AN INDEPENDENT CASE STUDY Mount Pleasant, Texas
MOUNT COMPLACENTTHE PAPER TRAIL
← All comparison topics

STATEMENTS & EVIDENCE

Searches and missing records

Compare the original requests with the City’s search settings, completeness statements and later deliveries. Follow the records that surfaced through separate requests.

Unreconciled inconsistency

01Certified complete, then screenshots acknowledged as unprovided

The statement

Candias Webster · signed certification for the Chief’s phone-record requestApril 27, 2026

The signed first option certifies that all existing responsive information was made available to the requestor. It gives the production date as “12/17/26” [as written], by email.

Chief’s call logs: request, typed response & WC05 certification · PDF p. 16Signed certification · OR-25-059503-IC

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The comparison records

Candias Webster to Kent RichardsonMay 7, 2026

“This was his personal cell phone and no he did not get screenshots. He was wanted metadata from his phone.”

Webster–Richardson–Beck · May 7–12, 2026 · PDF p. 3Question 10; Webster’s answer is red

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Candias Webster to KyleDecember 17, 2025

The response gives a typed account of two October 22 calls and discusses why the screenshots were not sent.

Chief’s call logs: request, typed response & WC05 certification · PDF p. 4Typed two-call account

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Chief’s call logs: request, typed response & WC05 certification · PDF p. 1Underlying request for call/voicemail records

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Candias Webster to Richardson and BeckMay 12, 2026

“Here are the documents from the phone.” The message lists image attachments and is addressed to Richardson and Beck.

Webster–Richardson–Beck · May 7–12, 2026 · PDF p. 1May 12 transmittal and attachment names

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What the comparison establishes

The signed form certifies that all existing responsive phone records had been supplied. On May 7, Webster told Richardson that Moring had not received the screenshots. A typed account of two calls is a different record from the underlying screenshots, leaving the certification and her later account unreconciled.

Limits of the finding

The form records the production date as “12/17/26,” as written, even though Webster signed it in April 2026. The apparent date error does not establish intent. Later delivery of two screenshots is credited separately; the question is whether the form accurately described what had been supplied when it was signed.

Later response & context

Two call screenshots appear in Moring’s documented June 2 production and were included again in the August 27 enclosure set. Those later deliveries do not by themselves establish that the screenshots were in the earlier October, November or February payloads.

Compare the August 27 delivery claim ↗
Directly conflicting representations

02August 27 says the call screenshots had already been supplied

The statement

Austin Beck · DTRGAugust 27, 2026

After listing October 23, November 2, February 2, June 2 and August 26 deliveries of C-2 texts, the letter says: “The same applies to Exhibit C-3,” identifying C-3 as the Chief’s personal-cell call logs.

DTRG · August 27, 2026 letter · PDF p. 1Item 1: delivery dates and C-2/C-3 assertion

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The comparison records

Candias Webster to RichardsonMay 7, 2026

Webster’s full response to question 10 reads: “This was his personal cell phone and no he did not get screenshots. He was wanted metadata from his phone.” The wording is preserved as written.

Webster–Richardson–Beck · May 7–12, 2026 · PDF p. 3Question 10 and answer

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Candias Webster to Richardson and BeckMay 12, 2026

Phone documents are sent to the two named recipients. Kyle is not listed as a recipient on this transmittal.

Webster–Richardson–Beck · May 7–12, 2026 · PDF p. 1Visible To field and attachment list

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October 23 mounted MPPD/Axon media · direct file-and-hash inventoryOctober 23, 2025; examined September 25, 2026

The mounted media contains exactly five user-delivered Axon MP4 videos and Table_of_Contents.xlsx. It contains no PNG, JPEG, PDF, or other call-history screenshot. All six user files were sized and hashed; their directory contents agree with the spreadsheet index.

Read the mounted-media and retained-package audit · 2 pages ↗ Prepared reading copy

June 2 SharePoint production listingJune 2–3, 2026

The saved OneDrive listing shows IMG_0486.PNG and IMG_0487.PNG in the OAG-complaint production folder, both displayed as modified by Candias Webster. This is documented delivery evidence; it does not prove that the same files appeared in an earlier production.

