Scribd Logo
Upload

Welcome to Scribd!

  • 18K views

    Maricopa PRR Re Runbeck Video

    Uploaded by

    Jordan Conradson
    A law firm representing We The People AZ Alliance submitted a public records request to Runbeck Election Services seeking security camera footage from November 2022. Runbeck refused to comply with the request, citing that it is a private company not subject to public records laws. The law firm is now asking Maricopa County to obtain the requested footage directly from Runbeck, as Runbeck serves as a de facto elections department due to its role supporting Maricopa County elections. The law firm warns that if the footage is not provided, its client will sue both Runbeck and Maricopa County.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    Maricopa PRR Re Runbeck Video

    Uploaded by

    Jordan Conradson
    18K views8 pages
    A law firm representing We The People AZ Alliance submitted a public records request to Runbeck Election Services seeking security camera footage from November 2022. Runbeck refused to comply with the request, citing that it is a private company not subject to public records laws. The law firm is now asking Maricopa County to obtain the requested footage directly from Runbeck, as Runbeck serves as a de facto elections department due to its role supporting Maricopa County elections. The law firm warns that if the footage is not provided, its client will sue both Runbeck and Maricopa County.

    Original Description:

    Maricopa PRR Re Runbeck Video

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    A law firm representing We The People AZ Alliance submitted a public records request to Runbeck Election Services seeking security camera footage from November 2022. Runbeck refused to comply with the request, citing that it is a private company not subject to public records laws. The law firm is now asking Maricopa County to obtain the requested footage directly from Runbeck, as Runbeck serves as a de facto elections department due to its role supporting Maricopa County elections. The law firm warns that if the footage is not provided, its client will sue both Runbeck and Maricopa County.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    18K views8 pages

    Maricopa PRR Re Runbeck Video

    Uploaded by

    Jordan Conradson
    A law firm representing We The People AZ Alliance submitted a public records request to Runbeck Election Services seeking security camera footage from November 2022. Runbeck refused to comply with the request, citing that it is a private company not subject to public records laws. The law firm is now asking Maricopa County to obtain the requested footage directly from Runbeck, as Runbeck serves as a de facto elections department due to its role supporting Maricopa County elections. The law firm warns that if the footage is not provided, its client will sue both Runbeck and Maricopa County.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    You are on page 1of 8

    April 30, 2023

    Stephen Richer
    Maricopa County Recorder
    Maricopa County Board of Supervisors
    Maricopa County Elections Department

    Dear Maricopa County,

    My client, We The People USA Alliance, served the PRR attached hereto as Exhibit A on
    your vendor, Runbeck Election Services, on April 8, 2023. Runbeck has refused to comply
    with said PRR See Exhibit B. On behalf of my client, I am formally requesting that you
    produce the documents sought by Exhibit A. As such, you should consider this both a PRR
    submission and a letter of representation.

    As you are aware, private companies cannot evade the legal obligations imposed on
    governmental entities when those private entities do the work of the government. To quote
    a recent opinion from the Arizona Court of Appeals:

    To the extent [Runbeck] is in sole possession of [election]-related public


    records because of its contract with [Maricopa County], [Runbeck] has
    become the custodian of those records under the PRL. And as to those
    records, [Runbeck] has assumed the obligations the PRL assigns to a
    "custodian" of public records. Under the PRL, a person seeking public
    records must make its request to the "custodian" of the records. A.R.S. §
    39-121.01 (D)(1). "Access to a public record is deemed denied if a custodian
    fails to promptly respond to a request for production of a public record."
    A.R.S. § 39-121.01(E).

    Cyber Ninjas, Inc. v. Hannah (Ariz. App. 2021), No. 1 CA-SA 21-0173 (Ariz. App. 2021).
    As transparency in the running of our public elections is of significant importance and
    Runbeck Election Services runs about 80% of all Maricopa County Elections, Runbeck
    serves as a de facto elections department and must comply with all obligations imposed on
    Maricopa County by law.

    I am asking that Maricopa County fulfill this public records request by obtaining the sought
    after video directly from its vendor. Should Runbeck refuse to turn over the video or should
    you refuse to request the video from Runbeck, my client will have no choice but to file a
    special action against Maricopa County and Runbeck collectively.

    You should receive this correspondence early Monday morning. My client would like a
    response no later than close of business on May 8, 2023. That gives you one full week to
    10869 N. Scottsdale Rd., Suite 103256, Scottsdale, AZ 85254 ▪ (office) 602.753.6213 ▪ bryan@blehmlegal.com
    determine whether your client has video cameras in use in the specified areas and is in
    possession of the requested videos.

