# D004 — Antithesis: ASP Had the System It Denied Having ## Counterclaim [[Ryan Roach]]'s April 14, 2025 sentence — *"Please be advised that ASP does not have a License Plate Reader system."* — was false when made, and the record that proves it false is ASP's own. Eight months earlier, ASP had drawn PO 4502235324 against a State of Arkansas term contract issued in its own name, buying 25 F4 ELSAG cameras, 11 Street Sentry cameras, mounts, ELSAG-configured computers, EOC licenses, and a HIDTA network license — $481,469.23, shipped to ASP Central Supply, tagged as ASP asset 800004054, requested by [[Dennis Overton]] *"For: Interstates/Highways throughout Arkansas."* Four months before the sentence, Overton was circulating names for *"the first four sites installed."* Three months before, he approved a 39-camera expansion: *"Good to go…"* Weeks after, ASP signed an MOU as the owner of an *"AR Arkansas State Police"* domain with hot lists, admin rights, and a covert silent list for its CID; its IT staff called the network *"our LPR system within Arkansas"*; and its troopers were quoting ELSAG reads in criminal reports. The thesis's custody defense fails on chronology, fails on the fiscal record, and fails on the statute — which keys the duties at issue to *use*, a fact ASP has never been able to deny. The one-sentence response was not an accurate custody statement; it was a non-production rationale that denied, to a records requester, an operation the agency was actively building, branding, and querying. ## Attack on the thesis **Against "Claim."** The thesis's central predicate — that *"ASP owned no ELSAG cameras per the network's own LPR Coordinator"* — is contradicted by ASP's own purchasing documents. PO 4502235324 (08/19/2024) itemizes *"Qty: 16 - F4 2L Cam 60ft 740nm POE"* and *"Qty: 9 - F4 Cam 100ft 740nm-POE"*, plus eleven Street Sentry cameras, delivered to *"ARKANSAS STATE POLICE"* / *"CENTRAL SUPPLY"* under asset number 800004054 ([[Term Contract 4600055190 and PO 4502235324 — Initial Leonardo ELSAG Buy]], `1513_001.pdf`, "Part #:421993 - Qty: 16 - F4 2L Cam 60ft 740nm POE - $7,590.00 ea"). An agency that buys cameras with state-administered funds, takes delivery at its own supply depot, and enters them in its asset register owns them in the only sense Arkansas fiscal law recognizes. April Gough's June 4, 2025 assertion that *"ASP does not currently own any ELSAG cameras"* is either flatly wrong or narrowly scoped to the Searcy-owned cameras in the Hess case — her own parenthetical, *"(he refers to in the Hess case)"*, signals the narrow reading. On neither reading does it support the thesis's generalization. Gough is Houston HIDTA's *"Financial Assistant and LPR Coordinator"* — a records authority for the Houston network's paperwork, not for Arkansas's property books; she is in no position to know what ASP bought from Leonardo on Arkansas purchase orders, and the thesis never checked her claim against the fiscal production. It could not have: the thesis's own "Anticipated counterarguments" section concedes it did not examine the procurement and deployment corpus at all. A `confidence: high` verdict of "true-when-made," reached by declining to read the ownership record, is not a finding about the world; it is an artifact of the reading list. **Against "Argument," first move ("the record fixes ASP's exact words, and they are ordinary").** Grant the premise — the words are fixed — and the words are false in their ordinary meaning. The sentence was Roach's *entire response* to a statutory records request; it was communicated to a requester as the reason nothing would be produced. The ordinary reading of "ASP does not have a License Plate Reader system," delivered in that posture, is: *there is no system, so there are no records.* Both halves were untrue: the system existed (bought, installed, expanding), and records about it saturated ASP's files — the term contract, the POs, the site surveys, the install schedules, the naming emails. The thesis's "custody" gloss requires "have" to mean "hosts the back-end server," a reading no requester could extract from the sentence and one the record contradicts anyway, since ASP's cameras and its EOC-named sites are precisely the parts of the system ASP does hold. The timing forecloses the charitable reading: Schriver's request arrived at 10:07 AM on April 14 and Roach's denial went out at 1:50 PM the same day — three hours and forty-three minutes later. No search of a fiscal system containing