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HRDC v. Centurion Correctional Healthcare, et al., NM, Complaint, Public Records, 2021

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FIRST JUDICIAL DISTRICT COURT
STATE OF NEW MEXICO
COUNTY OF SANTA FE
Human Rights Defense Center,
Plaintiff,
v.

No. __________________

Centurion Correctional Healthcare
of New Mexico, LLC,
The New Mexico Corrections Department,
Kevin L. Nault, in his official capacity
as records custodian for the New Mexico
Corrections Department, and DOES 1
through 3, in their official capacities,
Defendants.
COMPLAINT FOR PRODUCTION OF PUBLIC RECORDS,
FOR MANDAMUS, DAMAGES, AND
DECLARATORY AND INJUNCTIVE RELIEF
1.

The Human Rights Defense Center (“HRDC”) brings these causes of

action to enforce the New Mexico Inspection of Public Records Act, NMSA 1978, §§
14-2-1 to 14-2-12 (“IPRA”).
I.
2.

INTRODUCTION

Our democratic system of government requires public transparency.

Republican Party v. N.M. Tax’n & Revenue Dep’t, 2012-NMSC-026, ¶ 1, 283 P.3d 853.
3.

HRDC, a non-profit journalism and advocacy organization, brings this

action under IPRA to compel production of records maintained or controlled by
Defendants and for injunctive relief and damages arising from the willful failure and
refusal to produce public records as required by law.

4.

The records sought relate to a private company performing public

functions through contract with New Mexico Corrections Department (“NMCD”) and
other government entities in New Mexico. HRDC sought these records both from the
private contractor and, for the subset that relates to work performed under contract
for NMCD, from NMCD.
II.
5.

PARTIES, JURISDICTION, AND VENUE

HRDC is a non-profit organization, incorporated in the State of

Washington and with headquarters in Lake Worth Beach, Florida. It is a “person” as
defined by IPRA.
6.

Defendant Centurion Correctional Healthcare of New Mexico, LLC

(“Centurion”), is a domestic limited liability company incorporated in the State of
New Mexico. Centurion contracted with government entities in New Mexico to
provide healthcare services to inmates of prisons and jails. Centurion contracted with
NMCD to provide medical, mental health, pharmaceutical, and related services to
incarcerated persons. Centurion also provided similar services through contracts
with county governments, including, for example, a contract with Bernalillo County
to provide medical and mental health services to detainees of the Metropolitan
Detention Center in Albuquerque.
7.

Defendant NMCD is a department of the State of New Mexico and a

“public body” as defined by IPRA. NMCD is charged with the operation of prison
facilities in the State.
8.

NMCD has contracted with Centurion to provide healthcare services to

prisoners at NMCD facilities, including Central New Mexico Correctional Facility,
-2-

Northeast New Mexico Correctional Facility, Northwest New Mexico Correctional
Center (formerly New Mexico Women’s Correctional Facility), Penitentiary of New
Mexico, Roswell Correctional Facility, Southern New Mexico Correctional Facility,
Springer Correctional Facility, Western New Mexico Correctional Facility.
9.

Through inter-governmental agreements, NMCD also houses prisoners

at three privately operated county corrections facilities: Guadalupe County
Correctional Facility, Lea County Correctional Facility, and Otero County Prison
Facility. Those county corrections facilities have separately contracted with thirdparty, private entities to provide healthcare services to inmates. Upon information
and belief, Centurion has provided healthcare services to NMCD inmates housed at
these three facilities.
10.

Further, some of the county governments with whom Centurion

contracted have entered into inter-governmental agreements with NMCD to house
NMCD prisoners.
11.

Defendant Kevin L. Nault was assigned as Public Records Custodian for

the NMCD. Nault is Deputy General Counsel in the NMCD Office of General Counsel
and is sued in his official capacity.
12.

Upon information and belief, Defendant DOES 1 through 3 were

employed by Centurion or NMCD and acted as records custodians, were responsible
for maintaining public records, and/or participated in the decision or were responsible
for denying the inspection of records responsive to Plaintiff’s records requests.
13.

The Court has jurisdiction over this case pursuant to NMSA 1978, § 14-

2-12 and NMSA 1978, §§ 44-2-1 to 44-2-14.
-3-

14.

Venue lies in the District Court for Santa Fe County pursuant to NMSA

1978, § 38-3-1(G).
15.

There is an actual controversy between the parties about Defendants’

duties under IPRA. As a result, an action for declaratory relief is authorized under
NMSA 1978, §§ 44-6-2 and 44-6-4.
III.
16.

