reply memorandum of law in support of petition

7/30/2019 Reply Memorandum of Law in Support of Petition

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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORK

Application for a Judgment under Article 78 of the CPLR and other relief bySERGIO HERNANDEZ,

Petitioner,v.

THE OFFICE OF THE MAYOR OF THE CITY OF NEW YORK,

INDEX NUMBER: 106213/2011lAS Part 16 (Schlesinger, J. )

Res o n d e n ~

REPLY MEMORANDUM OF LA W IN FURTHER SUPPORT OF PETITIONFOR A JUDGMENT DIRECTING PRODUCTION OF

RECORDS UNDER FREEDOM OF INFORMATION LAW

SCHLAM STONE & DOLAN LLPElizabeth Wolstein, Esq.26 Broadway, 19th Floor

New York, New York 10004Telephone: (212) 344-5400Facsimile: (212) 344-7677Attorney for PetitionerSergio Hernandez


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TABLE OF CONTENTS

PRELIMINARY STATEMENT ..................................................................................................... 1ARGUMENT .................................................................................................................................. 2I. RESPONDENT CONCEDES THAT THE REQUESTED EMAILS ARENOT PROTECTED BY FOIL'S PERSONAL PRIVACY EXEMPTION ......................... 2II. RESPONDENT OFFERS NO LEGITIMATE BASIS TO WITHHOLDTHE BLACK EMAILS UNDER THE INTER- AND INTRA-AGENCY

EXEMPTION AND THEY SHOULD BE PRODUCED ................................................... 4A. Ms. Black And Her Hearst Colleagues Are Not Agencies Within TheMeaning Of FOIL And Therefore Are Not Subject To The Exemption ................. 4B. The Black Emails Are Not Subject To Withholding As Material PreparedBy A Consultant Retained By An Agency .............................................................. 7

III. PETITIONER IS ENTITLED AN AWARD OF ATTORNEYS' FEES ............................ 9CONCLUSION ............................................................................................................................. 12


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TABLE OF AUTHORITIESCASESBurtis v. N.Y. Police Dep't,

240 A.D.2d 259 (1st Dep't 1997) ................................................................................ .3Data Tree, LLC v. Romaine,

9 N.Y.3d 454 (2007) ..................................................................................................... 3Dep 't of he Interior v. Klamath Water Users Protective Ass 'n,

532 U.S. I (2001) .............................................................................................. 8, 9, IIGulf ns. Co. v. Transatlantic Reinsurance Co.,

886 N.Y.S.2d 133 (1st Dep't 2009) .............................................................................. 5Ho Myung Moo/san Co.,

665 F. Supp. 2d 239 (S.D.N.Y. 2009) .......................................................................... 5Matter ofGould v. New York City Police Dep't,

89 N.Y.2d 267 (1996) ................................................................................................... 6Matter ofHumane Soc y ofUS. v. Brennan,

861 N.Y.S.2d 234 (3d Dep't 2003) .............................................................................. 3Matter ofNew York Times Co. v. City ofN.Y. Fire Dep't,

4 N.Y.3d 477 (2005) ..................................................................................................... 6Matter ofXerox Corp. v. Town a/Webster,65 N.Y.2d 131 (1985) ...............................................................................................7, 8Miller v. N.Y. State Dep 't ofTrans.,

871 N.Y.S.2d 489 (3d Dep't 2009) ............................................................ ............ 6, IIN.Y. Comm . .for Occupational Safety and Health v. Bloomberg,

72 A.D.3d !53 (1st Dep't 2010) ................................................................................. ..4Obiajulu v. City ofRochester,

213 A.D.2d 1055 (4th Dep't 1995) ..............................................................................4Powhida v City ofAlbany,147 A.D.2d 236 (3d Dep't 1989) ................................................................................. 9Tuck-It-Away Assoc., L.P. v. Empire State Dev. Corp.,

861 N.Y.S.2d 51 (! 51 Dep't 2008) ......................................................................6, 8, 12Washington Post Co. v. New York State Ins. Dep 't,61 N.Y.2d 557 (1984) ................................................................................................... 3

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Woods v. Kings County Dis/. Atty s Office,234 A.D.2d 554 (2d Dep't 1996) .................................................................................4

