Josh Rubenstein Apparently Calls Black LAPD Officers “Boys” — Right To Their Faces — And When His African-American Subordinate Raymond Brown Complained Repeatedly Rubenstein And His Media Relations Sidekick Patricia Sandoval Apparently Told Him He’d Never Get Promoted — And Then Apparently Didn’t Promote Him At Least Twice — So In May Brown Filed A Suit Against The City Of Los Angeles — It’s Worth Reading And There’s A Copy Right Here For You!

On a date in or around late 2017, Director Josh Rubenstein greeted the officers in Media Relations Division’s open office space as “ladies, gents, and officers” and, immediately thereafter, approached the Online Unit office and stated, “How are you boys?” At the time, only Plaintiff and Police Officer III Lyle Knight were present in the Online Unit office. Both Plaintiff and Officer Knight are African-American. Within approximately one week, Rubenstein again asked Plaintiff and Officer Knight, “How are you boys?” Just days later, Rubenstein addressed Plaintiff and Officer Knight as “boys” for a third time. This time, however, Rubenstein did so in a snide and mocking tone of voice. Moreover, Rubenstein said “boys” so loudly that even Sgt. Preciado, who was sitting both outside of and a significant distance away from the Online Unit office, heard it.

Raymond Brown v. City of Los Angeles

The Los Angeles Police Department gets sued. It gets sued a lot. And it’s not just their civilian victims suing them. It turns out that an organization dedicated to violence, secrecy, machismo, and the defense of capital is, who’d have thought, not a very nice place to work. Which is why their own employees sue the LAPD a lot also.

Like for instance just last year LAPD Media Relations Officer Frank Preciado sued, alleging that his supervisor Josh Rubenstein1 didn’t allow Preciado and others to speak Spanish in the office. Preciado also alleged that Rubenstein banned Media Relations employees from tuning in to Spanish Language TV on the Department’s monitors.

The situation is not only discriminatory according to Preciado but, given that his official duties include speaking to Spanish language media folks, it also prevents him from doing his job properly. Rubenstein is LAPD’s most visible Anglophone public information officer. The dude is everywhere and he’s always got time for the media. Unless, I guess, they’re working in Spanish.

Preciado’s suit got some media attention in 2019 when it was filed, but not much since. That little bit is more than Raymond Brown’s suit, filed in May 2020, received, though. And Brown’s suit also hinges on Rubenstein’s weirdo antics, in particular the fact that apparently Rubenstein thinks it’s acceptable to refer to Black LAPD officers as “boys”.
Continue reading Josh Rubenstein Apparently Calls Black LAPD Officers “Boys” — Right To Their Faces — And When His African-American Subordinate Raymond Brown Complained Repeatedly Rubenstein And His Media Relations Sidekick Patricia Sandoval Apparently Told Him He’d Never Get Promoted — And Then Apparently Didn’t Promote Him At Least Twice — So In May Brown Filed A Suit Against The City Of Los Angeles — It’s Worth Reading And There’s A Copy Right Here For You!

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The Los Angeles Police Commission Asked The National Police Foundation To Write An “After Action Report” On Police Responses To George Floyd Protests Between May 27 and June 10 — The NPF Asked LAPD For A Huge Amount Of Evidence — Including Surveillance And Bodycam Video — Training Records For Every Cop Involved — Training Curriculums For Relevant Courses — Mental Health Referrals (Of Police) And So On — In Fact I Have A Copy Of NPF’s Initial Requests — Four Pages Of Requests — And Inspector General Mark Smith Sent NPF A Long List Of Activist Social Posts About LAPD — And I Have Live Links To All Of Them As Well! — Including For Some Reason A Link To This Blog!

On May 25, 2020 Minneapolis police murdered George Floyd and the United States, including the City of Los Angeles, erupted in massive protests. And police around the country, including right here in the City of Los Angeles, responded with disproportionate aggression and overwhelming violence against the protesters. In the wake of that first wave of protests and nearly universal criticism of their response, the LAPD opened over 50 internal investigations against officers for brutality.1

And the Los Angeles Police Commission, nominally an independent oversight body,2 arranged for the National Police Foundation to conduct a putatively independent report on the matter. It’s doubtful that this report will do anything more than evoke the famous “Few Bad Apples” theory to justify maybe tossing a few cops under the bus while vigorously reaffirming the structural and institutional soundness of the LAPD. The NPF is far too compromised to expect much else.

