FOIA 25-202: No RFP, no bid, no purchase order — and the emails that show how the system was picked

Watchdog Alerts

Why isn’t this basic information available to the public?

The office certified that it holds no request for proposals, vendor bid or purchase order for the case-management system it now runs — and in the same letter produced emails showing that PAAM ran the procurement and that Karpel won 52 of 66 county votes. If the county pays for the system, where is the county's procurement file?
The letter says the fee is “specifically outlined in the attached FOIA Fee Itemization.” No itemization is in the packet, and no dollar figure appears anywhere in its twenty-five pages. How is a requester supposed to accept, challenge or budget for a charge that was never stated?
The Notice of Denial checks box 3, “Redaction,” and cites MCL 15.243(1)(a) and (1)(iii). But the RFP portion was denied because the records do not exist, not because anything in them was redacted. Why does the denial form describe a different decision than the letter?
The communications portion was granted “subject to any necessary redaction” — but only on payment of the unstated fee. Until the fee is stated, the grant is not something a requester can accept. Thirteen pages arrived as a courtesy; the roughly 500 conversations the letter itself describes have not been produced.

Timing caveat. This is the first document in the archive that describes how ProsecutorByKarpel was chosen. It states that PAAM — not Delta County — administered the procurement and implementation, and the March 10, 2023 email records the selection vote: 66 votes cast, 52 for Karpel, 78.78 percent. The March 8, 2023 email is Prosecutor Wickman's own, written to the county administrator and the county's IT contact before the vote, laying out the three vendors' costs and saying the Karpel option “appears to be the most popular choice.” None of these documents states an implementation date. The June 2024 go-live used elsewhere in this archive remains an approximation drawn from the contracts and invoices in 25-201, and this page does not assert an exact date.

On August 18, 2025, a request went to the Delta County Prosecutor’s Office asking for the paperwork behind the office’s own software: any request for proposals, vendor bid, purchase order, or communication about acquiring or replacing a case management, records management, prosecutorial training, electronic discovery or digital evidence system, from January 1, 2020 forward. On September 8, 2025, the office answered. It granted the request in part and denied it in part. It certified that no RFP, no vendor bid and no purchase order exists anywhere in its records. Then, in the same letter, it produced thirteen pages of emails showing exactly how the system it now runs was chosen — that the Prosecuting Attorneys Association of Michigan administered the procurement, that three vendors demonstrated in November 2022, and that ProsecutorByKarpel won 52 of the 66 county votes cast, at 78.78 percent.

Both halves of that answer are in the record, and both are worth reading closely. The certificate of nonexistence is a formal, signed statement that the office holds no procurement file for the software it uses every day. The emails are the procurement file, or as much of it as the office says it possesses, and they are candid in a way that government records rarely are: they contain the vendors’ own price sheets, the counties’ own vote tally, and a March 8, 2023 email from Prosecutor Lauren M. Wickman to two county officials explaining that the change was coming and would cost more than the current budget line.

What the response does not contain is the thing it says it contains. The letter tells the requester that the cost of searching, reviewing and redacting the responsive emails “would result in unreasonably high costs to the County,” and that those costs are “specifically outlined in the attached FOIA Fee Itemization.” No itemization is attached. No page of the twenty-five-page packet states a fee, a deposit, an hourly rate, or an estimated number of hours. The office asserted a charge without ever stating one, and the approximately five hundred email conversations it described were never produced.

How to read this page

This page separates four things that are easy to blur together. First, what was asked. Second, what the office said it did not have, and how it said so. Third, what it actually produced — the emails, the vendor numbers, the vote. Fourth, what it charged, which is nothing stated and something asserted.

Where the record supports criticism, the criticism is made and the page cites the page of the packet. Where the record is silent, the page says so rather than filling the gap. The office’s decision to certify nonexistence and then produce the underlying correspondence is unusual enough that it deserves to be described precisely rather than characterized. The documents are linked at the bottom of this page in redacted form.

Summary

The request named four kinds of record: requests for proposals, vendor bids, purchase orders, and communications. The office’s answer treats them as two groups. The first three — RFP, bid, purchase order — are denied outright, with a signed certificate stating that after a search they “do not exist within the records of the public body under the name nor any other name reasonably known to the public body.” The fourth, communications, is granted subject to redaction, and it is the grant that carries the fee language.

