STATEMENTS & EVIDENCE

September 18: why the details mattered

Listen to the conversations beside the missing-record examples, search settings and production history that explain why Moring asked for verifiable answers.

The September 18 conversation

SEPTEMBER 18 · EARLIER ASSURANCES · PRODUCED RECORDS

Why the details mattered

The September 18, 2026 conversation puts the disputed search settings, missing documentation and possible repeat-search costs into the participants’ own words. Read those exchanges alongside earlier City statements and the produced records.

Listen to the continuous excerpts and open the supporting records below. The symbol ~ marks estimated timing. Personal recollections and conclusions are labeled as Moring’s account.

The search terms: AND requires both conditions; OR allows either. A keyword is a word being searched. A participant condition limits which senders or recipients qualify. These settings can change which emails a search finds.

The paper-clip analogy and the details needed to verify recordsSeptember 18 · 13:53–16:04 · excerpt 1

What was said

Ream says “the big picture is important,” uses a paper clip as an analogy for becoming “super focused” on details, and describes Moring as “sensitive to the details.” She was not saying he disputed literal paper clips. Moring had just asked for the Walmart search summary so he could see how the City searched. The exchange also includes Ream’s account of City expense and Moring saying he is exhausted by the process.

1. Documents, inspections, search details and costs · ~10:32–16:41

~10:32 / 16:41

One continuous excerpt. The player and transcript use the original recording clock; ~ means the timing is estimated.

Read the excerpt transcript

[~10:36] Lea Ream, City Attorney: So...

[~10:37] Kyle Moring: I saw your filing.

[~10:38] Kyle Moring: And, I've got the complete set right here.

[~10:41] Lea Ream, City Attorney: Mhmm.

[~10:42] Kyle Moring: But,

[~10:43] Kyle Moring: I mean, I don't know.

[~10:44] Lea Ream, City Attorney: So,

[~10:45] Lea Ream, City Attorney: this may be that we're like ships passing in the night here.

[~10:48] Kyle Moring: Mm-hmm.

[~10:54] Lea Ream, City Attorney: Like...umm...you might be just trying to talk about stuff

[~10:57] Lea Ream, City Attorney: as opposed to offering evidence.

[~10:58] Kyle Moring: Mhmm.

[~10:59] Lea Ream, City Attorney: And so, um,

[~11:03] Lea Ream, City Attorney: the rules of evidence are about the submission of evidence,

[~11:05] Lea Ream, City Attorney: right?

[~11:06] Kyle Moring: Right.

[~11:06] Lea Ream, City Attorney: So,

[~11:07] Lea Ream, City Attorney: that's where we get...

[~11:10] Lea Ream, City Attorney: challenges,

[~11:11] Lea Ream, City Attorney: right?

[~11:11] Kyle Moring: Mhmm.

[~11:11] Lea Ream, City Attorney: And so,

[~11:12] Lea Ream, City Attorney: and like,

[~11:13] Lea Ream, City Attorney: as I,

[~11:13] Lea Ream, City Attorney: as we talked about last Friday,

[~11:17] Lea Ream, City Attorney: documents have to be complete and all of those different things,

[~11:19] Lea Ream, City Attorney: because otherwise it appears

[~11:21] Lea Ream, City Attorney: that they're,

[~11:21] Lea Ream, City Attorney: I mean, who knows, right?

[~11:22] Kyle Moring: Right.

[~11:23] Lea Ream, City Attorney: They could be taken out of context or,

[~11:24] Lea Ream, City Attorney: and if you're on some

[~11:26] Lea Ream, City Attorney: sort of appeal or something like that, um,

[~11:29] Lea Ream, City Attorney: the court of appeals would not have any reference,

[~11:33] Lea Ream, City Attorney: right?

[~11:33] Kyle Moring: Mhmm.

[~11:33] Lea Ream, City Attorney: For that kind of thing. And so,

[~11:34] Lea Ream, City Attorney: So I'm not trying to be...um...

[~11:37] Kyle Moring: No, I get it.

[~11:38] Kyle Moring: I mean, it's your job to do that.

[~11:39] Lea Ream, City Attorney: Yeah, exactly.

[~11:40] Lea Ream, City Attorney: It's my job.

[~11:41] Kyle Moring: I totally get it.

[~11:42] Lea Ream, City Attorney: Exactly.

[~11:44] Kyle Moring: Yeah, I'd have the complete threads in there, but honestly, I don't know.

[~11:47] Kyle Moring: I'm really just tired of this.

[~11:49] Lea Ream, City Attorney: Well, we are too.

[~11:52] Lea Ream, City Attorney: But,

[~11:53] Lea Ream, City Attorney: I mean, Mr.

[~12:04] Lea Ream, City Attorney: Moring...

[~11:54] Lea Ream, City Attorney: Like really like if we're talking,

[~11:57] Lea Ream, City Attorney: if you think we haven't given you something,

[~11:59] Lea Ream, City Attorney: I mean I understand you have some like,

[~12:01] Lea Ream, City Attorney: I think this should have turned up

[~12:03] Lea Ream, City Attorney: or that should have turned up.

[~12:04] Lea Ream, City Attorney: And you know,

[~12:05] Lea Ream, City Attorney: I don't know what to say about that

[~12:07] Lea Ream, City Attorney: other than we did the searches,

[~12:10] Lea Ream, City Attorney: we produced the documents that we had.

[~12:12] Lea Ream, City Attorney: And I mean,

[~12:13] Lea Ream, City Attorney: I know you're very, very precise

[~12:15] Lea Ream, City Attorney: and very focused.

[~12:16] Lea Ream, City Attorney: on certain things and um but we want to bring this to an end right?

[~12:21] Kyle Moring: Right.

[~12:22] Lea Ream, City Attorney: when this is

[~12:22] Lea Ream, City Attorney: costing the city a lot of money.

[~12:23] Kyle Moring: No I'm yeah I understand that and I know that

[~12:26] Kyle Moring: like for example the the correspondence that you guys produced with you guys

[~12:31] Kyle Moring: part of that request was like the invoices you know for the billing it

[~12:35] Kyle Moring: wasn't produced.

[~12:37] Lea Ream, City Attorney: Well you have to understand that it's only what's

[~12:40] Lea Ream, City Attorney: available when you make that request

[~12:41] Kyle Moring: Mhm.

[~12:41] Lea Ream, City Attorney: so it may not have been in there right like

[~12:44] Lea Ream, City Attorney: it may have not been there at the time

[~12:45] Lea Ream, City Attorney: that you made the request.

[~12:46] Kyle Moring: Okay.

[~12:48] Lea Ream, City Attorney: It's one of those,

[~12:48] Lea Ream, City Attorney: like,

[~12:49] Lea Ream, City Attorney: you know, it's a snapshot right in time.

[~12:51] Kyle Moring: Right.

[~12:51] Lea Ream, City Attorney: You know that.

[~12:52] Lea Ream, City Attorney: And so I don't know.

[~12:53] Lea Ream, City Attorney: I mean, but,

[~12:54] Lea Ream, City Attorney: again,

[~12:54] Lea Ream, City Attorney: happy to, but,

[~12:55] Lea Ream, City Attorney: you know, we'll, there's also privileged communication

[~12:58] Lea Ream, City Attorney: in there.

[~12:58] Lea Ream, City Attorney: I'm assuming that you would agree to us redacting...

[~13:01] Kyle Moring: Right, right, right.

[~13:02] Lea Ream, City Attorney: Privileged communications umm...

[~13:03] Kyle Moring: And then, like,

[~13:04] Kyle Moring: the other thing was, like,

[~13:06] Kyle Moring: with the...

[~13:07] Kyle Moring: It's the main thing pretty much, the Walmart related stuff.

[~13:12] Kyle Moring: The permits and inspections,

[~13:13] Kyle Moring: Like HS Cloud, even the contract says, they've got the ability

[~13:18] Kyle Moring: to do the electronic export.

[~13:20] Kyle Moring: And some of the pages they print out weren't even saved when they...

[~13:24] Kyle Moring: printed them out,

[~13:25] Kyle Moring: you could tell

[~13:27] Kyle Moring: the bubbles,

[~13:28] Kyle Moring: you know, you put the

[~13:29] Kyle Moring: entries in,

[~13:29] Lea Ream, City Attorney: Mhmm.

[~13:29] Kyle Moring: like the violations and stuff,

[~13:31] Kyle Moring: they were still open.

[~13:33] Kyle Moring: And it's like,

[~13:34] Lea Ream, City Attorney: I mean...

[~13:34] Kyle Moring: and I know you don't

[~13:34] Kyle Moring: understand. Like

[~13:35] Lea Ream, City Attorney: I can't speak to whether

[~13:36] Kyle Moring: Right

[~13:36] Lea Ream, City Attorney: or not

[~13:37] Lea Ream, City Attorney: there's a better way to do it. I know that

[~13:39] Lea Ream, City Attorney: you know

[~13:39] Kyle Moring: Yeah

[~13:39] Lea Ream, City Attorney: the history of that

[~13:41] Lea Ream, City Attorney: better than I do,

[~13:41] Lea Ream, City Attorney: but that we

[~13:43] Lea Ream, City Attorney: didn't have the ability to print it, period,

[~13:45] Lea Ream, City Attorney: and then we're trying to figure out how to

[~13:46] Kyle Moring: Right.

[~13:47] Lea Ream, City Attorney: try, and I guess we've given you

[~13:48] Lea Ream, City Attorney: some of that stuff that you feel like it's not sufficient.

[~13:51] Kyle Moring: Pretty much, yeah.

[~13:52] Lea Ream, City Attorney: Okay.

[~13:52] Kyle Moring: Yeah.

[~13:53] Lea Ream, City Attorney: But, I mean, if we have some focused things,

[~13:55] Lea Ream, City Attorney: again, we're not refusing to um provide those

[~14:00] Lea Ream, City Attorney: to you.

[~14:01] Lea Ream, City Attorney: It's just uh but we need to be focused,

[~14:04] Lea Ream, City Attorney: right?

[~14:04] Lea Ream, City Attorney: Like, in fairness to you,

[~14:07] Lea Ream, City Attorney: you're a very intelligent person.

[~14:10] Lea Ream, City Attorney: I have no doubt about that.

[~14:14] Lea Ream, City Attorney: But sometimes when you're putting these things in the AI kind of filter,

[~14:18] Lea Ream, City Attorney: it just comes out as like...

[~14:20] Kyle Moring: Well,

[~14:20] Lea Ream, City Attorney: It's just too much.

[~14:21] Kyle Moring: yeah, that and I like to overthink everything.

[~14:23] Kyle Moring: And I know that I have a problem with that, too.

[~14:25] Lea Ream, City Attorney: I do that,

[~14:25] Lea Ream, City Attorney: too.

[~14:26] Kyle Moring: I mean, things are way more complex than they need to be

[~14:28] Kyle Moring: because I'm trying to cover all my bases, but...

[~14:30] Lea Ream, City Attorney: Well, we're not...

[~14:31] Lea Ream, City Attorney: I mean, honestly,

[~14:31] Lea Ream, City Attorney: we're really like...

[~14:33] Lea Ream, City Attorney: That's not, that's not in the City's best interest.

[~14:35] Lea Ream, City Attorney: it's not in your best interest.

[~14:36] Lea Ream, City Attorney: We're not, if it's something you requested,

[~14:38] Lea Ream, City Attorney: if the documents existed,

[~14:40] Lea Ream, City Attorney: of course,

[~14:41] Lea Ream, City Attorney: the snapshot,

[~14:42] Lea Ream, City Attorney: right, and the time frame

[~14:43] Kyle Moring: Mhmm.

[~14:43] Lea Ream, City Attorney: and all that,

[~14:44] Lea Ream, City Attorney: we're not,

[~14:47] Lea Ream, City Attorney: you know, if you think

[~14:49] Lea Ream, City Attorney: that this is missing or that's missing

[~14:51] Lea Ream, City Attorney: or there's some data missing,

[~14:52] Lea Ream, City Attorney: we're not refusing to provide

[~14:54] Lea Ream, City Attorney: that to you, but we just need to be focused on what that is.

[~14:56] Kyle Moring: Would they just produce,

[~14:58] Kyle Moring: you know, what the summary of the screenshot was,

[~15:01] Kyle Moring: you know,

[~15:02] Kyle Moring: the…

[~15:02] Lea Ream, City Attorney: On that Walmart?

[~15:03] Kyle Moring: …on the KeyQL?

[~15:04] Lea Ream, City Attorney: I can find out.

[~15:05] Kyle Moring: I mean, if they do that,

[~15:06] Kyle Moring: like where I can see what was searched,

[~15:08] Kyle Moring: just the summary of the KeyQL

[~15:10] Lea Ream, City Attorney: Yeah.

[~15:11] Kyle Moring: I mean, that's fine.

[~15:12] Kyle Moring: I mean I'm just tired of this.

[~15:14] Lea Ream, City Attorney: I'm sure it's stressful for you.

[~15:15] Kyle Moring: Because I've got a lot more things you guys don't even realize going on

[~15:19] Lea Ream, City Attorney: Yeah.

[~15:19] Kyle Moring: with other agencies.

[~15:20] Kyle Moring: And it's like,

[~15:21] Lea Ream, City Attorney: Yeah

[~15:21] Kyle Moring: and I'm representing myself.

[~15:23] Kyle Moring: And it's been going on for a year and a half and

[~15:25] Kyle Moring: I'm just tired. Like

[~15:27] Lea Ream, City Attorney: Well, and it's, I think, let me just say that.

[~15:35] Lea Ream, City Attorney: And let me just say that the umm

[~15:41] Lea Ream, City Attorney: the big picture is important,

[~15:42] Lea Ream, City Attorney: right?

[~15:42] Kyle Moring: Mhmm.

[~15:42] Lea Ream, City Attorney: And we can get super focused on whether or not um you know

[~15:48] Lea Ream, City Attorney: we gave it to you with a paper clip or not.

[~15:50] Kyle Moring: Right.

[~15:50] Lea Ream, City Attorney: You know what I mean?

[~15:50] Kyle Moring: Right right.

[~15:53] Lea Ream, City Attorney: And and that just doesn't I don't know if that's really meaningful

[~15:56] Lea Ream, City Attorney: and I appreciate that you are very

[~16:00] Lea Ream, City Attorney: sensitive to the details.

[~16:02] Lea Ream, City Attorney: And so, but,

[~16:03] Lea Ream, City Attorney: you know,

[~16:04] Lea Ream, City Attorney: that's not what we're here to do.

[~16:05] Lea Ream, City Attorney: You've been lots of places.

[~16:07] Lea Ream, City Attorney: We've, I mean, the City, the City is really

[~16:10] Lea Ream, City Attorney: spending an extraordinary amount

[~16:12] Lea Ream, City Attorney: of money responding to these things.

[~16:13] Lea Ream, City Attorney: This is our third trip.

[~16:15] Kyle Moring: Yeah. I know.

[~16:16] Lea Ream, City Attorney: To a court hearing.

[~16:17] Lea Ream, City Attorney: And so,

[~16:20] Lea Ream, City Attorney: um

[~16:21] Lea Ream, City Attorney: You know,

[~16:22] Lea Ream, City Attorney: it's the taxpayers that are paying that money.

[~16:26] Kyle Moring: Right.

[~16:26] Lea Ream, City Attorney: You know,

[~16:27] Kyle Moring: So...

[~16:27] Lea Ream, City Attorney: I'm even giving discounts upon discounts.

[~16:29] Kyle Moring: So...

[~16:30] Lea Ream, City Attorney: But I can't, I mean, at some point,

[~16:31] Lea Ream, City Attorney: like,

[~16:32] Lea Ream, City Attorney: you know, if I'm not spending my time here,

[~16:34] Lea Ream, City Attorney: I'm working for other people.

[~16:35] Kyle Moring: Right, right.