FACTUAL ALLEGATIONS

IPRA creates a foundation for open, functioning democracy. It is the
public policy of this state, that all persons are entitled to the
greatest possible information regarding the affairs of government
and the official acts of public officers and employees. It is further
the intent of the legislature, and it is declared to be the public
policy of this state, that to provide persons with such information
is an essential function of a representative government and an
integral part of the routine duties of public officers and
employees.

NMSA 1978, § 14-2-5.
17.

IPRA broadly defines the records which the public may access: “all

documents . . . that are used, created, received, maintained or held by or on behalf of
any public body and relate to public business, whether or not the records are required
by law to be created or maintained.” NMSA 1978, § 14-2-6(G).
18.

IPRA also broadly defines the organizations to which it applies to

include “all advisory boards, commissions, agencies or entities created by the
constitution or any branch of government that receives any public funding, including
political subdivisions, special taxing districts, school districts and institutions of
higher education.” NMSA 1978, § 14-2-6(F).

-4-

19.

Settlement agreements resulting from civil claims against a third-party

private entity for conduct arising under a contract with a public entity to provide a
public function, such as providing medical care to incarcerated persons, are subject
to disclosure under IPRA.
20.

On August 12, 2020, HRDC sent Centurion a records request “seeking

all records of litigation against Centurion and/or its employees or agents where
Centurion and/or its insurers paid $1,000 or more to resolve claims against it” “from
January 1, 2010 to the present.” The request stated that it was “directed where
Centurion or any of its subsidiaries or affiliates provides inmate healthcare under a
contract within the boundaries of New Mexico.” That letter is attached as Exhibit 1.
21.

The records sought in this request are public records.

22.

HRDC mailed its records request to the same address that Centurion

provided in its contract with NMCD as the location to receive notice required by the
contract: 1593 Spring Hill Road, Suite 600, Vienna, VA 22182.
23.

The letter was sent by certified mail, a receipt for which is attached as

Exhibit 2. USPS delivered the letter on August 15, 2020, at 12:39 PM. See Exhibit 2.
24.

To date, Centurion has not responded to the August 12, 2020 records

request.
25.

On August 12, 2020, HRDC sent a request to NMCD for verdicts,

settlements, and other records of litigation against Centurion and/or its employees or
agents where Centurion and/or its insurers paid $1,000 or more to resolve claims
against it related to inmate healthcare services by Centurion or its subsidiaries
within the boundaries of New Mexico. The records requested from the NMCD were a
-5-

subset of those requested from Centurion. The August 12, 2020 request to NMCD is
attached as Exhibit 3.
26.

On August 19, 2020, NMCD Deputy General Counsel Kevin L. Nault

emailed a response to HRDC stating that NMCD “has no records responsive” to
HRDC’s August 12, 2020 request. The email stated that NMCD forwarded the
request to Centurion, who “declined to provide any records to NMCD in response.”
The email indicated that HRDC’s request was considered closed. The August 19, 2020
NMCD email is attached as Exhibit 4 and copied below:

27.

To date, Defendants have produced no records responsive to either IPRA

requests.

-6-

COUNT ONE:
VIOLATIONS OF THE INSPECTION OF PUBLIC RECORDS ACT
(Against All Defendants)
28.

Plaintiff incorporates by reference the above allegations.

29.

Defendants have violated IPRA as they have failed to produce public

records requested by Plaintiff on August 12, 2020.
30.

Plaintiff properly directed its IPRA records request to NMCD’s public

records custodian and to the address that Centurion designated for service in its
contract with NMCD.
31.

NMCD failed to provide records responsive to HRDC’s August 12, 2020

request, which was properly directed at NMCD’s records custodian.
32.

NMCD acknowledged the request, did not claim that the records sought

were not public records nor that the records were exempt from IPRA. Rather, NMCD
claimed that another entity possessed the records and that such entity declined to
provide them to NMCD. NMCD produced no responsive records.
33.

By providing healthcare and related services to people incarcerated in

NMCD prisons and county jails, Centurion performed public functions and thus
records related to those services are “public records” as defined by IPRA.
34.

Centurion

has

not

provided

any

responsive

documents

nor

acknowledged Plaintiff’s request in any way.
35.

If Defendants are relying on any exemptions as a basis for withholding

records, then they have failed, when withholding documents responsive to the records
requests, to issue a proper denial of the records requests.
-7-

36.

