Avi S.

Adelman
5620 East Side Avenue
Dallas Texas 75214
Telephone 214.824.5771 / Fax 214.292.9761 / Avi@AviAdelman.com

TO

J. D. Spiller
Chief 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

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 by
BRANCH 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

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