a $481,469.23 ELSAG purchase order happened in that window. Roach either answered against his agency's records or without consulting them; "true-when-made" is unavailable either way. And when Roach did seek substance — two days later — his own internal words gave the game away: he described the matter as *"a request below about ASP's use of license plate readers"* ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender.msg`, "We received a request below about ASP's use of license plate readers"). Internally, the subject was ASP's use. Externally, the subject did not exist. **Against "Argument," second move ("the system's own authorities corroborate the predicate").** The thesis's two authorities corroborate the counterclaim. Robert Ryan's taxonomy — *"each individual agency is the 'owner' of the data they collect in their domain"* — makes ASP an owner, not a guest: ASP collects data through its own F4 network into its own domain, so under the vendor's own rule ASP owns that data. Server title was never the question; no one says they do not "have" email because their provider owns the mail server. Ryan also told Overton, of the requester's position, *"I believe he is correct with his explanation"* — the thesis's corroborating witness endorsing the challenge's core. And both consultations happened on June 4, 2025 — six weeks after the denial — while the MOU on which Gough's custody rule rests (*"Per our MOU, the owner of the cameras would have to be the one to provide that information"*) was only signed and transmitted on May 15, 2025, a month *after* Roach's sentence. As late as May 13, Leonardo's Duncan wrote that *"ASP is still in the process of executing the MOU with HIDTA"* ([[ASP–Houston HIDTA MOU and ELSAG Domain Architecture]], `Re_ Logon access.msg`). The custody structure the thesis calls the statement's "factual predicate" did not exist in executed form when the statement was made. A predicate that post-dates the sentence cannot have been its basis; it can only be its after-the-fact defense. **Against "Argument," third move ("the requester's rebuttal concedes the distinction").** Silence on ownership is not a concession of non-ownership, and Schriver was not silent. He asserted, factually: *"such license plate reader systems are in fact employed, relied upon and used by the ASP to conduct investigations"* — a direct contest of the operational substance behind Roach's sentence. What he did not do is litigate ASP's asset register, because he could not: a FOIA requester has no visibility into ASP's purchase orders, and ASP's one-sentence denial was designed to keep it that way. Treating the requester's information deficit as "corroboration through omission" inverts the epistemics — the party with the records issued the denial; the party without them is scored as conceding. Schriver argued in the alternative, as any competent advocate does: even on your own framing, the statute reaches you. That is argument economy, not agreement. The thesis's conclusion that "'ASP is obligated as a user' and 'ASP does not have a system' can both be true — and on this record, both are" fails on the second conjunct: the full record shows ASP both uses *and* owns and operates. And even if the conjunction held, it would concede the dispositive point — the duty attached — which makes the sentence, offered as the whole response to a duty-keyed demand, a non-answer that functioned as a denial. **Against "Argument," fourth move ("proof of use is proof of non-possession").** This is a non sequitur dressed as a discovery. Texas entries in a query result prove the database is shared; they prove nothing about whether ASP owns cameras or a system. ASP's own F4 network feeds that same shared database — the Arkansas read in Trooper Hess's report is exactly what ASP's Interstate cameras exist to produce. Shared-network membership and system ownership are not exclusive; ASP's procurement shows they are bundled: the very PO that bought the cameras includes *"One Time HIDTA LPR Network License Included"* ([[Term Contract 4600055190 and PO 4502235324 — Initial Leonardo ELSAG Buy]], `1513_001.pdf`). ASP *purchased its seat* on the multi-state network as a line item of its own system buy — the HIDTA connection is a feature ASP bought, not an entity that absorbed ASP's property. The argument also proves too much: if multi-state query results negate "having" a system, then no HIDTA member agency anywhere — including the City of Searcy, whose cameras Gough said could answer the request — "has" one, and a statewide surveillance architecture answers to no records requester at all. That is not a custody doctrine; it is a disappearing trick. **Against "Argument," fifth move ("conduct of an institution applying a custody doctrine").