[~16:36] Kyle Moring: And San Antonio is a good drive

[~16:38] Kyle Moring: or even if you fly

[~16:39] Kyle Moring: It's, you know, a decent amount of money

Earlier recorded statements

Vine and Hinton · February 18Original about 1:06:35–1:06:40 · released player about 50:15–50:20

In the discussion of estimate-template errors, Vine says, “Attention to detail.” Vine then says, “I would agree with you on that,” and Hinton adds, “Yeah, 100%.”

Hear the earlier passage · Vine and Hinton · February 18

Full recording & transcript ↗

What the records show

The produced Walmart search screenshot joins the keyword group to a Walmart-domain participant condition with AND. That requires both conditions, although the original request separately sought Walmart-domain correspondence and, “in addition,” records containing the listed Walmart terms. Internal City messages can match the keywords without involving a Walmart-domain sender or recipient. The same Moring-query statistics image also appears under both Moring and Walmart exhibit headings. Later productions provide identifiable records against which the earlier completeness statements can be tested.

July DSHS referrals: notice to the City, followed by much later production

DSHS sent Moring’s roof/public-exposure concerns to John Ankrum on July 15, 2025, and food-contamination concerns on July 21. Both messages refer to Walmart and Moring. Copies appear in the City’s August 4 and August 25, 2026 deliveries. The July 21 referral also falls within the July 30 code-compliance request’s July 18–30 complaint period, although whether an agency referral counts as a complaint “filed with the City” requires careful reading. The July 15 referral falls outside that item’s date range.

The two referrals’ outer message identifiers do not match the initial 19-message Walmart delivery. A focused comparison of the initial Moring set also found no matching identifiers or distinctive subjects in the fields checked. These are later-received records; the comparison does not claim they are still missing or that every embedded attachment has been exhaustively searched.

The locally retained August 13, 2025 code-compliance delivery folder has nine PDFs and no July 21 referral. Webster’s later signed form marks all existing responsive information as supplied on August 13. The saved folder and form raise a concrete question; the retained folder alone does not prove it contains every item that was accessible through the original SharePoint link.

July 15 DSHS referral · PDF ↗July 21 DSHS referral · PDF ↗August production history and the scope of the comparison ↗July 30 code-compliance request and response history ↗Signed completeness form · PDF page ↗

EPA–TCEQ–City/MPPD: another requester received the thread first

The October 27, 2025 forwarded complaint thread contains Walmart and Kyle Moring references. It was supplied to another requester on August 14, 2026, and to Moring on August 25—11 days later. The retained native copies from those deliveries are identical. Its subject matter also falls within the February 8 regulatory-agency request.

The October 27 message’s outer identifier is absent from the initial 19-message Walmart set. Keep it distinct from the separate October 28 “video” email, whose readable text had already been produced on May 21. The question is why this identifiable thread emerged through the later productions after the earlier search and closure assurances.

October 27 forwarded complaint thread · PDF ↗Both deliveries and the three request scopes ↗

Shared-link emails and Spark records: separate requests recovered older messages

On February 25, 2026, the shared-link request led first to two repository links and the October 28 email, then to the omitted October 23 transmittal after Moring pointed it out. Webster apologized and said both emails contained the same links. The later delivery is credited; it does not answer what the folders contained when originally shared.

The March 3 Spark production included a September 11, 2024 approval and a March 25, 2025 internal forward. Both contain Walmart text and fall within the earlier Walmart request’s period, but their outer identifiers are absent from the original 19-message delivery. “Spark” was a later search term; the original request already included an independent Walmart-keyword branch.

Shared-link request, replies and correction · PDF ↗Spark request and production correspondence · PDF ↗Compare the two later-produced Spark messages ↗

The fire-department email, the AG ruling and the later delivery

Rodriguez’s October 23, 2025 message said he would send fire-alarm and sprinkler-system emails and plans. Moring’s February 9 supplemental request pursued that omitted material. Moring challenged the need to seek an AG ruling over material he said he already held; the June 2 ruling expressly acknowledges his prior-release argument.

The ruling, OR2026-018153, required the City to withhold the marked critical-infrastructure details and release the remaining information. It did not say that everything submitted was confidential, or that prior disclosure overrides confidentiality imposed by law. That distinction matters to both the earlier disclosure concern and the later withholding concern.

Moring’s filed notice records an August 13 complaint to the Titus County DA about compliance with the ruling, the related native email’s appearance in the August 28 USB production, and Beck’s September 15 delivery of four pages under the ruling. The notice credits receipt and says the four pages repeat material already held. This documents production after the complaint; it does not establish why the City waited or prove that the complaint caused the delivery.

Supplemental request and counsel’s ruling correspondence · PDF ↗June 2 AG letter: what must be withheld and released · PDF ↗Filed production chronology and September 15 delivery email · PDF ↗

Native format and metadata are part of checking the record

Metadata can identify a message’s sender, recipients, date, attachments and relationship to a thread. Native files can preserve information that a printout does not expose. TSLAC treats existing metadata as part of an electronic record. Asking for that context addresses authenticity and completeness; it is not simply a cosmetic preference. The requested-medium rules separately depend on the agency’s technological ability and the applicable statutory conditions.

Moring’s August 26, 2025 email to Beck already cited Bluebeam and PDFKit properties in supplied PDFs and challenged additional print-and-scan labor. That correspondence documents the warning he gave; the software name alone does not prove how every source record was created or what each City account could export. The inspection-format comparison below adds the City’s contract and the specific capability questions.

August 26 format objection to Beck · PDF page 4 ↗TSLAC: metadata and electronic records ↗Texas Government Code §552.228: requested medium ↗Inspection copies, print output and electronic capability ↗

The methodology question predated September

On January 15, Beck told Webster that she did not need to answer the part of Moring’s emails asking how responsive information was located. That instruction concerned answering questions; it does not settle whether existing search records requested under the Public Information Act had to be produced.

At the February 18 meeting, Moring again described his unanswered requests for search methodology; Lyon asked whether the raw data showing what IT ran would help. On March 17, Webster pointed to “morning” as a term that returned more messages. City messages themselves had addressed Moring as “Mr. Morning,” which explains why he included that spelling. The remaining question is whether the actual query and scope matched both branches of his request.

January 15 Beck email · PDF page 7 ↗February 18 meeting audio and transcript ↗March 17 exchange · transcript page ↗

City plea Exhibit C · supplied search screenshots · PDF p. 18F-2: Walmart terms joined to a participant condition

Selected page 18 of 30. Page references refer to this version of the source.

Open this source page at full size ↗ City plea Exhibit C · supplied search screenshots, reading-copy PDF page 18. F-2: Walmart terms joined to a participant condition

City plea Exhibit C · supplied search screenshots, reading-copy PDF page 18. F-2: Walmart terms joined to a participant condition

August 27 · complete letter packet · PDF p. 19F-3: Moring query and statistics presented under the Walmart heading

Selected page 19 of 30. Page references refer to this version of the source.

Open this source page at full size ↗ August 27 · complete letter packet, reading-copy PDF page 19. F-3: Moring query and statistics presented under the Walmart heading

August 27 · complete letter packet, reading-copy PDF page 19. F-3: Moring query and statistics presented under the Walmart heading

Why this mattersThe comparison is testable: the Walmart request set out separate domain and keyword branches, while the produced search image adds a Walmart-domain participant condition with AND to the keyword group. That condition could exclude internal City messages containing the requested words. The City attributed gaps to Moring’s keywords; the saved query and later-produced messages require a separate explanation. A later delivery does not, by itself, explain or validate the original search.

Kyle Moring · Commentary

“When the details that establish a record’s accuracy are dismissed as irrelevant, records integrity and transparency become expendable.”

The City’s response and explanation

Ream also says the City is not refusing requested records that existed within the relevant period, asks for a focused description of what is missing and says “I can find out” about the Walmart summary. DTRG’s August 27 letter acknowledges the AND condition while maintaining that the request is closed. Those explanations are included for readers to compare with the request and the later-found messages. Vine and Hinton’s earlier “attention to detail” exchange concerns estimate-template errors, a different example of why accuracy mattered.

What was—and was not—being billed

Around ~16:07–16:27, Ream describes City expense, taxpayer resources and discounts. Around ~18:15–18:19, she says she is not billing the City for reviewing Moring’s emails and that she scans them. Those statements concern different categories of work; neither gives a total cost. Moring’s February 14 request expressly sought attorney fee bills, invoices and payment records relating to his Walmart matters. Compare any responsive billing records and the City’s response before assigning an amount or cause to the expense.

Email-review billing and the requested search summary · ~17:25–19:24

~17:25 / 19:24

Read the billing exchange transcript ↗

What remains unresolved

Moring disputes the adequacy of the City’s records management and its application of basic records guidance. That is his assessment of the documented pattern, not an agency finding about every employee’s knowledge. An absent outer message identifier does not exclude every possible quoted or embedded copy. The examples establish concrete questions about search coverage and production sequence; they do not establish intent or deliberate tampering.

Compare the duplicated search-statistics images ↗Read the template-error evidence ↗Metadata and email-integrity findings ↗

The keyword explanation beside the admitted AND conditionSeptember 18 · 31:20–33:47 · excerpt 4

What was said

Bryan asks about changing the participant condition from AND to OR, says the earlier search “did AND,” and anticipates more emails and a separate export. Moring identifies the participant condition as the concern. Lyon describes using both parameters and obtaining more results.

4. Telephone query discussion, rerun, possible cost and scope · ~30:28–36:18

~30:28 / 36:18

One continuous excerpt. The player and transcript use the original recording clock; ~ means the timing is estimated.

Read the excerpt transcript

[~30:28] Lea Ream, City Attorney: Okay, I'm gonna...I'm gonna

[~30:30] Lea Ream, City Attorney: Let me go see if I'm going to let him explain to y'all what it is that he's looking for.

[~30:43] Lea Ream, City Attorney: Okay,

[~30:43] Lea Ream, City Attorney: Kyle, so we have, I have Seth and Candias on the phone here.

[~30:49] Lea Ream, City Attorney: And like I'm, and of course here's the Mayor.

[~31:00] Kyle Moring: Okay.

[~30:53] Lea Ream, City Attorney: So this is that Walmart search,

[~30:56] Lea Ream, City Attorney: right?

[~30:56] Lea Ream, City Attorney: But you've seen that.

[~30:58] Kyle Moring: Right. I'm, I'm

[~30:59] Kyle Moring: And it also had the "AND",

[~31:00] Kyle Moring: like I pointed out why it's an issue

[~31:02] Kyle Moring: to have the "AND" in the participants.

[~31:04] Kyle Moring: Because they should be looking for both things,

[~31:05] Kyle Moring: but the actual KeyQL search with just,

[~31:09] Kyle Moring: you know,

[~31:10] Kyle Moring: even if it's just headers of the emails,

[~31:13] Kyle Moring: the email addresses,

[~31:14] Kyle Moring: or it shows kind of like

[~31:15] Kyle Moring: what he's doing for the um district attorney record request.

[~31:20] Lea Ream, City Attorney: Seth, can you hear that?

[~31:22] Seth Bryan, Bryan IT: Yes,

[~31:22] Seth Bryan, Bryan IT: yes.

[~31:23] Seth Bryan, Bryan IT: Okay,

[~31:23] Seth Bryan, Bryan IT: so just so I am getting this correct, Kyle

[~31:25] Seth Bryan, Bryan IT: so you want me to remove the "AND", uh,

[~31:28] Seth Bryan, Bryan IT: the "AND"

[~31:29] Seth Bryan, Bryan IT: condition there, to "OR"?

[~31:31] Kyle Moring: Yeah, I think that's the way that it would, it would pick up,

[~31:35] Kyle Moring: you know, what I had requested

[~31:37] Lea Ream, City Attorney: if it's with "OR".

[~31:38] Mayor Wesley Lyon: Is it SQL?

[~31:40] Kyle Moring: Mm-hmm.

[~31:40] Mayor Wesley Lyon: Uh, it's "AND", and "OR".

[~31:43] Lea Ream, City Attorney: Uh-huh.

[~31:43] Mayor Wesley Lyon: It's actually both of them.

[~31:45] Lea Ream, City Attorney: Okay,

[~31:46] Lea Ream, City Attorney: Okay so you want us to run this search again with it?

[~31:52] Kyle Moring: Yeah, just those same parameters. And I just you know just see what.

[~31:55] Lea Ream, City Attorney: But "AND/OR".

[~31:56] Kyle Moring: Mhmm.

[~31:56] Lea Ream, City Attorney: Okay,

[~31:57] Lea Ream, City Attorney: can we do that guys?

[~31:59] Seth Bryan, Bryan IT: Sure,

[~32:00] Seth Bryan, Bryan IT: yeah. Definitely.

[~32:01] Seth Bryan, Bryan IT: So let me just go back to that same uh search

[~32:06] Lea Ream, City Attorney: Those same keywords?

[~32:07] Seth Bryan, Bryan IT: and I'll just adjust those parameters

[~32:08] Kyle Moring: Yeah, I think the search is fine.

[~32:09] Kyle Moring: It's more just the participants.

[~32:11] Lea Ream, City Attorney: "AND/OR",

[~32:11] Kyle Moring: Mhmm.

[~32:12] Lea Ream, City Attorney: Yeah. Okay.

[~32:14] Lea Ream, City Attorney: And then what you get,

[~32:16] Lea Ream, City Attorney: and then that produces X documents,

[~32:20] Lea Ream, City Attorney: right?

[~32:20] Kyle Moring: Mm-hmm.

[~32:23] Lea Ream, City Attorney: So...

[~32:29] Candias Webster, City Secretary: And then we have to go through those again?

[~32:30] Lea Ream, City Attorney: Well so, would it, I would think that's what we'd have to do,

[~32:31] Lea Ream, City Attorney: but I guess what we

[~32:32] Lea Ream, City Attorney: did before was "AND"? or we did "OR"? Seth, do you know?

[~32:37] Seth Bryan, Bryan IT: Yeah, so yeah, it did "AND" umm and I...

[~32:41] Lea Ream, City Attorney: Oh who is this...

[~32:42] Seth Bryan, Bryan IT: I'm trying to think.

[~32:44] Seth Bryan, Bryan IT: So technically because it's looking for keywords with the word Walmart as well as participants

[~32:51] Seth Bryan, Bryan IT: of Walmart,

[~32:51] Seth Bryan, Bryan IT: so yeah, that would just produce,

[~32:55] Seth Bryan, Bryan IT: yeah, I can just change at the "AND/OR" or it will

[~32:57] Seth Bryan, Bryan IT: probably generate um a lot more emails and it would technically be a separate export.

[~33:03] Seth Bryan, Bryan IT: But um yeah, I can just go back to that original case and change that. That's not a hard thing to do.

[~33:07] Lea Ream, City Attorney: So,

[~33:08] Candias Webster, City Secretary: I have a screenshot here where we actually did do it with "OR" and it produced the same amount.

[~33:16] Candias Webster, City Secretary: Like I can send it to you.

[~33:18] Seth Bryan, Bryan IT: Oh,

[~33:18] Seth Bryan, Bryan IT: that's when I did the KeyQL.

[~33:20] Candias Webster, City Secretary: Yeah,

[~33:21] Candias Webster, City Secretary: and we did a screen, a

[~33:23] Candias Webster, City Secretary: screenshot where it pretty much produced the exact same stuff.

[~33:27] Lea Ream, City Attorney: So, okay just let me

[~33:28] Kyle Moring: But it's like he said, the "AND/OR", the participants.

[~33:30] Kyle Moring: You're right,

[~33:31] Kyle Moring: yeah.

[~33:31] Lea Ream, City Attorney: But why wouldn't, why wouldn't "OR" give you more?

[~33:35] Lea Ream, City Attorney: Like,

[~33:35] Lea Ream, City Attorney: if it's...

[~33:35] Mayor Wesley Lyon: If you don't use the "AND", that's what I did,

[~33:39] Mayor Wesley Lyon: like, the last 20 years.

[~33:40] Mayor Wesley Lyon: The "AND/OR" was actually using both of those parameters,

[~33:43] Lea Ream, City Attorney: Uh-huh

[~33:43] Mayor Wesley Lyon: so it'll pull more than just one

[~33:46] Mayor Wesley Lyon: or the other.