So I’m predicting that the report, when it finally comes out, will be tedious and fundamentally dishonest. But none of that means that the report creation process isn’t interesting. In fact it’s very interesting, as I learned recently when I obtained a few records relating to the process. These documents have to do with evidence requested by the NPF from both LAPD and the Police Commission, and they’re interesting to me for at least two reasons.

First, the fact that Mark Smith, the Inspector General, gave the NPF a huge list of social media posts about the protests3 and told Richard Tefank, the Executive Director of the Police Commission, in an email that the OIG staff had collected them.4 Wondering if the cops are reading your tweets? Not only are they, but they’re quite likely handing them over as evidence! Smith even sent the NPF a 2016 blog post of mine about Cory Palka.5 Also I made an html version of Smith’s links for maximum clickability and it’s at the end of this post.

And second, there’s the sheer bulk of the material the NPF requested and the sheer promptness with which LAPD handed it over. See this August 27, 2020 memo from the NPF to LAPD and Tefank consisting of four pages of detailed requests for evidence. The version I obtained was marked up in red and blue by Lizabeth Rhodes, director of LAPD’s Office of Constitutional Policing, with the Bates Stamp numbers of all the material they’d already produced as of September 17, just three weeks after the request.
Continue reading The Los Angeles Police Commission Asked The National Police Foundation To Write An “After Action Report” On Police Responses To George Floyd Protests Between May 27 and June 10 — The NPF Asked LAPD For A Huge Amount Of Evidence — Including Surveillance And Bodycam Video — Training Records For Every Cop Involved — Training Curriculums For Relevant Courses — Mental Health Referrals (Of Police) And So On — In Fact I Have A Copy Of NPF’s Initial Requests — Four Pages Of Requests — And Inspector General Mark Smith Sent NPF A Long List Of Activist Social Posts About LAPD — And I Have Live Links To All Of Them As Well! — Including For Some Reason A Link To This Blog!

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The Los Angeles Police Commission’s Advisory Committee On Building Trust And Equity Was Formed In July 2020 — And Won’t Report Out On Recommended Reforms Until The End Of This Year — But You Don’t Have To Wait! — I Obtained An Eighteen Page Draft Of Their Recommendations From October 26, 2020 — Get Your Copy Here! — Which Proposes Many Welcome Policy Changes — All Of Which Are Doomed To Fail If Implemented As Recommended — For The Same Old Reason — All Of Them Are To Be Enforced By The Police Themselves — Which In Practice Means They Would Be Voluntary — And Therefore Ignored

In July 2020 the Los Angeles Police Commission announced the formation of an Advisory Committee on Building Trust and Equity. Here’s the Commission’s press release on it, which summarizes the Committee’s charge:

The Advisory Committee is expected to focus its work on a review of discipline and accountability; assessing current policing reform proposals being considered throughout the country; evaluating the implementation of past LAPD reform proposals; examining the LAPD’s recruitment, hiring, retention and training process; and analyzing data collection and retention practices.

As part of this work the Committee ran a series of community meetings featuring different local organizations presenting their visions of police reform,1 all of which are available on the Commission’s surprisingly useful YouTube channel.

The point of the meetings was ostensibly to gather information related to the Committee’s main charge, which is to conduct “a comprehensive review of LAPD policies and procedures, and deliver recommendations for additional reforms.” The Committee’s recommendations are expected by the end of 2020.

Which is a long time to wait, but fortunately waiting isn’t completely necessary. I recently obtained a working draft, dated October 26, 2020, of some of the Committee’s work. This document has the current state of their recommendations on “Data Collection, Reporting, Use, Access, Retention and Transparency” and on “Stop, Search and Arrest Data (RIPA).” The original is an MS Word file, and I exported it to PDF for ease of use (and it’s also transcribed at the end of this post).
Continue reading The Los Angeles Police Commission’s Advisory Committee On Building Trust And Equity Was Formed In July 2020 — And Won’t Report Out On Recommended Reforms Until The End Of This Year — But You Don’t Have To Wait! — I Obtained An Eighteen Page Draft Of Their Recommendations From October 26, 2020 — Get Your Copy Here! — Which Proposes Many Welcome Policy Changes — All Of Which Are Doomed To Fail If Implemented As Recommended — For The Same Old Reason — All Of Them Are To Be Enforced By The Police Themselves — Which In Practice Means They Would Be Voluntary — And Therefore Ignored

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Los Angeles Police Protective League Presentation On Police Reform From October 1st Town Hall Is Unhinged — “Nearly all the reforms that are being talked about are already in place in the Department” — “44% of violent crime suspects are Black — If LAPD arrested these black violent crime suspects does that mean LAPD is biased against Black Angelenos?” — “Public ridicule by City leaders, City politicians, of Department and the officers” — City Leaders, you “have to do better protecting your police officers” — Here’s Video And A Copy Of Their Powerpoint Too!

