Pursuant to the California Public Records Act, Government Code Section 6250 et seq., I request that the City of Oakland ("the City") make available for inspection full and accurate copies of all the public records described below.
The term "DOCUMENTS" as used in this letter means writings and recordings (as defined in California Evidence Code Section 250), hard copy documents and electronically stored information, and includes reports that can be generated from the City's electronic information systems. The term "UBER" as used herein refers to Uber Technologies, Inc., Rasier, LLC, Rasier-CA, LLC, and any agents, attorneys, consultants and/or representatives acting or purporting to act on their behalf, or any predecessors in interest. Unless otherwise indicated, we request documents dated or generated from January 1, 2010 to the present.
I request that the City make available for inspection all DOCUMENTS in each of the following categories:
1. The City's file on, and/or all DOCUMENTS relating to, Oakland any taxicab driver permit, operating permit, fleet management permit, or vehicle permit held by or associated with Benedict Ezeokoli. There is no date limitation on this request.
2. All DOCUMENTS regarding any investigation, suspension, citation or proceeding regarding any taxicab-related permit held by Benedict Ezeokoli. There is no date limitation on this request.
3. All DOCUMENTS relating to taxicab permit and/or medallion sales, purchases, transfers or surrenders from 2010 to the present.
4. All DOCUMENTS relating to valuation of taxicab vehicle permits or medallions.
5. All DOCUMENTS relating to contracts, leases or payments for use of taxicab vehicle permits or medallions.
6. All studies, reports and analyses relating to contracts, leases, fees, gate fees, charges or payments made by Oakland taxicab driver permittees.
7. All studies, reports and analyses relating to ridership, revenues, receipts, fares, expenses, income or profits of Oakland taxicab driver permittees.
8. All studies, reports and analyses relating to the market for taxicabs or transportation for hire in Oakland.
9. All studies, reports and analyses relating to any impact of UBER, Lyft or Transportation Network Companies on the taxicab market, medallions, drivers or taxicab businesses.
10. All studies, reports and analyses relating to safety of taxicabs.
11. All studies, reports and analyses relating to safety of UBER, Lyft or Transportation Network Companies.
12. All DOCUMENTS relating to any advertising or publication by UBER.
13. DOCUMENTS sufficient to show the identity and contact information of Oakland taxicab driver and operating permittees.
14. DOCUMENTS sufficient to show the identity and contact information of Oakland taxicab vehicle permittees.
15. DOCUMENTS sufficient to show the identity and contact information of Oakland permitted taxicab fleet management permittees.
16. All minutes and resolutions of any City agency regarding taxicab permits.
Pursuant to Government Code Section 6253.1, I request that the City assist me in making a "focused and effective request" by identifying responsive records containing the information sought, describing the information technology and physical location in which the records exist, and providing suggestions for overcoming any practical basis for denying access to the records sought. In addition, even if a portion of the records sought is exempt from disclosure, any "reasonably segregable" portion of the records must be made available after deletion of the exempt portions. Gov. Code § 6253(a).
To the extent that a complete response to this request will take more than 10 calendar days, I request that the City make responsive documents available for inspection on a rolling basis as they are identified. Following inspection, I may request copies of some or all responsive documents, and I understand that, in that event, I will be required to pay the duplication costs.
Thank you for your prompt attention to this request.