The thirteen pages that follow are not a redacted email dump in the usual sense. They are three conversations, reproduced whole, with their quoted threads intact. The first is a PACC broadcast from October 4, 2022 announcing a day of vendor demonstrations to replace the statewide ACT and JCT case tracking systems, with LawBase/OnBase at 1 p.m., Karpel at 2 p.m. and Equivant at 3 p.m. The second is the March 10, 2023 announcement of the vote result: 66 votes cast, Karpel with 52 and 78.78 percent. The third is Wickman’s own March 8, 2023 email to Ashleigh Young and Brandon Couvillion, sent two days before the vote closed, laying out the three vendors’ costs and saying that Karpel “definitely appears… the most popular choice.”

The numbers inside those emails are the most concrete figures in the packet, and they are not small. Karpel’s own estimate to the association was $8,470,374 across 67 rollouts and 1,000 users in years one through three, dropping to $1,124,725 a year thereafter, or $1,124 per user per year at full rollout. Equivant’s was $975,000 in licensing plus $2,713,095 in implementation spread over four years at $678,476 a year, with ongoing costs around $429 per user. LawBase/OnBase quoted a $500,000 implementation fee and $175 per user per month — $2,100 per user per year — which at 500 users totals $1,050,000 a year. All three vendors listed migration from ACT/JCT, API connections and training as unknown costs.

Against that, the office’s own answer to the request is that it holds no RFP, no bid and no purchase order. The letter explains why: “the procurement and implementation of the ProsecutorbyKarpel program was administered by Prosecuting Attorney’s Association of Michigan.” That is a real and verifiable explanation. It is also an explanation that raises the next question rather than closing it, because the association is a public body too, and the county’s share of an $8.47 million multi-county contract is a public expenditure.

What was asked, and how the office answered

The request was dated August 18, 2025 and logged by the office as received on August 19, 2025. That same day the office issued a Notice to Extend Response Time, citing the need to search for, collect, or appropriately examine or review “a voluminous amount of separate and distinct public records,” and extending the response date to September 8, 2025. The extension was taken within the statutory window and the notice states a specific new date, which is what MCL 15.235(4) requires. The office then answered on the extended date. On timing, the record shows compliance.

The request itself reads:

“Copies of any requests for proposals (RFPs), vendor bids, purchase orders, or communications regarding the acquisition or implementation of new or replacement case management systems, records management systems, prosecutorial training systems, electronic discovery platforms, or digital evidence systems by the Delta County Prosecutor’s Office from January 1, 2020 to present.”

The disposition line is “GRANTED IN PART, DENIED IN PART.” The letter then splits the request. On the procurement documents it writes that “a review of the records reveal they do not exist,” and prints the standard certificate:

“The undersigned hereby certifies that, after a search for records and to the best of the undersigned’s knowledge and belief, the public records requested, and described below, do not exist within the records of the public body under the name nor any other name reasonably known to the public body.”

On the communications it grants, subject to redaction, and then explains the fee:

“Due to the breadth of your request and the number of records (approximately 500 email conversations with several lengthy and sensitive attachments), the County will require payment of fees… failing to charge for the costs of the search, examination, review, and deletion and separation of exempt from nonexempt information would result in unreasonably high costs to the County beyond those typically incurred in responding to FOIA requests. Such costs are specifically outlined in the attached FOIA Fee Itemization but include the significant time and cost for searching for and locating the records.”

That paragraph does three things at once. It estimates the size of the responsive set at roughly five hundred conversations. It invokes the “unreasonably high costs” standard that MCL 15.234(4) allows a public body to use when a request would otherwise be unreasonably burdensome. And it points to an attachment that is not there.

This page has been checked page by page against the twenty-five-page packet. There is no FOIA Fee Itemization. There is no line-item table, no hourly rate, no estimated hours, no deposit amount, no total. The only dollar figures in the entire packet are the $1,000 statutory-damages language reproduced on the appeal pages and the vendors’ own cost estimates inside the produced emails. The office did not tell the requester what the records would cost. It told the requester that they would cost something, that the something was itemized elsewhere, and then did not itemize it.

The practical effect is that the communications portion of the request was granted on paper and not produced in fact. A requester cannot pay an unstated fee. A requester cannot decide whether to narrow a request to fit a budget he has not been given. And a requester cannot challenge an estimate that does not exist. The grant is real, and it is also inert.

The paper trail

The chronology matters here because it shows how long the procurement ran before the request was made, and how much of it happened in writing that the office now says it does not hold.