** The chronology runs backwards. The denial issued April 14; the internal routing for "insight" began April 16; the vendor and HIDTA consultations occurred June 4. An institution applying a doctrine consults first and answers second. This record shows the reverse — a same-day denial, then a six-week-late search for its justification, which is the thesis's own listed counterargument #5, acknowledged and never engaged. The June thread the thesis reads as good-faith compliance reads, in full, as denial-defense engineering: the vendor advises narrowing the request as *"facially invalid,"* suggests *"use the terminology of HIDTA rather than ELSAG in the reports"* — a wording change whose only FOIA-relevant effect is to make trooper reports harder to connect to the queried system — and Gough closes with routing the requester to a third party he would *"have to track him down"* to reach. The thesis quotes Overton's *"very transparent"* line from this same exchange while omitting the renaming advice beside it. As for Overton's plan *"to determine what our reporting parameters are going to be in the future"*: that sentence is an admission that ASP had no § 12-12-1805 reporting practice when Schriver asked for the statutory report. The truthful April answer was "ASP uses an ALPR system and has not produced the report the statute contemplates." The sentence actually sent avoided that admission by denying the system instead. Finally, the thesis credits ASP with "adopt[ing] advisor language that affirmatively volunteers 'ASP does utilize LPRs'" — but nothing in this record shows that language, or any correction, was ever transmitted to Schriver. The only ASP-to-requester statement in evidence remains the false one. **Against "Argument," sixth move ("the same doctrine reappears, intact, months later").** Consistency is only exculpatory if the thing repeated is legitimate. What repeats here, per [[T007 - ASP No-LPR-System Position vs Documented ELSAG Operation|T007]], is a withholding posture ASP's own coach describes as *"an easy denial"* ([[T007 - ASP No-LPR-System Position vs Documented ELSAG Operation]] quoting [[Citizen Flock FOIA and ASP Withholding Strategy]], `RE_ Flock FOIA - ASP.msg`) — the thesis itself reproduces the line in its counterargument list and declines to engage it. A doctrine applied consistently to two requesters is a pattern; when the doctrine's function each time is non-production about a documented operation, the pattern aggravates rather than excuses. Worse for the thesis, the Flock-thread rule it quotes — FOIA applies *"as it applies to YOUR system"* — indicts the April sentence on its own terms: the F4/Street Sentry network is *"YOUR system"* by every marker in the record, down to cameras named with the agency's initials. Applying Overton's rule honestly in April 2025 required production, not denial. **Against "Evidence."** The thesis's evidence file is a closed loop: every citation is April–June 2025 FOIA-fight correspondence — the denial, the rebuttal, and the after-the-fact custody talk assembled to defend the denial. Not one procurement record, install record, naming email, training thread, domain request, or analyst-access checklist appears in it. The single operational artifact it cites — the Hess reads — it reads backwards, as evidence of non-possession. Evidence curated to exclude the operation will always vindicate the sentence that denied the operation; that is a property of the curation, not of the sentence. ## Independent argument for the counterclaim **ASP owns the system, on paper it wrote.** The State of Arkansas term contract for *"Fixed and Vehicle License Plate Recognition"* is *"issued by the Department of Public Safety-Arkansas State Police"* — ASP is the issuing agency, not a bystander ([[Term Contract 4600055190 and PO 4502235324 — Initial Leonardo ELSAG Buy]], `1513_001.pdf`). The first draw, PO 4502235324, names Overton as requestor, states its purpose as *"For: Interstates/Highways throughout Arkansas,"* ships to ASP Central Supply, assigns ASP asset number 800004054, and enumerates the physical system: 25 F4 fixed cameras, 11 Street Sentry cameras, ELSAG-configured PCs, 36 EOC Operation Center licenses, mounts, cabling, and field-engineering days — $481,469.23 in total, with the federal network seat (*"One Time HIDTA LPR Network License Included"*) bundled into the same purchase. In January 2025 ASP enlarged the build: *"This now has 39 F4 cameras vs. the original at 25 cameras"*, base cost *"$448,110"* — and Overton approved in three words: *"Good to go…"* ([[F4 Installs and Site Nomenclature]], `RE_ ARKANSAS STATE POLICE - FIXED LPR Project - Budget (2).msg`). Ownership does not get more documented than an agency's own contract, purchase order, asset tag, and expansion sign-off. **ASP deployed the system, before and after the denial.