June 2 production folder listing · PDF ↗ Prepared reading copy

Retained production packages · file-and-hash inventoryNovember 3, 2025; February 2 and June 2, 2026

The November 3 folder contains five audio files and three text-message screenshots, not the later call-history images. Every file and native MSG attachment in both original February 2 ZIPs was inventoried. Neither ZIP contains IMG_0486.PNG or IMG_0487.PNG or an image attachment matching either June SHA-256 hash. The two call-history images appear in the June 2 production.

Read the reproducible file-and-hash inventory · PDF ↗ Prepared reading copy

What the comparison establishes

The August 27 letter attributes the call-history screenshots to several earlier delivery dates. Direct examination of the October 23 physical media found five Axon videos and its spreadsheet index, but no call-history screenshots. The retained November 3 production and both original February 2 ZIPs likewise do not contain the two images by filename or hash. Webster had also said on May 7 that Moring did not receive screenshots, and her May 12 transmittal sent the images to Richardson and Beck. June 2 is the earliest verified delivery of these two call-history images to Moring in the reviewed physical media, retained folders, and original ZIP packages.

Check the two received call screenshots

The phone display records calls on October 22, 2025. The saved property views show May 11 content-creation and June 2 local file dates. These are different dates; neither view by itself proves when Moring first received the images.

John Beasley · October 22, 2025 · 8:51 a.m.Received phone call screenshot showing an outgoing call to John Beasley on October 22, 2025 at 8:51 a.m.

Open the received screenshot ↗Open the saved file-property view · PDF ↗

Carrie Mahon · October 22, 2025 · 8:48 a.m.Received phone call screenshot showing an outgoing call to Carrie Mahon on October 22, 2025 at 8:48 a.m.

Open the received screenshot ↗Open the saved file-property view · PDF ↗

Limits of the finding

The physical-media inventory establishes the USB contents visible to the filesystem on September 25, 2026, and records SHA-256 hashes for every user-delivered file. It cannot establish what existed elsewhere in City systems. The later call-image files carry May 11, 2026 creation metadata; that timestamp concerns the screenshot files, not the dates of the October 2025 calls displayed within them.

Later response & context

The October 23 media contains five Axon videos and its spreadsheet index, with no still images. The November 3 media contains three text-message screenshots and five audio files. The February 2 Moring-related ZIP contains those same three text screenshots as native-message attachments, but neither February ZIP contains the two later call-history images. The two call-history screenshots appear in the June 2 production and again in the August enclosure material; their embedded file timestamps are May 11, 2026.

Read Nipp’s November 12 text-message timestamps · selected PDF ↗Inspect the retained delivery inventory · PDF ↗John Beasley call screenshot · readable file properties ↗Carrie Mahon call screenshot · readable file properties ↗
Search-scope mismatch

03The requested two branches became an AND filter

The statement

Austin Beck · DTRGAugust 27, 2026

The letter acknowledges the search builder’s “AND” condition: it would populate the phrases “if it had a Walmart e-mail associated with it.” It then treats the request as closed.

DTRG · August 27, 2026 letter · PDF p. 3Item 3: AND acknowledgment and closure

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The comparison records

Kyle’s original requestDecember 30, 2025

Item 1 asks for emails to/from the Walmart domains. Item 2 begins “In addition” and asks for all records containing the listed Walmart terms; it is a separate branch.

December 30, 2025 · Walmart request · PDF p. 1Items 1 and 2

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December 30, 2025 · Walmart request · PDF p. 2Fallback preserves domain production and a department keyword search

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City’s supplied query screenshotExhibit F-2

The Walmart keyword group is joined by AND to a participant-domain condition for @walmart.com / @wal-mart.com.

City plea Exhibit C · supplied search screenshots · PDF p. 18Exhibit F-2 in City plea Exhibit C

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Example of the internal record categoryOctober 23, 2025

Vine and Barrett discuss Walmart and Moring in an internal City email chain. The visible From/To/Cc headers on these pages contain no Walmart-domain participant.

