630 S. W.2d 391, 394 ~
~ - proceeding) : Open Records Decision No . 538 at 1-2 (1990). -
411.084 - Use for Criminal History
Criminal history record information (CHRI) is confidential under section 4 l l .084(a) of the
Government Code. We do not believe the requestor is authorized to obtain the requested criminal
history record information so we believe the records are excepted from disclosure under section
Through formal decisions, the attorney general developed
the "special circumstances" test under common-law privacy to withhold certain information from
disclosure .367 "Special circumstances" refers to a very narrow set of situations in which the
release of information would likely cause someone to face "an imminent threat of hysical
danger."368
Section 552.109: Confidentiality of Certain Private Communications of an Elected Office

Holder
Section 552.109 of the Government Code excepts from required public disclosure :
Private correspondence or communications of an elected office holder relating to matters the
disclosure of which would constitute an invasion of privacy are excepted from the requirements of
Section 552.021.
Section 552.117: Confidentiality of Certain ~ one Numbers, Social Security

Numbers, and Personal Family Information~
The 87th Legislature passed five different bills, Senate Bills 56, 841 and 1134 and House Bills
1082 and 3607, amending section 552 .117 of the Government Code. Section 552 .117 excepts from
required public disclosure:
(a) Information that relates to the home address, home telephone number, emergency contact
information, or social security number of the following person or that reveals whether
the person has family members:
( 1) A current or former official or employee of a governmental body, except as
otherwise provided by Section 552 .024;
(4) A peace officer as defined by Article 2.12, Code of Criminal Procedure, or other
law, a reserve law enforcement officer, a commissioned deputy game warden,
or a corrections officer in a municipal, county, or state penal institution in this
state who was killed in the line of duty, regardless of whether the deceased
complied with Section 552 .024 or 552 .1175;
( 12) A current or former district attorney, criminal district attorney, or county or
municipal attorney whose jurisdiction includes any criminal law or child
protective services matters , regardless of whether the current or former attorney
complies with Section 552.024 or 552 .1175 ;
Informer's Privilege
As interpreted by the attorney general, section 552 . l Ol of the Government Code incorporates the
" informer's privilege." In Roviaro v. United States,3 79 the United States Supreme Court explained
the rationale underlying the informer's privilege :
The informer's privilege protects not only the informer's identity, but also any portion of the
informer's statement that might tend to reveal the informer's identity.383 Of course, protecting an
informer's identity and any identifying information under the informer's privilege serves no
purpose if the accused already knows the informer's identity. The attorney general has held that
the informer's privilege does not apply in such a situation.384
The informer's privilege facet of section 552. l O1 of the Government Code serves to protect the
flow of information to a governmental body; it does not serve to protect a third person.385 Thus,
because it exists to protect the governmental body's interest, this privilege, unlike other section
552 . l Ol claims, may be waived by the governmental body.386
Section 552.102: Confidentiality of Certain Personnel Information

Section 552 . l 02 of the Government Code provides as follows :
(a) Information is excepted from [ required public disclosure) if it is information in a personnel
file , the disclosure of which would constitute a clearly unwa1nnted invasion of personal
privacy, except that all information in the personnel file of an employee of a governmental
body is to be made available to that employee or the employee 's designated representative
as public information is made available under this chapter. The exception to public
disclosure created by this subsection is in addition to any exception created by Section
552 .024. Public access to personnel information covered by Section 552 .024 is denied to
the extent provided by that section.
A notice of our request fo r a ruling was sent to each requestor; please find enclosed copies of the
received requests, and a representative sample of the responsive records we wish to except from
required disclosure. Please feel free to contact me at (830) 278-41 l l ext. 203 if you have any
additional questions .
Sincerely,
4:14imot
Rovey Ramos , Records Clerk
EXHIBIT B
July 12, 2022

P.O. Box 12548
-004, -014, -016, -005, -006, -018, -007, -008, -009, -010, -011, -013, -015, -017, -019,
-020, -021, -022, -023, -024, -025, -136, -028, -030, -031, -033, -034, -036, -037, -039,
-042, -043, -044, -046, -047, -142, -048, -049, -052, -055, -057, -058, -059, -060, -138,
-067, -075, -077, -093, -080, -083, -086, -088, - 089, -090, -091, -095, 096, -098, -099,
-100, -101, -102, -103, -132, -105, -107, -110, -112, -113, -111, -115, -116, -119, -122,
-126, -130)

officers,
1
2
Page 2
school; and
552.103, 552.107, 552.108, 552.1175, 552.130, 552.136, and 552.152. See Exh. B.
Section 552.108
(1986).
3
Page 3
4
Page 4
5
Page 5
6
7
8
9
Page 6
10

Page 7
Section 552.101
records
11
Page 8
Acc. Bd., 540 S.W.2d 668, 685 (Tex. 1976).
Page 9
1701.661(a).
Ramos”).
Page 10

individual:

Page 11
numbers.
Page 12
such a showing.