In September and October the Los Angeles Police Commission Advisory Committee on Building Trust and Equity1 sponsored a number of Community Town Halls.2 Various organizations got ten minutes or so to present their ideas on police reform to the Committee including, interestingly, the Los Angeles Police Protective League.3

I didn’t pay much attention to these town hall things while they were happening but then I obtained a copy of an appalling LAPPL powerpoint file which turned out to be from that appalling organization’s presentation at the October 1st Town Hall. This crazy slide deck made me wonder what the heck had gone on in that meeting.4

The LAPPL was repped by well-known psychopath Rob Harris and not-quite-so-well-known psychopath Jeretta Sandoz. Their argument essentially, and I am paraphrasing it, but accurately, is that because 9% of Angelenos are Black and 44% of “violent crime suspects” are Black, it is therefore not racist that the police arrest disproportionately many Black people.5 Also LAPD is sad because local politicians are mean to them.6

After spilling the numbers, Sandoz gets to the point in pretty much the most offensive way possible: “Look at these numbers. Do Black lives really matter in the community?” As Sandoz says: “If the LAPD arrested the 13,485 black violent crime suspects does that mean the LAPD is biased against black Angelenos? The answer to that is no. The numbers don’t lie.” But, well, yes, actually, it does mean precisely that. The answer to that is yes. The numbers do, in fact, lie. Just ask anyone who’s learned about selection bias, whether in classrooms from statistics teachers or on the streets of Los Angeles from the LAPD.7 Then Harris again with a forever reel of disingenuously designed fake polling. Eleventy-seven percent of the public support cops and reject commies. And then things got strange.
Continue reading Los Angeles Police Protective League Presentation On Police Reform From October 1st Town Hall Is Unhinged — “Nearly all the reforms that are being talked about are already in place in the Department” — “44% of violent crime suspects are Black — If LAPD arrested these black violent crime suspects does that mean LAPD is biased against Black Angelenos?” — “Public ridicule by City leaders, City politicians, of Department and the officers” — City Leaders, you “have to do better protecting your police officers” — Here’s Video And A Copy Of Their Powerpoint Too!

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On October 29, 2020 LA Taco Demanded That LAPD Apologize For Physically Attacking And Beating Journalist Lexis-Olivier Ray — That Very Same Day LAPD Public Information Officer Josh Rubenstein Circulated A List Of His Related “Communications Initiatives” — Including Police Officers Videotaping “Violent” Protesters For The Express Purpose Of Posting Clips On Social Media To Shape A Pro-Police Narrative — And Monitoring Social Media Not Necessarily To Collect Evidence Of Crimes But Also To “Publicize [Violent] Acts” — And A Professional Press Org Is Working With LAPD On Publicizing “Acceptable Behavior Of The Press During Protests” — Which Is All Exactly As Creepy As It Sounds!

On October 28, 2020 LAPD officers attacked journalist Lexis-Olivier Ray while he was covering a spirited informal celebration of the Los Angeles Dodgers’ recent World Series victory. The next day, October 29, local news publication L.A. Taco sent a letter to LAPD Chief Michel Moore demanding an apology, an investigation, and a report on LAPD’s plans “to ensure the press is protected while they are working.”

I don’t know what’s up with all that, but I do know that also on October 29, whether or not related to the police attack on Ray, LAPD Public Information Officer Josh Rubenstein sent an email to LAPD’s most senior leaders listing “the many communications initiatives” that Rubenstein and his office would be working on over the next week.