October 23, 2025 · internal Vine / Barrett correspondence · PDF p. 1Internal City participants and Walmart text

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October 23, 2025 · internal Vine / Barrett correspondence · PDF p. 2Earlier internal forward

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MICROSOFT’S DOCUMENTATION

Why the AND condition matters

Microsoft explains that a keyword search joined to a condition with AND returns only items satisfying both. Its Participants property covers sender and recipient fields, including Cc and Bcc; a domain condition identifies messages involving that domain. Microsoft: search conditions ↗ · Microsoft: searchable email properties ↗

Two independent groups: matching keywords and a Walmart-domain participant. This illustrates the logic, not a measured search result.
Message matchesANDOR
Keywords onlyExcludedIncluded
Participant domain onlyExcludedIncluded
Both groupsIncludedIncluded

Application to the supplied records: the request above has two independent branches. The displayed AND condition makes the keyword branch depend on a Walmart-domain participant. That is the specific scope mismatch shown here; it does not establish that no other search ran or how many records were missed.

Microsoft’s documentation explains the query behavior. The request, screenshot and DTRG letters supply the case-specific evidence. Current documentation does not establish the City’s historical configuration. About Microsoft’s KeyQL editor ↗

Hear the September 11 explanation of missing emails, native formats and search history ↗

What the comparison establishes

The displayed AND query does not implement both independent requested branches. It narrows the keyword branch to records with a Walmart participant, excluding purely internal City discussions from that query.

Limits of the finding

The displayed query does not cover the request’s separate keyword branch on its own. The known internal Vine email appeared in a different Moring-related production, so it is not currently missing. These records do not establish that no other search ran or that every later-produced item was absent from every earlier delivery. The 19 supplied files are not a raw search-result count.

Later response & context

After reviewing the 19 Walmart-related emails and the separate Moring-related production, Moring’s February 4 email asked for the actual search scope, queries, date ranges, custodians and systems, and a supplemental search if needed. He raised search concerns again in the February 18 meeting and later Council submissions. DTRG’s August 27 letter acknowledges the displayed AND condition but maintains that the request is closed; its August 25 letter attributes a Walmart count to a January 13 search. Separate requests later brought the October 23 shared-link transmittal and Spark messages into view. August City deliveries also included July 2025 DSHS referrals and the October 27 EPA–TCEQ–City/MPPD thread. These identifiable records allow comparison with earlier deliveries, but do not reveal every search the City performed. On September 25, Ream reported approximately 11,000 results from an agreed new search; production was still pending.

Read Moring’s February 4 search objection · selected PDF ↗Read the name/OSHA search comparison ↗Compare the duplicated Moring/Walmart statistics image ↗Trace the methodology requests and meetings ↗Trace the agency thread across three request scopes and both August deliveries ↗Compare the two later-produced Spark messages ↗DSHS referrals and the documented inspection findings ↗July DSHS referrals and their later City delivery ↗
Unreconciled inconsistency

05May and August review statements need a scope reconciliation

The statement

Austin Beck to Richardson, copied to WebsterMay 13, 2026

Beck says the request yielded over 3,000 pages; maybe 1% was privileged, “which I’ve completed identifying and separating.” He promises the ruling request and remaining-records email that evening.

Beck’s May 13 email · forwarded by Richardson and Bailey · PDF p. 1Original Beck message forwarded by Richardson and Bailey

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The comparison records

DTRG’s later status lettersAugust 25 and 27, 2026

August 25 reports 344 potentially responsive emails and ongoing privilege review. August 27 says the review has now been completed in preparation for the hearing and promises that submission with the letter.

DTRG · August 25, 2026 letter · PDF p. 6Item 4: review under way

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DTRG · August 27, 2026 letter · PDF p. 3Item 4: later completion and production position

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Kent Richardson · OAG Criminal Prosecutions DivisionSeptember 23, 2026

Richardson wrote that he did not think Beck provided information on a request for ruling before the complaint was closed because of the mandamus filing. He requested the mandamus papers and later activity so he could decide whether the complaint should be reopened.