Figure 1 · Interactive

From the demo announcement to the answer

Select a marker to read what the record shows for that date. The request window opens in 2020; every dated event below comes from the thirteen pages the office produced.

Record

Days from request to answer21

Extension takenYes

Pages produced13

Fee statedNone

Source: the three emails reproduced in the responsive set, the Notice to Extend Response Time dated August 19, 2025, and the response letter dated September 8, 2025. The request window opened January 1, 2020; the earliest dated document the office produced is October 4, 2022.

Figure 1. The procurement ran in public view for at least eleven months before the vote, inside an association of prosecutors rather than inside Delta County. The office’s own March 8, 2023 email puts the county on notice that money and IT work were coming.

Four record types, three certified empty

The cleanest way to see what happened is to line the four record types in the request against the answer. This is a table rather than an interactive graphic, because the answer is a set of dispositions, not a body of responsive documents. There is nothing here to explore; there is only a result to read.

Table 1. The four record types in the request, and what the office said about each.
Record type	Disposition	What the response says
Requests for proposals (RFPs)	Denied — nonexistent	Certified that no RFP exists “under the name nor any other name reasonably known to the public body.” The letter explains that the association administered the procurement, so the county holds no RFP of its own.
Vendor bids	Denied — nonexistent	Same certificate. The office states it “does not possess or maintain any ‘request for proposals (RFPs), vendor bids, or purchase orders.’” The vendors’ price sheets survive only as attachments inside the produced emails.
Purchase orders	Denied — nonexistent	Same certificate. No purchase order, no contract, no invoice, no county board resolution authorizing a spend appears anywhere in the packet.
Communications about acquisition or implementation	Granted in part, subject to redaction and a fee	Thirteen pages produced: three emails with quoted threads. The letter estimates the responsive set at “approximately 500 email conversations” and conditions production on a fee itemized in an attachment that is not in the packet.

Read down the disposition column and the shape of the answer appears. Three of four categories are closed with a certificate. The fourth is opened, and then closed again by a condition. The net production is thirteen pages out of an estimated five hundred conversations, and even those thirteen pages were produced without payment — which means the office did not treat them as the fee-bearing set. They were included, the letter says, “for the sake of transparency.”

Figure 2 · Interactive

Four buckets, one open

Select a bar to read what landed in that bucket. The scale runs from zero to one: whether the office produced anything at all for that record type.

Requests for proposals 0 Certified nonexistent. The letter's explanation is that PAAM ran the procurement, so any RFP would be an association record, not a county record. That explanation is plausible and it is also untested by this request, which asked only the county.

Vendor bids 0 Certified nonexistent. What survives instead is the vendors' own budget comparison, forwarded inside the association's emails and reproduced in Wickman's March 8, 2023 message to the county. Those figures are quoted in Table 2 below.

Purchase orders 0 Certified nonexistent. No invoice, contract, board authorization or payment record appears in the packet. If the county pays an annual per-user fee, the payment runs through some account; this request did not reach it.

Communications 1 Granted. Thirteen pages produced out of an estimated five hundred conversations. The three produced emails are the announcement of the demos, the announcement of the vote result, and Wickman's own March 8, 2023 message to two county officials.

Record types asked4

Certified nonexistent3

Granted1

Pages produced13

Source: the disposition section of the September 8, 2025 response letter and the certificate of nonexistence printed beneath it, read against the four record types enumerated in the request.

Figure 2. Three of four record types end in a certificate. The one that was granted produced thirteen pages against an estimate of five hundred conversations, and the rest of that set was never produced because the fee was never stated.

The emails: how the system was actually picked

The three produced emails deserve to be read in order, because together they describe a procurement process that is neither secret nor fully documented. It is a process run by an association of elected prosecutors, using a committee, a day of vendor demonstrations, a SurveyMonkey ballot and a per-county vote. That is a legitimate way for eighty-three county prosecutors to choose shared software. It is also a process in which the only written record of the decision that reached Delta County consists of three forwarded messages.

The first email is from Dianna Collins at the Prosecuting Attorneys Coordinating Council, sent Tuesday, October 4, 2022 at 4:01 p.m. to roughly eighty county prosecutors, with Cheri Bruinsma copied. Its subject is “ACT replacement company demos.” It states that “the TS Committee has been working on reviewing and recommending a system to replace ACT/JCT,” and it schedules a day of demonstrations for November 10 beginning at 1 p.m.: LawBase/OnBase at one, Karpel at two, Equivant at three. After the 4 p.m. final demo, the group would stay on the line, discuss what had just been shown, and send out polls for feedback. The email adds a detail that matters later: “The only counties that will not be effected by this change are those that currently or will soon be using Karpel.”