Plaintiff has a right to recover damages, at up to $100 per day per

violation of each record Defendants failed to produce under Section 14-2-11(C) of the
IPRA.
37.

Plaintiff has a right to recover its costs and attorney’s fees in pursuing

this action under Section 14-2-12(D) of IPRA.

COUNT TWO:
DECLARATORY RELIEF
(Against All Defendants)
38.

Plaintiff incorporates by reference the above allegations.

39.

There is an actual controversy between Plaintiff and Defendants

whether Defendants’ conduct, as alleged above, violates IPRA.
40.

The law is clear that Centurion was performing a public function in

providing inmate healthcare in New Mexico on behalf of NMCD and other
government entities, and records created in that capacity are public records. Thus,
Centurion had a clear legal duty to provide public records to Plaintiff.
41.

The law is also clear that Kevin L. Nault, as NMCD records custodian,

is responsible for NMCD’s public records, even if the records are not in his actual
physical custody and control.
42.

Despite Defendants’ legal duties to permit Plaintiff to inspect public

records, no Defendant has complied with IPRA, produced any records, or properly
denied such records.

-8-

43.

Plaintiff is entitled to declaratory relief that Defendants have violated

IPRA, and that Defendants must provide the requested records to Plaintiff.

COUNT THREE:
INJUNCTIVE RELIEF AND MANDAMUS
(Against All Defendants)
44.

Plaintiff incorporates by reference the above allegations.

45.

Under NMSA 1978, § 14-2-12(B), Plaintiff is entitled to a writ of

mandamus or injunction ordering Defendants comply with their mandatory, nondiscretionary duties to produce all relevant public records responsive to Plaintiff’s
requests.
WHEREFORE, Plaintiff prays that the Court
1. declare that Defendants have violated IPRA in failing to respond to
Plaintiff’s records requests;
2. issue a writ of mandamus or injunction ordering Defendants to produce the
records and information requested without further delay, and to produce
all similar such records in the future; and,
3. enter an order for such other and further relief as the Court deems just and
proper, including, but not limited to, damages, costs, and reasonable
attorney’s fees.

-9-

Respectfully submitted,
/s/ Caroline "KC" Manierre
________________________________
Mark H. Donatelli
Caroline “KC” Manierre
Rothstein Donatelli LLP
P.O. Box 8180
Santa Fe, NM 87504
Tel: (505) 988-8004
mhd@rothsteinlaw.com
cmanierre@rothsteinlaw.com
-andJesse W. Isom
Pro Hac Vice application forthcoming
Human Rights Defense Center
P.O. Box 1151
Lake Worth, FL 33460
Tel: (561) 360-2523
jwisom@humanrightsdefensecenter.org
Attorneys for Plaintiff

- 10 -

Human Rights Defense Center
DEDICATED TO PROTECTING HUMAN RIGHTS

August 12, 2020
Centurion Managed Care
Attn: Public Records Officer
1593 Spring Hill Road, Suite 600
Vienna, VA 22182
Sent via certified mail: 7020 1290 0000 2794 3121
Re:

Request for Settlement and Verdict Records

To the Public Records Officer:
The Human Rights Defense Center (“HRDC”) makes this request pursuant to the New Mexico Inspection
of Public Records Act, N.M. Stat. Ann. § 14-2-1, et seq. HRDC is a non-profit dedicated to advocacy and
education around criminal justice issues. Among other activities, HRDC publishes the journals Prison
Legal News and Criminal Legal News.
This request is directed where Centurion or any of its subsidiaries or affiliates provides inmate healthcare
under a contract within the boundaries of New Mexico, in accordance with the recent changes to New
Mexico’s public records law which affirm that private entities performing a public function for a public
agency are subject to the Inspection of Public Records Act.
HRDC is seeking all records of litigation against Centurion and/or its employees or agents where
Centurion and/or its insurers paid $1,000 or more to resolve claims against it. These payments include
but are not limited to settlements, damages, attorney fee awards, and sanctions, irrespective of the identity
of the plaintiff or claimant. Specifically, HRDC requests the following records, provided in electronic
native format where possible, and otherwise in electronic format:
1. Records, regardless of physical form or characteristics, sufficient to show for all claims or lawsuits
brought against Centurion and/or any of its agents or employees in which payments totaling $1,000
or more were disbursed from January 1, 2010 to the present:
•

The name of all parties involved;

•

The case or claim number;

•

The jurisdiction in which the case or claim was brought (e.g., US District Court for the
District of New Mexico, New Mexico Supreme Court, etc.);

•

The date of resolution;

•

The amount of money involved, if any, in the resolution and to whom it was paid,

509 Olive Way, Suite #855, Seattle, WA 98101
206-257-1355 | foia@humanrightsdefensecenter.org

EXHIBIT 1

2. For each case or claim detailed above:
•

The complaint or claim form and any amended versions;

•

The verdict form, final judgment, settlement agreement, consent decree, or other paper that
resolved the case.