Richardson’s September 23 reply · selected redacted PDF ↗ Prepared reading copy

What the comparison establishes

Beck wrote in May that he had finished separating potentially privileged material from more than 3,000 responsive pages and would submit a ruling request that evening. The August letters describe a later review of 344 potentially responsive emails. Richardson’s September 23 reply says he does not think Beck supplied information about a ruling request before the complaint closed. The sources therefore leave the promised submission and the relationship between the May and August reviews unresolved.

Limits of the finding

The page and email counts use different units and are not a mathematical contradiction. A renewed or differently scoped review could explain the change. Richardson’s wording is qualified—“I don’t think”—and is not a formal finding that no submission existed or that privilege was waived.

Later response & context

DTRG said on August 27 that the later review was complete and separately delivered a USB at the August 28 hearing. On September 23 Richardson requested the mandamus record and a summary of later activity to decide whether the complaint should be reopened. The retained USB and transmittals remain the proper sources for determining which records were actually supplied.

Unreconciled inconsistency

06No-records responses beside pre-existing request-forwarding records

The statement

Candias WebsterFebruary 25 and 27, 2026

Webster closes the methodology request with no-records responses, then certifies that the City possesses no information responsive to the outstanding items because it uses Kyle’s keywords.

February 25 · no-records response · PDF p. 1Three no-records responses and closure

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February 27 · certification to Kyle · PDF p. 1Certification to Kyle; separate from ORD certification forms

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The comparison records

Kyle’s existing-records requestFebruary 9, 2026

Part A.4 expressly asks for exact executed search parameters, including screenshots, export reports or audit logs if maintained; Part B asks for existing custodian outreach and request-routing records. The request disclaims creation of new information.

February 9 · methodology request · PDF p. 1Parts A, B and C

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City-produced forwarding email · PDF copySent January 12, 2026

Webster’s January 12, 2026 email asks Seth Bryan to gather information and lists both December 30 requests as attachments. Moring’s PDF conversion of the produced message is linked here with contact addresses masked. It documents routing and instructions before the February methodology request; it does not prove what query was executed.

January 12 City forwarding email · privacy-screened PDF ↗ Prepared reading copy

Earlier request-routing examplesSeptember 15 and November 14, 2025

Two more City-produced forwarding emails show Webster asking Bryan to gather information for a Walmart inspection-authority request and asking how long another Walmart-related request would take. These establish that IT routing records existed before the February 2026 no-records response; they do not reveal the searches Bryan ultimately ran.

Read the two selected forwarding pages · PDF ↗ Prepared reading copy

Moring search screenshots supplied with both August lettersJanuary 13 completion shown; screenshot capture date unresolved

E-3 displays a January 13 search-completion date and 6,316 matches; E-4 displays the Moring condition builder. These records fit the February 9 request’s description if the screenshots or underlying reports existed when the City received it. The display date alone does not establish when a screenshot was captured. E-5 is an August rerun; the September 18 discussion refers to an additional Walmart OR screenshot without establishing its creation date.

February 9 · methodology request · PDF p. 1Part A.4 expressly includes maintained screenshots and reports

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City plea Exhibit C · supplied search screenshots · PDF p. 15E-3 · January 13 search completion and statistics

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City plea Exhibit C · supplied search screenshots · PDF p. 16E-4 · supplied Moring condition builder

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City’s red-font capability answersMarch 10, 2026

The City’s reply describes Purview searches across metadata and content, .pst/.msg export capability, and Bryan IT running complex mailbox searches at the City’s direction. The linked PDF pages show the reply’s text; this comparison does not rely on the native-file properties of that reply.

March 10 · red-font capability answers · PDF p. 2Platform, retention and export answers

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March 10 · red-font capability answers · PDF p. 3Administrator and IT-support answers

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Council agenda item 25March 17, 2026

At the March 17 Council meeting, Moring described the earlier no-records response and the follow-up IT request. Webster referred to a recently purchased program for screenshots. That later explanation does not account for the earlier forwarding emails. The linked City video starts at the agenda item; the cited PDF pages identify this passage within it.