And this email has an awful lot to say about the press at protests, but none of it sounds like it’s meant to protect them. To intimidate, corral, silence, yes, to work with the Radio, Television, and Digital News Association to describe “acceptable behavior of the press during protests,” and so on, but not to protect. But that’s not the worst thing in Rubenstein’s email.
Continue reading On October 29, 2020 LA Taco Demanded That LAPD Apologize For Physically Attacking And Beating Journalist Lexis-Olivier Ray — That Very Same Day LAPD Public Information Officer Josh Rubenstein Circulated A List Of His Related “Communications Initiatives” — Including Police Officers Videotaping “Violent” Protesters For The Express Purpose Of Posting Clips On Social Media To Shape A Pro-Police Narrative — And Monitoring Social Media Not Necessarily To Collect Evidence Of Crimes But Also To “Publicize [Violent] Acts” — And A Professional Press Org Is Working With LAPD On Publicizing “Acceptable Behavior Of The Press During Protests” — Which Is All Exactly As Creepy As It Sounds!

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In 2016 LAPD Bomb Detection Canine Section Officer Raymond Garvin’s Supervisor Kathryn Meek Demoted And Transferred Him Out Of His Prestige Position — In 2018 Garvin Sued The City of LA For Unfair Employment Practices And Retaliation — In September 2020 Deputy City Attorney Marianne Fratianne Recommended That City Council Pay $700K To Settle The Suit — Which They Did — Fratianne Identified The “Root Cause” Of The Lawsuit And Recommended A Single Preventative Correction — Out Of A Long Lurid List Of LAPD Transgressions Fratianne Identified Only The Single Most Anodyne — Out Of A Myriad Of Potential Preventative Measures Fratianne Recommended Only The Least Effective — How Will The City Government Of Los Angeles Reform LAPD Even A Little If Officials Are Completely Unwilling To Criticize Them — Even In Confidence — LAPD Is Completely Unable To Reform Itself Given The Level Of Internal Workplace Chaos They Evidently Find Normal And Acceptable

Synopsis:  LAPD officer Garvin sued the City because his superior officer Meek, who had a “romantic relationship” with another one of her subordinates, conspired with Deputy Chief Frank to get him demoted and transferred. Meek solicited damaging info from Garvin’s subordinates and used “completely fabricated” complaints against him to accomplish this goal. In a confidential report to LA City Council Deputy City Attorney Marianne Fratianne recommended that the City settle for $700K because Meek was not a credible witness but Garvin was.

From a long and lurid list of LAPD transgressions Fratianne chose only to recommend that the City avoid future liability by having LAPD supervisors think carefully about using the technical loophole in the complaint resolution process that allowed Meek to demote Garvin on the basis of fabricated complaints. This innocuous choice suggests that the City Attorney’s office is unwilling to recommend effective LAPD reforms to City Council even when they can recommend in secret and even when such reforms would be purely internal.

Continue reading In 2016 LAPD Bomb Detection Canine Section Officer Raymond Garvin’s Supervisor Kathryn Meek Demoted And Transferred Him Out Of His Prestige Position — In 2018 Garvin Sued The City of LA For Unfair Employment Practices And Retaliation — In September 2020 Deputy City Attorney Marianne Fratianne Recommended That City Council Pay $700K To Settle The Suit — Which They Did — Fratianne Identified The “Root Cause” Of The Lawsuit And Recommended A Single Preventative Correction — Out Of A Long Lurid List Of LAPD Transgressions Fratianne Identified Only The Single Most Anodyne — Out Of A Myriad Of Potential Preventative Measures Fratianne Recommended Only The Least Effective — How Will The City Government Of Los Angeles Reform LAPD Even A Little If Officials Are Completely Unwilling To Criticize Them — Even In Confidence — LAPD Is Completely Unable To Reform Itself Given The Level Of Internal Workplace Chaos They Evidently Find Normal And Acceptable

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Interesting Material About LAPD Recruitment And Hiring — Candidate Testing Outcomes Broken Out By Race And Gender — Recruiters Attend HCBU Job Fair Every Year — Changing Standards To Increase Psych Exam Pass Rate — Asking Candidates About Their Community Involvement And Cultural Sensitivity — Data On Engagement Rates For Specific Social Media Campaigns — And So Much More — Speaking Of Which LAPD Is Considering Possibility Of Hiring A Third Party To Carry Out “deeper investigation of candidates’ footprint on social media”

Remember in 2019 when LAPD’s recruiting ads ran on Breitbart? I’ve been trying to get some information about this and related topics since then but with very little success. First I asked LAPD. LAPD told me that they didn’t handle their own advertising1 and that I should talk to the City of LA Personnel Department.