[~33:47] Lea Ream, City Attorney: okay

[~33:47] Mayor Wesley Lyon: does that make sense

[~33:49] Mayor Wesley Lyon: it's weird

[~33:50] Lea Ream, City Attorney: Not to me it seems like if it has one

[~33:51] Lea Ream, City Attorney: it should pull it

[~33:52] Kyle Moring: It. Yeah

[~33:53] Lea Ream, City Attorney: yeah

[~33:53] Lea Ream, City Attorney: when it has both

[~33:54] Mayor Wesley Lyon: yeah it's a sequel thing

[~33:55] Seth Bryan, Bryan IT: Mhmm.

[~33:55] Lea Ream, City Attorney: okay

[~33:56] Lea Ream, City Attorney: alright

[~33:57] Lea Ream, City Attorney: so

[~33:58] Lea Ream, City Attorney: um

[~34:01] Lea Ream, City Attorney: okay

[~34:02] Lea Ream, City Attorney: and then we'll have to look through those

[~34:03] Lea Ream, City Attorney: and that's gonna take time

[~34:05] Kyle Moring: that's fine

[~34:06] Lea Ream, City Attorney: All right, so, so,

[~34:09] Lea Ream, City Attorney: Seth,

[~34:10] Lea Ream, City Attorney: can you write for me in words?

[~34:10] Seth Bryan, Bryan IT: Mhmm.

[~34:13] Lea Ream, City Attorney: Because I want to put this on the record before the judge, are you

[~34:16] Lea Ream, City Attorney: do you agree to that?

[~34:18] Lea Ream, City Attorney: That what the parties have agreed is basically to run this search again with "AND/OR" right?

[~34:27] Lea Ream, City Attorney: and once the city has reviewed those records

[~34:30] Lea Ream, City Attorney: and provided those in accordance with the normal,

[~34:33] Lea Ream, City Attorney: I mean, there might be a cost involved in that if it's additional.

[~34:36] Kyle Moring: Okay

[~34:38] Lea Ream, City Attorney: Then we'll,

[~34:40] Lea Ream, City Attorney: and that's it.

[~34:42] Lea Ream, City Attorney: We're done with this.

[~34:43] Kyle Moring: Mhmm.

[~34:43] Lea Ream, City Attorney: Right?

[~34:43] Lea Ream, City Attorney: We're done with the the lawsuit, and um,

[~34:47] Lea Ream, City Attorney: and it will be dismissed.

[~34:50] Lea Ream, City Attorney: Right?

[~34:51] Lea Ream, City Attorney: okay

[~34:52] Lea Ream, City Attorney: alright

[~34:52] Lea Ream, City Attorney: and I don't want

[~34:53] Lea Ream, City Attorney: we don't want to come back here

[~34:55] Kyle Moring: no

[~34:56] Kyle Moring: I don't either

[~34:59] Seth Bryan, Bryan IT: Sounds good

[~34:59] Seth Bryan, Bryan IT: okay

[~35:00] Seth Bryan, Bryan IT: so yeah

[~35:00] Seth Bryan, Bryan IT: I can I can certainly

[~35:01] Seth Bryan, Bryan IT: I'll change that over

[~35:02] Seth Bryan, Bryan IT: and I can write up an email

[~35:04] Seth Bryan, Bryan IT: and send it over to you

[~35:05] Lea Ream, City Attorney: thank you very much

[~35:07] Seth Bryan, Bryan IT: and send it to Candias

[~35:08] Seth Bryan, Bryan IT: yeah

[~35:08] Seth Bryan, Bryan IT: I will get this export

[~35:10] Seth Bryan, Bryan IT: started right now

[~35:11] Lea Ream, City Attorney: thank you

[~35:12] Lea Ream, City Attorney: I appreciate it so much

[~35:13] Lea Ream, City Attorney: and thank you Candias

[~35:15] Lea Ream, City Attorney: and I think you're

[~35:16] Lea Ream, City Attorney: Candias you're on

[~35:17] Lea Ream, City Attorney: you don't need to come down

[~35:18] Lea Ream, City Attorney: I think right now

[~35:20] Candias Webster, City Secretary: Yes ma'am

[~35:20] Lea Ream, City Attorney: All right,

[~35:21] Lea Ream, City Attorney: thank you.

[~35:21] Kyle Moring: Thank you.

[~35:22] Candias Webster, City Secretary: You're welcome.

[~35:23] Seth Bryan, Bryan IT: Thank you guys.

[~35:24] [Overlapping speech; words unclear.]

[~35:26] Mayor Wesley Lyon: So they're running that in, for the mail database?

[~35:32] Lea Ream, City Attorney: Uh yeah, that's right,

[~35:33] Lea Ream, City Attorney: that's what they're

[~35:33] Lea Ream, City Attorney: I mean,

[~35:34] Lea Ream, City Attorney: whatever it was he requested before

[~35:35] Lea Ream, City Attorney: in terms of the database.

[~35:36] Mayor Wesley Lyon: [Unclear: “So more like the emails?”]

[~35:36] Kyle Moring: Yeah, it said email,

[~35:39] Kyle Moring: but it's like,

[~35:40] Kyle Moring: I'm not even gonna push my luck on the rest of it.

[~35:41] Kyle Moring: I mean,

[~35:42] Kyle Moring: it was supposed to be all the platforms,

[~35:44] Kyle Moring: but it's, I'm not gonna do that.

[~35:46] Lea Ream, City Attorney: Email,

[~35:47] Lea Ream, City Attorney: that's what you're looking for.

[~35:48] Lea Ream, City Attorney: okay all right

[~35:53] Lea Ream, City Attorney: all right well see this is this is what conferring does for us, we can...all right

[~36:02] Lea Ream, City Attorney: let me um

[~36:03] Mayor Wesley Lyon: So who's running that query is that gonna be Seth or Austin?

[~36:07] Lea Ream, City Attorney: Yeah Seth is

[~36:08] Mayor Wesley Lyon: Seth is?

[~36:10] Lea Ream, City Attorney: yeah okay let me go and um communicate with the court just so we can get one thing off her docket if she's um....

Earlier recorded statements

Lyon · February 18Original about 17:55 · released player about 1:35

Discussing the missing records, Lyon says “they’re not meeting those keywords” and suggests identifying senders, recipients and a date range. He attributes the explanation to Webster.

Hear the earlier passage · Lyon · February 18

Full recording & transcript ↗

What the records show

The original request has two separate branches: Walmart-domain correspondence and, “In addition,” records containing Walmart terms. F-2 requires both a keyword match and a Walmart participant. An internal City email can contain the requested words and still be excluded by that additional condition. The August 27 letter acknowledges the AND condition while treating the request as closed.

December 30, 2025 · Walmart request · PDF p. 1Original request: items 1 and 2

Selected page 1 of 3. Page references refer to this version of the source.

Open this source page at full size ↗

December 30, 2025 · Walmart request, reading-copy PDF page 1. Original request: items 1 and 2

City plea Exhibit C · supplied search screenshots · PDF p. 18Supplied F-2 condition builder

Selected page 18 of 30. Page references refer to this version of the source.

Open this source page at full size ↗

City plea Exhibit C · supplied search screenshots, reading-copy PDF page 18. Supplied F-2 condition builder

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

Selected page 3 of 5. Page references refer to this version of the source.

Open this source page at full size ↗

DTRG · August 27, 2026 letter, reading-copy PDF page 3. DTRG: AND acknowledgment and closure position

Why this mattersThe September discussion identifies a technical reason to question the earlier keyword explanation and the adequacy of the search defended in the City’s filing materials. Whether a message contains a keyword and whether it passes an added participant filter are different questions.

The City’s response and explanation

Webster says an earlier OR screenshot produced the same amount and offers to send it. Bryan responds, “that’s when I did the KeyQL.” These accounts sit alongside his expectation of more emails; the saved settings and result lists are needed to reconcile them.

What remains unresolved

Equal result totals are possible. The 19 delivered MSG files are not a verified raw search-hit total. “AND/OR” is the speakers’ description, not verified executed syntax. The extra OR screenshot has not been located in the compared sets; this is not proof that it never existed.

Read the full search-scope comparison ↗Follow the methodology chronology and March 17 context ↗

Search-documentation assurances, followed by another request to see itSeptember 18 · 14:56–15:11 and 34:02–35:10 · excerpts 1 and 4

What was said

Moring again asks to see the search summary. Ream responds, “I can find out.” Later, Bryan says he will change the search, email Ream and Webster, and start the export. Ream says review will take time and that “there might be a cost involved in that if it’s additional.”

1. Documents, inspections, search details and costs · ~10:32–16:41

~10:32 / 16:41

One continuous excerpt. The player and transcript use the original recording clock; ~ means the timing is estimated.

Read the excerpt transcript

[~10:36] Lea Ream, City Attorney: So...

[~10:37] Kyle Moring: I saw your filing.

[~10:38] Kyle Moring: And, I've got the complete set right here.

[~10:41] Lea Ream, City Attorney: Mhmm.

[~10:42] Kyle Moring: But,

[~10:43] Kyle Moring: I mean, I don't know.

[~10:44] Lea Ream, City Attorney: So,

[~10:45] Lea Ream, City Attorney: this may be that we're like ships passing in the night here.

[~10:48] Kyle Moring: Mm-hmm.

[~10:54] Lea Ream, City Attorney: Like...umm...you might be just trying to talk about stuff

[~10:57] Lea Ream, City Attorney: as opposed to offering evidence.

[~10:58] Kyle Moring: Mhmm.

[~10:59] Lea Ream, City Attorney: And so, um,

[~11:03] Lea Ream, City Attorney: the rules of evidence are about the submission of evidence,

[~11:05] Lea Ream, City Attorney: right?

[~11:06] Kyle Moring: Right.

[~11:06] Lea Ream, City Attorney: So,

[~11:07] Lea Ream, City Attorney: that's where we get...

[~11:10] Lea Ream, City Attorney: challenges,

[~11:11] Lea Ream, City Attorney: right?

[~11:11] Kyle Moring: Mhmm.

[~11:11] Lea Ream, City Attorney: And so,

[~11:12] Lea Ream, City Attorney: and like,

[~11:13] Lea Ream, City Attorney: as I,

[~11:13] Lea Ream, City Attorney: as we talked about last Friday,

[~11:17] Lea Ream, City Attorney: documents have to be complete and all of those different things,

[~11:19] Lea Ream, City Attorney: because otherwise it appears

[~11:21] Lea Ream, City Attorney: that they're,

[~11:21] Lea Ream, City Attorney: I mean, who knows, right?

[~11:22] Kyle Moring: Right.

[~11:23] Lea Ream, City Attorney: They could be taken out of context or,

[~11:24] Lea Ream, City Attorney: and if you're on some

[~11:26] Lea Ream, City Attorney: sort of appeal or something like that, um,

[~11:29] Lea Ream, City Attorney: the court of appeals would not have any reference,

[~11:33] Lea Ream, City Attorney: right?

[~11:33] Kyle Moring: Mhmm.

[~11:33] Lea Ream, City Attorney: For that kind of thing. And so,

[~11:34] Lea Ream, City Attorney: So I'm not trying to be...um...

[~11:37] Kyle Moring: No, I get it.

[~11:38] Kyle Moring: I mean, it's your job to do that.

[~11:39] Lea Ream, City Attorney: Yeah, exactly.

[~11:40] Lea Ream, City Attorney: It's my job.

[~11:41] Kyle Moring: I totally get it.

[~11:42] Lea Ream, City Attorney: Exactly.

[~11:44] Kyle Moring: Yeah, I'd have the complete threads in there, but honestly, I don't know.

[~11:47] Kyle Moring: I'm really just tired of this.

[~11:49] Lea Ream, City Attorney: Well, we are too.

[~11:52] Lea Ream, City Attorney: But,

[~11:53] Lea Ream, City Attorney: I mean, Mr.

[~12:04] Lea Ream, City Attorney: Moring...

[~11:54] Lea Ream, City Attorney: Like really like if we're talking,

[~11:57] Lea Ream, City Attorney: if you think we haven't given you something,

[~11:59] Lea Ream, City Attorney: I mean I understand you have some like,

[~12:01] Lea Ream, City Attorney: I think this should have turned up

[~12:03] Lea Ream, City Attorney: or that should have turned up.

[~12:04] Lea Ream, City Attorney: And you know,

[~12:05] Lea Ream, City Attorney: I don't know what to say about that

[~12:07] Lea Ream, City Attorney: other than we did the searches,

[~12:10] Lea Ream, City Attorney: we produced the documents that we had.

[~12:12] Lea Ream, City Attorney: And I mean,

[~12:13] Lea Ream, City Attorney: I know you're very, very precise

[~12:15] Lea Ream, City Attorney: and very focused.

[~12:16] Lea Ream, City Attorney: on certain things and um but we want to bring this to an end right?

[~12:21] Kyle Moring: Right.

[~12:22] Lea Ream, City Attorney: when this is

[~12:22] Lea Ream, City Attorney: costing the city a lot of money.

[~12:23] Kyle Moring: No I'm yeah I understand that and I know that

[~12:26] Kyle Moring: like for example the the correspondence that you guys produced with you guys

[~12:31] Kyle Moring: part of that request was like the invoices you know for the billing it

[~12:35] Kyle Moring: wasn't produced.

[~12:37] Lea Ream, City Attorney: Well you have to understand that it's only what's

[~12:40] Lea Ream, City Attorney: available when you make that request

[~12:41] Kyle Moring: Mhm.

[~12:41] Lea Ream, City Attorney: so it may not have been in there right like

[~12:44] Lea Ream, City Attorney: it may have not been there at the time

[~12:45] Lea Ream, City Attorney: that you made the request.

[~12:46] Kyle Moring: Okay.

[~12:48] Lea Ream, City Attorney: It's one of those,

[~12:48] Lea Ream, City Attorney: like,

[~12:49] Lea Ream, City Attorney: you know, it's a snapshot right in time.

[~12:51] Kyle Moring: Right.

[~12:51] Lea Ream, City Attorney: You know that.

[~12:52] Lea Ream, City Attorney: And so I don't know.

[~12:53] Lea Ream, City Attorney: I mean, but,

[~12:54] Lea Ream, City Attorney: again,

[~12:54] Lea Ream, City Attorney: happy to, but,

[~12:55] Lea Ream, City Attorney: you know, we'll, there's also privileged communication

[~12:58] Lea Ream, City Attorney: in there.

[~12:58] Lea Ream, City Attorney: I'm assuming that you would agree to us redacting...

[~13:01] Kyle Moring: Right, right, right.

[~13:02] Lea Ream, City Attorney: Privileged communications umm...

[~13:03] Kyle Moring: And then, like,

[~13:04] Kyle Moring: the other thing was, like,

[~13:06] Kyle Moring: with the...

[~13:07] Kyle Moring: It's the main thing pretty much, the Walmart related stuff.

[~13:12] Kyle Moring: The permits and inspections,

[~13:13] Kyle Moring: Like HS Cloud, even the contract says, they've got the ability

[~13:18] Kyle Moring: to do the electronic export.

[~13:20] Kyle Moring: And some of the pages they print out weren't even saved when they...

[~13:24] Kyle Moring: printed them out,

[~13:25] Kyle Moring: you could tell

[~13:27] Kyle Moring: the bubbles,

[~13:28] Kyle Moring: you know, you put the

[~13:29] Kyle Moring: entries in,

[~13:29] Lea Ream, City Attorney: Mhmm.

[~13:29] Kyle Moring: like the violations and stuff,

[~13:31] Kyle Moring: they were still open.

[~13:33] Kyle Moring: And it's like,

[~13:34] Lea Ream, City Attorney: I mean...

