Originating 311 Complaint Excluded by City’s Own Export Cutoff

2 — Expanded Header

The City's own File Detail Report carries an "Open Date" of 03/18/2023, and its earliest Activity Log entries — INITIAL COMPLAINT and INITIAL INSPECTION — are dated 03/20/2023; no Activity Log entry bearing the 03/17/2023 complaint date appears anywhere in the produced case file M001. When the City produced a 311 export through the CPRA request that asked for the originating complaint R.25-3549, that export's "Date/Time Opened" filter began on March 20, 2023. The requester identified that cutoff in writing R.25-3549 and pointed out that it would exclude the very complaint the case file says triggered the case — the requester naming the originating ticket number (#230317-1609966), the November 2023 follow-up ticket number (#231107-2094683), and asking the City to identify "which systems and custodians are being searched" R.25-3549. The City thereafter released a further 311 export and closed the request R.25-3549.

The produced file kept later neighbor-characterization content throughout — an 01/09/2026 caller relaying late-night unpermitted work and "illegal wiring is a fire hazard" M011, an 03/26/2026 caller naming the resident and describing him "terrorizing the neighborhood with construction noise" M012, and an 01/27/2026 inspector's own note recording a neighbor's fence and dumped-appliance complaints and stating "I took pictures for case documents" M039. The contrast frames the gap: the later complaint content stayed in the file, while the export that should have carried the originating intake was keyed to a date that fell on the far side of the complaint.

This case started with a neighbor complaint phoned in through the City's 311 line. When the owner's side asked for that originating complaint through a public-records request, the City handed over a spreadsheet of 311 tickets — filtered to start on March 20, three days after the complaint that actually opened the case came in on March 17. The one record that triggered everything fell just outside the date window the City used to pull the report. The owner's representative caught the cutoff in writing, named the exact ticket number (#230317-1609966), and asked the City to rerun the search without the date filter and to say which systems it was even searching R.25-3549; the City thereafter posted another export and closed the request. The City never flagged that its own filter sat on the wrong side of the complaint — the filter problem only became visible because the requester read the export closely enough to notice the start date.

3 — Record Chain

4 — Requested City Action

1. Produce a copy of the City's initial 311 export for Request 25-3549 — or a search log — showing that the originating ticket (#230317-1609966) was included despite the March 20 "Date/Time Opened" filter, or explain why the export was keyed to March 20 rather than to the complaint date of March 17 R.25-3549. The production contains no such explanation on the record reviewed.
2. Identify which systems and custodians were searched in response to Request 25-3549, as demanded in writing by the requester R.25-3549. If 311 intake is held by a separate City unit, identify that unit and confirm whether a coordinated search was conducted under the duty to assist GC § 7922.600.
3. Absent that documentation, explain how the City's closure of the request as "All responsive records have been provided" R.25-3549 is consistent with an initial export that omitted the predicate complaint because the search window was keyed to a date three days after the complaint was filed — see C47.

5 — Full Circle

The 311 complaint is the legal predicate of Case 23-009185 M001 R.25-3549, and on the City's own production it fell on the wrong side of the City's own export filter: a March 17 complaint, a March 20 cutoff, and an export that did not carry the originating intake until the requester caught the cutoff in writing and demanded a broader search R.25-3549. The file retained the later neighbor-characterization entries the whole time M011 M012 M039 — a hearing officer could read the 2026 complaint content while the originating intake had to be drawn out by a corrected search. The originating 311 complaint surfaced in CPRA production only after a March 20 export filter was challenged in writing and a broader search demanded R.25-3549.

The two points that anchor this claim survive adversarial test. First, the case file's own Open Date is 03/18/2023 and its earliest log entries are 03/20/2023, with no entry on the 03/17/2023 complaint date M001 — the predicate complaint is documented only by date reference, not by a contemporaneous intake entry in the produced file. Second, the 311 export the City produced was keyed to a "Date/Time Opened" cutoff of March 20, 2023 R.25-3549; the requester identified that the cutoff would exclude a March 17 complaint and demanded a broader search R.25-3549; the City released a further export and closed the request R.25-3549.

Anticipated City defense: 311 intake is a separate system not held by Code Enforcement; the March 20 case-open date in the case-management system is a distinct administrative step from the complaint date; and the initial export reasonably keyed to the case-open date.

Answer: That answer does not close the gap. The CPRA obligation runs to all records the agency holds or controls, and a department that opens an enforcement case on a 311 complaint is obligated to identify and produce the predicate complaint or coordinate with the City unit that holds it, under the duty to assist GC § 7922.600. A complaint-date / case-open-date distinction — if real — should have been disclosed in the CPRA response, not left for the requester to discover by reading the export's start date. The complaint that opened the case landed just outside the City's own search filter, and it came forward only after the requester caught that in writing.

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Applicable Law

• GC § 7922.600 — California Government Code § 7922.600 — CPRA duty to assist; each agency shall assist requesters to identify responsive records and coordinate production across all systems and custodians, not one system's records.