Cost Estimate Regarding Responses to TTUS's Clarifications/Narrowings¶

Good Afternoon,


Texas Tech University System (TTUS) is in receipt of your responses to our clarifications/narrowings and your additional request received on October 20, 2025. The responses and request are attached herein.  Due to our receipt of your responses and request on the same calendar day, we are treating them as a single request for the purposes of calculating costs as permitted under the Texas Government Code.



We must also note that while our correspondences sought to clarify or narrow the scope of your requests, your subsequent responses have generally served to broaden them. As such, we have determined that complying with the request will result in the imposition of a charge that exceeds $40. Therefore, the following statement is provided pursuant to sections [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:



  1.  The requested information is not currently available in a form suitable for public release, and since the request involves manipulation of data, documents are not feasible to retrieve, will result in substantial interference with ongoing operations and can only be provided at a cost that covers the manipulation of data and other costs, you are entitled to an estimate of the costs and time to provide the information in the requested form.



Therefore, the itemized statement of estimated charges is:



Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25

Overhead @ 20% =                            $ 644.85

Estimated Total Cost =                     $3,869.10



  1.  Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is providing you with an alternative, less expensive method of obtaining some of the requested information.  An alternative method would be to narrow your request by eliminating some of the data requested, such as narrowing the date range or information requested. It may also be less expensive to view the documents here at the office.



  1.  Your request will be considered automatically withdrawn if you do not notify us in writing and within 10 (ten) business days from the date of this statement that you:



     *   Accept the estimated charges and will pay them.  Because your request is over $100.00, you are required to either deposit $1,934.55 (50% of the estimated costs) or provide TTUS with a bond for the total estimated cost. Please note that pursuant to §552.263(e), your request will be considered received when we receive your payment.  Additionally, if you fail to pay within 10 business days, your request will be considered withdrawn pursuant to §552.263(f).
     *   Are modifying the request (state the modification); or
     *   Have sent a complaint to the Office of the Attorney General of Texas alleging that you have been overcharged for a copy of public information.



  1.  You may choose to respond by email to me at bronte.staugaard@ttu.edu<mailto:bronte.staugaard@ttu.edu>, regular mail (1508 Knoxville Ave., Ste. 301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the Texas Tech University System Building, located at 1508 Knoxville Ave., Ste. 301, Lubbock, Tx 79409-2021.



  1.  Your check, money order, or bond must be made payable to: Texas Tech University System.



  1.  If we determine that a change in estimated charges will exceed the amount in this written itemized statement by 20%, we will send you an updated written itemized statement. As noted above, the same response requirements are imposed on you once an updated itemized statement is sent.



  1.  TTUS expects it to take approximately 2 weeks to complete this request at current workloads.


Finally, some of the documents or information that you have requested may be withheld under State law.  Therefore, if you choose to pay the deposit, we may request an Attorney General Open Records Decision (“ORD”) seeking to withhold some documents or information pursuant to the Texas Public Information Act.  Texas Government Code § 552.001, et seq.  Once the Attorney General makes a decision regarding the public disclosure of these documents, TTUS will make those documents that are determined by the Attorney General to be public, if any, available for inspection or copying.

Sincerely,
Brontë C. Staugaard
Assistant General Counsel
Texas Tech University System
(806) [REDACTED – PARTIAL-PHONE]

This communication, including any attachments, originates from an Attorney and may contain confidential information and is intended only for the individual or entity to whom it is addressed. Any review, dissemination, or copying of this communication by anyone other than the intended recipient is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail, delete and destroy all copies of the original message.

[cid:image001.png@01DC4CCF.659E0BB0]

Brontë,

This is my timely response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](d).

Itemization required. Please issue a corrected, fully itemized estimate
that breaks out and supports, by task and rate:

   1.

   Search/collection time (by custodian and data source),
   2.

   Compilation/duplication time,
   3.

   Redaction time (identify the specific mandatory confidentiality
   provisions), and
   4.

   Any programming/manipulation tasks (use programmer rate and describe the
   steps).
   Explicitly exclude attorney review and AG-brief preparation time. See §
   [REDACTED – PARTIAL-PHONE]; 1 TAC § 70.3(d)(3)–(4), (e). Also confirm overhead ≤ 20% of
   allowable labor and note the 20% update rule (issue a new written estimate
   if actual charges will exceed the prior estimate by ≥20%).

“Programming/manipulation” basis. Your email says the request “involves
manipulation of data.” Identify which tasks require programming (coding) or
manipulation (human reordering/decoding) as used in the Act, and quantify
those hours separately. Using built-in e-discovery/search tools is not
“programming.” Inspection of electronic records may not be charged unless
programming/manipulation is required (§ 552.272).

Aggregation. You say you aggregated my clarification responses and an
additional same-day request. List each request you aggregated and provide
separate line-item estimates per request. A clarification response is not
itself a new “request,” and aggregation should not inflate costs across
discrete requests. See § 552.261(e).

Phased production to cut costs (my election). Proceed in phases, starting
with OGC/PIO custodians (Staugaard, Wall) for Oct 3–31, 2025 using the
terms: “Kevin Bass,” “kbassphiladelphia,” “Preservation Notice,” “P3,”
“SPPCC,” “professionalism.” After Phase-1 lands, we’ll scope Phase-2
(Registrar/Student Life/IT). Re-estimate Phase-1 only.

Inspection to minimize charges. For Phase-1, I elect on-site or remote
inspection of electronic records in native format where feasible (§
552.272), unless you specifically identify required
programming/manipulation (with task detail). If programming is necessary,
itemize it and use the programmer rate.

Rolling production required. Promptly produce any responsive records not
subject to your AG request and any clearly public/segregable information
now, while your AG brief is pending. See § 552.221; ORD-664 (2000).