    Sincerely,

    Blehm Law PLLC

    Bryan James Blehm

    Page 2 of 2
    EXHIBIT A
    April 8, 2023

    Ann Bakker
    Runbeck Election Services
    2838 S. 36th Street
    Phoenix, AZ 85072
    Email: abakker@runbeck.net

    Re: Public Records Request - #20230408-01

    Dear Public Records:

    Pursuant to the Arizona Public Records Law, A.R.S. § 39-121 et seq., We the People AZ Alliance requests: Any
    and all video recorded from November 8, 2022 through November 15, 2022 that depicts the following:

    1. Exterior video of all loading dock locations which clearly shows any item(s) being delivered and/or
    picked up.
    2. Interior video of all loading dock locations/wharehouse space which clearly shows any item(s) being
    delivered and/or picked up.

    Where possible, please provide responsive materials in an electronic format by email. Given the importance of
    free, fair, and transparent elections and the public's skepticism regarding the conduct of recent elections, We the
    People AZ Alliance PAC is seeking production of these documents on an expedited basis.

    We the People AZ Alliance PAC is a reportorial organization (as referenced in A.R.S. § 16-168(F)) with a current
    focus on election integrity. We are requesting this information for the purpose of providing information to the
    public, they are not sought for commercial purposes. As such, we request a waiver of all fees for this request or
    at most fees be limited to copying and postage charges. A.R.S. § 39-121.01(D)(1). If such charges are required,
    We the People AZ Alliance agrees to pay up to $25. If the costs for such fees will exceed $25, please notify us
    prior to incurring such costs. This request is for noncommercial purposes and additional fees are not applicable
    to this request. Disclosure of the requested information to us is in the public interest because it is likely to
    contribute significantly to public understanding of the operations or activities of the government and its election
    process. Please be aware that these documents, whether produced by the Custodian of Records or not, are public
    documents and they may be relevant to future litigation. Any deletion of said public documents can give rise to
    a negative inference in a court of law.

    Please respond to this request within 10 days. If you expect any delays beyond this time, we ask that you notify
    us of such delay with an expected date of compliance with this lawful FOIA request.
    April 8, 2023
    Page 2

    If any of the items requested are denied, we ask for a written response that cites each specific exemption and your
    basis for refusing to comply with the request. If you conclude that only a portion of the items requested are
    exempt, please send the remainder of such records for inspection and copying, redacting only the exempt
    portion(s).

    Please contact me at FOIA@wethepeopleazalliance.com or (602) 574-2376, if you require any additional


    information. I appreciate your cooperation and look forward to hearing from you soon.

    Sincerely,

    Shelby Busch
    Chairman
    We The People AZ Alliance PAC
    DOC #20230408-01
    EXHIBIT B
    01231245ÿ4708ÿ9
    ÿÿ9ÿ
     ÿÿ7ÿ ÿ ÿ ! "5ÿ#$

    12345ÿ1789:ÿ;<2345=<789:78>47?@A:B

    CDEÿCF5<8@GÿD78@HIA5ÿJ82KI@8LMÿN5@?
    O5P3ÿQ4A54ÿR&S T "$U V5ÿW%ÿ235ÿ2'24ÿÿ2700ÿ9