March 17 · agenda item 25 transcript · PDF p. 2818:56–19:29 within item-25 excerpt

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March 17 · agenda item 25 transcript · PDF p. 2919:31–20:20 · new-program explanation

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City Council video · agenda item 25 begins ↗ External source

IT request quoted in the March 10 responseRequested February 27, 2026

Items 3 and 5 request existing search/export procedures, syntax documentation and City/vendor communications about searches, exports and retention from January 1, 2024 through receipt of the request. They define the categories and time period relevant to this comparison.

March 10 · red-font capability answers · PDF p. 2Request period and search/export documentation, item 3

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March 10 · red-font capability answers · PDF p. 3IT responsibility and support communications, items 4–5

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Lea Ream · DTRGSeptember 25, 2026

Ream reports that the City ran the search agreed during the September conferral, identified approximately 11,000 responsive emails, is reviewing them and hopes to produce them the following week. She also says the City will not charge for the agreed search.

September 25 search update · selected redacted PDF ↗ Prepared reading copy

What the comparison establishes

Pre-existing forwarding emails document routing records that existed before the February methodology request. Later-produced search screenshots provide separate search context; their displayed search dates do not establish when the screenshots themselves were created. The newly agreed search returned approximately 11,000 responsive emails. Its eventual production will permit a direct comparison between the earlier searches, the corrected search methodology and what the City now locates.

Limits of the finding

Forwarding an instruction to IT is different from executing or preserving a query. A result count does not establish responsiveness, completeness or duplication. The September 25 email reports a search result while review and production remain pending; the files must be examined before drawing a final conclusion.

Later response & context

The March 10 capability response and March 17 Council discussion describe the City’s search tools and earlier explanation. The September 18 discussion and September conferral led to a newly agreed search. On September 25, Ream reported approximately 11,000 responsive emails and no charge. This comparison should be updated again when that production arrives.

January 12 City forwarding email · PDF ↗Trace the dated evidence chain ↗DSHS referrals and the documented inspection findings ↗
Unreconciled inconsistency

07The Moring statistics image is also presented as Walmart F-3

The statement

DTRG · August 25 letterAugust 25, 2026

Item 3 attributes 5,991 matches in 174 of 984 locations to a January 13 Walmart search and identifies F-2/F-3 as the supporting query/data screenshots.

DTRG · August 25, 2026 letter · PDF p. 4Item 3 · Walmart result count and stated date

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The comparison records

Full August 25 packetPDF pages 12 and 14

Both pages contain the same embedded statistics image. Its visible query contains Moring/name, whistleblower and OSHA terms, and its completion date is August 13, 2026. It reports 5,991 matches in 174 of 984 locations.

August 25 · complete letter packet · PDF p. 12Moring statistics

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August 25 · complete letter packet · PDF p. 14Same image following Walmart query

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Full August 27 packetE-5 and F-3 · PDF pages 17 and 19

The same statistics image is repeated with the separate E-5 and F-3 labels. The underlying embedded image bytes match both August 25 copies. This is a duplicated Moring-search image under different exhibit headings, not independent Walmart-search statistics.

August 27 · complete letter packet · PDF p. 17E-5 · Moring query and August 13 completion

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August 27 · complete letter packet · PDF p. 19F-3 · same Moring query and completion

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What the comparison establishes

The supplied F-3 image does not substantiate the letter’s stated January 13 Walmart result. Its query and date identify the August Moring search; image matching confirms reuse in both packets.

Limits of the finding

This establishes a mismatch between the supporting screenshot and the represented search. It does not establish whether a separate Walmart run had the same total, identify omitted records, or establish intent. The original request and F-2 AND filter are a separate scope issue.

Later response & context

Moring requested search details when accepting the January cost estimate, repeated the request on February 4 and raised the search questions at the February 18 meeting and in later Council submissions. He identified the cross-request statistics mismatch in his August 26 response. Beck’s August 27 letter acknowledged the Walmart AND condition and maintained closure, but F-3 still displays the Moring query rather than independently verifiable Walmart statistics. Beck separately corrected the January location count from 290 to 209.

Read the February 4 request for search details · selected PDF ↗Trace the methodology requests and meeting ↗Read the Walmart AND comparison ↗Read the Moring search comparison ↗