Deposit posture. Given the defects in TTUS’s Nov 3 estimate and the
magnitude of the proposed deposit, I will not remit any funds unless and
until TTUS provides a § [REDACTED – PARTIAL-PHONE]-compliant written itemized statement that
sets out task-level hours and rates (search/collection,
compilation/duplication, redaction—identifying any mandatory
confidentiality—and any programming/manipulation, if applicable) and
identifies less-costly alternatives. I am invoking my rights under §
552.269 and will seek Attorney General review of the estimate. For clarity,
the 10-business-day withdrawal provision in § [REDACTED – PARTIAL-PHONE](d) is triggered only
by a compliant itemized statement with the required notices; any attempt to
treat this request as withdrawn before such a statement issues is improper.
Likewise, any deposit request under § 552.263(a) must follow and be based
on a compliant § [REDACTED – PARTIAL-PHONE] itemized statement. I also elect inspection where
it reduces charges, consistent with § 552.272.

Please confirm receipt and provide a date/time for initial rolling
production of non-exempt material. Also send the revised, itemized Phase-1
estimate within 3 business days, so I can respond within the statute’s
window.
Kevin Bass PhD MS
Phone: *[REDACTED – PHONE]*


On Mon, Nov 3, 2025 at 4:51 PM Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
wrote:

> Good Afternoon,
>
>
>
> Texas Tech University System (TTUS) is in receipt of your responses to our
> clarifications/narrowings and your additional request received on October
> 20, 2025. The responses and request are attached herein.  Due to our
> receipt of your responses and request on the same calendar day, we are
> treating them as a single request for the purposes of calculating costs as
> permitted under the Texas Government Code.
>
>
>
> We must also note that while our correspondences sought to clarify or
> narrow the scope of your requests, your subsequent responses have generally
> served to broaden them. As such, we have determined that complying with the
> request will result in the imposition of a charge that exceeds
> $40. Therefore, the following statement is provided pursuant to sections
> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>
>
>
>    1. The requested information is not currently available in a form
>    suitable for public release, and since the request involves manipulation of
>    data, documents are not feasible to retrieve, will result in substantial
>    interference with ongoing operations and can only be provided at a cost
>    that covers the manipulation of data and other costs, you are entitled to
>    an estimate of the costs and time to provide the information in the
>    requested form.
>
>
>
> Therefore, the itemized statement of estimated charges is:
>
>
>
> Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25
>
> *Overhead @ 20% =                            $ 644.85             *
>
>
> *Estimated Total Cost =                     $3,869.10*
>
>
>
>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>    providing you with an alternative, less expensive method of obtaining some
>    of the requested information.  An alternative method would be to narrow
>    your request by eliminating some of the data requested, such as narrowing
>    the date range or information requested. It may also be less expensive to
>    view the documents here at the office.
>
>
>
>    3. *Your request will be considered automatically withdrawn if you do
>    not notify us in writing and within 10 (ten) business days from the date of
>    this statement that you:*
>
>
>
>    1. Accept the estimated charges and will pay them.  Because your
>       request is over $100.00, you are required to either deposit $1,934.55 (50%
>       of the estimated costs) or provide TTUS with a bond for the total estimated
>       cost. *Please note that pursuant to §552.263(e), your request will
>       be considered received when we receive your payment.  Additionally, if you
>       fail to pay within 10 business days, your request will be considered
>       withdrawn pursuant to §552.263(f).*
>       2. Are modifying the request (state the modification); or
>       3. Have sent a complaint to the Office of the Attorney General of
>       Texas alleging that you have been overcharged for a copy of public
>       information.
>
>
>
>    4. You may choose to respond by email to me at bronte.staugaard@ttu.edu,
>    regular mail (1508 Knoxville Ave., Ste. 301 Box 42021, Lubbock, Tx
>    79409-2021), or in person to Ste. 301 of the Texas Tech University System
>    Building, located at 1508 Knoxville Ave., Ste. 301, Lubbock, Tx
>    79409-2021.
>
>
>
>    5. Your check, money order, or bond must be made payable to: Texas
>    Tech University System.
>
>
>
>    6. If we determine that a change in estimated charges will exceed the
>    amount in this written itemized statement by 20%, we will send you an
>    updated written itemized statement. As noted above, the same response
>    requirements are imposed on you once an updated itemized statement is sent.
>
>
>
>    7. TTUS expects it to take approximately 2 weeks to complete this
>    request at current workloads.
>
>
>
> Finally, some of the documents or information that you have requested may
> be withheld under State law.  Therefore, if you choose to pay the deposit,
> we may request an Attorney General Open Records Decision (“ORD”) seeking to
> withhold some documents or information pursuant to the Texas Public
> Information Act.  Texas Government Code § 552.001, et seq.  Once the
> Attorney General makes a decision regarding the public disclosure of these
> documents, TTUS will make those documents that are determined by the
> Attorney General to be public, if any, available for inspection or copying.
>
>
>
> Sincerely,
>
> Brontë C. Staugaard
>
> Assistant General Counsel
>
> Texas Tech University System
>
> (806) [REDACTED – PARTIAL-PHONE]
>
>
>
> This communication, including any attachments, originates from an Attorney
> and may contain confidential information and is intended only for the
> individual or entity to whom it is addressed. Any review, dissemination, or
> copying of this communication by anyone other than the intended recipient
> is strictly prohibited. If you are not the intended recipient, please
> contact the sender by reply e-mail, delete and destroy all copies of the
> original message.
>
>
>
>
>

Hi Ms. Staugaard,

Today, November 13, 2025, at approximately 1:50 PM CT, I hand-delivered a
sealed envelope to the receptionist Grant Moos at 1508 Knoxville Ave., Ste.
301, Lubbock, TX 79409-2021 addressed to:

Texas Tech University System

Attn: Public Information Office / Brontë Staugaard

The envelope contains my 50% deposit check in the amount of $1,934.55,
payable to Texas Tech University System, together with my signed cover
letter titled:

“Texas Public Information Act — 50% Deposit (Tendered UNDER PROTEST) and
Phase-1 Sequencing (Requests/clarifications dated Oct 20, 2025; TTUS
estimate dated Nov 3, 2025).”

