Code Enforcement's Refusal to Enforce Laws Requiring Deadbolts at the Baltimore Hotel owned by-AIDS Healthcare Foundation

To Whom It May Concern:

Pursuant to the California Public Records Act, I hereby request the following records:

Please provide all notes, entries, photos, videos, reports, complaints, emails, text messages, and other communications, concerning the following:

1.Code Enforcement Complaint #897099, filed April 30, 2024, in which a tenant complained he did not have a deadbolt, and more than 100 other units at the AIDS Healthcare Foundation's Baltimore Hotel did not have deadbolts
2. Inspector Tony Robles noted that on May 9, 2024, he went to the Baltimore and spoke with the complaining tenant, and took photos. Please provide all of those notes, documents, photos or videos.
3. All communications regarding the February 2022 inspection by Tony Robles of the Baltimore, during which he noted over 100 violations for lack of deadbolts, but James Heiberg said to delete those violations.
4. All communications between anyone from Code Enforcement and anyone at AIDS Healthcare Foundation, regarding the deadbolts at the Baltimore. This is including but not limited to the text messages and emails that Robert Gilardi kindly sends to Mark Dyer rather than issuing a Notice to Comply. This includes communications between Code Enforcement on the one hand, and on the other hand, AHF's: Mark Dyer, Michael Weinstein, Jonathan Eisenberg, Tom Myers, Conrad Sison, Beatrice Di Marco, Dominique Eastman, Herbert Ellis, Juan Larios.
5. Any discussion (including emails, text messages, memos, notes) between any Code Enforcement employee, (including but not limited to James Heiberg, Robert Gilardi, Tony Robles, Ann Sewill, etc.), that includes any of the following terms: "1941.3" "deadbolt" "dead bolt" "91.8607" "door lock" "91.8607" and/or "897099."
6. Any discussion between any Code Enforcement employee, about why it decided to exclude the exact complaint language from the publicly accessible Property Activity Report on complaint #897099.
7. Any emails with the subject line "Complaint # 897099 / Baltimore Hotel / Carlos Brum/ Lack of Deadbolts"

This public records act request is not limited to the custodian of records simply forwarding this request to the named individuals here. This request demands that the custodian of records actually contact its IT department and conduct a search with the specific parameters and search terms. This request demands electronic copies of these records in their native format, and not printed out and scanned.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 calendar days, as the statute requires.

Sincerely,

Annette Morasch

A response was due on June 23, and then Code Enforcement extended its deadline to July 8. What date will documents be produced? At a minimum the complaint #897099, photos, investigation, notice to comply and related documents should be produced immediately.
Let me know if filing a writ will speed things up.

If I do not get a meaningful and substantive response by July 26, I will engage an attorney to file a petition for writ of mandate to compel compliance. Obtaining documents through a writ opens up the City to paying for the prevailing party's attorneys' fees and costs. The response was due a month ago and I have not received a single document.

These records do not include any of the attachments to the emails. As just one example, the email from Mark Dyer to the City dated 2/12/2024 has several attachments which were not produced. (See attached.) None of the emails which show they have attachments were produced with the attachments.
These records also do not include any of the following requested documents:

2. Inspector Tony Robles noted that on May 9, 2024, he went to the Baltimore and spoke with the complaining tenant, and took photos. Please provide all of those notes, documents, photos or videos.
3. All communications regarding the February 2022 inspection by Tony Robles of the Baltimore, during which he noted over 100 violations for lack of deadbolts, but James Heiberg said to delete those violations.
4. All communications between anyone from Code Enforcement and anyone at AIDS Healthcare Foundation, regarding the deadbolts at the Baltimore. This is including but not limited to the text messages and emails that Robert Gilardi kindly sends to Mark Dyer rather than issuing a Notice to Comply. This includes communications between Code Enforcement on the one hand, and on the other hand, AHF's: Mark Dyer, Michael Weinstein, Jonathan Eisenberg, Tom Myers, Conrad Sison, Beatrice Di Marco, Dominique Eastman, Herbert Ellis, Juan Larios.
5. Any discussion (including emails, text messages, memos, notes) between any Code Enforcement employee, (including but not limited to James Heiberg, Robert Gilardi, Tony Robles, Ann Sewill, etc.), that includes any of the following terms: "1941.3" "deadbolt" "dead bolt" "91.8607" "door lock" "91.8607" and/or "897099."

Documents have been redacted without reason. I understand why you woudl redact tenant contact information (which you did for some, but not others). But there are whole chunks of communications redacted without saying who was involved in the redacted communication. Thus the majority of my requests were ignored by the City.

Conclusion. If I do not receive a fully compliant response to my PRA, we will file a writ of mandate and seek attorneys' fees on August 19, 2024.