Conclusion
Sincerely,
Laura Lee Prather

On behalf of:

Page 13

Pro Publica, Inc.
Scripps
laura.prather@haynesboone.com
see attached sheet for more Plaintiffs

CIVIL COVERSHEET ADDITIONAL PLAINTIFFS
Dow Jones & Co.

The E.W. Scripps Company
Gannett Co., Inc.
Graham Media Group, Houston
Graham Media Group, San Antonio
Hearst Newspapers, LLC
NBC News
The New York Times Co.
Pro Publica, Inc.
Sinclair Broadcast Group, Inc.
TEGNA Inc.
TelevisaUnivision
The Washington Post

Petition For Writ of Mandamus KSAT Lawsuit

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Petition For Writ of Mandamus KSAT Lawsuit

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CAUSE NO.

TEXAS TRIBUNE, § IN THE DISTRICT COURT OF

PETITION FOR WRIT OF MANDAMUS

TO THE HONORABLE COURT:

PETITION FOR WRIT OF MANDAMUS Page 1

1. Pursuant to TEX. R. CIV. P. 190.1, discovery is expected to be conducted under

JURISDICTION AND VENUE

governmental body refuses to supply the public information.

because the main office of each Defendant is located in Uvalde County.

4. Plaintiff The Texas Tribune (“Texas Tribune”) is a news media organization

its product throughout the state.

5. Plaintiff ABC News (“ABC News”) is a news media organization primarily

PETITION FOR WRIT OF MANDAMUS Page 2

and distributes its product throughout the state.

7. Plaintiff Cable News Network, Inc. (“CNN”) is a news media organization

product throughout the state.

9. Plaintiff The E.W. Scripps Company (“Scripps”) is a news media organization

its product throughout the state.

Globe-News, and the Lubbock Avalanche-Journal, as well as USA Today.

PETITION FOR WRIT OF MANDAMUS Page 3

(collectively “Graham”) are news media organizations primarily engaged in disseminating

12. Plaintiff Hearst Newspapers, LLC, (“Hearst”) is a news media organization

San Antonio Express-News and Houston Chronicle.

engaged in disseminating information to the public. NBC News is a division of NBCUniversal

journalists in Texas and distributes its product throughout the state.

journalists in Texas and distributes its product throughout the state.

engaged in disseminating information to the public. ProPublica is a 501(c)(3) nonprofit

distributes its product throughout the state.

primarily engaged in disseminating information to the public. Sinclair Broadcast Group is

PETITION FOR WRIT OF MANDAMUS Page 4

Paso), KBTV-TV (Beaumont/Port Arthur), KVII-TV (Amarillo), and KTXS-TV (Sweetwater).

(Beaumont), and KIDY/KXVA (San Angelo).

18. Plaintiff TelevisaUnivision (“TelevisaUnivision”) is a news media organization

primarily engaged in disseminating information to the public. TelevisaUnivision is incorporated

KUVN-DT (Dallas-Fort Worth).

PETITION FOR WRIT OF MANDAMUS Page 5

on the District at the above address.

on the Sheriff’s Office at the above address.

disclosure under various exceptions contained in the Public Information Act.

records, pursuant to § 552.321.

injured — inside Robb Elementary School in Uvalde, Texas, by an 18-year-old gunman.

PETITION FOR WRIT OF MANDAMUS Page 6

from scrutiny and accountability. 3

PETITION FOR WRIT OF MANDAMUS Page 7

minutes after the shooter entered.

• Recordings of 911 calls, radio traffic, computer-aided dispatch (CAD) notes,

• Recordings of body camera footage and dashboard camera footage from

• Rosters, calendars, communications, training materials, use-of-force reports

• Ballistics reports and evidence logs related to events at Robb Elementary on

• Police reports and any recordings of calls regarding a suspicious person or

• Investigative file for an alleged school-shooting plot in 2018; and

PETITION FOR WRIT OF MANDAMUS Page 8

withhold certain information under §§ 552.108(b)(1), 552.108(a)(1), 552.101, 552.117(a)(2), and

in response to their requests.

PETITION FOR WRIT OF MANDAMUS Page 9

and led to accusations of a “cover up” among government agencies.

information in its possession with the public.

PETITION FOR WRIT OF MANDAMUS Page 10

information following a completed investigation.

sheriff’s deputies who responded to the scene.

commander during the response.

PETITION FOR WRIT OF MANDAMUS Page 11

• Records showing which UCISD Police Department personnel were on duty on