As stated in the cover letter, this payment is tendered UNDER PROTEST and
does not narrow or modify the scope of my requests; it only sets Phase-1
sequencing (final Title IX/Student-Conduct items, P3 professionalism finals
for AY 2022–23 and AY 2023–24, Transcript/Title-IV finals, existing
handling artifacts, and the relevant retention/hold policies under
§552.022(a)).

For your convenience, I have attached photos of the signed cover letter,
the deposit check, and the addressed envelope that I delivered.

Please confirm receipt and provide the deposit deadline you are using and
the date/time for the first Phase-1 release. I am filing a §552.269 cost
complaint regarding the estimate; this does not suspend your obligation to
promptly produce non-excepted records on a rolling basis.

Thank you,

Kevin Bass

[REDACTED – PHONE]

Kevin Bass PhD MS
Phone: *[REDACTED – PHONE]*


On Tue, Nov 4, 2025 at 8:00 Kevin Bass <kbassphiladelphia@gmail.com> wrote:

> Brontë,
>
> This is my timely response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](d).
>
> Itemization required. Please issue a corrected, fully itemized estimate
> that breaks out and supports, by task and rate:
>
>    1.
>
>    Search/collection time (by custodian and data source),
>    2.
>
>    Compilation/duplication time,
>    3.
>
>    Redaction time (identify the specific mandatory confidentiality
>    provisions), and
>    4.
>
>    Any programming/manipulation tasks (use programmer rate and describe
>    the steps).
>    Explicitly exclude attorney review and AG-brief preparation time. See
>    § [REDACTED – PARTIAL-PHONE]; 1 TAC § 70.3(d)(3)–(4), (e). Also confirm overhead ≤ 20% of
>    allowable labor and note the 20% update rule (issue a new written estimate
>    if actual charges will exceed the prior estimate by ≥20%).
>
> “Programming/manipulation” basis. Your email says the request “involves
> manipulation of data.” Identify which tasks require programming (coding) or
> manipulation (human reordering/decoding) as used in the Act, and quantify
> those hours separately. Using built-in e-discovery/search tools is not
> “programming.” Inspection of electronic records may not be charged unless
> programming/manipulation is required (§ 552.272).
>
> Aggregation. You say you aggregated my clarification responses and an
> additional same-day request. List each request you aggregated and provide
> separate line-item estimates per request. A clarification response is not
> itself a new “request,” and aggregation should not inflate costs across
> discrete requests. See § 552.261(e).
>
> Phased production to cut costs (my election). Proceed in phases, starting
> with OGC/PIO custodians (Staugaard, Wall) for Oct 3–31, 2025 using the
> terms: “Kevin Bass,” “kbassphiladelphia,” “Preservation Notice,” “P3,”
> “SPPCC,” “professionalism.” After Phase-1 lands, we’ll scope Phase-2
> (Registrar/Student Life/IT). Re-estimate Phase-1 only.
>
> Inspection to minimize charges. For Phase-1, I elect on-site or remote
> inspection of electronic records in native format where feasible (§
> 552.272), unless you specifically identify required
> programming/manipulation (with task detail). If programming is necessary,
> itemize it and use the programmer rate.
>
> Rolling production required. Promptly produce any responsive records not
> subject to your AG request and any clearly public/segregable information
> now, while your AG brief is pending. See § 552.221; ORD-664 (2000).
>
> Deposit posture. Given the defects in TTUS’s Nov 3 estimate and the
> magnitude of the proposed deposit, I will not remit any funds unless and
> until TTUS provides a § [REDACTED – PARTIAL-PHONE]-compliant written itemized statement that
> sets out task-level hours and rates (search/collection,
> compilation/duplication, redaction—identifying any mandatory
> confidentiality—and any programming/manipulation, if applicable) and
> identifies less-costly alternatives. I am invoking my rights under §
> 552.269 and will seek Attorney General review of the estimate. For clarity,
> the 10-business-day withdrawal provision in § [REDACTED – PARTIAL-PHONE](d) is triggered only
> by a compliant itemized statement with the required notices; any attempt to
> treat this request as withdrawn before such a statement issues is improper.
> Likewise, any deposit request under § 552.263(a) must follow and be based
> on a compliant § [REDACTED – PARTIAL-PHONE] itemized statement. I also elect inspection where
> it reduces charges, consistent with § 552.272.
>
> Please confirm receipt and provide a date/time for initial rolling
> production of non-exempt material. Also send the revised, itemized Phase-1
> estimate within 3 business days, so I can respond within the statute’s
> window.
> Kevin Bass PhD MS
> Phone: *[REDACTED – PHONE]*
>
>
> On Mon, Nov 3, 2025 at 4:51 PM Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
> wrote:
>
>> Good Afternoon,
>>
>>
>>
>> Texas Tech University System (TTUS) is in receipt of your responses to
>> our clarifications/narrowings and your additional request received on
>> October 20, 2025. The responses and request are attached herein.  Due to
>> our receipt of your responses and request on the same calendar day, we are
>> treating them as a single request for the purposes of calculating costs as
>> permitted under the Texas Government Code.
>>
>
>>
>> We must also note that while our correspondences sought to clarify or
>> narrow the scope of your requests, your subsequent responses have generally
>> served to broaden them. As such, we have determined that complying with the
>> request will result in the imposition of a charge that exceeds
>> $40. Therefore, the following statement is provided pursuant to sections
>> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>
>>
>>
>>    1. The requested information is not currently available in a form
>>    suitable for public release, and since the request involves manipulation of
>>    data, documents are not feasible to retrieve, will result in substantial
>>    interference with ongoing operations and can only be provided at a cost
>>    that covers the manipulation of data and other costs, you are entitled to
>>    an estimate of the costs and time to provide the information in the
>>    requested form.
>>
>>
>>
>> Therefore, the itemized statement of estimated charges is:
>>
>>
>>
>> Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25
>>
>> *Overhead @ 20% =                            $ 644.85             *
>>
>>
>> *Estimated Total Cost =                     $3,869.10*
>>
>>
>>
>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>    providing you with an alternative, less expensive method of obtaining some
>>    of the requested information.  An alternative method would be to narrow
>>    your request by eliminating some of the data requested, such as narrowing
>>    the date range or information requested. It may also be less expensive to
>>    view the documents here at the office.
>>
>>
>>
>>    3. *Your request will be considered automatically withdrawn if you do
>>    not notify us in writing and within 10 (ten) business days from the date of
>>    this statement that you:*
>>
>>
>>
>>    1. Accept the estimated charges and will pay them.  Because your
>>       request is over $100.00, you are required to either deposit $1,934.55 (50%
>>       of the estimated costs) or provide TTUS with a bond for the total estimated
>>       cost. *Please note that pursuant to §552.263(e), your request will
>>       be considered received when we receive your payment.  Additionally, if you
>>       fail to pay within 10 business days, your request will be considered
>>       withdrawn pursuant to §552.263(f).*
>>       2. Are modifying the request (state the modification); or
>>       3. Have sent a complaint to the Office of the Attorney General of
>>       Texas alleging that you have been overcharged for a copy of public
>>       information.
>>
>>
>>
>>    4. You may choose to respond by email to me at
>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste. 301
>>    Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the Texas
>>    Tech University System Building, located at 1508 Knoxville Ave., Ste.
>>    301, Lubbock, Tx 79409-2021.
>>
>>
>>
>>    5. Your check, money order, or bond must be made payable to: Texas
>>    Tech University System.
>>
>>
>>
>>    6. If we determine that a change in estimated charges will exceed the
>>    amount in this written itemized statement by 20%, we will send you an
>>    updated written itemized statement. As noted above, the same response
>>    requirements are imposed on you once an updated itemized statement is sent.
>>
>>
>>
>>    7. TTUS expects it to take approximately 2 weeks to complete this
>>    request at current workloads.
>>
>>
>>
>> Finally, some of the documents or information that you have requested may
>> be withheld under State law.  Therefore, if you choose to pay the deposit,
>> we may request an Attorney General Open Records Decision (“ORD”) seeking to
>> withhold some documents or information pursuant to the Texas Public
>> Information Act.  Texas Government Code § 552.001, et seq.  Once the
>> Attorney General makes a decision regarding the public disclosure of these
>> documents, TTUS will make those documents that are determined by the
>> Attorney General to be public, if any, available for inspection or copying.
>>
>>
>>
>> Sincerely,
>>
>> Brontë C. Staugaard
>>
>> Assistant General Counsel
>>
>> Texas Tech University System
>>
>> (806) [REDACTED – PARTIAL-PHONE]
>>
>>
>>
>> This communication, including any attachments, originates from an
>> Attorney and may contain confidential information and is intended only for
>> the individual or entity to whom it is addressed. Any review,
>> dissemination, or copying of this communication by anyone other than the
>> intended recipient is strictly prohibited. If you are not the intended
>> recipient, please contact the sender by reply e-mail, delete and destroy
>> all copies of the original message.
>>
>>
>>
>>
>>
>