[~13:34] Kyle Moring: and I know you don't

[~13:34] Kyle Moring: understand. Like

[~13:35] Lea Ream, City Attorney: I can't speak to whether

[~13:36] Kyle Moring: Right

[~13:36] Lea Ream, City Attorney: or not

[~13:37] Lea Ream, City Attorney: there's a better way to do it. I know that

[~13:39] Lea Ream, City Attorney: you know

[~13:39] Kyle Moring: Yeah

[~13:39] Lea Ream, City Attorney: the history of that

[~13:41] Lea Ream, City Attorney: better than I do,

[~13:41] Lea Ream, City Attorney: but that we

[~13:43] Lea Ream, City Attorney: didn't have the ability to print it, period,

[~13:45] Lea Ream, City Attorney: and then we're trying to figure out how to

[~13:46] Kyle Moring: Right.

[~13:47] Lea Ream, City Attorney: try, and I guess we've given you

[~13:48] Lea Ream, City Attorney: some of that stuff that you feel like it's not sufficient.

[~13:51] Kyle Moring: Pretty much, yeah.

[~13:52] Lea Ream, City Attorney: Okay.

[~13:52] Kyle Moring: Yeah.

[~13:53] Lea Ream, City Attorney: But, I mean, if we have some focused things,

[~13:55] Lea Ream, City Attorney: again, we're not refusing to um provide those

[~14:00] Lea Ream, City Attorney: to you.

[~14:01] Lea Ream, City Attorney: It's just uh but we need to be focused,

[~14:04] Lea Ream, City Attorney: right?

[~14:04] Lea Ream, City Attorney: Like, in fairness to you,

[~14:07] Lea Ream, City Attorney: you're a very intelligent person.

[~14:10] Lea Ream, City Attorney: I have no doubt about that.

[~14:14] Lea Ream, City Attorney: But sometimes when you're putting these things in the AI kind of filter,

[~14:18] Lea Ream, City Attorney: it just comes out as like...

[~14:20] Kyle Moring: Well,

[~14:20] Lea Ream, City Attorney: It's just too much.

[~14:21] Kyle Moring: yeah, that and I like to overthink everything.

[~14:23] Kyle Moring: And I know that I have a problem with that, too.

[~14:25] Lea Ream, City Attorney: I do that,

[~14:25] Lea Ream, City Attorney: too.

[~14:26] Kyle Moring: I mean, things are way more complex than they need to be

[~14:28] Kyle Moring: because I'm trying to cover all my bases, but...

[~14:30] Lea Ream, City Attorney: Well, we're not...

[~14:31] Lea Ream, City Attorney: I mean, honestly,

[~14:31] Lea Ream, City Attorney: we're really like...

[~14:33] Lea Ream, City Attorney: That's not, that's not in the City's best interest.

[~14:35] Lea Ream, City Attorney: it's not in your best interest.

[~14:36] Lea Ream, City Attorney: We're not, if it's something you requested,

[~14:38] Lea Ream, City Attorney: if the documents existed,

[~14:40] Lea Ream, City Attorney: of course,

[~14:41] Lea Ream, City Attorney: the snapshot,

[~14:42] Lea Ream, City Attorney: right, and the time frame

[~14:43] Kyle Moring: Mhmm.

[~14:43] Lea Ream, City Attorney: and all that,

[~14:44] Lea Ream, City Attorney: we're not,

[~14:47] Lea Ream, City Attorney: you know, if you think

[~14:49] Lea Ream, City Attorney: that this is missing or that's missing

[~14:51] Lea Ream, City Attorney: or there's some data missing,

[~14:52] Lea Ream, City Attorney: we're not refusing to provide

[~14:54] Lea Ream, City Attorney: that to you, but we just need to be focused on what that is.

[~14:56] Kyle Moring: Would they just produce,

[~14:58] Kyle Moring: you know, what the summary of the screenshot was,

[~15:01] Kyle Moring: you know,

[~15:02] Kyle Moring: the…

[~15:02] Lea Ream, City Attorney: On that Walmart?

[~15:03] Kyle Moring: …on the KeyQL?

[~15:04] Lea Ream, City Attorney: I can find out.

[~15:05] Kyle Moring: I mean, if they do that,

[~15:06] Kyle Moring: like where I can see what was searched,

[~15:08] Kyle Moring: just the summary of the KeyQL

[~15:10] Lea Ream, City Attorney: Yeah.

[~15:11] Kyle Moring: I mean, that's fine.

[~15:12] Kyle Moring: I mean I'm just tired of this.

[~15:14] Lea Ream, City Attorney: I'm sure it's stressful for you.

[~15:15] Kyle Moring: Because I've got a lot more things you guys don't even realize going on

[~15:19] Lea Ream, City Attorney: Yeah.

[~15:19] Kyle Moring: with other agencies.

[~15:20] Kyle Moring: And it's like,

[~15:21] Lea Ream, City Attorney: Yeah

[~15:21] Kyle Moring: and I'm representing myself.

[~15:23] Kyle Moring: And it's been going on for a year and a half and

[~15:25] Kyle Moring: I'm just tired. Like

[~15:27] Lea Ream, City Attorney: Well, and it's, I think, let me just say that.

[~15:35] Lea Ream, City Attorney: And let me just say that the umm

[~15:41] Lea Ream, City Attorney: the big picture is important,

[~15:42] Lea Ream, City Attorney: right?

[~15:42] Kyle Moring: Mhmm.

[~15:42] Lea Ream, City Attorney: And we can get super focused on whether or not um you know

[~15:48] Lea Ream, City Attorney: we gave it to you with a paper clip or not.

[~15:50] Kyle Moring: Right.

[~15:50] Lea Ream, City Attorney: You know what I mean?

[~15:50] Kyle Moring: Right right.

[~15:53] Lea Ream, City Attorney: And and that just doesn't I don't know if that's really meaningful

[~15:56] Lea Ream, City Attorney: and I appreciate that you are very

[~16:00] Lea Ream, City Attorney: sensitive to the details.

[~16:02] Lea Ream, City Attorney: And so, but,

[~16:03] Lea Ream, City Attorney: you know,

[~16:04] Lea Ream, City Attorney: that's not what we're here to do.

[~16:05] Lea Ream, City Attorney: You've been lots of places.

[~16:07] Lea Ream, City Attorney: We've, I mean, the City, the City is really

[~16:10] Lea Ream, City Attorney: spending an extraordinary amount

[~16:12] Lea Ream, City Attorney: of money responding to these things.

[~16:13] Lea Ream, City Attorney: This is our third trip.

[~16:15] Kyle Moring: Yeah. I know.

[~16:16] Lea Ream, City Attorney: To a court hearing.

[~16:17] Lea Ream, City Attorney: And so,

[~16:20] Lea Ream, City Attorney: um

[~16:21] Lea Ream, City Attorney: You know,

[~16:22] Lea Ream, City Attorney: it's the taxpayers that are paying that money.

[~16:26] Kyle Moring: Right.

[~16:26] Lea Ream, City Attorney: You know,

[~16:27] Kyle Moring: So...

[~16:27] Lea Ream, City Attorney: I'm even giving discounts upon discounts.

[~16:29] Kyle Moring: So...

[~16:30] Lea Ream, City Attorney: But I can't, I mean, at some point,

[~16:31] Lea Ream, City Attorney: like,

[~16:32] Lea Ream, City Attorney: you know, if I'm not spending my time here,

[~16:34] Lea Ream, City Attorney: I'm working for other people.

[~16:35] Kyle Moring: Right, right.

[~16:36] Kyle Moring: And San Antonio is a good drive

[~16:38] Kyle Moring: or even if you fly

[~16:39] Kyle Moring: It's, you know, a decent amount of money

4. Telephone query discussion, rerun, possible cost and scope · ~30:28–36:18

~30:28 / 36:18

One continuous excerpt. The player and transcript use the original recording clock; ~ means the timing is estimated.

Read the excerpt transcript

[~30:28] Lea Ream, City Attorney: Okay, I'm gonna...I'm gonna

[~30:30] Lea Ream, City Attorney: Let me go see if I'm going to let him explain to y'all what it is that he's looking for.

[~30:43] Lea Ream, City Attorney: Okay,

[~30:43] Lea Ream, City Attorney: Kyle, so we have, I have Seth and Candias on the phone here.

[~30:49] Lea Ream, City Attorney: And like I'm, and of course here's the Mayor.

[~31:00] Kyle Moring: Okay.

[~30:53] Lea Ream, City Attorney: So this is that Walmart search,

[~30:56] Lea Ream, City Attorney: right?

[~30:56] Lea Ream, City Attorney: But you've seen that.

[~30:58] Kyle Moring: Right. I'm, I'm

[~30:59] Kyle Moring: And it also had the "AND",

[~31:00] Kyle Moring: like I pointed out why it's an issue

[~31:02] Kyle Moring: to have the "AND" in the participants.

[~31:04] Kyle Moring: Because they should be looking for both things,

[~31:05] Kyle Moring: but the actual KeyQL search with just,

[~31:09] Kyle Moring: you know,

[~31:10] Kyle Moring: even if it's just headers of the emails,

[~31:13] Kyle Moring: the email addresses,

[~31:14] Kyle Moring: or it shows kind of like

[~31:15] Kyle Moring: what he's doing for the um district attorney record request.

[~31:20] Lea Ream, City Attorney: Seth, can you hear that?

[~31:22] Seth Bryan, Bryan IT: Yes,

[~31:22] Seth Bryan, Bryan IT: yes.

[~31:23] Seth Bryan, Bryan IT: Okay,

[~31:23] Seth Bryan, Bryan IT: so just so I am getting this correct, Kyle

[~31:25] Seth Bryan, Bryan IT: so you want me to remove the "AND", uh,

[~31:28] Seth Bryan, Bryan IT: the "AND"

[~31:29] Seth Bryan, Bryan IT: condition there, to "OR"?

[~31:31] Kyle Moring: Yeah, I think that's the way that it would, it would pick up,

[~31:35] Kyle Moring: you know, what I had requested

[~31:37] Lea Ream, City Attorney: if it's with "OR".

[~31:38] Mayor Wesley Lyon: Is it SQL?

[~31:40] Kyle Moring: Mm-hmm.

[~31:40] Mayor Wesley Lyon: Uh, it's "AND", and "OR".

[~31:43] Lea Ream, City Attorney: Uh-huh.

[~31:43] Mayor Wesley Lyon: It's actually both of them.

[~31:45] Lea Ream, City Attorney: Okay,

[~31:46] Lea Ream, City Attorney: Okay so you want us to run this search again with it?

[~31:52] Kyle Moring: Yeah, just those same parameters. And I just you know just see what.

[~31:55] Lea Ream, City Attorney: But "AND/OR".

[~31:56] Kyle Moring: Mhmm.

[~31:56] Lea Ream, City Attorney: Okay,

[~31:57] Lea Ream, City Attorney: can we do that guys?

[~31:59] Seth Bryan, Bryan IT: Sure,

[~32:00] Seth Bryan, Bryan IT: yeah. Definitely.

[~32:01] Seth Bryan, Bryan IT: So let me just go back to that same uh search

[~32:06] Lea Ream, City Attorney: Those same keywords?

[~32:07] Seth Bryan, Bryan IT: and I'll just adjust those parameters

[~32:08] Kyle Moring: Yeah, I think the search is fine.

[~32:09] Kyle Moring: It's more just the participants.

[~32:11] Lea Ream, City Attorney: "AND/OR",

[~32:11] Kyle Moring: Mhmm.

[~32:12] Lea Ream, City Attorney: Yeah. Okay.

[~32:14] Lea Ream, City Attorney: And then what you get,

[~32:16] Lea Ream, City Attorney: and then that produces X documents,

[~32:20] Lea Ream, City Attorney: right?

[~32:20] Kyle Moring: Mm-hmm.

[~32:23] Lea Ream, City Attorney: So...

[~32:29] Candias Webster, City Secretary: And then we have to go through those again?

[~32:30] Lea Ream, City Attorney: Well so, would it, I would think that's what we'd have to do,

[~32:31] Lea Ream, City Attorney: but I guess what we

[~32:32] Lea Ream, City Attorney: did before was "AND"? or we did "OR"? Seth, do you know?

[~32:37] Seth Bryan, Bryan IT: Yeah, so yeah, it did "AND" umm and I...

[~32:41] Lea Ream, City Attorney: Oh who is this...

[~32:42] Seth Bryan, Bryan IT: I'm trying to think.

[~32:44] Seth Bryan, Bryan IT: So technically because it's looking for keywords with the word Walmart as well as participants

[~32:51] Seth Bryan, Bryan IT: of Walmart,

[~32:51] Seth Bryan, Bryan IT: so yeah, that would just produce,

[~32:55] Seth Bryan, Bryan IT: yeah, I can just change at the "AND/OR" or it will

[~32:57] Seth Bryan, Bryan IT: probably generate um a lot more emails and it would technically be a separate export.

[~33:03] Seth Bryan, Bryan IT: But um yeah, I can just go back to that original case and change that. That's not a hard thing to do.

[~33:07] Lea Ream, City Attorney: So,

[~33:08] Candias Webster, City Secretary: I have a screenshot here where we actually did do it with "OR" and it produced the same amount.

[~33:16] Candias Webster, City Secretary: Like I can send it to you.

[~33:18] Seth Bryan, Bryan IT: Oh,

[~33:18] Seth Bryan, Bryan IT: that's when I did the KeyQL.

[~33:20] Candias Webster, City Secretary: Yeah,

[~33:21] Candias Webster, City Secretary: and we did a screen, a

[~33:23] Candias Webster, City Secretary: screenshot where it pretty much produced the exact same stuff.

[~33:27] Lea Ream, City Attorney: So, okay just let me

[~33:28] Kyle Moring: But it's like he said, the "AND/OR", the participants.

[~33:30] Kyle Moring: You're right,

[~33:31] Kyle Moring: yeah.

[~33:31] Lea Ream, City Attorney: But why wouldn't, why wouldn't "OR" give you more?

[~33:35] Lea Ream, City Attorney: Like,

[~33:35] Lea Ream, City Attorney: if it's...

[~33:35] Mayor Wesley Lyon: If you don't use the "AND", that's what I did,

[~33:39] Mayor Wesley Lyon: like, the last 20 years.

[~33:40] Mayor Wesley Lyon: The "AND/OR" was actually using both of those parameters,

[~33:43] Lea Ream, City Attorney: Uh-huh

[~33:43] Mayor Wesley Lyon: so it'll pull more than just one

[~33:46] Mayor Wesley Lyon: or the other.

[~33:47] Lea Ream, City Attorney: okay

[~33:47] Mayor Wesley Lyon: does that make sense

[~33:49] Mayor Wesley Lyon: it's weird

[~33:50] Lea Ream, City Attorney: Not to me it seems like if it has one

[~33:51] Lea Ream, City Attorney: it should pull it

[~33:52] Kyle Moring: It. Yeah

[~33:53] Lea Ream, City Attorney: yeah

[~33:53] Lea Ream, City Attorney: when it has both

[~33:54] Mayor Wesley Lyon: yeah it's a sequel thing

[~33:55] Seth Bryan, Bryan IT: Mhmm.

[~33:55] Lea Ream, City Attorney: okay

[~33:56] Lea Ream, City Attorney: alright

[~33:57] Lea Ream, City Attorney: so

[~33:58] Lea Ream, City Attorney: um

[~34:01] Lea Ream, City Attorney: okay

[~34:02] Lea Ream, City Attorney: and then we'll have to look through those

[~34:03] Lea Ream, City Attorney: and that's gonna take time

[~34:05] Kyle Moring: that's fine

[~34:06] Lea Ream, City Attorney: All right, so, so,

[~34:09] Lea Ream, City Attorney: Seth,

[~34:10] Lea Ream, City Attorney: can you write for me in words?

[~34:10] Seth Bryan, Bryan IT: Mhmm.

[~34:13] Lea Ream, City Attorney: Because I want to put this on the record before the judge, are you

[~34:16] Lea Ream, City Attorney: do you agree to that?

[~34:18] Lea Ream, City Attorney: That what the parties have agreed is basically to run this search again with "AND/OR" right?

[~34:27] Lea Ream, City Attorney: and once the city has reviewed those records

[~34:30] Lea Ream, City Attorney: and provided those in accordance with the normal,

[~34:33] Lea Ream, City Attorney: I mean, there might be a cost involved in that if it's additional.