I request that the above-described public records be provided to me in electronic format if they exist in
electronic format, pursuant to NMSA § 14-2-9(B). In the event that such documents are only available in
hard copy format, I request an opportunity to inspect and copy the specific public records I select from the
records identified above.
If this request encompasses information or records that Centurion claims are exempt from disclosure
pursuant to any applicable statute or law, then please redact such information, as required by NMSA
1978, §14-2-1(B), from the document or record rather than withhold the entire document from disclosure.
If you apply any redactions, please describe the redacted information and provide a basis for your claim
that the redacted information is not subject to disclosure.
If you claim that any of the requested records are not a public record, or if you claim a privilege not to
disclose any record, please describe the record(s) being withheld and state the basis for your claim of
privilege or confidentiality. Please produce all public records for which you do not claim an exemption or
privilege, as the above requests are segregable.
HRDC is a non-profit organization. These records are not for any profit-related or commercial purpose.
Should there be any fees incurred related to the production of the public records I am requesting, I request
a waiver of such fees.
Please respond to this records request within fifteen (15) days of receipt of same. Note that failure to
respond to this records request within fifteen (15) days will be considered a denial of my public records
request, and I will duly take appropriate action. If you need additional time in which to produce the
requested records, please advise in writing so I may consider your request for an extension of time.
Please contact me if this request does not describe all of the above-requested documents with sufficient
specificity for you to make a reasonable response, and I will attempt to reformulate the request in a
manner that meets your requirements. If you are not the custodian of the records I am requesting, please
promptly forward this request to the custodian of the requested records and notify me accordingly. Please
contact me via email, foia@humanrightsdefensecenter.org, should you require any additional information.
Thank you for your time and attention in this matter.
HUMAN RIGHTS DEFENSE CENTER

Kathrine Browne
Public Records Manager

509 Olive Way, Suite #855, Seattle, WA 98101
206-257-1355 | foia@humanrightsdefensecenter.org

EXHIBIT 2

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8/12/2020

Mail - Kathrine Browne - Outlook

Public records request from the Human Rights Defense Center

EXHIBIT 3

FOIA General Mailbox <FOIA@humanrightsdefensecenter.org>
Wed 8/12/2020 10:04 AM
To: NMCD-IPRA@state.nm.us <NMCD-IPRA@state.nm.us>
Cc: Dan Marshall <dmarshall@humanrightsdefensecenter.org>; Paul Wright <pwright@prisonlegalnews.org>; Eric Taylor
<etaylor@humanrightsdefensecenter.org>
1 attachments (40 KB)
Centurion - HRDC NM - 8-12-20-Sent to NMCD.pdf;

A ached, please find a public records request from the Human Rights Defense Center; the text of this request is
duplicated in the body of this message.

To Deputy General Counsel, Kevin Nault:
The Human Rights Defense Center (“HRDC”) makes this request pursuant to the New Mexico Inspec on
of Public Records Act, N.M. Stat. Ann. § 14-2-1, et seq. HRDC is a non-profit dedicated to advocacy and
educa on around criminal jus ce issues. Among other ac vi es, HRDC publishes the journals Prison
Legal News and Criminal Legal News.
This request is directed where the New Mexico Correc ons Department contracts Centurion or any of its
subsidiaries or affiliates to provide inmate healthcare under a contract within the boundaries of New
Mexico, in accordance with the recent changes to New Mexico’s public records law which affirm that
private en es performing a public func on for a public agency are subject to the Inspec on of Public
Records Act.
HRDC is seeking all records of li ga on against Centurion and/or its employees or agents where
Centurion and/or its insurers paid $1,000 or more to resolve claims against it. These payments include
but are not limited to se lements, damages, a orney fee awards, and sanc ons, irrespec ve of the
iden ty of the plain ff or claimant. Specifically, HRDC requests the following records, provided in
electronic na ve format where possible, and otherwise in electronic format:
1. Records, regardless of physical form or characteris cs, sufficient to show for all claims or lawsuits
brought against Centurion and/or any of its agents or employees in which payments totaling $1,000 or
more were disbursed from January 1, 2010 to the present:
The name of all par es involved;
The case or claim number;
The jurisdic on in which the case or claim was brought (e.g., US District Court for the District of
New Mexico, New Mexico Supreme Court, etc.);
The date of resolu on;
The amount of money involved, if any, in the resolu on and to whom it was paid,
2. For each case or claim detailed above:
The complaint or claim form and any amended versions;
The verdict form, final judgment, se lement agreement, consent decree, or other paper that
resolved the case.
https://outlook.office365.com/mail/sentitems/id/AAQkADA0MGU0MmE1LTIwYTItNDFiMy1iOGQwLTI0Y2ZiNDI5ZWRkZgAQACyrpGfCJKBHo57QGIQ…