Good Afternoon,





Texas Tech University System (TTUS) is in receipt of your responses to our estimate and your request to inspect the responsive records below. As we previously pointed out, our correspondences sought to clarify or narrow the scope of your requests; however, your subsequent responses generally served to broaden them.







Additionally, we received your deposit of $1,934.55 on November 13, 2025, relating to the cost estimate provided on November 3, 2025. However, we also noted your November 4, 2025, response to the cost estimate wherein you requested to inspect the records in person. To ensure we proceed correctly, please confirm if you would prefer to inspect the documentation or be provided copies. Please be advised that, some of the documents or information that you have requested may be withheld under State law. As such, even if a deposit is made, we may request an Attorney General Open Records Decision (“ORD”) seeking to withhold some documents or information pursuant to the Texas Public Information Act.  Texas Government Code § 552.001, et seq.  Once the Attorney General makes a decision regarding the public disclosure of these documents, TTUS will make those documents that are determined by the Attorney General to be public, if any, available for inspection or copying.







In response to your request to inspect, we have determined that complying with the request will result in the imposition of a charge that exceeds $40. Therefore, the following statement is provided pursuant to sections [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:







  1.  The requested information is not currently available in a form suitable for public release, and since the request involves manipulation of data, documents are not feasible to retrieve, will result in substantial interference with ongoing operations and can only be provided at a cost that covers the manipulation of data and other costs, you are entitled to an estimate of the costs and time to provide the information in the requested form.







Therefore, the itemized statement of estimated charges is:







Labor 118.64 hrs. @ $15/hr. =           $ 1,779.60



Estimated Total Cost =                     $1,779.60







  1.  Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is providing you with an alternative, less expensive method of obtaining some of the requested information.  An alternative method would be to narrow your request by eliminating some of the data requested, such as narrowing the date range or information requested. It is usually less expensive to view the documents here at the office; however, this estimate is for the cost of viewing as per your request.