[~34:36] Kyle Moring: Okay

[~34:38] Lea Ream, City Attorney: Then we'll,

[~34:40] Lea Ream, City Attorney: and that's it.

[~34:42] Lea Ream, City Attorney: We're done with this.

[~34:43] Kyle Moring: Mhmm.

[~34:43] Lea Ream, City Attorney: Right?

[~34:43] Lea Ream, City Attorney: We're done with the the lawsuit, and um,

[~34:47] Lea Ream, City Attorney: and it will be dismissed.

[~34:50] Lea Ream, City Attorney: Right?

[~34:51] Lea Ream, City Attorney: okay

[~34:52] Lea Ream, City Attorney: alright

[~34:52] Lea Ream, City Attorney: and I don't want

[~34:53] Lea Ream, City Attorney: we don't want to come back here

[~34:55] Kyle Moring: no

[~34:56] Kyle Moring: I don't either

[~34:59] Seth Bryan, Bryan IT: Sounds good

[~34:59] Seth Bryan, Bryan IT: okay

[~35:00] Seth Bryan, Bryan IT: so yeah

[~35:00] Seth Bryan, Bryan IT: I can I can certainly

[~35:01] Seth Bryan, Bryan IT: I'll change that over

[~35:02] Seth Bryan, Bryan IT: and I can write up an email

[~35:04] Seth Bryan, Bryan IT: and send it over to you

[~35:05] Lea Ream, City Attorney: thank you very much

[~35:07] Seth Bryan, Bryan IT: and send it to Candias

[~35:08] Seth Bryan, Bryan IT: yeah

[~35:08] Seth Bryan, Bryan IT: I will get this export

[~35:10] Seth Bryan, Bryan IT: started right now

[~35:11] Lea Ream, City Attorney: thank you

[~35:12] Lea Ream, City Attorney: I appreciate it so much

[~35:13] Lea Ream, City Attorney: and thank you Candias

[~35:15] Lea Ream, City Attorney: and I think you're

[~35:16] Lea Ream, City Attorney: Candias you're on

[~35:17] Lea Ream, City Attorney: you don't need to come down

[~35:18] Lea Ream, City Attorney: I think right now

[~35:20] Candias Webster, City Secretary: Yes ma'am

[~35:20] Lea Ream, City Attorney: All right,

[~35:21] Lea Ream, City Attorney: thank you.

[~35:21] Kyle Moring: Thank you.

[~35:22] Candias Webster, City Secretary: You're welcome.

[~35:23] Seth Bryan, Bryan IT: Thank you guys.

[~35:24] [Overlapping speech; words unclear.]

[~35:26] Mayor Wesley Lyon: So they're running that in, for the mail database?

[~35:32] Lea Ream, City Attorney: Uh yeah, that's right,

[~35:33] Lea Ream, City Attorney: that's what they're

[~35:33] Lea Ream, City Attorney: I mean,

[~35:34] Lea Ream, City Attorney: whatever it was he requested before

[~35:35] Lea Ream, City Attorney: in terms of the database.

[~35:36] Mayor Wesley Lyon: [Unclear: “So more like the emails?”]

[~35:36] Kyle Moring: Yeah, it said email,

[~35:39] Kyle Moring: but it's like,

[~35:40] Kyle Moring: I'm not even gonna push my luck on the rest of it.

[~35:41] Kyle Moring: I mean,

[~35:42] Kyle Moring: it was supposed to be all the platforms,

[~35:44] Kyle Moring: but it's, I'm not gonna do that.

[~35:46] Lea Ream, City Attorney: Email,

[~35:47] Lea Ream, City Attorney: that's what you're looking for.

[~35:48] Lea Ream, City Attorney: okay all right

[~35:53] Lea Ream, City Attorney: all right well see this is this is what conferring does for us, we can...all right

[~36:02] Lea Ream, City Attorney: let me um

[~36:03] Mayor Wesley Lyon: So who's running that query is that gonna be Seth or Austin?

[~36:07] Lea Ream, City Attorney: Yeah Seth is

[~36:08] Mayor Wesley Lyon: Seth is?

[~36:10] Lea Ream, City Attorney: yeah okay let me go and um communicate with the court just so we can get one thing off her docket if she's um....

Earlier recorded statements

Lyon · February 18Original about 1:02:15 · released player about 45:55

During the search-documentation discussion, Lyon says “there’s no reason why we can’t get that.” Near the end of the same meeting, he says Moring should get the search parameters to see them (original 1:40:46–1:40:48).

Hear the earlier passage · Lyon · February 18

Full recording & transcript ↗

What the records show

The February 9 request expressly sought existing search parameters and routing records. No-records responses followed. The March 10 production then supplied a January 12 forwarding email and capability answers describing searches and native email exports. The routing email demonstrably predates the request; a screenshot’s displayed search date does not by itself establish when that screenshot was created.

February 9 · methodology request · PDF p. 1Requested maintained search parameters and routing records

Selected page 1 of 2. Page references refer to this version of the source.

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February 9 · methodology request, reading-copy PDF page 1. Requested maintained search parameters and routing records

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

Selected page 1 of 3. Page references refer to this version of the source.

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February 25 · no-records response, reading-copy PDF page 1. Three no-records responses and closure

March 10 · red-font capability answers · PDF p. 2Red-font platform and export-capability answers

Selected page 2 of 3. Page references refer to this version of the source.

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March 10 · red-font capability answers, reading-copy PDF page 2. Red-font platform and export-capability answers

Why this mattersThe documented sequence raises a specific follow-through question: which search records were supplied after the earlier assurances, and why was Moring still seeking an explanation in September? The possible added cost also deserves an explanation in the context of the disputed original search.

The City’s response and explanation

The City did supply later routing records and search panels, and Bryan offered to begin another export. Those responses are credited. Ream’s cost statement is conditional; this recording does not establish an issued bill or completed rerun.

What remains unresolved

A repeated request is not proof that every requested item remained missing. Fulfillment must be checked against the exact request, record, production and date. No final dismissal or court ruling is inferred from this conversation.

January 12 routing email · PDF reading copy ↗Compare requests, replies and later productions ↗

Inspection records: what the received copy can actually verifySeptember 18 · 13:07–13:51 · excerpt 1

What was said

Moring raises electronic export and inspection pages he says were printed with entry fields still open. Ream says she cannot speak to whether there is a better way, acknowledges that he knows that history better, and describes the City’s efforts to provide the material.

1. Documents, inspections, search details and costs · ~10:32–16:41

~10:32 / 16:41

One continuous excerpt. The player and transcript use the original recording clock; ~ means the timing is estimated.

Read the excerpt transcript

[~10:36] Lea Ream, City Attorney: So...

[~10:37] Kyle Moring: I saw your filing.

[~10:38] Kyle Moring: And, I've got the complete set right here.

[~10:41] Lea Ream, City Attorney: Mhmm.

[~10:42] Kyle Moring: But,

[~10:43] Kyle Moring: I mean, I don't know.

[~10:44] Lea Ream, City Attorney: So,

[~10:45] Lea Ream, City Attorney: this may be that we're like ships passing in the night here.

[~10:48] Kyle Moring: Mm-hmm.

[~10:54] Lea Ream, City Attorney: Like...umm...you might be just trying to talk about stuff

[~10:57] Lea Ream, City Attorney: as opposed to offering evidence.

[~10:58] Kyle Moring: Mhmm.

[~10:59] Lea Ream, City Attorney: And so, um,

[~11:03] Lea Ream, City Attorney: the rules of evidence are about the submission of evidence,

[~11:05] Lea Ream, City Attorney: right?

[~11:06] Kyle Moring: Right.

[~11:06] Lea Ream, City Attorney: So,

[~11:07] Lea Ream, City Attorney: that's where we get...

[~11:10] Lea Ream, City Attorney: challenges,

[~11:11] Lea Ream, City Attorney: right?

[~11:11] Kyle Moring: Mhmm.

[~11:11] Lea Ream, City Attorney: And so,

[~11:12] Lea Ream, City Attorney: and like,

[~11:13] Lea Ream, City Attorney: as I,

[~11:13] Lea Ream, City Attorney: as we talked about last Friday,

[~11:17] Lea Ream, City Attorney: documents have to be complete and all of those different things,

[~11:19] Lea Ream, City Attorney: because otherwise it appears

[~11:21] Lea Ream, City Attorney: that they're,

[~11:21] Lea Ream, City Attorney: I mean, who knows, right?

[~11:22] Kyle Moring: Right.

[~11:23] Lea Ream, City Attorney: They could be taken out of context or,

[~11:24] Lea Ream, City Attorney: and if you're on some

[~11:26] Lea Ream, City Attorney: sort of appeal or something like that, um,

[~11:29] Lea Ream, City Attorney: the court of appeals would not have any reference,

[~11:33] Lea Ream, City Attorney: right?

[~11:33] Kyle Moring: Mhmm.

[~11:33] Lea Ream, City Attorney: For that kind of thing. And so,

[~11:34] Lea Ream, City Attorney: So I'm not trying to be...um...

[~11:37] Kyle Moring: No, I get it.

[~11:38] Kyle Moring: I mean, it's your job to do that.

[~11:39] Lea Ream, City Attorney: Yeah, exactly.

[~11:40] Lea Ream, City Attorney: It's my job.

[~11:41] Kyle Moring: I totally get it.

[~11:42] Lea Ream, City Attorney: Exactly.

[~11:44] Kyle Moring: Yeah, I'd have the complete threads in there, but honestly, I don't know.

[~11:47] Kyle Moring: I'm really just tired of this.

[~11:49] Lea Ream, City Attorney: Well, we are too.

[~11:52] Lea Ream, City Attorney: But,

[~11:53] Lea Ream, City Attorney: I mean, Mr.

[~12:04] Lea Ream, City Attorney: Moring...

[~11:54] Lea Ream, City Attorney: Like really like if we're talking,

[~11:57] Lea Ream, City Attorney: if you think we haven't given you something,

[~11:59] Lea Ream, City Attorney: I mean I understand you have some like,

[~12:01] Lea Ream, City Attorney: I think this should have turned up

[~12:03] Lea Ream, City Attorney: or that should have turned up.

[~12:04] Lea Ream, City Attorney: And you know,

[~12:05] Lea Ream, City Attorney: I don't know what to say about that

[~12:07] Lea Ream, City Attorney: other than we did the searches,

[~12:10] Lea Ream, City Attorney: we produced the documents that we had.

[~12:12] Lea Ream, City Attorney: And I mean,

[~12:13] Lea Ream, City Attorney: I know you're very, very precise

[~12:15] Lea Ream, City Attorney: and very focused.

[~12:16] Lea Ream, City Attorney: on certain things and um but we want to bring this to an end right?

[~12:21] Kyle Moring: Right.

[~12:22] Lea Ream, City Attorney: when this is

[~12:22] Lea Ream, City Attorney: costing the city a lot of money.

[~12:23] Kyle Moring: No I'm yeah I understand that and I know that

[~12:26] Kyle Moring: like for example the the correspondence that you guys produced with you guys

[~12:31] Kyle Moring: part of that request was like the invoices you know for the billing it

[~12:35] Kyle Moring: wasn't produced.

[~12:37] Lea Ream, City Attorney: Well you have to understand that it's only what's

[~12:40] Lea Ream, City Attorney: available when you make that request

[~12:41] Kyle Moring: Mhm.

[~12:41] Lea Ream, City Attorney: so it may not have been in there right like

[~12:44] Lea Ream, City Attorney: it may have not been there at the time

[~12:45] Lea Ream, City Attorney: that you made the request.

[~12:46] Kyle Moring: Okay.

[~12:48] Lea Ream, City Attorney: It's one of those,

[~12:48] Lea Ream, City Attorney: like,

[~12:49] Lea Ream, City Attorney: you know, it's a snapshot right in time.

[~12:51] Kyle Moring: Right.

[~12:51] Lea Ream, City Attorney: You know that.

[~12:52] Lea Ream, City Attorney: And so I don't know.

[~12:53] Lea Ream, City Attorney: I mean, but,

[~12:54] Lea Ream, City Attorney: again,

[~12:54] Lea Ream, City Attorney: happy to, but,

[~12:55] Lea Ream, City Attorney: you know, we'll, there's also privileged communication

[~12:58] Lea Ream, City Attorney: in there.

[~12:58] Lea Ream, City Attorney: I'm assuming that you would agree to us redacting...

[~13:01] Kyle Moring: Right, right, right.

[~13:02] Lea Ream, City Attorney: Privileged communications umm...

[~13:03] Kyle Moring: And then, like,

[~13:04] Kyle Moring: the other thing was, like,

[~13:06] Kyle Moring: with the...

[~13:07] Kyle Moring: It's the main thing pretty much, the Walmart related stuff.

[~13:12] Kyle Moring: The permits and inspections,

[~13:13] Kyle Moring: Like HS Cloud, even the contract says, they've got the ability

[~13:18] Kyle Moring: to do the electronic export.

[~13:20] Kyle Moring: And some of the pages they print out weren't even saved when they...

[~13:24] Kyle Moring: printed them out,

[~13:25] Kyle Moring: you could tell

[~13:27] Kyle Moring: the bubbles,

[~13:28] Kyle Moring: you know, you put the

[~13:29] Kyle Moring: entries in,

[~13:29] Lea Ream, City Attorney: Mhmm.

[~13:29] Kyle Moring: like the violations and stuff,

[~13:31] Kyle Moring: they were still open.

[~13:33] Kyle Moring: And it's like,

[~13:34] Lea Ream, City Attorney: I mean...

[~13:34] Kyle Moring: and I know you don't

[~13:34] Kyle Moring: understand. Like

[~13:35] Lea Ream, City Attorney: I can't speak to whether

[~13:36] Kyle Moring: Right

[~13:36] Lea Ream, City Attorney: or not

[~13:37] Lea Ream, City Attorney: there's a better way to do it. I know that

[~13:39] Lea Ream, City Attorney: you know

[~13:39] Kyle Moring: Yeah

[~13:39] Lea Ream, City Attorney: the history of that

[~13:41] Lea Ream, City Attorney: better than I do,

[~13:41] Lea Ream, City Attorney: but that we

[~13:43] Lea Ream, City Attorney: didn't have the ability to print it, period,

[~13:45] Lea Ream, City Attorney: and then we're trying to figure out how to

[~13:46] Kyle Moring: Right.

[~13:47] Lea Ream, City Attorney: try, and I guess we've given you

[~13:48] Lea Ream, City Attorney: some of that stuff that you feel like it's not sufficient.

[~13:51] Kyle Moring: Pretty much, yeah.

[~13:52] Lea Ream, City Attorney: Okay.

[~13:52] Kyle Moring: Yeah.

[~13:53] Lea Ream, City Attorney: But, I mean, if we have some focused things,

[~13:55] Lea Ream, City Attorney: again, we're not refusing to um provide those

[~14:00] Lea Ream, City Attorney: to you.

[~14:01] Lea Ream, City Attorney: It's just uh but we need to be focused,

[~14:04] Lea Ream, City Attorney: right?

[~14:04] Lea Ream, City Attorney: Like, in fairness to you,

[~14:07] Lea Ream, City Attorney: you're a very intelligent person.

[~14:10] Lea Ream, City Attorney: I have no doubt about that.

[~14:14] Lea Ream, City Attorney: But sometimes when you're putting these things in the AI kind of filter,

[~14:18] Lea Ream, City Attorney: it just comes out as like...

[~14:20] Kyle Moring: Well,

[~14:20] Lea Ream, City Attorney: It's just too much.

[~14:21] Kyle Moring: yeah, that and I like to overthink everything.

[~14:23] Kyle Moring: And I know that I have a problem with that, too.

[~14:25] Lea Ream, City Attorney: I do that,

[~14:25] Lea Ream, City Attorney: too.

[~14:26] Kyle Moring: I mean, things are way more complex than they need to be

[~14:28] Kyle Moring: because I'm trying to cover all my bases, but...