STATUTESN.Y. Pub. Off. Law

86(3) ..........................................................................................................................5, 11 87(2)(b ) ............................................................................................................................2 87(2)(g) .......................................................................................................................... 10 89(2)(c)(i) ........................................................................................................................ 3 89(4)(c) ............................................................................................................................ 9 89(4)(c)(i) ........................................................................................................................ 8

OTHER AUTHORITIESRestatement (Second) ofAgency 1, crnt. b ( 1958) ............................................................... 5

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SUPREME COURT OF THE STATE OF NEW YORKCOUNTY OF NEW YORKApplication for a Judgment under Article 78 of theCPLR and other relief bySERGIO HERNANDEZ,

Petitioner,v.

OFFICE OF THE MAYOR OF THE CITY OFNEW YORK,

Respondent.

Index Number.: l 06213/20l l!AS Part 16 (Schlesinger, J.)

Petitioner Sergio Hernandez respectfully submits this reply memorandum oflaw infmiher support of his petition for a judgment directing production of records under theFreedom of Information Law.

PRELIMINARY STATEMENT

In response to Mr. Hernandez's November 2010 FOIL request, the Mayor's Officeasserted two exemptions to justify its refusal to disclose emails among the Mayor's Office,Cathleen Black, and other Hearst Corporation employees relating to the Mayor's selection ofMs. Black to be New York City Schools Chancellor- the personal privacy exemption andthe exemption for inter- and intra- agency documents reflecting the government'sdeliberative process. In opposing Mr. Hernandez's petition in this Court, however, theMayor's Office has abandoned its privacy justification, declining to dispute Petitioner'sshowing that FOIL's privacy exemption is inapplicable in these circumstances and therebyconfirming that the requested emails (apart fiom cell phone and personal email data

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contained within them) are not, and have never been, properly withheld under thatexemption,

The Mayor's Office's reliance on its sole remaining exemption is similarlymisguided. The Mayor's Office argues that the requested emails (the "Black Emails" or the"Emails") are protected because Ms. Black was the Mayor's agent and therefore their emailcorrespondence constitute inter or intra-agency communications. FOIL, however, providesits own clear definition of an "agency" as governmental entity, and private individuals likeMs. Black are not included. Nor are the Emails protected as within the consultant corollaryto the inter- and intra-agency exemption, since Ms. Black was not retained by any agency toparticipate in its deliberative process, and was advancing her own interest in promoting hercandidacy while engaging in the withheld communications.

Respondent has therefore failed to demonstrate any valid basis for withholding theBlack Emails, and they should be produced.

ARGUMENTI. RESPONDENT CONCEDES THAT THE REQUESTED EMAILS ARE NOT

PROTECTED BY FOIL'S PERSONAL PRIVACY EXEMPTIONDespite having asserted FOIL's privacy exemption as a basis for withholding the

Black Emails, Respondent offers no argument defending its initial withholding of the Emailson that basis. FOIL's privacy exemption protects records that "i f disclosed would constitutean unwarranted invasion of personal privacy." N.Y. Pub. Off. Law 87(2)(b). Petitioner'sopening brief showed that the Black Emails are not protected by the exemption because theMayor's Office failed to show that the requested emails contained "intimate, privateinformation," and because there is a strong public interest in disclosure of information aboutgovernmental hiring practices. See Memorandum of Law in Support of Petition ("Pet. Br.")at 7-11. By failing to dispute (or even address) this point, Respondent has conceded that the0.0 02 - 2-


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emails as a whole are not properly withheld under the personal privacy exemption, and,necessarily, that its assertion of the privacy exemption as a basis for withholding the Emailswas entirely without merit.