  1.  Your request will be considered automatically withdrawn if you do not notify us in writing and within 10 (ten) business days from the date of this statement that you:







     *   Accept the estimated charges and will pay them.  Because your request is over $100.00, you are required to either deposit $889.80 (50% of the estimated costs) or provide TTUS with a bond for the total estimated cost. Please note that pursuant to §552.263(e), your request will be considered received when we receive your payment.  Additionally, if you fail to pay within 10 business days, your request will be considered withdrawn pursuant to §552.263(f).

     *   Are modifying the request (state the modification); or

     *   Have sent a complaint to the Office of the Attorney General of Texas alleging that you have been overcharged for a copy of public information.







  1.  You may choose to respond by email to me at bronte.staugaard@ttu.edu<mailto:bronte.staugaard@ttu.edu>, regular mail (1508 Knoxville Ave., Ste. 301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the Texas Tech University System Building, located at 1508 Knoxville Ave., Ste. 301, Lubbock, Tx 79409-2021.







  1.  Your check, money order, or bond must be made payable to: Texas Tech University System.







  1.  If we determine that a change in estimated charges will exceed the amount in this written itemized statement by 20%, we will send you an updated written itemized statement. As noted above, the same response requirements are imposed on you once an updated itemized statement is sent.







  1.  TTUS expects it to take approximately 3 weeks to complete this request at current workloads.





Sincerely,

Brontë C. Staugaard

Assistant General Counsel

Texas Tech University System

(806) [REDACTED – PARTIAL-PHONE]



This communication, including any attachments, originates from an Attorney and may contain confidential information and is intended only for the individual or entity to whom it is addressed. Any review, dissemination, or copying of this communication by anyone other than the intended recipient is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail, delete and destroy all copies of the original message.



Sincerely,

Brontë C. Staugaard

Assistant General Counsel

Texas Tech University System

(806) [REDACTED – PARTIAL-PHONE]



This communication, including any attachments, originates from an Attorney and may contain confidential information and is intended only for the individual or entity to whom it is addressed. Any review, dissemination, or copying of this communication by anyone other than the intended recipient is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail, delete and destroy all copies of the original message.



[cid:image001.png@01DC5884.689784C0]



From: Kevin Bass <kbassphiladelphia@gmail.com<mailto:kbassphiladelphia@gmail.com>>

Sent: Tuesday, November 4, 2025 8:00 AM

To: Staugaard, Bronte <Bronte.Staugaard@ttu.edu<mailto:Bronte.Staugaard@ttu.edu>>

Subject: Re: Cost Estimate Regarding Responses to TTUS's Clarifications/Narrowings and Additional Request Received on 10.20.2025



This email originated outside TTU. Please exercise caution<https://askit.ttu.edu/phishing>!





Brontë,



This is my timely response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](d).



Itemization required. Please issue a corrected, fully itemized estimate that breaks out and supports, by task and rate:



  1.

  2.

  3.  Search/collection time (by custodian

  4.  and data source),

  5.

  6.

  7.

  8.

  9.  Compilation/duplication time,

  10.

  11.

  12.

  13.

  14. Redaction time (identify the specific

  15. mandatory confidentiality provisions), and

  16.

  17.

  18.

  19.

  20. Any programming/manipulation tasks

  21. (use programmer rate and describe the steps).

  22. Explicitly exclude attorney

  23. review and AG-brief preparation time. See § [REDACTED – PARTIAL-PHONE]; 1 TAC § 70.3(d)(3)–(4), (e). Also confirm overhead ≤ 20% of allowable labor and note the 20% update rule (issue a new written estimate if actual charges will exceed the prior estimate by ≥20%).

  24.



“Programming/manipulation” basis. Your email says the request “involves manipulation of data.” Identify which tasks require programming (coding) or manipulation (human reordering/decoding) as used in the Act, and quantify those hours separately. Using built-in e-discovery/search tools is not “programming.” Inspection of electronic records may not be charged unless programming/manipulation is required (§ 552.272).



Aggregation. You say you aggregated my clarification responses and an additional same-day request. List each request you aggregated and provide separate line-item estimates per request. A clarification response is not itself a new “request,” and aggregation should not inflate costs across discrete requests. See § 552.261(e).



Phased production to cut costs (my election). Proceed in phases, starting with OGC/PIO custodians (Staugaard, Wall) for Oct 3–31, 2025 using the terms: “Kevin Bass,” “kbassphiladelphia,” “Preservation Notice,” “P3,” “SPPCC,” “professionalism.” After Phase-1 lands, we’ll scope Phase-2 (Registrar/Student Life/IT). Re-estimate Phase-1 only.



Inspection to minimize charges. For Phase-1, I elect on-site or remote inspection of electronic records in native format where feasible (§ 552.272), unless you specifically identify required programming/manipulation (with task detail). If programming is necessary, itemize it and use the programmer rate.



Rolling production required. Promptly produce any responsive records not subject to your AG request and any clearly public/segregable information now, while your AG brief is pending. See § 552.221; ORD-664 (2000).



Deposit posture. Given the defects in TTUS’s Nov 3 estimate and the magnitude of the proposed deposit, I will not remit any funds unless and until TTUS provides a § [REDACTED – PARTIAL-PHONE]-compliant written itemized statement that sets out task-level hours and rates (search/collection, compilation/duplication, redaction—identifying any mandatory confidentiality—and any programming/manipulation, if applicable) and identifies less-costly alternatives. I am invoking my rights under § 552.269 and will seek Attorney General review of the estimate. For clarity, the 10-business-day withdrawal provision in § [REDACTED – PARTIAL-PHONE](d) is triggered only by a compliant itemized statement with the required notices; any attempt to treat this request as withdrawn before such a statement issues is improper. Likewise, any deposit request under § 552.263(a) must follow and be based on a compliant § [REDACTED – PARTIAL-PHONE] itemized statement. I also elect inspection where it reduces charges, consistent with § 552.272.