That sentence is worth pausing on. In October 2022, before the demonstrations, before the vote, the association already knew which counties would be unaffected because they were already on Karpel or about to be. Delta County was not one of them. The record does not say when Delta County began using Karpel, and this page does not assert a date. What the record does show is that the association treated Karpel as an incumbent with a county footprint, not as one of three equal options being explored from scratch.

The second email is the vote result, sent Friday, March 10, 2023 at 2:49 p.m., also from Collins. It reads, in full: “Results for the ACT/JCT replacement system: There were 66 votes cast. Karpel had 78.78% of the votes cast in their favor, with 52 votes. We are going to continue to work on funding options to offset the cost of implementing a new system. We will keep everyone informed of the status of the funding request as we know more.” The quoted thread beneath it preserves the run-up: a February 23 recap explaining that a February 17 vote at the PAAM Business Meeting had been postponed for low attendance in favor of one final meeting and multi-day electronic voting; a March 6 reminder; a March 7 message with the SurveyMonkey link and the rule that “only one vote per county will be permitted”; and a March 10 morning reminder that voting closed at noon.

The February 23 message is the one that carries the money warning. It states that “one-time and on-going costs for each of these systems are significantly higher than each county’s current ACT/JCT costs,” and that the association “continues to work on identify funding sources to assist with some of these initial one-time costs of licensing fees.” That is the association telling its members, in writing, five weeks before the vote, that whichever system won would cost more than what they were paying.

The third email is the one that connects all of this to Delta County. It was sent Wednesday, March 8, 2023 at 7:30 a.m. by Lauren Wickman to Ashleigh Young and Brandon Couvillion, subject “Prosecutor Case Tracking System.” She writes that she wanted “to bring this up before any sort of budget planning that might occur,” that the association is looking at shifting to a newer system, that it is “going to likely cost some additional funds than what is currently budgeted for the PAAC dues,” and that she has included Brandon “as it obviously includes some IT involvement.” She then reproduces the full three-vendor comparison, notes that “we had a Zoom call with all the Prosecutor’s offices to discuss,” and writes that “it definitely appears the Karpel option is the most popular choice, and many offices already run the system.” She closes by saying a vote is coming, that after the vote she can provide a cost estimate, and that the change “might not start immediately” but she did not want to sit on the information.

This is a prosecutor doing the right thing with information she had. She told the county’s administrator and its IT contact, before the vote, that a cost was coming and roughly what the options were. The email is not evidence of concealment. It is evidence of the opposite, and it is the strongest single document in the packet for anyone who wants to understand how the decision reached Escanaba.

It is also the document that makes the certificate awkward. The office told the requester it holds no procurement records, and then produced an email in which its elected prosecutor forwards the vendors’ price sheets to county officials and predicts the winner two days before the ballot closed. Both statements can be true at once — the county held no RFP, and the prosecutor held a forwarded email — but the combination means the public’s picture of this purchase depends entirely on what an association in Lansing chooses to keep.

What the three vendors would have cost, and why the numbers do not line up

The vendor comparison inside the emails is the most substantive financial document in the packet, and it is also the hardest to read as a like-for-like comparison. Each vendor priced a different scope, on a different basis, with different unknowns. The table below reproduces the figures as they appear, without adjustment.

Figure 3 · Interactive

Three vendors, one vote

Select a vendor to read what its own proposal said. Filter by whether it won the March 2023 county vote.

Select a vendor

Source: the three-vendor budget comparison reproduced in the association’s February 23, 2023 email and in Wickman’s March 8, 2023 email, plus the March 10, 2023 vote result. Figures are quoted as the vendors supplied them and are not adjusted for scope differences.

Figure 3. Three vendors, three different pricing structures. Karpel’s number is a multi-county total; Equivant’s is a statewide-style deployment at 1,000 users; LawBase’s is case management only at a 500-user minimum. Only the per-user figures can be compared at all.

