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.
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 — for a digital file, that means one you can search and copy text from, like a normal computer document rather than a stack of photocopies. GC §7922.570 The city handed over this exact case file once in a searchable form anyone could keyword-search and compare page by page. R.25-3549 Five months later, asked for a fresh copy of the very same case, the city produced it as an image-only print — a file where the words are baked into pictures, so searching or comparing it is like flipping through a phonebook by hand instead of using “find.” R.26-1549 The city’s own file labels show one version was made by a normal export tool R.25-3549 and the other by “Microsoft: Print to PDF,” R.26-1549 with the second version naming the request’s contact person as the file’s author. R.26-1549 The city never said why the format changed or that a searchable version was unavailable. R.26-1549 This downgrade only became clear after the owner’s representative obtained both versions and ran a side-by-side digital comparison, which is what surfaced the missing text layer and the differing file fingerprints. R.26-1549 R.25-3549
Bottom line: the city had already proven it could hand over this case file in a searchable form, then re-issued the same record as an unsearchable image-only file with no explanation — right when a searchable copy mattered most for checking what had changed.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. R.25-3549 The second production of the same case carried zero extractable text: 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. 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. Card 41
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. R.25-3549
The November 2025 590-page case file, produced under R.25-3549, had /Creator = wkhtmltopdf 0.12.6, no /Author field, and a full extractable text layer. SHA-256: eb324451b81cf67af2a792b0432cbae7abe89b93f3b75f0baf8b9f9bc1f223d5. File size: approximately 51 MB. R.25-3549
The April 2026 636-page case file, 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. R.26-1549
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. 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 Card 45
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 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, and 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; 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. Card 41 “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 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, 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 Card 41 and when the April 24 requester notice raising the downgrade went unanswered in the portal record. R.26-1549 Card 45