** By December 11, 2024, Overton was circulating *"names for the first four sites installed"* ([[F4 Installs and Site Nomenclature]], `Re_ Thoughts on this.msg`) — installed, four months before Roach's sentence. On January 23, 2025 he cleared the expanded survey: *"This is perfect and ready to proceed…"* (`RE_ ASP SITE SURVEY F4 - UPDATED.msg`). In July 2025 the install cadence continues with dated site visits, GPS coordinates, and even lifecycle maintenance — Site 3's entry reads *"(Replace 2 LPR cameras)"* (`ASP - F4 INSTALLS - Nomenclature.msg`): an agency replacing worn cameras is operating an installed base, not visiting someone else's. The sites carry ASP's name into the shared platform itself — Overton's naming convention opens every entry with *"AR ASP"* (`RE_ Names for Sites.msg`), and Leonardo asks ASP, not HIDTA, what each camera should *"be called on the HIDTA EOC."* The operator who names the nodes is the operator. **ASP administers the system.** The platform's own architecture, described by Leonardo, centers on an *"'AR Arkansas State Police' domain"* — with an Arkansas Highway Police group nested inside it holding *"query and hot list management access,"* a hot list *"seen by all in that domain,"* designated ASP points of contact, and, at Overton's request, a *"'AR Arkansas SP Silent List' domain for his CID use only"* ([[ASP–Houston HIDTA MOU and ELSAG Domain Architecture]], `RE_ MOU and Point(s) of Contact.msg`). ASP signed the governing MOU (*"Please see attached the ASP / Houston HIDTA MOU (signed) as well as POC for ASP"*, same file), and user creation waited on ASP's signature — *"Until that is complete, we cannot create any new users"* (`Re_ Logon access.msg`). By August 2025 ASP was provisioning covert list infrastructure: *"ASP is requesting a new silent list domain for their Interstate Criminal Patrol(ICP) hot list"* (`Arkansas State Police - Request for new SILENT LIST DOMAIN.msg`). Deciding who may query, which hot lists run, which lists alert silently, and who holds admin rights is what *having* a system means operationally. The corpus even supplies the epitaph for the April sentence in ASP's own house style: the denial began *"Please be advised that ASP does not have a License Plate Reader system"*; four months later the same corpus records *"Please be advised that ASP is requesting a new silent list domain…"* **ASP staffs and queries the system, and calls it its own.** ASP's Fusion Center checklist provisions an ASP analyst across the ALPR stack with Overton personally coordinating the ELSAG item — *"ELSAG: Lt Overton may you coordinate this?"* — and Overton asking a partner to get the analyst *"access to the ALPR's as well"* ([[Cross-Network Analyst Access and the Arkansas State Fusion Center]], `RE_ Justin Dennis - Additional Analyst Support_ ICP Accesses (1).msg`), in January 2025, three months before the denial. In September 2025, ASP's IT infrastructure analyst specifies the integration goal in the possessive: a trooper *"is able to see any reads from our LPR system within Arkansas"* (`FW_ API Information.msg`), and Overton describes him as *"assisting with our ALPR systems."* In the field, the use is admitted in ASP's own investigative product: Trooper Hess's report recites that *"Entries on the ELSAG license plate reader system showed that a white Sprinter van"* traveled in Arkansas and Texas on stated dates, and that the system's data *"disproved his answers regarding when he left Georgia"* ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender.msg`; vehicle registration withheld per surveillance-PII handling). ASP says "our system" when engineering it, uses it to build criminal cases, and says "no system" only when a requester asks. That asymmetry is the tension in one sentence. **The statute forecloses the escape hatch anyway.