Table 2. The three vendors’ cost figures as reproduced in the association’s emails, March 2023.
Vendor	Up-front / licensing	Ongoing	Basis stated	Unknowns listed
Jworks / Equivant	$975,000 licensing; $2,713,095 implementation over four years ($678,476/yr)	≈ $429,000/yr, or $429 per user	1,000 users	Migration from ACT/JCT, API connections, training
LawBase / OnBase	$500,000 implementation fee	$175 per user per month = $2,100 per user per year; $1,050,000/yr at 500 users	At least 500 users; case management only	Migration from ACT/JCT, API connections, training
Karpel	Years 1–3 rise as counties are added; total $8,470,374 across 67 rollouts and 1,000 users	Years 4–5 fall to $1,124,725/yr; $1,124 per user per year at 1,000 users	67 county rollouts, 1,000 users	Migration from ACT/JCT, API connections, training

The Karpel figure is a multi-county total, not Delta County’s share. That is the single most important caveat in the table: $8,470,374 across 67 rollouts is the association’s aggregate cost, and nothing in the packet divides it by county or by user for Delta County specifically. The per-user figure of $1,124 is the only number in the comparison that can be applied to a single county’s headcount, and even that is an average across a rollout schedule that rises and then falls.

The Equivant and LawBase figures are also not directly comparable to Karpel’s. Equivant’s $975,000 licensing plus $2,713,095 implementation is a statewide-style deployment priced at 1,000 users. LawBase’s $500,000 implementation plus $175 per user per month is priced at a minimum of 500 users and covers “case management only,” which means the figure excludes whatever else the other two bundles included. Reading across the row is not reading like for like.

What the table does establish is scale. Every option was going to cost more than the ACT/JCT dues line the counties were then paying, which is exactly what the association’s February 23 email warned. A prosecutor’s office in a county of roughly thirty-six thousand people was being asked to absorb a per-user annual fee in the four figures, on a system selected by a vote of its peers. That is a real budget event, and it happened with no RFP in the county’s own file.

The vote: 52 of 66

Michigan has eighty-three counties. Sixty-six votes were cast. The record does not explain the gap, and this page will not guess at it. Some counties may have been unrepresented on the call; some may have abstained; some may have already been on Karpel and therefore outside the change. The October 2022 email says counties already using or about to use Karpel would not be affected, which suggests at least a partial explanation, but the packet contains no attendance list and no abstention count.

What the packet does establish is the arithmetic of the result. Fifty-two of sixty-six is 78.78 percent, which is the figure Collins reported. One vote per county, cast by SurveyMonkey link, closing at noon on March 10, 2023. The winner was announced the same afternoon.

That is a small electorate making a large decision. Sixty-six votes determined a system that would be deployed across dozens of counties at a cost in the millions, and the only public trace of the deliberation in Delta County’s file is a forwarded email from its prosecutor two days before the ballot closed. There is nothing improper in that. There is something thin about it, and the thinness is the point: a decision this large left this little paper.

The fee that was never stated

MCL 15.234 governs fees. It permits a public body to charge for the cost of searching for, locating and examining records, for review and separation of exempt from nonexempt information, and for copying. It permits a deposit of up to half the projected cost when the estimate exceeds fifty dollars. It requires that a public body not charge more than the actual cost. And in subsection (4) it permits a public body to charge for the cost of reviewing records when failing to do so would result in “unreasonably high costs” beyond those typically incurred.

The office invoked that last provision. It said the breadth of the request and the volume of records meant that not charging would produce unreasonably high costs to the county. That is a recognized basis. The problem is not the basis. The problem is that the statute’s scheme depends on a number, and no number was given.

An itemization is not a formality. It is what makes the other protections work. The deposit provision only functions if there is an estimate to take half of. The requester’s ability to narrow a request under MCL 15.235(2)(c) only functions if the requester knows which part is expensive. The appeal right under MCL 15.240(1)(a) over a fee only functions if there is a fee to appeal. A letter that asserts a charge, describes it as itemized elsewhere, and encloses no itemization leaves the requester with no move to make.

There is a charitable reading, and it should be stated plainly. The office may have prepared an itemization and simply failed to attach it, either through clerical error or because the packet was assembled from a template. The letter’s language — “specifically outlined in the attached FOIA Fee Itemization” — reads like a sentence written for a document that existed. If that is what happened, the fix is a one-page attachment and a re-issued response, and the record would look very different.

But this page can only describe the record as it exists. As it exists, the office estimated five hundred conversations, said the cost of processing them was itemized, produced thirteen pages for free, and never stated a dollar figure. Whether that is a clerical omission or a way of closing a request without denying it, the effect on the requester is the same: the records were granted and not received.