Instead, Respondent asserts only that cell phone numbers and personal emailaddresses contained in the Black Emails should be withheld under the privacy exemption.Memorandum ofLaw in Support ofVerified Answer ("Opp.") at I2-I4. Disclosure ofprivate telephone numbers may constitute an unwarranted invasion of privacy in somecircumstances. See, e.g., Burtis v. NY Police Dep't, 240 A.D. 2d 259,260 (1st Dep'tI 997). However, the proper method for protecting this information is not the wholesalewithholding of otherwise disclosable documents, but rather redaction of the privateinformation and production of the remainder of the document. See, e.g,. Washington PostCo. v. New York State Ins. Dep't, 61 N.Y.2d 557, 567 (1984); (requiring agency to producedocuments with segregable exempt information redacted, unless agency can establish thatdocuments are exempt in their entirety); see also Data Tree, LLC v. Romaine, 9 N.Y.3d 454,464 (2007) (citing N.Y. Pub. Off. Law 89(2)(c)(i)) (holding that "even when a documentsubject to FOIL contains such private, protected information, agencies may be required toprepare a redacted version with the exempt material removed"). Indeed, FOIL expresslymandates such an approach, by dictating that "disclosure shall not be construed to constitutean unwarranted invasion of personal privacy .. when identifying details are deleted." N.Y.Pub. Off. Law 89(2)(c)(i).

Accordingly, courts routinely require redaction of email addresses and phonenumbers fiom documents that otherwise are not properly withheld, and order production ofthe redacted version. See, e.g., Matter ofHumane Soc 'y ofU.S. v. Brennan, 53 A.D.3d 909,91 I (3d Dep't 2008) (requiring production of responsive documents with telephone numbers

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redacted); Woods v. Kings County Dist. Atty's Office, 234 A.D.2d 554, 556 (2d Dep't 1996)(same). Redaction is appropriately limited to "private, protected infmmation" that wouldidentify an individual. See, e.g, NY Committee for Occupational Safety and Health v.Bloomberg, 72 A.DJd 153, 160 (1st Dep't 2009) (ordering New York City Mayor's Officeto produce redacted workers compensation records, which would "preserve the personalprivacy of any claimants who might be identified therein"); Obiajulu v. City ofRochester,213 A.D.2d 1055, 1056 (4th Dep't 1995) (ordering disclosure of work performanceevaluations "with 'identifying details' redacted"). Here, then, while identifying phonenumbers and email addresses may be redacted from the Black Emails, Respondent hasoffered no privacy-related justification for withholding the emails as a whole, and theremaining portions of each doctm1ent should therefore be produced.II. RESPONDENT OFFERS NO LEGITIMATE BASIS TO WITHHOLD THE

BLACK EMAILS UNDER THE INTER- AND INTRA-AGENCYEXEMPTION AND THEY SHOULD BE PRODUCEDA. Ms. Black And Her Hearst Colleagues Are Not Agencies Within The

Meaning Of FOIL And Therefore Are Not Subject To The ExemptionThe Mayor's Office argues that Ms. Black was a common law agent of the Mayor

once the Mayor selected her to become Chancellor, and therefore that the inter- and intra-agency FOIL exemption applies to her communications. See Opp. at 7 ("[I]t is clear thatMs. Black was acting as Respondent's agent. . . . Thus, the responsive documents . . . areintra-agency documents and may be withheld from disclosure."). The argument is utterlydevoid of merit and indeed borders on the frivolous.

As an initial matter, the suggestion that a mayoral nominee is an agent of the Mayorbefore she takes office is tmpersuasive, because she is not bound to act on his behalf and hehas no basis to exert control over her. Common law agency exists where there has been a"manifestation of consent by one person to another that the other shall act on his behalf and0.0 02 - 4-


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subject to his control," as well as "the consent of the other to act." Gulf ns. Co. v.Transatlantic Reinsurance Co., 886 N.Y.S.2d 133, 152 (1st Dep't 2009) (citation omitted);see also Restatement (Second) ofAgency 1, cmt. b (1958). As the Mayor's Office pointsout, the principal's control over the agent is essential, and is established where "the principalprescribes what the agent shall or shall not do before the agent acts, or at the time the agentacts, or both." Ho Myung Moo/san Co., 665 F. Supp. 2d 239,258 (S.D.N.Y. 2009) (internalquotation marks and citation omitted).

But the Mayor's Office nowhere asserts that Ms. Black was controlled by the Mayor.Rather, she acted on "Respondent's advice and guidance." Opp. at 7 (citing VerifiedAnswer ( " A n s w e r " ) ~ 36); see also id. (describing Ms. Black as "having acted underRespondent's guidance"). Thus, by Respondent's own admission, Ms. Black's actions werenot prescribed by the Mayor's Office as an agent's would be, but rather were suggested asway to advance their mutual interests. See Opp. at 6 ("Ms. Black indisputably shared"Mayor's interest in addressing public concerns about her nomination, and "she acted infurtherance and support of this goal"). Respondent's papers therefore fall short of providinga factual basis to support its argument that Ms. Black and other Hearst Corporationemployees were Respondent's common law agents during the period covered by the Em ails.