[~14:30] Lea Ream, City Attorney: Well, we're not...

[~14:31] Lea Ream, City Attorney: I mean, honestly,

[~14:31] Lea Ream, City Attorney: we're really like...

[~14:33] Lea Ream, City Attorney: That's not, that's not in the City's best interest.

[~14:35] Lea Ream, City Attorney: it's not in your best interest.

[~14:36] Lea Ream, City Attorney: We're not, if it's something you requested,

[~14:38] Lea Ream, City Attorney: if the documents existed,

[~14:40] Lea Ream, City Attorney: of course,

[~14:41] Lea Ream, City Attorney: the snapshot,

[~14:42] Lea Ream, City Attorney: right, and the time frame

[~14:43] Kyle Moring: Mhmm.

[~14:43] Lea Ream, City Attorney: and all that,

[~14:44] Lea Ream, City Attorney: we're not,

[~14:47] Lea Ream, City Attorney: you know, if you think

[~14:49] Lea Ream, City Attorney: that this is missing or that's missing

[~14:51] Lea Ream, City Attorney: or there's some data missing,

[~14:52] Lea Ream, City Attorney: we're not refusing to provide

[~14:54] Lea Ream, City Attorney: that to you, but we just need to be focused on what that is.

[~14:56] Kyle Moring: Would they just produce,

[~14:58] Kyle Moring: you know, what the summary of the screenshot was,

[~15:01] Kyle Moring: you know,

[~15:02] Kyle Moring: the…

[~15:02] Lea Ream, City Attorney: On that Walmart?

[~15:03] Kyle Moring: …on the KeyQL?

[~15:04] Lea Ream, City Attorney: I can find out.

[~15:05] Kyle Moring: I mean, if they do that,

[~15:06] Kyle Moring: like where I can see what was searched,

[~15:08] Kyle Moring: just the summary of the KeyQL

[~15:10] Lea Ream, City Attorney: Yeah.

[~15:11] Kyle Moring: I mean, that's fine.

[~15:12] Kyle Moring: I mean I'm just tired of this.

[~15:14] Lea Ream, City Attorney: I'm sure it's stressful for you.

[~15:15] Kyle Moring: Because I've got a lot more things you guys don't even realize going on

[~15:19] Lea Ream, City Attorney: Yeah.

[~15:19] Kyle Moring: with other agencies.

[~15:20] Kyle Moring: And it's like,

[~15:21] Lea Ream, City Attorney: Yeah

[~15:21] Kyle Moring: and I'm representing myself.

[~15:23] Kyle Moring: And it's been going on for a year and a half and

[~15:25] Kyle Moring: I'm just tired. Like

[~15:27] Lea Ream, City Attorney: Well, and it's, I think, let me just say that.

[~15:35] Lea Ream, City Attorney: And let me just say that the umm

[~15:41] Lea Ream, City Attorney: the big picture is important,

[~15:42] Lea Ream, City Attorney: right?

[~15:42] Kyle Moring: Mhmm.

[~15:42] Lea Ream, City Attorney: And we can get super focused on whether or not um you know

[~15:48] Lea Ream, City Attorney: we gave it to you with a paper clip or not.

[~15:50] Kyle Moring: Right.

[~15:50] Lea Ream, City Attorney: You know what I mean?

[~15:50] Kyle Moring: Right right.

[~15:53] Lea Ream, City Attorney: And and that just doesn't I don't know if that's really meaningful

[~15:56] Lea Ream, City Attorney: and I appreciate that you are very

[~16:00] Lea Ream, City Attorney: sensitive to the details.

[~16:02] Lea Ream, City Attorney: And so, but,

[~16:03] Lea Ream, City Attorney: you know,

[~16:04] Lea Ream, City Attorney: that's not what we're here to do.

[~16:05] Lea Ream, City Attorney: You've been lots of places.

[~16:07] Lea Ream, City Attorney: We've, I mean, the City, the City is really

[~16:10] Lea Ream, City Attorney: spending an extraordinary amount

[~16:12] Lea Ream, City Attorney: of money responding to these things.

[~16:13] Lea Ream, City Attorney: This is our third trip.

[~16:15] Kyle Moring: Yeah. I know.

[~16:16] Lea Ream, City Attorney: To a court hearing.

[~16:17] Lea Ream, City Attorney: And so,

[~16:20] Lea Ream, City Attorney: um

[~16:21] Lea Ream, City Attorney: You know,

[~16:22] Lea Ream, City Attorney: it's the taxpayers that are paying that money.

[~16:26] Kyle Moring: Right.

[~16:26] Lea Ream, City Attorney: You know,

[~16:27] Kyle Moring: So...

[~16:27] Lea Ream, City Attorney: I'm even giving discounts upon discounts.

[~16:29] Kyle Moring: So...

[~16:30] Lea Ream, City Attorney: But I can't, I mean, at some point,

[~16:31] Lea Ream, City Attorney: like,

[~16:32] Lea Ream, City Attorney: you know, if I'm not spending my time here,

[~16:34] Lea Ream, City Attorney: I'm working for other people.

[~16:35] Kyle Moring: Right, right.

[~16:36] Kyle Moring: And San Antonio is a good drive

[~16:38] Kyle Moring: or even if you fly

[~16:39] Kyle Moring: It's, you know, a decent amount of money

Earlier recorded statements

Vine · December 3Original 39:54–40:05 · reviewed excerpt 39:32–40:10

Vine asks, “Why go out there and then rubber stamp it?” He immediately qualifies that: “So I’m not saying that’s what happened, but if I’m looking at a blank form, it should have words on it.”

Hear the earlier passage · Vine · December 3

Full recording & transcript ↗

Vine · February 18Original about 1:33:50–1:34:11 · released player about 1:17:30–1:17:51

Vine compares a full report with a limited public copy and suggests checking the application, expressly qualifying the explanation with “I don’t know with this system.”

Hear the earlier passage · Vine · February 18

Full recording & transcript ↗

What the records show

The HS GovTech agreement describes configurable printed output and modifiable permit and inspection forms. That sits beside the City’s explanations about printing and scanning and the format objections Moring had already raised. Separately, the January inspection request, completion certification and Webster’s later acknowledgment that she did not answer each category with a no-records response raise questions about whether the supplied copies account for the requested material.

What the City’s own agreement says

The agreement’s configuration-tools section describes connecting printed output to system tools and managing inspection output. Its software-upgrade terms separately address modifiable permit and inspection forms. Those are concrete features to compare with the City’s explanation. “Printed output” does not, by itself, establish a particular PDF-export setting or prove that every report could be exported unchanged.

The August 26, 2025 objection to Beck cites PDFKit and Bluebeam properties and asks for vendor or IT support if electronic export is said to be unavailable. Moring’s account about copies sent to other recipients calls for a document-by-document comparison of the source attachments, their properties and the copies supplied to him.

HS GovTech agreement: configuration and printed output · PDF page 17 ↗Agreement: permit and inspection forms · PDF page 7 ↗Earlier PDFKit/Bluebeam objection to Beck · PDF page 4 ↗Permit report sent toward Titus CAD · PDF page 3 ↗Vendor documentation and the City’s agreement ↗

January inspection request, response & WC06 certification · PDF p. 4January inspection request: six categories

Selected page 4 of 71. Page references refer to this version of the source.

Open this source page at full size ↗ January inspection request, response & WC06 certification, reading-copy PDF page 4. January inspection request: six categories

January inspection request, response & WC06 certification, reading-copy PDF page 4. January inspection request: six categories

January inspection request, response & WC06 certification · PDF p. 70WC06: completion certification

Selected page 70 of 71. Page references refer to this version of the source.

Open this source page at full size ↗ January inspection request, response & WC06 certification, reading-copy PDF page 70. WC06: completion certification

January inspection request, response & WC06 certification, reading-copy PDF page 70. WC06: completion certification

Webster–Richardson–Beck · May 7–12, 2026 · PDF p. 4Webster’s category-by-category response acknowledgment

Selected page 4 of 11. Page references refer to this version of the source.

Open this source page at full size ↗ Webster–Richardson–Beck · May 7–12, 2026, reading-copy PDF page 4. Webster’s category-by-category response acknowledgment

Webster–Richardson–Beck · May 7–12, 2026, reading-copy PDF page 4. Webster’s category-by-category response acknowledgment

Why this mattersA readable page may still omit fields, attachments or history needed to verify the record. The issue is whether the City supplied the existing information in an available form that preserves its relevant context, and whether its explanation is consistent with the system documentation and other versions of the same records.

The City’s response and explanation

Vine offered possible explanations and a check of the application; Ream acknowledged the limits of her technical knowledge. Those qualifications matter. The City’s actual deliveries remain part of the comparison.

What remains unresolved

A blank field or a PDF producer name alone does not prove falsification or deliberate removal. The contract documents features, while a specific record’s exportability depends on its module, configuration and retained data. Moring’s account of the other recipients’ PDFKit copies is identified as his account; the linked August correspondence establishes that he raised the format issue with counsel.

Compare the inspection request and response categories ↗Read the file-property findings and their limits ↗Compare the actual City and DSHS inspection findings ↗HS GovTech agreement and electronic export documentation ↗

6 selected excerpts · 15:49 total

Six selected conversation excerpts from September 18, 2026. Each plays continuously within its stated interval. The symbol ~ marks an estimated timestamp.

Player positions and transcript locators use the original recording clock. The symbol ~ marks estimated timing.

1. Documents, inspections, search details and costs

Original recording · 10:32–16:41 · 06:09 excerpt

Transcript timestamps are approximate.

1. Documents, inspections, search details and costs · ~10:32–16:41

~10:32 / 16:41

Return to the four comparisons ↑

Transcript excerpt · 10:32–16:41

[~10:36] Lea Ream, City Attorney: So...

[~10:37] Kyle Moring: I saw your filing.

[~10:38] Kyle Moring: And, I've got the complete set right here.

[~10:41] Lea Ream, City Attorney: Mhmm.

[~10:42] Kyle Moring: But,

[~10:43] Kyle Moring: I mean, I don't know.

[~10:44] Lea Ream, City Attorney: So,

[~10:45] Lea Ream, City Attorney: this may be that we're like ships passing in the night here.

[~10:48] Kyle Moring: Mm-hmm.

[~10:54] Lea Ream, City Attorney: Like...umm...you might be just trying to talk about stuff

[~10:57] Lea Ream, City Attorney: as opposed to offering evidence.

[~10:58] Kyle Moring: Mhmm.

[~10:59] Lea Ream, City Attorney: And so, um,

[~11:03] Lea Ream, City Attorney: the rules of evidence are about the submission of evidence,

[~11:05] Lea Ream, City Attorney: right?

[~11:06] Kyle Moring: Right.

[~11:06] Lea Ream, City Attorney: So,

[~11:07] Lea Ream, City Attorney: that's where we get...

[~11:10] Lea Ream, City Attorney: challenges,

[~11:11] Lea Ream, City Attorney: right?

[~11:11] Kyle Moring: Mhmm.

[~11:11] Lea Ream, City Attorney: And so,

[~11:12] Lea Ream, City Attorney: and like,

[~11:13] Lea Ream, City Attorney: as I,

[~11:13] Lea Ream, City Attorney: as we talked about last Friday,

[~11:17] Lea Ream, City Attorney: documents have to be complete and all of those different things,

[~11:19] Lea Ream, City Attorney: because otherwise it appears

[~11:21] Lea Ream, City Attorney: that they're,

[~11:21] Lea Ream, City Attorney: I mean, who knows, right?

[~11:22] Kyle Moring: Right.

[~11:23] Lea Ream, City Attorney: They could be taken out of context or,

[~11:24] Lea Ream, City Attorney: and if you're on some

[~11:26] Lea Ream, City Attorney: sort of appeal or something like that, um,

[~11:29] Lea Ream, City Attorney: the court of appeals would not have any reference,

[~11:33] Lea Ream, City Attorney: right?

[~11:33] Kyle Moring: Mhmm.

[~11:33] Lea Ream, City Attorney: For that kind of thing. And so,

[~11:34] Lea Ream, City Attorney: So I'm not trying to be...um...

[~11:37] Kyle Moring: No, I get it.

[~11:38] Kyle Moring: I mean, it's your job to do that.

[~11:39] Lea Ream, City Attorney: Yeah, exactly.

[~11:40] Lea Ream, City Attorney: It's my job.

[~11:41] Kyle Moring: I totally get it.

[~11:42] Lea Ream, City Attorney: Exactly.

[~11:44] Kyle Moring: Yeah, I'd have the complete threads in there, but honestly, I don't know.

[~11:47] Kyle Moring: I'm really just tired of this.

[~11:49] Lea Ream, City Attorney: Well, we are too.

[~11:52] Lea Ream, City Attorney: But,

[~11:53] Lea Ream, City Attorney: I mean, Mr.

[~12:04] Lea Ream, City Attorney: Moring...

[~11:54] Lea Ream, City Attorney: Like really like if we're talking,

[~11:57] Lea Ream, City Attorney: if you think we haven't given you something,

[~11:59] Lea Ream, City Attorney: I mean I understand you have some like,

[~12:01] Lea Ream, City Attorney: I think this should have turned up

[~12:03] Lea Ream, City Attorney: or that should have turned up.

[~12:04] Lea Ream, City Attorney: And you know,

[~12:05] Lea Ream, City Attorney: I don't know what to say about that

[~12:07] Lea Ream, City Attorney: other than we did the searches,

[~12:10] Lea Ream, City Attorney: we produced the documents that we had.

[~12:12] Lea Ream, City Attorney: And I mean,

[~12:13] Lea Ream, City Attorney: I know you're very, very precise

[~12:15] Lea Ream, City Attorney: and very focused.

[~12:16] Lea Ream, City Attorney: on certain things and um but we want to bring this to an end right?

[~12:21] Kyle Moring: Right.

[~12:22] Lea Ream, City Attorney: when this is

[~12:22] Lea Ream, City Attorney: costing the city a lot of money.

[~12:23] Kyle Moring: No I'm yeah I understand that and I know that

[~12:26] Kyle Moring: like for example the the correspondence that you guys produced with you guys

[~12:31] Kyle Moring: part of that request was like the invoices you know for the billing it

[~12:35] Kyle Moring: wasn't produced.

[~12:37] Lea Ream, City Attorney: Well you have to understand that it's only what's

[~12:40] Lea Ream, City Attorney: available when you make that request

[~12:41] Kyle Moring: Mhm.

[~12:41] Lea Ream, City Attorney: so it may not have been in there right like

[~12:44] Lea Ream, City Attorney: it may have not been there at the time

[~12:45] Lea Ream, City Attorney: that you made the request.

[~12:46] Kyle Moring: Okay.

[~12:48] Lea Ream, City Attorney: It's one of those,

[~12:48] Lea Ream, City Attorney: like,

[~12:49] Lea Ream, City Attorney: you know, it's a snapshot right in time.

[~12:51] Kyle Moring: Right.

[~12:51] Lea Ream, City Attorney: You know that.

[~12:52] Lea Ream, City Attorney: And so I don't know.

[~12:53] Lea Ream, City Attorney: I mean, but,

[~12:54] Lea Ream, City Attorney: again,

[~12:54] Lea Ream, City Attorney: happy to, but,

[~12:55] Lea Ream, City Attorney: you know, we'll, there's also privileged communication

[~12:58] Lea Ream, City Attorney: in there.

[~12:58] Lea Ream, City Attorney: I'm assuming that you would agree to us redacting...

[~13:01] Kyle Moring: Right, right, right.

[~13:02] Lea Ream, City Attorney: Privileged communications umm...

[~13:03] Kyle Moring: And then, like,

[~13:04] Kyle Moring: the other thing was, like,

[~13:06] Kyle Moring: with the...

[~13:07] Kyle Moring: It's the main thing pretty much, the Walmart related stuff.

[~13:12] Kyle Moring: The permits and inspections,

[~13:13] Kyle Moring: Like HS Cloud, even the contract says, they've got the ability

[~13:18] Kyle Moring: to do the electronic export.