The denial form describes a different decision

Page nine of the packet is a “Notice of Denial of FOIA Request” form. It records request number 25-202, date received 08/19/2025, date of notice 09/08/2025, and it has a set of checkboxes for the reason for denial. The form is a state-issued template with numbered reasons: the record is exempt, the record does not exist, the record is in the possession of another public body, and so on.

On this form, box 3 — Redaction — is the box that is checked, and the citation written beside it is FOIA Section 13, subsections (1)(a) and (1)(iii): information of a personal nature where disclosure would constitute a clearly unwarranted invasion of privacy, and the personal address or telephone number of an active or retired law enforcement officer. The contact listed for questions is Emily DeSalvo at 906-789-5100.

Box 2 — the record does not exist — is not checked, even though the letter’s central holding on the RFP, bid and purchase-order portion is precisely that those records do not exist. The certificate of nonexistence is printed in the letter, and the form that is supposed to record the reason for denial records a different reason.

This is a documentation error, and it is a meaningful one. A person reading only the form would conclude that the office denied the request by redacting exempt material — a partial withholding of records that exist. A person reading only the letter would conclude that the office certified three categories of records out of existence and granted a fourth. Those are different decisions, and the file contains both descriptions of the same response.

The redaction citations themselves are not obviously wrong. The letter says the communications were granted subject to redaction, and personal-nature and law-enforcement-contact exemptions are the ordinary grounds for redacting names and phone numbers from email. The responsive set as produced contains no visible redactions at all, which is consistent with the office having removed personal information before assembling the thirteen pages. The problem is not the redaction basis. The problem is that a form describing a redaction-only denial was used to close a response that also contained a certificate of nonexistence, and the nonexistence box was left blank.

Opinion: the certificate and the email

Here is the thing about this response that will not leave me alone. The office certified, under signature, that the records do not exist. And then, in the same envelope, it handed over an email from its own prosecutor, dated March 8, 2023, in which she forwards three vendors’ price sheets to the county administrator and writes that “it definitely appears the Karpel option is the most popular choice.” The certificate and the email are not contradictory in the narrow legal sense. They are contradictory in the sense that matters to a citizen trying to understand how his government spends money.

I want to be careful here, because it would be easy and wrong to turn this into an accusation. There is a completely ordinary explanation. Michigan’s prosecutors do not each buy their own case management software. They buy it together, through the Prosecuting Attorneys Association of Michigan, which negotiates, demonstrates, ballots and administers. When an association runs a procurement, the county does not end up with an RFP in its file. It ends up with a membership, a vote, and a bill. The office’s letter says exactly that, in plain language, and it is telling the truth.

So the certificate is honest. And that is precisely why it is worth publishing. Because if the county genuinely holds no procurement file, then the procurement file lives somewhere else — at an association that is not subject to the county’s records practices, funded by the counties, and answerable to a board of its members rather than to the voters of Delta County. The public’s ability to see how a multi-million-dollar system was chosen depends on a body the public has never heard of. That is not a scandal. It is a structural fact about how Michigan prosecutes crime, and almost nobody knows it.

The second thing that will not leave me alone is the fee. Five hundred conversations. Thirteen pages produced. A fee described as itemized and never stated. I have read a lot of FOIA responses from this office, and most of them are legible: they grant, they deny, they cite a statute, they tell you what it costs. This one does something subtler. It grants the request in a paragraph that makes the grant unusable, and it does so while appearing cooperative — it even volunteers thirteen pages “for the sake of transparency.” The volunteering is real. So is the wall.

I do not think the wall was built to hide the Karpel decision. The Karpel decision is in the thirteen pages, in more detail than most counties would ever release. I think the wall was built by habit: a form designed for redaction denials, a fee paragraph designed for large requests, a packet assembled from a template, and nobody checking whether the pieces described the same answer. That is a less dramatic explanation than concealment and a more troubling one, because it means the office’s records process can produce an incoherent response to a straightforward request without anyone noticing.

The remedy is not an apology. It is a one-page itemization and a corrected form. If the office sends both, this page will say so and the record will be better for it. Until then, the record shows a county that cannot produce the paperwork for its own software, an association that can, and a fee that exists only as an adjective.

The legal framework, in plain terms

The statutes below are the ones the response itself relies on, plus the ones that govern the parts of the response that are missing. They are set out here so a reader can check the analysis against the text rather than against this page’s summary of it.