Graham, Donna
From: Laurie Ortolano io
Sent: Friday, July 30, 2021 5:11 P
To: Graham, Donna
Ce: Bell, Patricia
Subject: Letter for Board Packet
CAUTION: This email came from outside of the organization. Do not click links/open attachments if source is
unknown.
Could you see to it that this letter is placed in the Board packet
Thank you,
Rebuttal to Attorney Bolton’s explanation on Court Order
A Telegraph article ran July 28, 2021, regarding the Court order for the City to pay my legal
expenses for disregarding a discovery request to obtain emails from Director Kleiner.
The request made in July 2020 was for specific time and content for emails from a single person.
Kim Kleiner’s emails, relative to assessing, sent from August 9 through September 30, 2019. This
was not an extensive search.
Attorney Bolton offered explanations to the Telegraph that were not part of the City’s objection
to my Attorney’s motion for sanctions. Apparently, given enough time, he’s able to fabricate more
absurd excuses to explain the City’s bad faith.
According to Attorney Bolton, the reasons for disregarding the discovery:
COVID
City Hall Renovations
Employees working remotely
No employees available to conduct searches
COVID is a pandemic political excuse with little relevance to searching for emails. Ms. Kleiner
assured the public that employees were working at 100%. The search required Ms. Kleiner’s time
and an IT Department employee.
Kleiner’s office and the IT Department were not under renovations. Ms. Kleiner’s office was open
to the public throughout the pandemic without an appointment.
This request was a computer driven search, so Ms. Kleiner should have been able to remotely
compile her emails and the IT department had a worker in City Hall.
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