[~13:20] Kyle Moring: And some of the pages they print out weren't even saved when they...

[~13:24] Kyle Moring: printed them out,

[~13:25] Kyle Moring: you could tell

[~13:27] Kyle Moring: the bubbles,

[~13:28] Kyle Moring: you know, you put the

[~13:29] Kyle Moring: entries in,

[~13:29] Lea Ream, City Attorney: Mhmm.

[~13:29] Kyle Moring: like the violations and stuff,

[~13:31] Kyle Moring: they were still open.

[~13:33] Kyle Moring: And it's like,

[~13:34] Lea Ream, City Attorney: I mean...

[~13:34] Kyle Moring: and I know you don't

[~13:34] Kyle Moring: understand. Like

[~13:35] Lea Ream, City Attorney: I can't speak to whether

[~13:36] Kyle Moring: Right

[~13:36] Lea Ream, City Attorney: or not

[~13:37] Lea Ream, City Attorney: there's a better way to do it. I know that

[~13:39] Lea Ream, City Attorney: you know

[~13:39] Kyle Moring: Yeah

[~13:39] Lea Ream, City Attorney: the history of that

[~13:41] Lea Ream, City Attorney: better than I do,

[~13:41] Lea Ream, City Attorney: but that we

[~13:43] Lea Ream, City Attorney: didn't have the ability to print it, period,

[~13:45] Lea Ream, City Attorney: and then we're trying to figure out how to

[~13:46] Kyle Moring: Right.

[~13:47] Lea Ream, City Attorney: try, and I guess we've given you

[~13:48] Lea Ream, City Attorney: some of that stuff that you feel like it's not sufficient.

[~13:51] Kyle Moring: Pretty much, yeah.

[~13:52] Lea Ream, City Attorney: Okay.

[~13:52] Kyle Moring: Yeah.

[~13:53] Lea Ream, City Attorney: But, I mean, if we have some focused things,

[~13:55] Lea Ream, City Attorney: again, we're not refusing to um provide those

[~14:00] Lea Ream, City Attorney: to you.

[~14:01] Lea Ream, City Attorney: It's just uh but we need to be focused,

[~14:04] Lea Ream, City Attorney: right?

[~14:04] Lea Ream, City Attorney: Like, in fairness to you,

[~14:07] Lea Ream, City Attorney: you're a very intelligent person.

[~14:10] Lea Ream, City Attorney: I have no doubt about that.

[~14:14] Lea Ream, City Attorney: But sometimes when you're putting these things in the AI kind of filter,

[~14:18] Lea Ream, City Attorney: it just comes out as like...

[~14:20] Kyle Moring: Well,

[~14:20] Lea Ream, City Attorney: It's just too much.

[~14:21] Kyle Moring: yeah, that and I like to overthink everything.

[~14:23] Kyle Moring: And I know that I have a problem with that, too.

[~14:25] Lea Ream, City Attorney: I do that,

[~14:25] Lea Ream, City Attorney: too.

[~14:26] Kyle Moring: I mean, things are way more complex than they need to be

[~14:28] Kyle Moring: because I'm trying to cover all my bases, but...

[~14:30] Lea Ream, City Attorney: Well, we're not...

[~14:31] Lea Ream, City Attorney: I mean, honestly,

[~14:31] Lea Ream, City Attorney: we're really like...

[~14:33] Lea Ream, City Attorney: That's not, that's not in the City's best interest.

[~14:35] Lea Ream, City Attorney: it's not in your best interest.

[~14:36] Lea Ream, City Attorney: We're not, if it's something you requested,

[~14:38] Lea Ream, City Attorney: if the documents existed,

[~14:40] Lea Ream, City Attorney: of course,

[~14:41] Lea Ream, City Attorney: the snapshot,

[~14:42] Lea Ream, City Attorney: right, and the time frame

[~14:43] Kyle Moring: Mhmm.

[~14:43] Lea Ream, City Attorney: and all that,

[~14:44] Lea Ream, City Attorney: we're not,

[~14:47] Lea Ream, City Attorney: you know, if you think

[~14:49] Lea Ream, City Attorney: that this is missing or that's missing

[~14:51] Lea Ream, City Attorney: or there's some data missing,

[~14:52] Lea Ream, City Attorney: we're not refusing to provide

[~14:54] Lea Ream, City Attorney: that to you, but we just need to be focused on what that is.

[~14:56] Kyle Moring: Would they just produce,

[~14:58] Kyle Moring: you know, what the summary of the screenshot was,

[~15:01] Kyle Moring: you know,

[~15:02] Kyle Moring: the…

[~15:02] Lea Ream, City Attorney: On that Walmart?

[~15:03] Kyle Moring: …on the KeyQL?

[~15:04] Lea Ream, City Attorney: I can find out.

[~15:05] Kyle Moring: I mean, if they do that,

[~15:06] Kyle Moring: like where I can see what was searched,

[~15:08] Kyle Moring: just the summary of the KeyQL

[~15:10] Lea Ream, City Attorney: Yeah.

[~15:11] Kyle Moring: I mean, that's fine.

[~15:12] Kyle Moring: I mean I'm just tired of this.

[~15:14] Lea Ream, City Attorney: I'm sure it's stressful for you.

[~15:15] Kyle Moring: Because I've got a lot more things you guys don't even realize going on

[~15:19] Lea Ream, City Attorney: Yeah.

[~15:19] Kyle Moring: with other agencies.

[~15:20] Kyle Moring: And it's like,

[~15:21] Lea Ream, City Attorney: Yeah

[~15:21] Kyle Moring: and I'm representing myself.

[~15:23] Kyle Moring: And it's been going on for a year and a half and

[~15:25] Kyle Moring: I'm just tired. Like

[~15:27] Lea Ream, City Attorney: Well, and it's, I think, let me just say that.

[~15:35] Lea Ream, City Attorney: And let me just say that the umm

[~15:41] Lea Ream, City Attorney: the big picture is important,

[~15:42] Lea Ream, City Attorney: right?

[~15:42] Kyle Moring: Mhmm.

[~15:42] Lea Ream, City Attorney: And we can get super focused on whether or not um you know

[~15:48] Lea Ream, City Attorney: we gave it to you with a paper clip or not.

[~15:50] Kyle Moring: Right.

[~15:50] Lea Ream, City Attorney: You know what I mean?

[~15:50] Kyle Moring: Right right.

[~15:53] Lea Ream, City Attorney: And and that just doesn't I don't know if that's really meaningful

[~15:56] Lea Ream, City Attorney: and I appreciate that you are very

[~16:00] Lea Ream, City Attorney: sensitive to the details.

[~16:02] Lea Ream, City Attorney: And so, but,

[~16:03] Lea Ream, City Attorney: you know,

[~16:04] Lea Ream, City Attorney: that's not what we're here to do.

[~16:05] Lea Ream, City Attorney: You've been lots of places.

[~16:07] Lea Ream, City Attorney: We've, I mean, the City, the City is really

[~16:10] Lea Ream, City Attorney: spending an extraordinary amount

[~16:12] Lea Ream, City Attorney: of money responding to these things.

[~16:13] Lea Ream, City Attorney: This is our third trip.

[~16:15] Kyle Moring: Yeah. I know.

[~16:16] Lea Ream, City Attorney: To a court hearing.

[~16:17] Lea Ream, City Attorney: And so,

[~16:20] Lea Ream, City Attorney: um

[~16:21] Lea Ream, City Attorney: You know,

[~16:22] Lea Ream, City Attorney: it's the taxpayers that are paying that money.

[~16:26] Kyle Moring: Right.

[~16:26] Lea Ream, City Attorney: You know,

[~16:27] Kyle Moring: So...

[~16:27] Lea Ream, City Attorney: I'm even giving discounts upon discounts.

[~16:29] Kyle Moring: So...

[~16:30] Lea Ream, City Attorney: But I can't, I mean, at some point,

[~16:31] Lea Ream, City Attorney: like,

[~16:32] Lea Ream, City Attorney: you know, if I'm not spending my time here,

[~16:34] Lea Ream, City Attorney: I'm working for other people.

[~16:35] Kyle Moring: Right, right.

[~16:36] Kyle Moring: And San Antonio is a good drive

[~16:38] Kyle Moring: or even if you fly

[~16:39] Kyle Moring: It's, you know, a decent amount of money

2. Email handling and the requested search summary

Original recording · 17:25–19:24 · 01:59 excerpt

Transcript timestamps are approximate.

2. Email handling and the requested search summary · ~17:25–19:24

~17:25 / 19:24

Return to the four comparisons ↑

Transcript excerpt · 17:25–19:24

[~17:25] Kyle Moring: So with this,

[~17:27] Kyle Moring: so like if, what if we just say we

[~17:28] Kyle Moring: you know,

[~17:30] Kyle Moring: agree to do...

[~17:32] Lea Ream, City Attorney: Let me, let me, let me, um I would really need, um

[~17:35] Lea Ream, City Attorney: let me

[~17:37] Kyle Moring: Because I mean,

[~17:38] Kyle Moring: I don't know if she would take this and it's like I don't want to get yelled at again.

[~17:42] Speaker 1 — unidentified: It's

[~17:45] Lea Ream, City Attorney: not fun

[~17:45] Lea Ream, City Attorney: being yelled at.

[~17:46] Kyle Moring: No.

[~17:54] Lea Ream, City Attorney: Um, Okay,

[~17:58] Lea Ream, City Attorney: let me,

[~17:59] Lea Ream, City Attorney: okay,

[~18:00] Lea Ream, City Attorney: so can you,

[~18:01] Lea Ream, City Attorney: okay,

[~18:01] Lea Ream, City Attorney: do this.

[~18:03] Lea Ream, City Attorney: Can you write me an email what it is you think that you're asking for so I can understand what that is?

[~18:07] Kyle Moring: Mhmm.

[~18:08] Lea Ream, City Attorney: And then let me...umm

[~18:11] Lea Ream, City Attorney: let me visit with

[~18:14] Lea Ream, City Attorney: because I don't know

[~18:15] Lea Ream, City Attorney: I have not been

[~18:16] Lea Ream, City Attorney: I'm not billing the city

[~18:17] Lea Ream, City Attorney: for reviewing

[~18:18] Lea Ream, City Attorney: all of your emails

[~18:18] Lea Ream, City Attorney: and all that

[~18:19] Lea Ream, City Attorney: I kind of scan them

[~18:20] Lea Ream, City Attorney: and let Austin deal with them

[~18:22] Lea Ream, City Attorney: we have to be more efficient

[~18:23] Lea Ream, City Attorney: you know

[~18:24] Kyle Moring: right

[~18:24] Lea Ream, City Attorney: obviously

[~18:25] Lea Ream, City Attorney: and

[~18:26] Lea Ream, City Attorney: unless it's something

[~18:27] Lea Ream, City Attorney: that really requires

[~18:28] Lea Ream, City Attorney: my attention

[~18:28] Lea Ream, City Attorney: but um

[~18:31] Lea Ream, City Attorney: if you can write to me what it is that we're talking about

[~18:34] Kyle Moring: Mhmm

[~18:34] Lea Ream, City Attorney: and we can enter into some something

[~18:36] Lea Ream, City Attorney: and that results in the resolution of this I think we're good

[~18:40] Kyle Moring: okay

[~18:40] Lea Ream, City Attorney: Okay

[~18:41] Kyle Moring: yeah I can do that

[~18:44] Lea Ream, City Attorney: I mean I just don't

[~18:44] Lea Ream, City Attorney: want to commit to something

[~18:45] Kyle Moring: right no I understand that

[~18:46] Kyle Moring: yeah

[~18:46] Lea Ream, City Attorney: I don't understand what it is because you're much deeper into

[~18:49] Lea Ream, City Attorney: the detail.

[~18:50] Kyle Moring: Yeah.

[~18:50] Kyle Moring: No, it won't be that detailed.

[~18:52] Kyle Moring: It'll be pretty much, you know.

[~18:55] Lea Ream, City Attorney: You're looking for the,

[~18:56] Lea Ream, City Attorney: what the search we did for the records on the, on the permits?

[~19:00] Kyle Moring: No,

[~19:01] Kyle Moring: on the,

[~19:02] Kyle Moring: just the Walmart domain search.

[~19:03] Lea Ream, City Attorney: Okay.

[~19:04] Kyle Moring: And that's it.

[~19:05] Lea Ream, City Attorney: Okay.

[~19:05] Lea Ream, City Attorney: So I saw that we did,

[~19:07] Lea Ream, City Attorney: we gave you something on that and that's not what you're looking for.

[~19:09] Kyle Moring: So this is just a screenshot but there's like an actual summary,

[~19:12] Kyle Moring: like a list that will show like the headers and stuff.

[~19:15] Kyle Moring: The,

[~19:17] Kyle Moring: Seth Bryan's doing it for a request I did with uh...

[~19:19] Lea Ream, City Attorney: Mr. Bailey?

[~19:19] Kyle Moring: Chuck Bailey's office.

[~19:22] Lea Ream, City Attorney: Okay, let me, um

[~19:23] Lea Ream, City Attorney: let me, let me talk to...oop I'm not going to call in here

3. Apparent screenshot request — wording uncertain

Original recording · 28:58–29:30 · 00:32 excerpt

The words in this brief exchange are uncertain.

3. Apparent screenshot request — wording uncertain · ~28:58–29:30

~28:58 / 29:30

Return to the four comparisons ↑

Listening note · 28:58–29:30

Around 28:58–29:30, Ream appears to ask Candias for a screenshot; the exact words are unclear.

The recording does not identify the screenshot or establish whether it was sent. The later OR screenshot discussion is a separate exchange.

4. Telephone query discussion, rerun, possible cost and scope

Original recording · 30:28–36:18 · 05:50 excerpt

Transcript timestamps are approximate.

4. Telephone query discussion, rerun, possible cost and scope · ~30:28–36:18

~30:28 / 36:18

Return to the four comparisons ↑

Transcript excerpt · 30:28–36:18

[~30:28] Lea Ream, City Attorney: Okay, I'm gonna...I'm gonna

[~30:30] Lea Ream, City Attorney: Let me go see if I'm going to let him explain to y'all what it is that he's looking for.

[~30:43] Lea Ream, City Attorney: Okay,

[~30:43] Lea Ream, City Attorney: Kyle, so we have, I have Seth and Candias on the phone here.

[~30:49] Lea Ream, City Attorney: And like I'm, and of course here's the Mayor.

[~31:00] Kyle Moring: Okay.

[~30:53] Lea Ream, City Attorney: So this is that Walmart search,

[~30:56] Lea Ream, City Attorney: right?

[~30:56] Lea Ream, City Attorney: But you've seen that.

[~30:58] Kyle Moring: Right. I'm, I'm

[~30:59] Kyle Moring: And it also had the "AND",

[~31:00] Kyle Moring: like I pointed out why it's an issue

[~31:02] Kyle Moring: to have the "AND" in the participants.

[~31:04] Kyle Moring: Because they should be looking for both things,

[~31:05] Kyle Moring: but the actual KeyQL search with just,

[~31:09] Kyle Moring: you know,

[~31:10] Kyle Moring: even if it's just headers of the emails,

[~31:13] Kyle Moring: the email addresses,

[~31:14] Kyle Moring: or it shows kind of like

[~31:15] Kyle Moring: what he's doing for the um district attorney record request.

[~31:20] Lea Ream, City Attorney: Seth, can you hear that?

[~31:22] Seth Bryan, Bryan IT: Yes,

[~31:22] Seth Bryan, Bryan IT: yes.

[~31:23] Seth Bryan, Bryan IT: Okay,

[~31:23] Seth Bryan, Bryan IT: so just so I am getting this correct, Kyle

[~31:25] Seth Bryan, Bryan IT: so you want me to remove the "AND", uh,

[~31:28] Seth Bryan, Bryan IT: the "AND"

[~31:29] Seth Bryan, Bryan IT: condition there, to "OR"?

[~31:31] Kyle Moring: Yeah, I think that's the way that it would, it would pick up,

[~31:35] Kyle Moring: you know, what I had requested

[~31:37] Lea Ream, City Attorney: if it's with "OR".