** The [[Arkansas Automatic License Plate Reader System Act]], as quoted in the exchange itself, authorizes that *"an automatic license plate reader system may be used: (1) by a state, county, or municipal law enforcement agency…"* and § 12-12-1805 attaches its data-preservation and reporting regime to entities that use such systems — *"'use' is the threshold requirement, and ASP does use such technology"* ([[Federal Public Defender FOIA and the No-LPR-System Position]], same file). ASP's use is conceded everywhere in this record: by Gough's proposed language (*"ASP does utilize LPRs"*), by Roach's internal framing (*"ASP's use of license plate readers"*), by the trooper's report, by the vendor. So even if the ownership question were close — and the fiscal record shows it is not — the duties the requester sought to enforce never depended on it. A response keyed to "have," answering a demand keyed to "use," did not engage the statute; it changed the subject. The counterclaim therefore holds at both levels: as a matter of fact, ASP owns and operates an ELSAG ALPR system; as a matter of law, its admitted use suffices to attach the obligations its one-sentence denial was deployed to avoid. ## Evidence **Ownership — the fiscal record** - ([[Term Contract 4600055190 and PO 4502235324 — Initial Leonardo ELSAG Buy]], `1513_001.pdf`, "This is a term contract issued by the Department of Public Safety-Arkansas State Police.") — the LPR term contract is ASP's own instrument; scope line "Fixed and Vehicle License Plate Recognition"; target value $460,294.80. - ([[Term Contract 4600055190 and PO 4502235324 — Initial Leonardo ELSAG Buy]], `1513_001.pdf`, "Requestor: Dennis Overton") — with "For: Interstates/Highways throughout Arkansas" and "Asset#800004054" on PO 4502235324, 08/19/2024, total $481,469.23, Ship To ASP "CENTRAL SUPPLY." - ([[Term Contract 4600055190 and PO 4502235324 — Initial Leonardo ELSAG Buy]], `1513_001.pdf`, "Part #:421993 - Qty: 16 - F4 2L Cam 60ft 740nm POE - $7,590.00 ea") — and "Part #:421995 - Qty: 9 - F4 Cam 100ft 740nm-POE - $7,590.00 ea": 25 F4 cameras bought by ASP in August 2024, plus Street Sentry cameras (Qty 4 + 7) and 36 EOC licenses. - ([[Term Contract 4600055190 and PO 4502235324 — Initial Leonardo ELSAG Buy]], `1513_001.pdf`, "One Time HIDTA LPR Network License Included") — ASP bought its HIDTA network seat as a line item of its own system purchase. - ([[F4 Installs and Site Nomenclature]], `RE_ ARKANSAS STATE POLICE - FIXED LPR Project - Budget (2).msg`, "This now has 39 F4 cameras vs. the original at 25 cameras or 14 more F4 cameras than originally detailed.") — Duncan to Overton, 2025-01-20, base cost "$448,110"; Overton, 2025-01-23: "Good to go…" **Deployment — installed before the denial, expanding after it** - ([[F4 Installs and Site Nomenclature]], `Re_ Thoughts on this.msg`, "These names for the first four sites installed. Simple enough?") — Overton, 2024-12-11: four fixed sites installed four months before the April 14, 2025 sentence. - ([[F4 Installs and Site Nomenclature]], `RE_ ASP SITE SURVEY F4 - UPDATED.msg`, "This is perfect and ready to proceed…") — Overton clears the 39-camera survey, 2025-01-23. - ([[F4 Installs and Site Nomenclature]], `ASP - F4 INSTALLS - Nomenclature.msg`, "Can you advise up front on what you want the below to be called on the HIDTA EOC please?") — dated July 2025 installs with GPS coordinates; Site 3 entry "(Replace 2 LPR cameras)" shows lifecycle maintenance of an operating base. - ([[F4 Installs and Site Nomenclature]], `RE_ Names for Sites.msg`, "I'm going to allow the field techs to install the cameras and then I will come back and adjust the names once they are live.") — Leonardo executes; ASP names. Overton's convention opens each site entry "AR ASP." **Administration — domain, hot lists, silent list, MOU** - ([[ASP–Houston HIDTA MOU and ELSAG Domain Architecture]], `RE_ MOU and Point(s) of Contact.msg`, "we need to create a 'AR Arkansas Highway Police' group within the 'AR Arkansas State Police' domain. This group will have query and hot list management access.") — the platform's Arkansas namespace is ASP's domain. - ([[ASP–Houston HIDTA MOU and ELSAG Domain Architecture]], `RE_ MOU and Point(s) of Contact.msg`, "Lt. Overton is requesting a 'AR Arkansas SP Silent List' domain for his CID use only.") — covert-list infrastructure provisioned at ASP's request. - ([[ASP–Houston HIDTA MOU and ELSAG Domain Architecture]], `RE_ MOU and Point(s) of Contact.msg`, "Please see attached the ASP / Houston HIDTA MOU (signed) as well as