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8/12/2020

Mail - Kathrine Browne - Outlook

I request that the above-described public records be provided to me in electronic format if they exist in
electronic format, pursuant to NMSA § 14-2-9(B). In the event that such documents are only available in
hard copy format, I request an opportunity to inspect and copy the specific public records I select from
the records iden fied above.
If this request encompasses informa on or records that Centurion or the New Mexico Correc ons
Department claim are exempt from disclosure pursuant to any applicable statute or law, then please
redact such informa on, as required by NMSA 1978, §14-2-1(B), from the document or record rather
than withhold the en re document from disclosure. If you apply any redac ons, please describe the
redacted informa on and provide a basis for your claim that the redacted informa on is not subject to
disclosure.
If you claim that any of the requested records are not a public record, or if you claim a privilege not to
disclose any record, please describe the record(s) being withheld and state the basis for your claim of
privilege or confiden ality. Please produce all public records for which you do not claim an exemp on or
privilege, as the above requests are segregable.
HRDC is a non-profit organiza on. These records are not for any profit-related or commercial purpose.
Should there be any fees incurred related to the produc on of the public records I am reques ng, I
request a waiver of such fees.
Please respond to this records request within fi een (15) days of receipt of same. Note that failure to
respond to this records request within fi een (15) days will be considered a denial of my public records
request, and I will duly take appropriate ac on. If you need addi onal me in which to produce the
requested records, please advise in wri ng so I may consider your request for an extension of me.
Please contact me if this request does not describe all of the above-requested documents with sufficient
specificity for you to make a reasonable response, and I will a empt to reformulate the request in a
manner that meets your requirements. If you are not the custodian of the records I am reques ng,
please promptly forward this request to the custodian of the requested records and no fy me
accordingly. Please contact me via email, foia@humanrightsdefensecenter.org, should you require any
addi onal informa on.
Thank you for your me and a en on in this ma er.

Kathrine Browne
Public Records Manager
Development Coordinator
Human Rights Defense Center
Prison Legal News
509 Olive Way, Suite 855
Sea le, WA 98101
206-257-1355

https://outlook.office365.com/mail/sentitems/id/AAQkADA0MGU0MmE1LTIwYTItNDFiMy1iOGQwLTI0Y2ZiNDI5ZWRkZgAQACyrpGfCJKBHo57QGIQ…

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8/20/2020

Mail - Kathrine Browne - Outlook

RE: Public records request from the Human Rights Defense Center
Nault, Kevin, NMCD <Kevin.Nault@state.nm.us>
Thu 8/20/2020 9:35 AM
To: FOIA General Mailbox <FOIA@humanrightsdefensecenter.org>
Cc: Dan Marshall <dmarshall@humanrightsdefensecenter.org>; Paul Wright <pwright@prisonlegalnews.org>; Eric Taylor
<etaylor@humanrightsdefensecenter.org>; NMCD-IPRA <NMCD-IPRA@state.nm.us>

Ms. Browne:
The New Mexico Corrections Department has no records responsive to your request. Your
request was forwarded to Centurion, but they declined to provide any records to NMCD in
response.
The Department has responded to your request as we understand it, and it is now considered
closed. Any denial herein is the responsibility of records custodian Kevin L. Nault.
Kevin L. Nault
Deputy General Counsel
New Mexico Corrections Department
P.O. Box 27116
Santa Fe, NM 87502
4337 NM 14, Santa Fe
(505) 827-8690
From: FOIA General Mailbox <FOIA@humanrightsdefensecenter.org>
Sent: Wednesday, August 12, 2020 11:05 AM
To: NMCD-IPRA <NMCD-IPRA@state.nm.us>
Cc: Dan Marshall <dmarshall@humanrightsdefensecenter.org>; Paul Wright <pwright@prisonlegalnews.org>; Eric
Taylor <etaylor@humanrightsdefensecenter.org>
Subject: [EXT] Public records request from the Human Rights Defense Center
A ached, please find a public records request from the Human Rights Defense Center; the text of this request is
duplicated in the body of this message.