[~31:38] Mayor Wesley Lyon: Is it SQL?

[~31:40] Kyle Moring: Mm-hmm.

[~31:40] Mayor Wesley Lyon: Uh, it's "AND", and "OR".

[~31:43] Lea Ream, City Attorney: Uh-huh.

[~31:43] Mayor Wesley Lyon: It's actually both of them.

[~31:45] Lea Ream, City Attorney: Okay,

[~31:46] Lea Ream, City Attorney: Okay so you want us to run this search again with it?

[~31:52] Kyle Moring: Yeah, just those same parameters. And I just you know just see what.

[~31:55] Lea Ream, City Attorney: But "AND/OR".

[~31:56] Kyle Moring: Mhmm.

[~31:56] Lea Ream, City Attorney: Okay,

[~31:57] Lea Ream, City Attorney: can we do that guys?

[~31:59] Seth Bryan, Bryan IT: Sure,

[~32:00] Seth Bryan, Bryan IT: yeah. Definitely.

[~32:01] Seth Bryan, Bryan IT: So let me just go back to that same uh search

[~32:06] Lea Ream, City Attorney: Those same keywords?

[~32:07] Seth Bryan, Bryan IT: and I'll just adjust those parameters

[~32:08] Kyle Moring: Yeah, I think the search is fine.

[~32:09] Kyle Moring: It's more just the participants.

[~32:11] Lea Ream, City Attorney: "AND/OR",

[~32:11] Kyle Moring: Mhmm.

[~32:12] Lea Ream, City Attorney: Yeah. Okay.

[~32:14] Lea Ream, City Attorney: And then what you get,

[~32:16] Lea Ream, City Attorney: and then that produces X documents,

[~32:20] Lea Ream, City Attorney: right?

[~32:20] Kyle Moring: Mm-hmm.

[~32:23] Lea Ream, City Attorney: So...

[~32:29] Candias Webster, City Secretary: And then we have to go through those again?

[~32:30] Lea Ream, City Attorney: Well so, would it, I would think that's what we'd have to do,

[~32:31] Lea Ream, City Attorney: but I guess what we

[~32:32] Lea Ream, City Attorney: did before was "AND"? or we did "OR"? Seth, do you know?

[~32:37] Seth Bryan, Bryan IT: Yeah, so yeah, it did "AND" umm and I...

[~32:41] Lea Ream, City Attorney: Oh who is this...

[~32:42] Seth Bryan, Bryan IT: I'm trying to think.

[~32:44] Seth Bryan, Bryan IT: So technically because it's looking for keywords with the word Walmart as well as participants

[~32:51] Seth Bryan, Bryan IT: of Walmart,

[~32:51] Seth Bryan, Bryan IT: so yeah, that would just produce,

[~32:55] Seth Bryan, Bryan IT: yeah, I can just change at the "AND/OR" or it will

[~32:57] Seth Bryan, Bryan IT: probably generate um a lot more emails and it would technically be a separate export.

[~33:03] Seth Bryan, Bryan IT: But um yeah, I can just go back to that original case and change that. That's not a hard thing to do.

[~33:07] Lea Ream, City Attorney: So,

[~33:08] Candias Webster, City Secretary: I have a screenshot here where we actually did do it with "OR" and it produced the same amount.

[~33:16] Candias Webster, City Secretary: Like I can send it to you.

[~33:18] Seth Bryan, Bryan IT: Oh,

[~33:18] Seth Bryan, Bryan IT: that's when I did the KeyQL.

[~33:20] Candias Webster, City Secretary: Yeah,

[~33:21] Candias Webster, City Secretary: and we did a screen, a

[~33:23] Candias Webster, City Secretary: screenshot where it pretty much produced the exact same stuff.

[~33:27] Lea Ream, City Attorney: So, okay just let me

[~33:28] Kyle Moring: But it's like he said, the "AND/OR", the participants.

[~33:30] Kyle Moring: You're right,

[~33:31] Kyle Moring: yeah.

[~33:31] Lea Ream, City Attorney: But why wouldn't, why wouldn't "OR" give you more?

[~33:35] Lea Ream, City Attorney: Like,

[~33:35] Lea Ream, City Attorney: if it's...

[~33:35] Mayor Wesley Lyon: If you don't use the "AND", that's what I did,

[~33:39] Mayor Wesley Lyon: like, the last 20 years.

[~33:40] Mayor Wesley Lyon: The "AND/OR" was actually using both of those parameters,

[~33:43] Lea Ream, City Attorney: Uh-huh

[~33:43] Mayor Wesley Lyon: so it'll pull more than just one

[~33:46] Mayor Wesley Lyon: or the other.

[~33:47] Lea Ream, City Attorney: okay

[~33:47] Mayor Wesley Lyon: does that make sense

[~33:49] Mayor Wesley Lyon: it's weird

[~33:50] Lea Ream, City Attorney: Not to me it seems like if it has one

[~33:51] Lea Ream, City Attorney: it should pull it

[~33:52] Kyle Moring: It. Yeah

[~33:53] Lea Ream, City Attorney: yeah

[~33:53] Lea Ream, City Attorney: when it has both

[~33:54] Mayor Wesley Lyon: yeah it's a sequel thing

[~33:55] Seth Bryan, Bryan IT: Mhmm.

[~33:55] Lea Ream, City Attorney: okay

[~33:56] Lea Ream, City Attorney: alright

[~33:57] Lea Ream, City Attorney: so

[~33:58] Lea Ream, City Attorney: um

[~34:01] Lea Ream, City Attorney: okay

[~34:02] Lea Ream, City Attorney: and then we'll have to look through those

[~34:03] Lea Ream, City Attorney: and that's gonna take time

[~34:05] Kyle Moring: that's fine

[~34:06] Lea Ream, City Attorney: All right, so, so,

[~34:09] Lea Ream, City Attorney: Seth,

[~34:10] Lea Ream, City Attorney: can you write for me in words?

[~34:10] Seth Bryan, Bryan IT: Mhmm.

[~34:13] Lea Ream, City Attorney: Because I want to put this on the record before the judge, are you

[~34:16] Lea Ream, City Attorney: do you agree to that?

[~34:18] Lea Ream, City Attorney: That what the parties have agreed is basically to run this search again with "AND/OR" right?

[~34:27] Lea Ream, City Attorney: and once the city has reviewed those records

[~34:30] Lea Ream, City Attorney: and provided those in accordance with the normal,

[~34:33] Lea Ream, City Attorney: I mean, there might be a cost involved in that if it's additional.

[~34:36] Kyle Moring: Okay

[~34:38] Lea Ream, City Attorney: Then we'll,

[~34:40] Lea Ream, City Attorney: and that's it.

[~34:42] Lea Ream, City Attorney: We're done with this.

[~34:43] Kyle Moring: Mhmm.

[~34:43] Lea Ream, City Attorney: Right?

[~34:43] Lea Ream, City Attorney: We're done with the the lawsuit, and um,

[~34:47] Lea Ream, City Attorney: and it will be dismissed.

[~34:50] Lea Ream, City Attorney: Right?

[~34:51] Lea Ream, City Attorney: okay

[~34:52] Lea Ream, City Attorney: alright

[~34:52] Lea Ream, City Attorney: and I don't want

[~34:53] Lea Ream, City Attorney: we don't want to come back here

[~34:55] Kyle Moring: no

[~34:56] Kyle Moring: I don't either

[~34:59] Seth Bryan, Bryan IT: Sounds good

[~34:59] Seth Bryan, Bryan IT: okay

[~35:00] Seth Bryan, Bryan IT: so yeah

[~35:00] Seth Bryan, Bryan IT: I can I can certainly

[~35:01] Seth Bryan, Bryan IT: I'll change that over

[~35:02] Seth Bryan, Bryan IT: and I can write up an email

[~35:04] Seth Bryan, Bryan IT: and send it over to you

[~35:05] Lea Ream, City Attorney: thank you very much

[~35:07] Seth Bryan, Bryan IT: and send it to Candias

[~35:08] Seth Bryan, Bryan IT: yeah

[~35:08] Seth Bryan, Bryan IT: I will get this export

[~35:10] Seth Bryan, Bryan IT: started right now

[~35:11] Lea Ream, City Attorney: thank you

[~35:12] Lea Ream, City Attorney: I appreciate it so much

[~35:13] Lea Ream, City Attorney: and thank you Candias

[~35:15] Lea Ream, City Attorney: and I think you're

[~35:16] Lea Ream, City Attorney: Candias you're on

[~35:17] Lea Ream, City Attorney: you don't need to come down

[~35:18] Lea Ream, City Attorney: I think right now

[~35:20] Candias Webster, City Secretary: Yes ma'am

[~35:20] Lea Ream, City Attorney: All right,

[~35:21] Lea Ream, City Attorney: thank you.

[~35:21] Kyle Moring: Thank you.

[~35:22] Candias Webster, City Secretary: You're welcome.

[~35:23] Seth Bryan, Bryan IT: Thank you guys.

[~35:24] [Overlapping speech; words unclear.]

[~35:26] Mayor Wesley Lyon: So they're running that in, for the mail database?

[~35:32] Lea Ream, City Attorney: Uh yeah, that's right,

[~35:33] Lea Ream, City Attorney: that's what they're

[~35:33] Lea Ream, City Attorney: I mean,

[~35:34] Lea Ream, City Attorney: whatever it was he requested before

[~35:35] Lea Ream, City Attorney: in terms of the database.

[~35:36] Mayor Wesley Lyon: [Unclear: “So more like the emails?”]

[~35:36] Kyle Moring: Yeah, it said email,

[~35:39] Kyle Moring: but it's like,

[~35:40] Kyle Moring: I'm not even gonna push my luck on the rest of it.

[~35:41] Kyle Moring: I mean,

[~35:42] Kyle Moring: it was supposed to be all the platforms,

[~35:44] Kyle Moring: but it's, I'm not gonna do that.

[~35:46] Lea Ream, City Attorney: Email,

[~35:47] Lea Ream, City Attorney: that's what you're looking for.

[~35:48] Lea Ream, City Attorney: okay all right

[~35:53] Lea Ream, City Attorney: all right well see this is this is what conferring does for us, we can...all right

[~36:02] Lea Ream, City Attorney: let me um

[~36:03] Mayor Wesley Lyon: So who's running that query is that gonna be Seth or Austin?

[~36:07] Lea Ream, City Attorney: Yeah Seth is

[~36:08] Mayor Wesley Lyon: Seth is?

[~36:10] Lea Ream, City Attorney: yeah okay let me go and um communicate with the court just so we can get one thing off her docket if she's um....

5. Closing search terms and platform scope

Original recording · 39:35–40:18 · 00:43 excerpt

Transcript timestamps are approximate.

5. Closing search terms and platform scope · ~39:35–40:18

~39:35 / 40:18

Return to the four comparisons ↑

Transcript excerpt · 39:35–40:18

[~39:38] Lea Ream, City Attorney: and this uh these the these are the terms that you saw in that picture are correct right?

[~39:45] Kyle Moring: Yeah, I think the term's right.

[~39:46] Kyle Moring: The only thing I could tell was the participant thing.

[~39:51] Lea Ream, City Attorney: Yeah,

[~39:52] Lea Ream, City Attorney: and so instead of this "OR", we're going to do "AND/OR".

[~39:56] Kyle Moring: Right, the "AND/OR".

[~39:58] Lea Ream, City Attorney: Gotcha.

[~39:58] Lea Ream, City Attorney: Okay.

[~39:59] Kyle Moring: And I know that, like,

[~40:00] Kyle Moring: what Wesley was saying,

[~40:03] Kyle Moring: it says at the top, you know, where it searches.

[~40:05] Kyle Moring: I think that one says email.

[~40:06] Lea Ream, City Attorney: Mhmm.

[~40:07] Kyle Moring: I don't even know if, like...

[~40:10] Lea Ream, City Attorney: It doesn't stop you from submitting some other request.

[~40:12] Kyle Moring: No, no, I get that.

[~40:13] Kyle Moring: I don't even know if their system would handle, like,

[~40:16] Kyle Moring: the Axon search with the KeyQL.

6. Post-hearing follow-up conversation

Original recording · 47:28–48:04 · 00:36 excerpt

Transcript timestamps are approximate.

6. Post-hearing follow-up conversation · ~47:28–48:04

~47:28 / 48:04

Return to the four comparisons ↑

Transcript excerpt · 47:28–48:04

[~47:35] Lea Ream, City Attorney: okay we have a deal

[~47:37] Kyle Moring: yeah yeah

[~47:38] Lea Ream, City Attorney: okay and you're gonna call me if you have a problem

[~47:42] Kyle Moring: right

[~47:43] Lea Ream, City Attorney: okay

[~47:44] Lea Ream, City Attorney: we have like i'm not we're not messing with you we're just trying to get i mean i understand you

[~47:49] Lea Ream, City Attorney: can get kind of

[~47:51] Lea Ream, City Attorney: We can go down the rabbit hole, but let's try not to.

[~47:53] Kyle Moring: No, no,

[~47:54] Kyle Moring: let's.

[~47:54] Lea Ream, City Attorney: Okay.

[~47:55] Lea Ream, City Attorney: Okay.

[~47:56] Kyle Moring: Thank you.

[~47:56] Lea Ream, City Attorney: Yes, sir.

Participants and source context

September 18: rerunning the search, possible costs, and dismissal

Seth Bryan asks whether changing the added AND condition to OR would find more messages and says the earlier search used AND. Lyon discusses using both sets of parameters. Webster says she has a screenshot of an OR run that produced the same amount; Moring says he has not received it. These descriptions need comparison with the saved query settings and result lists. A proposed rerun and export do not show that either was completed.

The conversation includes Kyle Moring, City Attorney Lea Ream and Mayor Wesley Lyon. City Secretary Candias Webster and Seth Bryan join by telephone.

10:54–13:02 · ~Ream says documents need to be complete and describes the searches and City expense. Moring raises missing threads and invoices. Ream notes that a particular invoice may not have existed on the request date. The February 14 request expressly sought attorney bills; the actual billing response must be checked separately.

13:07–16:04 · ~Moring raises electronic inspection records and asks for the Walmart search summary. Ream acknowledges limits to her technical knowledge, says she can ask about the summary and uses a paper clip as an analogy for the level of detail under discussion.

17:37–19:22 · ~Ream says she scans Moring’s emails and is not billing the City for reviewing them all. Moring again asks for the Walmart search summary with more than the pictured query. Neither statement determines the total expense or establishes that the summary was delivered.

28:58–29:30 · ~Ream appears to ask Candias for a screenshot. The exact words are unclear, and the exchange does not identify the screenshot or show whether it was sent.

30:43–36:10 · ~Bryan discusses changing the added AND condition, anticipates more messages and offers another export. Webster describes an earlier OR screenshot with the same amount. The two accounts require the actual query settings and result lists to reconcile.

39:38–40:16 · ~Moring identifies the participant condition as his concern and notes the displayed search covers email. His request and the search records must be compared to assess any other systems.

47:38–47:51 · ~In a later conversation excerpt, Ream asks Moring to call if he has a problem and says they can “go down the rabbit hole” but should try not to. The short exchange is separate from the earlier search discussion.

The details at issue: search logic, metadata and native format

Ream says the City is not refusing requested records that exist and asks for a focused description of what is missing. Moring asks for the Walmart search summary so he can see what was searched; Ream says, “I can find out.” She then uses a paper clip as an analogy for attention to details and says Moring is “very sensitive to the details.” The locators around 13:53–16:00 are estimated.

Moring’s response is about verifiable search and production: an added AND condition changes which messages qualify, headers identify senders and dates, and native files may preserve structure lost in a printout. These are specific completeness and history questions. Not every metadata field necessarily exists in every source file.

Read the TPIA guide and linked TSLAC resources ↗

Transcript timestamps are approximate. The wording of the apparent screenshot request is uncertain. Search-result counts are comparable only when custodians, dates, fields and other settings match; delivered file counts are not raw search-hit counts.