# T026 — Rogers Record-Creation Objection Versus What Was Produced Rogers raised a record-creation concern and then produced several existing native records. The first delivery does not establish that every requested export existed. ## Statement A City Attorney [[John Pesek]], 2026-07-22 at 11:23 CDT: > "The City is in receipt of your request. You use many terms we are not familiar with and your request is quite long and seemingly asking the City to create many records that do not exist and will…" (Gmail message `19f8aa3d0b34cf45`) ## Statement B On 2026-07-24, [[Missi Craig]] produced twenty-one documents. Among them: - **`SharedNetworks_2026_July_10.csv`** — a native platform export listing **2,408 organizations**, generated fourteen days before production ([[Rogers SharedNetworks 2026-07-10 Export]], full-file parse). - **`The Meraki Camera Inventory.xlsx`** — a native inventory of **263 cameras** with site, position, MAC address, serial number, model, and firmware ([[Rogers Meraki Camera Inventory]], `Sheet1!A1:F264`). - **Seven governance documents**, including policies on the Public Safety Camera Network, ALPR, artificial intelligence, and the Real Time Information Center ([[Rogers RTIC AI and Camera Policies]]). - The Flock order form and invoice, the Axon master agreement, and three ARDOT permit items. ## Why it matters The two positions are not formally contradictory. An objection raised on day one does not bind the agency on day three, and the City is entitled to reconsider. The tension is evidentiary rather than logical, and it is about **what the objection tells us regardless of how it was resolved**. The production settles the existence question for the sharing CSV and Meraki workbook. It does not settle the native devices-and-locations export: Rogers supplied a Google Earth image without coordinates, and the record does not establish whether a native coordinate export was generated, retained, or exportable for this tenant. That matters beyond Rogers because the same objection is available to every custodian in the corpus holding the same platform, and in several it has not been tested. Bentonville's produced internal deliberation reasoned along the same line about sharing configuration ([[T022 - Bentonville Click-to-Allow Sharing Statement vs Produced Sharing Records]]); Rogers supplies the counter-example in which the objection was made and the records appeared anyway. ## Resolution status open — the objection was never withdrawn in writing, and the production did not address it. Both remain in the record. On 2026-07-29, Rogers reported that its search was complete and a flash drive was ready, but no additional files had been delivered into the corpus by the July 30 audit. Joshua's secure-electronic-delivery reply remains an unsent Gmail draft (`19fb01f14091252a`) in thread `19f8600b411f92dc`. The Flock devices-and-locations question remains open for the reason above. ## Discovery Surfaced 2026-07-24 during ingest of the first Rogers production. ## Notes The Department's conduct throughout was cooperative in a way the objection does not suggest: Craig invited the requester to identify gaps, and Pesek named a specific extension date rather than letting the category lapse. The tension is recorded about the framing, not as a criticism of the handling.