I sent Personnel a public records act request in early October 2019 and, despite four followups, they haven’t responded yet. So I don’t have news on the Breitbart thing yet but the other day I got some records relating to other aspects of LAPD hiring:

⦿ LAPD Pass rates — LAPD recruit pass/fail rates broken down by race and gender from March 2019 through June 2020. Also available as a spreadsheet.

⦿ Personnel Department Public Safety Division hiring recap — For the week of September 7, 2020. This has detailed statistics on various LAPD recruiting ad campaigns as well as that week’s pass/fail stats.

⦿ Public Safety Division Presentation — A 41 slide August 2020 presentation to a Police Commission committee about hiring practices. This has essential information about what kinds of ads they run, where they run them, and so on.

So for instance LAPD recruits heavily at HBCUs by advertising but also by sending officers annually to job fairs at Alcorn State, Fayetteville, Grambling, and Southern Universities. They staff tables at Taste of Soul and “barbershop and beauty salon gatherings” and run an “annual hiring seminar at Crenshaw Christian Center.”
Continue reading Interesting Material About LAPD Recruitment And Hiring — Candidate Testing Outcomes Broken Out By Race And Gender — Recruiters Attend HCBU Job Fair Every Year — Changing Standards To Increase Psych Exam Pass Rate — Asking Candidates About Their Community Involvement And Cultural Sensitivity — Data On Engagement Rates For Specific Social Media Campaigns — And So Much More — Speaking Of Which LAPD Is Considering Possibility Of Hiring A Third Party To Carry Out “deeper investigation of candidates’ footprint on social media”

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On October 10, 2020 LAPD Chief Michel Moore “Was Personally Insulted By The Content” Of A Tweet On Marqueece Harris-Dawson’s Twitter — So He Asked MHD About It — MHD Denied Writing It Or Even Knowing About It — But Promised To Replace It With “A Positive And Supportive Message” — Then Moore Emailed 27 LAPD Brass And Told Them That He Had “Personally Discussed This With The CM And Expect[ed] Better” — Who Is It That’s In Charge Of This City Again?

On October 10, 2020, LAPD Chief Michel Moore sent an email to a bunch of police luminaries with the subject line CM Marqueece Harris-Dawson Tweet – Ridiculous. The outline is in the headline and the full text is below. But first, is anyone still wondering who actually runs this City?

After the City Council choosing layoffs and furloughs over even freezing LAPD’s budget, let alone reducing it? After seeing police officers surround and intimidate CD 7 rep Monica Rodriguez? After the LAPPL’s disingenuous attacks on CD11 rep Mike Bonin?

If so, they won’t be wondering after reading Michel Moore tell more than twenty five of his subordinates that he “expect[s] better” from Councilmember Harris-Dawson, that he’s “committed to holding [politicians] accountable,” that after their conversation Harris-Dawson had the “ridiculous” tweet, apparently neither written nor approved by him, deleted and replaced “with a positive and supportive message.” Here’s a transcription of the email:
Continue reading On October 10, 2020 LAPD Chief Michel Moore “Was Personally Insulted By The Content” Of A Tweet On Marqueece Harris-Dawson’s Twitter — So He Asked MHD About It — MHD Denied Writing It Or Even Knowing About It — But Promised To Replace It With “A Positive And Supportive Message” — Then Moore Emailed 27 LAPD Brass And Told Them That He Had “Personally Discussed This With The CM And Expect[ed] Better” — Who Is It That’s In Charge Of This City Again?

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Today I Filed Yet Another Complaint Against LAPD Detective Kris Tu — Sub-Boss Of Their Public Records Unit — And His Subordinate Thanh Su — For Willfully Violating The California Public Records Act — Read All About It Right Here!


This post is about a complaint I filed just now with LAPD Captain Bryan Lium against Kris Tu and Thanh Su of the Department’s Public Records Unit. If you want to skip straight to it here is the link!

The LAPD let me know recently that they will not comply with the California Public Records Act when it comes to my requests. Which isn’t much of a change, actually. Other than a few months in 2018 when they followed the law they have never complied. It took them over a year to get to my first request to them in 2015 and things have only gotten worse.