To Deputy General Counsel, Kevin Nault:
The Human Rights Defense Center (“HRDC”) makes this request pursuant to the New Mexico Inspec on
of Public Records Act, N.M. Stat. Ann. § 14-2-1, et seq. HRDC is a non-profit dedicated to advocacy and
educa on around criminal jus ce issues. Among other ac vi es, HRDC publishes the journals Prison
Legal News and Criminal Legal News.
This request is directed where the New Mexico Correc ons Department contracts Centurion or any of its
subsidiaries or affiliates to provide inmate healthcare under a contract within the boundaries of New
Mexico, in accordance with the recent changes to New Mexico’s public records law which affirm that
private en es performing a public func on for a public agency are subject to the Inspec on of Public
Records Act.

EXHIBIT 4
https://outlook.office365.com/mail/none/id/AAQkADA0MGU0MmE1LTIwYTItNDFiMy1iOGQwLTI0Y2ZiNDI5ZWRkZgAQACyrpGfCJKBHo57QGIQgWE…

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8/20/2020

Mail - Kathrine Browne - Outlook

HRDC is seeking all records of li ga on against Centurion and/or its employees or agents where
Centurion and/or its insurers paid $1,000 or more to resolve claims against it. These payments include
but are not limited to se lements, damages, a orney fee awards, and sanc ons, irrespec ve of the
iden ty of the plain ff or claimant. Specifically, HRDC requests the following records, provided in
electronic na ve format where possible, and otherwise in electronic format:
1. Records, regardless of physical form or characteris cs, sufficient to show for all claims or lawsuits
brought against Centurion and/or any of its agents or employees in which payments totaling $1,000 or
more were disbursed from January 1, 2010 to the present:
The name of all par es involved;
The case or claim number;
The jurisdic on in which the case or claim was brought (e.g., US District Court for the District of
New Mexico, New Mexico Supreme Court, etc.);
The date of resolu on;
The amount of money involved, if any, in the resolu on and to whom it was paid,
2. For each case or claim detailed above:
The complaint or claim form and any amended versions;
The verdict form, final judgment, se lement agreement, consent decree, or other paper that
resolved the case.
I request that the above-described public records be provided to me in electronic format if they exist in
electronic format, pursuant to NMSA § 14-2-9(B). In the event that such documents are only available in
hard copy format, I request an opportunity to inspect and copy the specific public records I select from
the records iden fied above.
If this request encompasses informa on or records that Centurion or the New Mexico Correc ons
Department claim are exempt from disclosure pursuant to any applicable statute or law, then please
redact such informa on, as required by NMSA 1978, §14-2-1(B), from the document or record rather
than withhold the en re document from disclosure. If you apply any redac ons, please describe the
redacted informa on and provide a basis for your claim that the redacted informa on is not subject to
disclosure.
If you claim that any of the requested records are not a public record, or if you claim a privilege not to
disclose any record, please describe the record(s) being withheld and state the basis for your claim of
privilege or confiden ality. Please produce all public records for which you do not claim an exemp on or
privilege, as the above requests are segregable.
HRDC is a non-profit organiza on. These records are not for any profit-related or commercial purpose.
Should there be any fees incurred related to the produc on of the public records I am reques ng, I
request a waiver of such fees.
Please respond to this records request within fi een (15) days of receipt of same. Note that failure to
respond to this records request within fi een (15) days will be considered a denial of my public records
request, and I will duly take appropriate ac on. If you need addi onal me in which to produce the
requested records, please advise in wri ng so I may consider your request for an extension of me.
Please contact me if this request does not describe all of the above-requested documents with sufficient
specificity for you to make a reasonable response, and I will a empt to reformulate the request in a
manner that meets your requirements. If you are not the custodian of the records I am reques ng,
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Mail - Kathrine Browne - Outlook

please promptly forward this request to the custodian of the requested records and no fy me
accordingly. Please contact me via email, foia@humanrightsdefensecenter.org, should you require any
addi onal informa on.
Thank you for your me and a en on in this ma er.

Kathrine Browne
Public Records Manager
Development Coordinator
Human Rights Defense Center
Prison Legal News
509 Olive Way, Suite 855
Sea le, WA 98101
206-257-1355

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