But even assuming that Ms. Black and the Hearst Corporation staff wereRespondent's common law agents, that does not make them "agencies" within the meaningof FOIL. The statute provides an unambiguous definition of"agency." An '"[a]gency'means any state or municipal department, bureau, division, commission, committee, publicauthority, public corporation, cotmcil, office, or other governmental agency performing agovernmental or proprietary function for the state or any one or more municipalities thereof,except the judiciary or the state legislature." N.Y. Pub. Off. Law 86(3).

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The definition could not be clearer: an agency is (i) an "entity," and (ii)"goverm11ental." It does not encompass (i) individuals, or (ii) private (non-governmental)actors. Ms. Black, however, during the period of the Emails, was both an individual (not anentity), and a private citizen (not a governmental actor). Respondent's argument that Ms.Black's status as a common law agent makes her an agency whose communications areimmune from disclosure under the inter- and intra-agency exemption is at odds with theplain language of the statute.

Respondent's argument is also inconsistent with the rationale behind the inter- andintra-agency exemption. The exemption exists to allow uninhibited decisionmaking withingovernment by permitting "people within an agency to exchange opinions, advice andcriticism freely and frankly, without the chilling prospect of public disclosure." Matter ofNew York Times Co. v. City ofN. Y Fire Dep 't, 4 N.Y.3d 477, 488 (2005); see also Matter ofGould v. New York City Police Dep 't, 89 N.Y.2d 267, 276 (1996); Tuck-It-Away Assoc., L.P.v. Empire State Dev. Corp., 54 A.D. 3d 154, 166 (lst Dep't 2008). It is therefore recognizedthat records "which consist of communications with people outside the agency" are not partof the government's deliberative process, and their disclosure will not inhibitdecisionmaking within the government. See Miller v. N. Y State Dep 'I ofTrans., 58 A.D. 3d981, 984-85 (3d Dep't 2009).

Ms. Black and her Hearst colleagues were not making governmental decisionsduring the period covered by the Emails, while her appointment was pending. She was aprivate citizen waiting for the government to make a decision about her- whether she wouldbe excused fiom the normal eligibility requirements for the Chancellor position. Seegenerally n s w e r ~ ~ 30-37. The Emails do not relate to the State Education Department'sdeliberative process in deciding whether to grant Ms. Black the requested waiver, but rather

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to preparation of the request for a waiver, "routine queries" relating to mayoral appointees,and community outreach "to address concerns that had been publicly raised regarding Ms.Black." A n s w e r ~ 33; see also id. 34 (withheld emails discuss Ms. Black's background,contacts with govemment officials, and drafts of letter to State Education Commissionerrequesting waiver from Chancellor qualification requirements). There is no reasonableargument that keeping such communications secret would serve the purpose of the inter- andintra-agency communications exemption.

B. The Black Emails Are Not Suh.iect To Withholding As MaterialPrepared By A Consultant Retained By An Agency

Respondent also falls short in arguing that the Black Emails are intra-agencycommunications because "Ms. Black's function . . . was similar to that of a consultant."Opp. at 10.) While "records may be considered 'intra-agency material' even thoughprepared by an outside consultant at the behest of an agency," Matter ofXerox Corp. v.Town ofWebster, 65 N.Y.2d 131,133 (1985), Ms. Black's purpmied similarity to aconsultant is not enough to invoke this doctrine. Protected consultant communications areonly those that are prepared by individuals "retained by the agency" to assist in adeliberative process and that serve essentially the same purpose as documents prepared byagency employees, id., requirements that clearly are not met here.

Consultant communications are protected if they originate with consultants who areretained by the agency in order to assist in the agency's deliberative process. Xerox Corp.,65 N.Y.2d at 133 (holding that communications are protected when, inter alia, they areprepared as part of an agency's deliberative process by "outside consultants retained byagencies"). Ms. Black and other Hearst employees did not fulfill this role. Respondentmakes no suggestion that Ms. Black or other Hearst employees were hired or contracted

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with the City, and thus they cannot fairly be considered "outside consultants retained by theagency," Xerox Corp., 65 N.Y.2d at 133.