POC for ASP") — Overton, 2025-05-15: the MOU is signed and transmitted a month after Roach's April 14 sentence. - ([[ASP–Houston HIDTA MOU and ELSAG Domain Architecture]], `Re_ Logon access.msg`, "ASP is still in the process of executing the MOU with HIDTA. Until that is complete, we cannot create any new users.") — Duncan, 2025-05-13: the custody framework the thesis calls the statement's predicate was unexecuted when the statement was made. - ([[ASP–Houston HIDTA MOU and ELSAG Domain Architecture]], `Arkansas State Police - Request for new SILENT LIST DOMAIN.msg`, "Please be advised that ASP is requesting a new silent list domain for their Interstate Criminal Patrol(ICP) hot list.") — 2025-08-14; the corpus's mirror to "Please be advised that ASP does not have a License Plate Reader system." **Staffing and query use — ASP's own voice** - ([[Cross-Network Analyst Access and the Arkansas State Fusion Center]], `RE_ Justin Dennis - Additional Analyst Support_ ICP Accesses (1).msg`, "1. ELSAG: Lt Overton may you coordinate this?") — Fusion Center provisioning checklist, January 2025; Overton: "Can you assist with getting Justin access to the ALPR's as well?" - ([[Cross-Network Analyst Access and the Arkansas State Fusion Center]], `FW_ API Information.msg`, "a Trooper enters plate 'ZZZ980' into ATLAS and is able to see any reads from our LPR system within Arkansas that match 'ZZZ980'") — ASP IT analyst James Sutton, 2025-09-17; Overton in the same thread: "our IT Analyst, James Sutton who is assisting with our ALPR systems." - ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender.msg`, "Entries on the ELSAG license plate reader system showed that a white Sprinter van") — Trooper Hess's report as quoted by the requester; continuing, "information gathered from the ELSAG license plate reader system disproved his answers regarding when he left Georgia" (vehicle registration withheld per surveillance-PII handling). **The denial, its timing, and its after-the-fact defense** - ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender.msg`, "Please be advised that ASP does not have a License Plate Reader system.") — Roach to Schriver, 2025-04-14, 1:50 PM; the request arrived 10:07 AM the same day. Three hours and forty-three minutes, against a records set containing a $481,469.23 ELSAG purchase order. - ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender.msg`, "We received a request below about ASP's use of license plate readers") — Roach internally, 2025-04-16: the agency's own description of the subject matter is its use. - ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender.msg`, "We are aware that such license plate reader systems are in fact employed, relied upon and used by the ASP to conduct investigations") — Schriver, 2025-04-15: the requester contested the operational substance, not merely the legal relevance; and "'use' is the threshold requirement, and ASP does use such technology," quoting § 12-12-1803(b): "an automatic license plate reader system may be used: (1) by a state, county, or municipal law enforcement agency…" - ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender (1).msg`, "I believe he is correct with his explanation, but his request is facially invalid because he is not requesting specific dates.") — the vendor endorses the requester's explanation while supplying narrowing grounds; same email: "That's another change I would suggest is to use the terminology of HIDTA rather than ELSAG in the reports." and "each individual agency is the 'owner' of the data they collect in their domain." - ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender (7).msg`, "ASP does not currently own any ELSAG cameras. ASP does utilize LPRs, but since you don't own the cameras (he refers to in the Hess case) you are not able to provide the data requested.") — Gough, 2025-06-04: dated six weeks after the denial, qualified to the Hess case, contradicted by the August 2024 PO, and never shown to have been transmitted to the requester. - ([[Federal Public Defender FOIA and the No-LPR-System Position]], `RE_ Freedom Of Information Request from Arkansas Federal Public Defender (2).msg`, "We are trying to determine what our reporting parameters are going to be in the future and how we need to change our reports now to make that easier.") — Overton, 2025-06-04: ASP had no § 12-12-1805 reporting practice when the statutory report was requested; the denial concealed a compliance gap rather than describing a custody fact.