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Avi S. Adelman5620 East Side Avenue

Dallas Texas 75214

Telephone 214.824.5771 / Fax 214.292.9761 / Avi@AviAdelman.com

TO J. D. SpillerChief of Police

Dallas Area Rapid Transit

By email and fax 214-749-5941

Copy to Gary C. Thomas President/Executive Director, Dallas Area Rapid Transit

Morgan Lyons Public Information Officer, Dallas Area Rapid Transit

By email and fax 214-749-0281

Date February 15, 2016

In accordance with the Texas Public Information Act, I make the following requests for information.

This letter shall also serve as a formal notice and demand for the preservation of all records

(paper and electronic) covered by this request until such time as determined under applicable

state law or other requirements.

This request is made under the Texas Open Records Act, chapter 552 of the Government Code (formerly

V.T.C.S. article 6252) as well as Article I, Sec. 8 of the Texas Constitution, the First Amendment to the

United States Constitution, the common law of the State of Texas and any statue providing for public

access to government information:

I request that I be sent copies of the following documents or, if there are a large number, be permitted to

inspect the following documents and receive one copy of the ones I would like.

Subject of Open Records Request

The arrest of Avi S. Adelman

Alias: Avis Adelman

For Criminal Trespass 30.05(a) PG, Misdemeanor Class B

Case Number M1616393 (Dallas County Courts)

Time/Date of interest Tuesday, February 9, 2016

730pm through 830pm local time

Location of Incident Rosa Parks Plaza

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Documents Requested

The personnel file (aka jacket) of DART Officer BRANCH / Badge #331 (Branch)

The original criminal offense report filed by BRANCH for this incident

The original criminal complaint filed by BRANCH for this incident

Any and all reports or other documentation filed by BRANCH and / or other officers at the

scene, or any follow-up questions and reports

Copies of any and all dashcam audio and video files generated by the numerous DART

Police vehicles at this location during the referenced timeframe. This would include audio

transmitted from a microphone device worn by any DART officer to their dashcam systems

Copies of any and all bodycam video cameras that may have been worn by DART Police

officers on the scene of this incident

Copies of any video created by DARTs surveillance camera system in and around the Rosa

Parks Plaza at the time of this incident

Audio files containing all communications on the DART Police radio system between

7:30pm and 8:30pm regarding this incident, including but not limited to BRANCH and any

other DART officers at the scene of the incident, in transit or otherwise contacted

Audio files containing all telephone conversations on all cellular/mobile phones used byBRANCH and any other DART officers, either between themselves or with the DART Police

office in regards to this incident

Any and all correspondence, notes, records, including email and reports generated in regards

to this incident between BRANCH, other DART officers, and DARTs Police Department

Any and all correspondence, notes, records, including email and reports generated between

staff of DARTs Police Department and DARTs Public Information Office (all staff) in

regards to this incident

Any and all correspondence, notes, records, including email received and reports generated

by DARTs Public Information Office in response to requests for information on this incident

by the media or general public

Any and all internal correspondence generated by any DART department or staff person in

the time between the incident and the receipt of this Open Records Request in regards to this

incident

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If you have any questions about the nature or scope of this request, please call me at the phone number

listed above. Should you determine that all or some portion of the information requested is excepted

from required disclosure, I request that you provide me with the portions of the requested information

that are public and reasonably segrable from that which you believe is excepted. If any records are in

active use or in storage, please certify this fact in writing and set a date and hour within a reasonable

time when the records will be available, as required by section 552.221 of the Act.

If you determine that all or some portion of the information requested is excepted from required public

disclosure under a particular exception, I request that you advise me as to which exceptions you believe

apply. If you rely on previous determination, please advise me of the applicable court decision or

Attorney General's opinion. If there is no such determination, please advise me of the request for such an

opinion, as required under section 552.301 of the Act, and a dated copy of your letter to the Attorney

General. I call your attention to section 522.353 of the Act, which provides penalties for a failure to

release public records.

I am prepared to pay reasonable costs for copying, within the guidelines set by sections 552.261,

552.262, 552.263, 552.267, 552.268, 552.269.

As an alternative to condensing or compiling information to the specific pieces requested, the City may

provide me copies or access to documents ("raw documents") which contain the information requested.

If you have any questions, I can be reached by telephone at the number above.

Thank you for your timeliness and I await your response.

Sincerely,

Avi S. Adelman

Dallas

Copy to Mickey H. Osterreicher

General Counsel

National Press Photographers Association