Please confirm receipt and provide a date/time for initial rolling production of non-exempt material. Also send the revised, itemized Phase-1 estimate within 3 business days, so I can respond within the statute’s window.

Kevin Bass PhD MS

Phone: [REDACTED – PHONE]





On Mon, Nov 3, 2025 at 4:51 PM Staugaard, Bronte <Bronte.Staugaard@ttu.edu<mailto:Bronte.Staugaard@ttu.edu>> wrote:

Good Afternoon,





Texas Tech University System (TTUS) is in receipt of your responses to our clarifications/narrowings and your additional request received on October 20, 2025. The responses and request are attached herein.  Due to our receipt of your responses and request on the same calendar day, we are treating them as a single request for the purposes of calculating costs as permitted under the Texas Government Code.







We must also note that while our correspondences sought to clarify or narrow the scope of your requests, your subsequent responses have generally served to broaden them. As such, we have determined that complying with the request will result in the imposition of a charge that exceeds $40. Therefore, the following statement is provided pursuant to sections [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:







  1.  The requested information is not currently available in a form suitable for public release, and since the request involves manipulation of data, documents are not feasible to retrieve, will result in substantial interference with ongoing operations and can only be provided at a cost that covers the manipulation of data and other costs, you are entitled to an estimate of the costs and time to provide the information in the requested form.







Therefore, the itemized statement of estimated charges is:







Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25



Overhead @ 20% =                            $ 644.85



Estimated Total Cost =                     $3,869.10







  1.  Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is providing you with an alternative, less expensive method of obtaining some of the requested information.  An alternative method would be to narrow your request by eliminating some of the data requested, such as narrowing the date range or information requested. It may also be less expensive to view the documents here at the office.







  1.  Your request will be considered automatically withdrawn if you do not notify us in writing and within 10 (ten) business days from the date of this statement that you:







     *   Accept the estimated charges and will pay them.  Because your request is over $100.00, you are required to either deposit $1,934.55 (50% of the estimated costs) or provide TTUS with a bond for the total estimated cost. Please note that pursuant to §552.263(e), your request will be considered received when we receive your payment.  Additionally, if you fail to pay within 10 business days, your request will be considered withdrawn pursuant to §552.263(f).

     *   Are modifying the request (state the modification); or

     *   Have sent a complaint to the Office of the Attorney General of Texas alleging that you have been overcharged for a copy of public information.







  1.  You may choose to respond by email to me at bronte.staugaard@ttu.edu<mailto:bronte.staugaard@ttu.edu>, regular mail (1508 Knoxville Ave., Ste. 301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the Texas Tech University System Building, located at 1508 Knoxville Ave., Ste. 301, Lubbock, Tx 79409-2021.







  1.  Your check, money order, or bond must be made payable to: Texas Tech University System.







  1.  If we determine that a change in estimated charges will exceed the amount in this written itemized statement by 20%, we will send you an updated written itemized statement. As noted above, the same response requirements are imposed on you once an updated itemized statement is sent.







  1.  TTUS expects it to take approximately 2 weeks to complete this request at current workloads.





Finally, some of the documents or information that you have requested may be withheld under State law.  Therefore, if you choose to pay the deposit, we may request an Attorney General Open Records Decision (“ORD”) seeking to withhold some documents or information pursuant to the Texas Public Information Act.  Texas Government Code § 552.001, et seq.  Once the Attorney General makes a decision regarding the public disclosure of these documents, TTUS will make those documents that are determined by the Attorney General to be public, if any, available for inspection or copying.



Sincerely,

Brontë C. Staugaard

Assistant General Counsel

Texas Tech University System

(806) [REDACTED – PARTIAL-PHONE]



This communication, including any attachments, originates from an Attorney and may contain confidential information and is intended only for the individual or entity to whom it is addressed. Any review, dissemination, or copying of this communication by anyone other than the intended recipient is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail, delete and destroy all copies of the original message.



[cid:image001.png@01DC5884.689784C0]

Hello Counsel Staugaard,

This confirms my request remains an inspection request and is not a request
for copies at this time. No explanation of purpose is required; please
treat this request uniformly under the Act.

1) Inspection first (no copies yet).
I elect to inspect the responsive records. Please set a date and hour for
in‑person inspection within a reasonable time (or certify active
use/storage and give the inspection appointment date) as required by Tex.
Gov’t Code §552.221(c)–(d). Please also comply with §552.221(a)’s
requirement to *promptly* produce non‑contested records “as soon as
possible.” If the records are ready sooner, please just confirm a time and
the location. In the meantime, please begin rolling production of any
portions that are readily available now. If you contend any portion is in
active use or storage, please identify those records and provide the
certification required by §552.221(c) together with the appointment date.

2) Electronic records: no charge to inspect absent programming/manipulation
+ §552.231 statement.
For information that exists in an electronic medium, access for inspection
may not be charged unless you must perform programming or manipulation of
data. If you believe that is required, please send the written §552.231
statement that (a) says the data is not available in the requested form,
(b) describes the form in which it is available, (c) lists any
contracts/services needed, and (d) gives the estimated cost and time—within
the statute’s 20‑day window (30 with notice). If the only reason
programming is needed is to convert records into a different format, I will
accept the information in the form in which it is currently available to
avoid programming charges under §552.231(d). For clarity, routine keyword
searches/filters are not “programming or manipulation”; if you contend
otherwise, please identify the specific script/process.