In addition, Respondent 's papers do not identify any "deliberative process" that Ms.Black and other Hearst employees participated in that is reflected in the withheld emails.The only "process" described in Respondent's papers as being reflected in the Emails wasthe advocacy and outreach on behalf of her candidacy, which was not deliberative or indeedconnected to any decision involving Respondent addressed in the Emails. This alone doomsthe applicability of the consultant exemption because "[w] here the exemption has beenextended to consultants performing work on behalf of an agency, 'the records submitted byoutside consultants played essentially the same part in an agency's process of deliberation asdocuments prepared by agency personnel might have done."' Tuck-It-Away Assoc., 54 A.D.3d at 163 (quoting Dep 't of he Interior v. Klamath Water Users Protective Ass 'n, 532 U.S.I, 10 (2001)). Accordingly, the Black Emails are not consultant communications exemptfrom disclosure under the inter- and intra-agency exemption.

Finally, the Emails are also not exempt for the independent reason that Ms. Blackwas communicating with the City in her own interest. Consultant communications "losetheir exemption if there is reason to believe that the consultant is communicating with theagency in its own interest." Tuck-It-Away, 861 N.Y.S.2d at 58. In Klamath, the UnitedStates Supreme Court clarified that an analogous doctrine under the federal Freedom ofInfonnation Act (FOIA) renders unprotected consultants' self-advocacy- a case the FirstDepartment described as "instructive," Tuck-It-Away, 54 A.D.3d at 164. In Klamath, theDepartment of the Interior asked several Native American tribes to consult the Departmentconcerning the allocation of water between competing uses and users. Id. at 1. The tribes,which all had interests in the water allocations, see id. at 13, provided the Department with

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advisory memoranda. ld. at 1-2. When a nonprofit group filed a FOIA request for thesememoranda, the Department withheld them under FOIA's analogous inter- and intra-agencyexemption. Klamath, 532 U.S. at 2 The Court held that the exemption was not properlyinvoked because the tribes, in their communications with the government, were acting as"self-advocates at the expense of others seeking benefits inadequate to satisfy everyone."Klamath, 532 U.S. at 12.

Respondent's submissions make clear that Ms. Black was likewise acting in her ownself-interest as a "self-advocate" in her communications with the Mayor's Office. See Opp.at 6 (noting shared interest between Mayor and Ms. Black in addressing public concerns);Answer '1[ 36 (withheld emails show Ms. Black and her staff were working with Mayor inpursuit of common goal). This is also a matter of common sense, as Ms. Black's principalinterest in helping the Mayor with his "public outreach" and advocacy to the State EducationCommissioner was her self-interest in obtaining the Chancellor position. FOIL's inter- andintra-agency communications exemption, however, does not protect from disclosurecommunications relating to the self-advocacy of non-governmental employees.

In short; none of Respondent's inter- and intra agency theories justifies withholdingof the Black Emails, and the Court should order that they be produced.III. PETITIONER IS ENTITLED AN AWARD OF ATTORNEYS' FEES

As the Mayor's Office notes, a FOIL petitioner may recover attorneys' fees if he"substantially prevails" in the litigation. N.Y. Public Off Law 89( 4)(c). A Petitionersubstantially prevails when "the agency has no reasonable basis for denying access" to therequested documents. N.Y. Public Off. Law 89(4)(c)(i); see also Powhida v City ofAlbany, 147 A.D.2d 236, 238 (3d Dep't 1989). Respondent 's opposition papers make

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apparent that it had no reasonable basis for withholding the requested e-mails, and,accordingly, Mr. Hernandez is entitled to an award of attorney's fees and costs.

