The City produced the same case file twice, five months apart. The November 2025 production carried a full searchable text layer. The April 2026 production of the same case carried zero extractable text — generated through "Microsoft: Print To PDF," with the request's point of contact named as both file author and creator in the metadata — and the City stated no reason for the format change.
The City provided the same case file twice, but the second version was an unsearchable image-only file instead of the searchable document produced five months earlier. In November 2025, the City produced a 51 MB file that allowed users to search and copy text directly. In April 2026, the City replaced this with a 209 MB "Microsoft: Print to PDF" version that carried no machine-readable text, making it impossible to perform automated searches or page comparisons. Metadata in the second file identifies Melanie Haage, the request's point of contact, as both the author and creator of the document. While state law requires agencies to provide electronic records in a format they already use or can easily produce, the City provided no explanation for why it abandoned the searchable format it had previously used. This change occurred just as the file’s new content and redactions became a subject of dispute, and a formal notice regarding the format downgrade has received no response from the City.
The City produced one case record twice, and the two productions differ on the single property that lets a record be audited: the presence or absence of a text layer. The first production carried a full extractable text layer — keyword-searchable, text-extractable, and amenable to automated page-by-page comparison N R.25-3549. The second production of the same case carried zero extractable text A R.26-1549: it was generated through "Microsoft: Print To PDF," its PDF metadata names Melanie Haage as both /Author and /Creator, and the text content was recoverable only after running OCR. Melanie Haage is the named point of contact on the request that produced the flattened file R.26-1549.
The CPRA's electronic-format provision entitles a requester to an identifiable record in an electronic format the agency uses or can readily produce GC § 7922.570. The City had just produced this very record in a searchable electronic format five months earlier N R.25-3549. The downgrade arrived precisely when comparison mattered most — the April production is the file whose new content and redaction handling are in dispute in a related card C41.
When you ask a city for a copy of a case file, the law says you are entitled to it in a usable electronic form the city already uses GC § 7922.570. For a digital file, that means one you can search and copy text from — a normal computer document, not a stack of photocopies. The City handed over this exact case file in a searchable form in November 2025 N R.25-3549. Five months later, asked for a fresh copy of the same case, the City produced it as an image-only print A R.26-1549: words baked into pictures, making searching or comparing it equivalent to flipping through a phonebook by hand instead of using "find." The City's own file metadata shows one version was made by a normal export tool and the other by "Microsoft: Print to PDF," with the second version naming the request's contact person as the file's author A R.26-1549. The City never said why the format changed or that a searchable version was unavailable R.26-1549.
Electronic records must be provided in the electronic format in which they are held or in which they can be readily produced GC § 7922.570. The November 2025 production proves the City holds and can produce this case file as a searchable electronic export: it carried approximately 1,081,688 characters of selectable text N R.25-3549.
The November 2025 590-page case file N was produced under R.25-3549 with /Creator = wkhtmltopdf 0.12.6, no /Author field, and a full extractable text layer. SHA-256: eb324451b81cf67af2a792b0432cbae7abe89b93f3b75f0baf8b9f9bc1f223d5. File size: approximately 51 MB.
The April 2026 636-page case file A, produced under R.26-1549, carries zero characters in its text layer; the PDF producer is "Microsoft: Print To PDF"; both /Author and /Creator fields name Melanie Haage. SHA-256: ff6c83546627aacf46e3ce7a413d2e8e22e57ae91b8c1c96877bb3251088f600. File size: approximately 209 MB. OCR analysis of the image layer yields approximately 1,176,101 characters of text content; none is machine-readable from the file's native text layer.
The R.26-1549 portal record names Melanie Haage as the request's point of contact R.26-1549. The April production's PDF metadata names Melanie Haage as both /Author and /Creator A. The request was opened April 20, 2026, the document was released the same day, and the closure states that all responsive records have been provided — with no explanation of why the format differs from the November production R.26-1549.
Christopher T. Foley's April 24, 2026 message posted to the portal states: the April production was "manually generated using 'Microsoft Print to PDF' on April 20, 2026, at 1:46:33 PM"; the November 2025 file is 51 MB and the April 2026 file is 209 MB; SHA-256 hashes for both files are stated R.26-1549. That notice received no response in the portal record and no later record entry addresses the format change R.26-1549 C45.
The City's closure message of April 20, 2026, signed by Mindy Cuppy (City Clerk), states: "The City has collected all documents that appear to be responsive to your request. The documents have been uploaded to the portal." No entry in the portal record, before or after closure, explains why the November searchable export was replaced by an April image-only print, or states that a searchable export was technically unavailable R.26-1549.
The November and April productions have different SHA-256 hashes, confirming they are not the same file: eb324451…1f223d5 (November, N) versus ff6c8354…1088f600 (April, A). The producer metadata change from wkhtmltopdf to Microsoft: Print To PDF is embedded in the files themselves N A.
The City might argue that PDF export format is a mere technical detail — that the same pages were delivered and an image-only file satisfies the CPRA. Content is not the point; format is. The CPRA's electronic-format provision attaches to exactly the choice the City made GC § 7922.570. The City produced this identical case file as a searchable electronic export in November N R.25-3549; it uses and can readily produce that format. Replacing it five months later with a zero-text-layer "Print to PDF," with no stated reason R.26-1549, hands the requester a copy that cannot be searched or compared at the moment the April production's new content and redactions are in active dispute C41. "Same pages" is not "same record" when the property that makes the record auditable has been removed.
The City produced this case file twice. In November 2025 it came as a searchable electronic export N R.25-3549 — the format the CPRA's electronic-records provision points to GC § 7922.570 and the format the City demonstrably holds and can produce. In April 2026, asked for a current copy of the same record, the City produced an image-only "Print to PDF" with zero extractable text, authored in its metadata by the same person who served as the request's point of contact A R.26-1549, and said nothing about why the format changed R.26-1549. A searchable record became an unsearchable one in the City's own hands, between two productions of the same case, with no reason given. The change arrived when a searchable copy mattered most — when the April production's new content and redactions were in dispute C41 and when the April 24 requester notice raising the downgrade went unanswered in the portal record C45 R.26-1549.
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