Private camera access, product expansion, communications, vendor research, and legal review

Purpose and response organization

The request thanks the Sheriff’s Office for its prior production and explains that questions remain because attachments were not consistently matched to request items and exemptions were not tied to specific records or redactions.

For each numbered item, the request asks the agency to identify exact responsive filenames, identify any previously produced record by filename and production, and specify every item to which a multi-purpose record responds. It also asks the agency not to answer only with “see attachments” or supply unrelated mass-marketing material.

1. Access to privately owned Flock cameras

Records sufficient to identify every privately owned or privately operated Flock or ALPR camera within Amador County that ACSO personnel can currently—or could previously—view, search, query, receive alerts from, access through a shared network, or otherwise use.

The request specifically includes the three cameras reported at or near Lowe’s Home Improvement on Industry Boulevard in the Martell/Jackson area.

For each private camera or system, the request seeks:

1. The owner or responsible organization.
2. The location.
3. The beginning and ending dates of ACSO access.
4. The access type and permissions.
5. Sharing invitations, contracts, MOUs, terms, authorizations, or other governing records.
6. Whether access is reciprocal.
7. Whether ACSO can run historical searches, receive alerts, view live or recorded information, or use other functions.
8. Authorized ACSO users or account roles.
9. Audit, search, alert, access, or usage reports showing actual ACSO use.

Requested period: January 1, 2023 through the date of the agency’s search.

2. Possible expansion into other Flock products

Communications, meeting invitations, demonstrations, presentations, notes, proposals, quotes, budget estimates, purchasing records, and planning records concerning ACSO’s consideration, testing, acquisition, or planned use of:

• Flock Nova.
• Flock Live Video.
• FlockOS video integrations.
• Condor or pan-tilt-zoom cameras.
• Raven gunshot detection.
• Aerodome or Drone as First Responder services.
• Mobile or temporary Flock cameras.
• Additional ALPR cameras, expanded subscriptions, relocations, or future phases.
• Any other Flock product or subscription beyond the presently disclosed fixed ALPR cameras.

Generic mass-marketing is excluded unless ACSO responded, requested information or a demonstration, attended or scheduled a meeting, received tailored pricing or a proposal, forwarded the material internally, or discussed evaluation, acquisition, budgeting, testing, or deployment.

Requested period: January 1, 2024 through the date of the agency’s search.

3. Outgoing ACSO emails to Flock Safety

All outgoing emails and attachments sent from any ACSO or Amador County account to a Flock employee or @flocksafety.com address from January 1, 2023 through the date of the search.

The request notes that the prior production contained many direct incoming Flock messages but comparatively few direct outgoing ACSO messages, with some ACSO messages appearing only as quoted text in later replies.

The requested search includes sent folders, archives, shared mailboxes, complete conversation views, retained or reasonably recoverable deleted mail, forwarded messages, calendar responses, and County-managed email retained from mobile devices. It seeks complete available headers, bodies, attachments, Message-ID, In-Reply-To, References, CC/BCC information, and other metadata.

It also asks the agency to identify the custodians, accounts, systems, folders, date ranges, addresses, names, and search terms used.

4. Records supporting the claim of competitor research

Records sufficient to substantiate the Sheriff’s prior statement that extensive research into competing ALPR vendors or products occurred before Flock was selected.

The request seeks:

1. Every competing vendor, platform, and product researched or considered.
2. Communications with those vendors.
3. Quotes, proposals, demonstrations, presentations, pricing, literature, and technical materials.
4. Evaluation criteria, notes, comparison charts, scoring sheets, spreadsheets, and internal discussions.
5. Comparisons involving price, accuracy, reliability, privacy, constitutional concerns, retention, sharing, cybersecurity, interoperability, or misuse safeguards.
6. Recommendations or communications explaining why Flock was selected.
7. The people who conducted the evaluation or made the recommendation.
8. The second company the Sheriff previously said was researched.
9. The person or body that made or approved the final decision.

Historical invoices showing use of another product are expressly distinguished from records showing that a competitor was actually evaluated as part of the Flock selection process.

Requested period: January 1, 2023 through March 31, 2025.

5. Constitutional, privacy, and legal review

Existing records showing whether ACSO, County Counsel, County Administration, command staff, or the Board considered the constitutional, legal, privacy, or civil-liberties implications of acquiring, deploying, sharing, or using Flock or other ALPR technology.

The requested subjects include:

• The Fourth Amendment and California constitutional privacy protections.
• Long-term, aggregated, or repeated tracking of movement.
• Historical searches without a warrant, court order, probable cause, or reasonable suspicion.
• Whether repeated observations may reveal residences, workplaces, medical visits, religious attendance, political activity, associations, travel, or other private-life patterns.
• Access to privately collected ALPR data.
• Sharing with agencies, task forces, fusion centers, federal entities, contractors, or private organizations.
• Retention, downloading, export, flagging, archiving, or preservation beyond the default period.
• Misuse, discriminatory use, unauthorized access, and searches outside an authorized law-enforcement purpose.
• Possible requirements for warrants, court orders, supervisor approval, case numbers, reasonable suspicion, audits, or other safeguards.

The request seeks existing records and does not ask the agency to create a new legal opinion. If records are withheld as privileged, it asks for the general category, date range, applicable item, participant type, withholding status, and precise exemption without disclosure of privileged substance.

Requested period: January 1, 2023 through the date of the agency’s search.

Production, withholding, and redaction instructions

The request asks for native electronic files where reasonably available, including EML or MSG messages with original attachments and metadata, and original spreadsheet or report formats rather than PDF-only conversions.

For each record withheld in full or redacted in part, it asks the Sheriff’s Office to identify the applicable request item, filename or other identifying description, date, sender and recipients where releasable, exact exemption, general nature of the withheld material, segregability review, and the person responsible for the denial.

It specifically asks the agency not to rely only on a general list of exemptions without identifying which records, categories, items, or redacted portions each exemption applies to.

No records, destroyed records, and clarification

For any item with no responsive records, the request asks the agency to say so directly and identify the custodians, systems, date range, and principal search criteria used. If records previously existed but were destroyed, it asks for the record type, retention policy, approximate deletion date, and whether destruction occurred routinely. If wording is considered unclear, the agency is asked to seek clarification before treating the item as unanswerable.