But late last year they settled a major CPRA case with the ACLU and part of the agreement required the Department to adopt a policy stating explicitly that LAPD employees, both sworn and nonsworn, were subject to discipline for willful violations of the law. And since they will no longer produce records in response to my requests I’ve been using the time I would have spent reviewing and writing about their records to file complaints against them instead.

In August of this year I filed one against LAPD CPRA Sub-boss Kris Tu and his supervisor, Lieutenant Marla Ciuffetelli. Then another against Ciuffetelli alone. A few weeks ago I filed my third, this against Tu again and also Discovery Analyst Masoomeh Cheraghi.

And today I filed my fourth! This one’s against Tu and Analyst Thanh Su. There are two issues involved here. First their refusal to state which exemptions they claim justify their redactions and withholdings and second their refusal to state the name of the person who determined to apply the exemptions. Read the transcription below for the details and stay tuned to see what happens!1
Continue reading Today I Filed Yet Another Complaint Against LAPD Detective Kris Tu — Sub-Boss Of Their Public Records Unit — And His Subordinate Thanh Su — For Willfully Violating The California Public Records Act — Read All About It Right Here!

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The City of Los Angeles Continues To Produce Emails As Non-Text-Searchable Super Low Quality PDFs Rather Than MBOX Or EML Files — But The California Public Records Act Requires Them To Produce In Any Format They Use To Make Copies For Their Own Use — Which Includes MBOXes — We Are Finally Litigating This Issue — Hearing On November 11, 2020 — Read The Trial Brief Here — And A Declaration From Computer Pioneer Martin Haeberli — Explaining Why The City’s Reasons For Not Producing MBOXes Aren’t Reality-Based

This is what the City of Los Angeles does to image files when it converts emails to PDFs. It’s obviously not an exact copy, the provision of which is required by law. This is a completely faithful copy of an image file the City of LA produced in response to a CPRA request.
Maybe you remember that back in December 2019 I filed yet another CPRA suit against the City of Los Angeles. Here I was after a varied bunch of emails from the City’s Information Technology Agency. As usual, the City started handing over records almost immediately, which counts as a concession that they were wrong in denying my original requests.1

Also as usual they produced emails and their attachments as huge, unwieldy, non-text-searchable PDFs with highly degraded quality even though I asked them for MBOX files and the law requires them to produce MBOX files.2 They also produced attachments this way. You can see from the image what this process does to image files3 but imagine how incredibly useless it makes a spreadsheet! The CPRA’s requirement, found at §6253.9, is clear:

6253.9. (a) Unless otherwise prohibited by law, any agency that has information that constitutes an identifiable public record not exempt from disclosure pursuant to this chapter that is in an electronic format shall make that information available in an electronic format when requested by any person and, when applicable, shall comply with the following:

(1) The agency shall make the information available in any electronic format in which it holds the information.

(2) Each agency shall provide a copy of an electronic record in the format requested if the requested format is one that has been used by the agency to create copies for its own use or for provision to other agencies. The cost of duplication shall be limited to the direct cost of producing a copy of a record in an electronic format.

They refuse to do it, though, as they have been refusing since at least 2014. They change their reasons all the time, often in response to my pointing out that they’re lying about their capabilities. These days they’re not denying that they can produce MBOX files because everyone knows by now that they can do it even they used to say explicitly that it was impossible.4 Their current argument, also a lie, is that it’s impossible to redact MBOXes, so they can only produce as PDFs, which they can redact.

But this time we’re not willing to settle with them! We’re about to litigate this file format issue! The hearing is on November 11 at 1:30 before James Chalfant. Here’s the trial brief. There’s also a declaration from Internet and Apple Computer pioneer Martin Haeberli explaining the reasons why producing emails as MBOX files is far superior to PDFs and also explaining two perfectly workable ways to redact them in this form.5 Read on for excerpts from the brief and stay tuned for news!
Continue reading The City of Los Angeles Continues To Produce Emails As Non-Text-Searchable Super Low Quality PDFs Rather Than MBOX Or EML Files — But The California Public Records Act Requires Them To Produce In Any Format They Use To Make Copies For Their Own Use — Which Includes MBOXes — We Are Finally Litigating This Issue — Hearing On November 11, 2020 — Read The Trial Brief Here — And A Declaration From Computer Pioneer Martin Haeberli — Explaining Why The City’s Reasons For Not Producing MBOXes Aren’t Reality-Based

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