    X7ÿ Tÿ ÿRTS  & $U


    7ÿW"ÿY"ÿRT"S T "$U
    Z*ÿ- 5ÿ T7
    ÿ
    Xÿ& ÿ&ÿÿ ÿ%5ÿ ÿ ÿ ! "5ÿ#$ÿ ÿÿ[% T\ÿÿTÿ  ]"ÿW% ÿ35ÿ2'24ÿ% ÿ *"
    ^ "ÿ" &ÿ"ÿ" Tÿ ÿ-& ÿ " ÿÿ"ÿÿ & ÿ &ÿÿ*ÿ"$
    ÿ
    W"ÿTÿÿ 5ÿ ÿ"ÿÿ%! ÿ%ÿ&_ *ÿ* ÿW_ÿ ÿ̀Tÿÿ-*ÿ"ÿ-ÿÿ- ÿ
     ÿW_ÿ%ÿ""ÿ a$ÿ#ÿ"ÿÿÿ[% ÿ*T[ÿ* ÿW_]"ÿ% ÿ *"ÿ ÿ̀[9\abÿÿ"5ÿÿ"
    ÿ["ÿ" 5ÿTÿT5ÿT5ÿ5ÿ" ÿ*"5ÿ%  ÿ"*!"ÿÿc"%% *ÿ*"ÿÿ"ÿ" 5ÿTÿ5
    * % 5ÿ*5ÿ 5ÿ""5ÿ ÿÿ ÿ-ÿ ÿ- &&5ÿ*ÿTÿ% ÿ&_ÿÿ& T5
    "%% *ÿÿ ÿÿÿ%ÿTÿ "ÿ-ÿ"ÿ" ÿÿTÿ%  ÿ"*!"ÿ-ÿ"ÿ" 5ÿÿ c% *&ÿ "
    %!* *ÿTÿ"ÿ" ÿÿTÿ%  ÿ"*!"ÿ-ÿ"ÿ" $\ÿW$$$ÿdÿ48+2+$'+`Wa`2aÿ̀* -&ÿ[% ÿ*T\a$
    ÿ
    YÿW% ÿ245ÿ2'24ÿ  ÿ*   "ÿÿ ÿ"ÿÿ[% ÿ*T\ÿ " ÿÿ[ c% *e"fÿ*1ÿe"fÿ%*ÿ "ÿTÿ
    " ÿ*1ÿÿ%  ÿ"*!"ÿ -ÿÿ-  ÿ-ÿ ÿ" ÿ*1ÿ%  ÿ"*!"]"ÿ& "5\ÿ ÿ! &
     ÿ-ÿÿ ÿ"Tÿ && ÿTÿ ÿ*- "ÿ ÿ%" ÿ[% ÿ&_ÿÿ& T$\ÿ 5ÿ-ÿ" 5ÿ"
      ÿ-ÿ " $ÿW*ÿ ! ÿ-ÿ ÿ ÿÿ! ÿ& ÿÿ ÿ"ÿ"g ÿÿ ÿ9ÿÿ" ÿTÿ̀*ÿ ]"
    a5ÿ-& ÿ-ÿÿ" Tÿ"T" ÿÿ ÿ %"ÿÿ ÿ & ÿ" ÿ-ÿ"ÿ%! ÿ" ""ÿ% "ÿ"ÿÿ
    [% ÿ *\ÿ* ÿTÿ *&ÿ-ÿ ÿ9$
    ÿ
    h ÿ*]ÿ *ÿ"ÿ  ÿÿ%!* ÿÿ c"! ÿ "ÿ-ÿ ]"ÿ* - " "ÿÿ ÿ &ÿT]! ÿ   *ÿÿ  -
    -ÿTÿ  5ÿÿ "ÿ"" *ÿÿ ÿ ÿ!&" Tÿ* - *ÿTÿ"ÿ &$ÿW*ÿÿ ÿ"%ÿ-ÿTÿW% ÿ24
     ]"ÿ&ÿÿ""ÿ*ÿ T]"ÿ- "5ÿ ÿ " ! "ÿ ÿ&"ÿÿ" ÿ"ÿÿ- "ÿ*ÿ""ÿ" *ÿT
    " ÿÿ% *$
    ÿ
    #-ÿTÿ  ÿ* "ÿ- ÿÿ"%  ÿÿ&"ÿ 5ÿ#ÿÿ_ *ÿÿ c  ÿÿ! ÿ-ÿ" ! ÿ-ÿ""ÿÿ"
      -$ÿ9 " ÿ" *ÿ &ÿ% "ÿ-ÿ ! T&ÿTÿ- ÿ*ÿÿ! ÿ-5ÿ*ÿ#] ÿ%% Tÿ ÿÿ"& *ÿ! "ÿ-ÿT
    ÿ- ÿÿ ÿ$
    ÿ
    9 " ÿ ÿ-ÿT]*ÿ  ÿÿ*"""ÿ"ÿ ÿTÿ- $
    ÿ
     &*"5
    ÿ
    O5P3ÿQ4A54
    ` 11"a
    /'2$43+$003/
    %"711 $&& $1 11'1()8'82*+*,! )%," ) ,% "&*)"&-7+./0003/08/20.+02/4,"% )"&-7+./0003/08/20.+02/4 +12
    01231245ÿ4708ÿ9
    ÿÿ9ÿ
     ÿÿ7ÿ ÿ ÿ ! "5ÿ#$
    &1 2 "$
    ÿ
    34567ÿ 2ÿ ÿ821  & $9
    :;<=7ÿ>"*25ÿ?% ÿ2.5ÿ2'24ÿ+270+ÿ9

    @57ÿ?*2ÿAÿ8&1 2 "$9


    BC7ÿ?"ÿD"ÿ82"1 2 "$9
    :EFG;C=7ÿ 7ÿ ÿ ÿ ! "5ÿ#$ÿH 
    ?#IJK$L#J4+++04M
    ÿ
    HN>I?ÿIJM
    J "ÿ2ÿ  ÿ *ÿÿ% 2(ÿ#-ÿ5ÿ ÿ ÿÿ"ÿ ÿÿ& ÿ ÿ &ÿ* 2ÿ"ÿ"ÿ"ÿ%"" $ÿ?*ÿ-
    5ÿ ÿ2ÿ &ÿÿ! ÿ" ! ÿÿ  -ÿ-ÿ2ÿ  (
    HO *ÿ Pÿ** M

    %"711 $&& $1 11'1()8'82*+*,! )%," ) ,% "&*)"&-7+./0003/08/20.+02/4,"% )"&-7+./0003/08/20.+02/4 212

    You might also like