Petitioner demonstrated in his opening brief that communications between Ms. Blackand the Mayor's Office are not properly withheld under FOIL's privacy exemption. SeePetit. Br. at 7-11. Even though this exemption was invoked by the Mayor's Office to justifywithholding the Black Emails in response to Mr. Hernandez's November 2010 request, theMayor's Office makes no opposing argument. Rather, its only contention concerning theprivacy exemption is that the cell phone nwnbers and e-mail addresses contained within theemails should be withheld. See Opp. at 13. But the phone numbers and e-mail addresses arenot the subject of the Petitioner's FOIL request, and if their disclosure constitutes anunwarranted invasion of privacy, the proper approach under FOIL is simply to redact themfrom the produced documents. By abandoning its privacy justification and failing to disputePetitioner's showing that the Emails are not properly withheld under the privacy exemption,Respondent has conceded that it had, and has, no reasonable basis for withholding themunder that exemption.

The Mayor's Office also has failed to demonstrate a reasonable basis for withholdingthe requested emails under FOIL's inter- and intra-agency exemption. The Mayor's Officeargues that Ms. Black was the Mayor 's common law agent, and that any communicationsare therefore properly withheld under the intra- and interagency exemption. See N.Y. Pub.Off. Law 87(2)(g). Respondent admits, however, that Ms. Black's actions were notprescribed by the Mayor 's Office, but merely guided by it. See supra at 5. Concededly,then, before she was appointed Schools Chancellor, the Mayor exercised no control overMs. Black and she was under no duty to carry out his or his Office's suggestions. Shetherefore fails to qualify as the Mayor's Office's common law agent.

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Moreover, even if she could be deemed the Mayor's common law agent before shewas appointed to tl1e Chancellor position, that does not make her an "agency" for purposesof the inter and intra-agency exemption. FOIL specifically defines an agency as "any stateor municipal department, bureau ... or other governmental entity performing a governmentalor proprietary function for the state or any one or more municipalities thereof. .. " N.Y. Pub.Off. Law 86(3). Ms. Black, an individual who was privately employed during the periodof Petitioner's FOIL request, is not a "goverm11ental entity" performing a governmentalfunction, and is therefore not an agency within the meaning of FOIL. There is noconceivable argument that Ms. Black meets the statutory definition, or that the statutorydefinition is optional in FOIL litigation. The Mayor's Office therefore had no reasonablebasis for withholding the Black Emails under the inter- and intra-agency exemption. Itseffort to justify invocation of the exemption based on Ms. Black's similarity to a consultantis similarly misplaced for the reasons explained in detail above, see supra at 7-9.

As if to justify its withholding ofmaterials that plainly require disclosure,Respondent attempts to depict this case as presenting an issue of first impression. Theargument lacks merit. The Black Emails date to the period after Ms. Black was nominatedfor the Chancellor position but before she received the appointment, i.e., while she was aprivate citizen. The facts, therefore, merely present the issue of whether communicationsbetween a government agency and a person outside that agency fall within the intra- andinteragency exemption, which they plainly do not. Far from a case of first impression, thisis simply an example of the Mayor's Office attempting to withhold a category ofcommunications that by any measure is not exempt from disclosure under FOIL. SeeKlamath, 532 U.S. at 10 (2001); Miller 58 A.D.3d 984-5 (communications with individualsoutside Department ofTransportation not subject to intra- and inter agency exemption);

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Tuck-it Away, 861 N.Y.S.2d at 58 (communications between department and consultantwere not exempt from disclosure because consultant was an interested party); supra at 7-9.

CONCLUSIONFor the foregoing reasons, and those set forth in Petitioner's opening memorandum

of law, this Court should grant Mr. Hernandez's Petition and enter judgment declaring thatRespondent has acted unlawfully, and enjoining Respondent to: (I) immediately produce alldocuments responsive to Mr. Hernandez's FOIL request, and (2) provide a specific andparticularized justification for withholding each document, portion of a document, orcategory of documents claimed to be exempt from disclosure; and awarding Mr. Hernandezhis litigation costs, including attorneys' fees, together with such other and further relief as isjust and proper under the circumstances.Dated: New York, New YorkAugust 16, 2011

By:Eliz eth Wolstein26 Broadway, 19th FloorNew York, New York I 0004Telephone: (212) 344-5400Facsimile: (212) 344-7677E-Mail: [email protected] for Petitioner

1 This reply brief was prepared in large part by Jennifer Bishop, Jeffrey Love, andMonika Isia Jsiewicz, law students in the Yale Law School Media Freedom and InformationAccess Clinic.

reply memorandum of law in support of petition

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