3) Your “viewing” estimate / paper inspection.
The itemized estimate you sent frames this as “viewing as per your
request.” For paper records, a deposit for inspection is allowed only in
the narrow §552.271(c)–(d) scenarios. For ≥16 FTEs: the records must be
older than five years or fill six+ archival boxes and exceed five hours to
prepare. For <16 FTEs: three years/three boxes/two hours. Please confirm
whether your estimate rests on §552.271(c)–(d), and if so, identify which
prong(s) apply. Otherwise, inspection should be scheduled without these
charges.

4) Deposit = copies only.
You note a deposit received on November 13, 2025. Under §552.263(e), when a
deposit is properly required, a request for a copy is considered “received”
on the date the deposit arrives. That rule does not convert an inspection
into a copy request. Please apply or hold my deposit for any copies I later
select after inspection, or refund any excess after copy fulfillment.

5) Estimates > $40 must be compliant.
Any estimate over $40 must comply with §[REDACTED – PARTIAL-PHONE] and 1 TAC §70.7 (full
itemization; notice of less‑costly options; clear response instructions;
and an updated statement if the estimate will exceed the original by ≥20%).
Please ensure any future estimate includes those elements.

6) What you cannot charge.
Time for attorney/legal review to decide what to withhold is not a
recoverable cost. If included in your labor math, please remove it. Please
also confirm that overhead will not be applied to inspection where no
inspection charge is permitted. See 1 TAC §70.3(d)(3).

7) Clarification and timing.
To avoid unnecessary delay, the request is sufficiently clear as stated. If
you believe any discrete item is unclear, please identify it specifically
in a single clarification request and also identify the portions you
already understand and will produce now. Consistent with *City of Dallas v.
Abbott* (2010), any AG‑ruling deadline would run from any clarification
only for the clarified portion; clarification cannot be used to extend
deadlines indefinitely.

8) Aggregation / “large‑requestor” policy.
Please do not aggregate separate‑day requests for cost purposes
(§552.261(e)). If you intend to apply a “large requestor” policy under
§552.275, please provide the adopted policy and my cumulative hour ledger
for this fiscal period.

9) If you intend to seek an AG ruling.
If you believe any information is excepted, please timely request a
decision under §552.301. Otherwise, the information is presumed public
under §552.302, and non‑contested portions should be released promptly.
Also, please send me the copy of your written comments to the ORD by the
15th business day, as §552.301(e‑1) requires (redacted if your comments
would reveal the substance of the records).

10) Scheduling windows.
For scheduling, I am available to inspect this week during normal business
hours. My preferred times (Central) are:
• Wednesday, November 19, 2025: 1:00–5:00 PM
• Thursday, November 20, 2025: 1:00–5:00 PM
• Friday, November 21, 2025: 1:00–5:00 PM
If those are not workable, I can also be available:
• Monday, November 24, 2025: 1:00–5:00 PM
• Tuesday, November 25, 2025: 1:00–5:00 PM
If another weekday afternoon is more convenient, please propose it and I
will accommodate.

11) Time for examination.
Once you make records available, I will complete my review within
§552.225’s 10‑business‑day window, with any needed written extension.

12) Segregability & marking of redactions.
Please release all reasonably segregable, non‑excepted portions and
identify each redaction by specific statutory authority.

13) Third‑party notice (if applicable).
If you invoke §552.305 for proprietary/third‑party interests, please make
timely notice and let me know the date notices went out.

14) Preservation.
Please preserve all potentially responsive records, including ESI, during
processing. Willful destruction or alteration is an offense under §552.351.

15) Requestor equipment during inspection.
I plan to use a phone or portable scanner for copies of non‑confidential
pages during inspection, consistent with OAG guidance; if you contend this
would be disruptive or would expose confidential content on mixed pages,
please identify the specific constraint.

For avoidance of doubt, this message is my timely response under
§[REDACTED – PARTIAL-PHONE](b) to your November 18, 2025 estimate: I do not accept the quoted
“viewing” labor charge for inspection; I do not withdraw my request; and I
am requesting a cost‑compliant itemization and, if programming is claimed,
a §552.231 statement. Nothing in this email narrows, modifies, or withdraws
the scope of my request.

Cost‑complaint notice: For completeness, this message also serves as my
written response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](b)(3) to your November
18, 2025 itemized estimate. I have submitted a written cost complaint to
the Office of the Attorney General under § 552.269 regarding the estimate’s
charge of 118.64 hours of “viewing” at $15/hour for electronic inspection
without a § 552.231 programming statement. My request is not withdrawn or
narrowed. I continue to elect inspection and ask that you proceed promptly
under §§ 552.221 and 552.272; if you contend programming/manipulation is
required, please issue the written § 552.231 statement within the statutory
window.

Best,

Kevin Bass PhD MS
Phone: *[REDACTED – PHONE]*


On Tue, Nov 18, 2025 at 4:56 PM Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
wrote:

