Please provide records created or received from 1/1/24 to the date of your response to this request by any City Council member or Zaheer A. Samee related to an Open Meeting Law Complaint involving the City Council, as dated 1/22/24. Relevant records may be characterized as the following:
> Email with any attachments
> Text Messages
> Lists, Documents, Exhibits, Tables, Spreadsheets, Reports (Draft and Final) containing outlines, questions, compilations of responses, of results and analysis
> All records related to a 2/20/24 document by Atty Samee, with specificity of conversations and summary of supporting statements related to:
>> “I spoke with every city councillor …” and “Any communications between the members on the topic were mostly brief and sporadic verbal exchanges, and usually involved only two (at most three) members at a time.”
>> “These conversations, most of which were ad hoc and casual, were uncoordinated.”
>> “There was no serial communication between members …”
>> “There is no evidence that a quorum of the Malden City Council deliberated outside a properly noticed meeting, or otherwise sought to circumvent the open meeting law.”
For any record Atty Samee withholds based on attorney-client privilege, please provide an appropriate Privilege Log and Index citing the specific client and its attorney/counsel representation agreement, joint defense or other statement warranting a “seal of secrecy”, evidence that individual Council members have waived conflicts introduced by other individuals similarly but separately represented.
For any record Atty Samee withholds under exemptions allowed by https://www.mass.gov/info-details/exemptions please make the specific exemption known.
Statute establishes a clear "presumption that the record sought is public" and places the burden on the record's custodian to "prove with specificity the exemption which applies" to any withheld documents. G. L. c. 66, s. 10 (c). Thank you.
Please see attached documents as requested
Request Date
2024-03-18
Agency Tracking
2024-0099
Acquisition Notes
This record was automatically imported from https://www.townforms.com/FOIADirect-MaldenMACitizens/
