Dear Messrs. Harriss, Brown, Wilson, Gardner, Williamson, et al. and Ms. Burk:
Will you please agree by return E-mail by 2 PM today to preserve inviolate all City records in any location, including but not limited to City Hall, the Warehouse, the Police Administration Building and Firehouses and Commissioners' and City managers' and attorneys' homes, offices and boats?
As you are all aware, there are pending criminal complaints with federal and state entities regarding possible criminal activity, including pollution, Sunshine violations and other matters.
Under federal and state law, it would be an obstruction of justice and civilly actionable spoliation of evidence for anyone to remove, alter, destroy, conceal, shred or censor documents.
It has come to my attention that lights were burning on the top floor of City Hall last night.
The public has a right to know what, if any, meetings may have been held there and whether anyone has used any shredding machines in recent days. For that reason, I hereby request that all shredders be secured, disconnected, disabled or removed, to prevent the willful or negligent destruction of public records, and that the securing of the shredders be witnessed and documented by videotape no later than 3 PM today.
The term "document" means all writings of any kind, including the originals or a copy of the original and any nonidentical copy, including copies with marks, comments or marginal notations, regardless of original location, including Commissioners' and City employees' offices, boats, trucks, residences, private files, "Do Not File" files, briefcases, automobiles and safety deposit boxes, of any recorded, written, printed, typed or other graphic material of any kind, variety, character or type, including by way of example but not limited to, the following: agendas; reports; recommendations; transcripts; minutes; charters; books; records; contracts; subcontracts; Requests for Proposals; pre-bid conference announcements; solicitations; documents of any kind at contractor or other locations whether or not they formally said to exist; proposals; bids; notices of violations by regulatory agencies; work orders; environmental sampling and industrial hygiene reports; archaeological reports; newspaper articles; notices; contract modifications; deliverables; drafts; final products; questions; comments; suggestions; agreements; invoices; orders; bills; certificates; deeds; bills of sale; certificates of title; financing statements; instruments; expense accounts; receipts; disbursement journals; tax returns; financial statements; check stubs; promissory notes; resumes; address books; appointment books; telephone logs; worksheets; pictures; income statements; profit and loss statements; deposit slips; credit card receipts; records or notations of telephone or personal conversations; conferences; intraoffice communications; postcards; letters; telex; partnership agreements; catalog price lists; sound, tape and video records; memoranda (including written memoranda of telephone conversations, other conversations, discussions, agreements, acts and activities); manuals; diaries; calendars or desk pads; scrapbooks; notebooks; correspondence; bulletins; circulars; policies; forms; pamphlets; notices; statements; journals; postcards; letters; telegrams; reports; interoffice communications; photostats; microfilm; microfiche; maps; deposition transcripts; drawings; blueprints; photographs; negatives; and any other data, information or statistics contained within any data storage modules, discs, or any other memory devices (including IBM or similar cards for information, data, and programs) or any other information retrievable on storage systems, including computer-generated reports and print-outs. Non-duplicate copies are separate documents. Documents include any documents in any City of St. Augustine or contractor location, including outside counsel, architectural and engineering and building contractors, personnel property or third party containing records of government activities kept with government materials on government time (e.g., Franklin Planners, etc. that may be located in residences and briefcases); City Manager; City Attorney; City Clerk; Police Department; Fire Department; Purchasing; management; union negotiation; pension plans; and any other department or entity.
Please contact me by 2 PM today in order to state your agreement to preserve all City documents, as defined above, and otherwise.
Herein faileth not.
Please call me if you have any questions on this request.
Thank you in advance for your kind cooperation.
With kindest regards, I am,
Sincerely yours,
Ed
Ed Slavin
Box 3084
St. Augustine, Florida 32085
904-471-7023
904-471-9918 (fax)
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