> Good Afternoon,
>
>
>
> Texas Tech University System (TTUS) is in receipt of your responses to our
> estimate and your request to inspect the responsive records below. As we
> previously pointed out, our correspondences sought to clarify or narrow the
> scope of your requests; however, your subsequent responses generally served
> to broaden them.
>
>
>
> Additionally, we received your deposit of $1,934.55 on November 13, 2025,
> relating to the cost estimate provided on November 3, 2025. However, we
> also noted your November 4, 2025, response to the cost estimate wherein you
> requested to inspect the records in person. To ensure we proceed correctly,
> please confirm if you would prefer to inspect the documentation or be
> provided copies. Please be advised that, some of the documents or
> information that you have requested may be withheld under State law. As
> such, even if a deposit is made, we may request an Attorney General Open
> Records Decision (“ORD”) seeking to withhold some documents or
> information pursuant to the Texas Public Information Act.  Texas Government
> Code § 552.001, et seq.  Once the Attorney General makes a decision
> regarding the public disclosure of these documents, TTUS will make those
> documents that are determined by the Attorney General to be public, if any,
> available for inspection or copying.
>
>
>
> In response to your request to inspect, we have determined that complying
> with the request will result in the imposition of a charge that exceeds
> $40. Therefore, the following statement is provided pursuant to sections
> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>
>
>
>    1. The requested information is not currently available in a form
>    suitable for public release, and since the request involves manipulation of
>    data, documents are not feasible to retrieve, will result in substantial
>    interference with ongoing operations and can only be provided at a cost
>    that covers the manipulation of data and other costs, you are entitled to
>    an estimate of the costs and time to provide the information in the
>    requested form.
>
>
>
> Therefore, the itemized statement of estimated charges is:
>
>
>
> *Labor 118.64 hrs. @ $15/hr. =           $ 1,779.60*
>
> *Estimated Total Cost =                     $1,779.60*
>
>
>
>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>    providing you with an alternative, less expensive method of obtaining some
>    of the requested information.  An alternative method would be to narrow
>    your request by eliminating some of the data requested, such as narrowing
>    the date range or information requested. It is usually less expensive to
>    view the documents here at the office; however, this estimate is for the
>    cost of viewing as per your request.
>
>
>
>    3. *Your request will be considered automatically withdrawn if you do
>    not notify us in writing and within 10 (ten) business days from the date of
>    this statement that you:*
>
>
>
>    1. Accept the estimated charges and will pay them.  Because your
>       request is over $100.00, you are required to either deposit $889.80 (50% of
>       the estimated costs) or provide TTUS with a bond for the total estimated
>       cost. *Please note that pursuant to §552.263(e), your request will
>       be considered received when we receive your payment.  Additionally, if you
>       fail to pay within 10 business days, your request will be considered
>       withdrawn pursuant to §552.263(f).*
>       2. Are modifying the request (state the modification); or
>       3. Have sent a complaint to the Office of the Attorney General of
>       Texas alleging that you have been overcharged for a copy of public
>       information.
>
>
>
>    4. You may choose to respond by email to me at bronte.staugaard@ttu.edu,
>    regular mail (1508 Knoxville Ave., Ste. 301 Box 42021, Lubbock, Tx
>    79409-2021), or in person to Ste. 301 of the Texas Tech University System
>    Building, located at 1508 Knoxville Ave., Ste. 301, Lubbock, Tx
>    79409-2021.
>
>
>
>    5. Your check, money order, or bond must be made payable to: Texas
>    Tech University System.
>
>
>
>    6. If we determine that a change in estimated charges will exceed the
>    amount in this written itemized statement by 20%, we will send you an
>    updated written itemized statement. As noted above, the same response
>    requirements are imposed on you once an updated itemized statement is sent.
>
>
>
>    7. TTUS expects it to take approximately 3 weeks to complete this
>    request at current workloads.
>
>
>
> Sincerely,
>
> Brontë C. Staugaard
>
> Assistant General Counsel
>
> Texas Tech University System
>
> (806) [REDACTED – PARTIAL-PHONE]
>
>
>
> This communication, including any attachments, originates from an Attorney
> and may contain confidential information and is intended only for the
> individual or entity to whom it is addressed. Any review, dissemination, or
> copying of this communication by anyone other than the intended recipient
> is strictly prohibited. If you are not the intended recipient, please
> contact the sender by reply e-mail, delete and destroy all copies of the
> original message.
>
>
>
> Sincerely,
>
> Brontë C. Staugaard
>
> Assistant General Counsel
>
> Texas Tech University System
>
> (806) [REDACTED – PARTIAL-PHONE]
>
>
>
> This communication, including any attachments, originates from an Attorney
> and may contain confidential information and is intended only for the
> individual or entity to whom it is addressed. Any review, dissemination, or
> copying of this communication by anyone other than the intended recipient
> is strictly prohibited. If you are not the intended recipient, please
> contact the sender by reply e-mail, delete and destroy all copies of the
> original message.
>
>
>
>
>
> *From:* Kevin Bass <kbassphiladelphia@gmail.com>
> *Sent:* Tuesday, November 4, 2025 8:00 AM
> *To:* Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
> *Subject:* Re: Cost Estimate Regarding Responses to TTUS's
> Clarifications/Narrowings and Additional Request Received on 10.20.2025
>
>
>
> This email originated outside TTU. Please exercise caution
> <https://askit.ttu.edu/phishing>!
>
>
>
> Brontë,
>
> This is my timely response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](d).
>
> Itemization required. Please issue a corrected, fully itemized estimate
> that breaks out and supports, by task and rate:
>
>    1.
>    2.
>    3. Search/collection time (by custodian
>    4. and data source),
>    5.
>    6.
>    7.
>    8.
>    9. Compilation/duplication time,
>    10.
>    11.
>    12.
>    13.
>    14. Redaction time (identify the specific
>    15. mandatory confidentiality provisions), and
>    16.
>    17.
>    18.
>    19.
>    20. Any programming/manipulation tasks
>    21. (use programmer rate and describe the steps).
>    22. Explicitly exclude attorney
>    23. review and AG-brief preparation time. See § [REDACTED – PARTIAL-PHONE]; 1 TAC §
>    70.3(d)(3)–(4), (e). Also confirm overhead ≤ 20% of allowable labor and
>    note the 20% update rule (issue a new written estimate if actual charges
>    will exceed the prior estimate by ≥20%).
>    24.
>
> “Programming/manipulation” basis. Your email says the request “involves
> manipulation of data.” Identify which tasks require programming (coding) or
> manipulation (human reordering/decoding) as used in the Act, and quantify
> those hours separately. Using built-in e-discovery/search tools is not
> “programming.” Inspection of electronic records may not be charged unless
> programming/manipulation is required (§ 552.272).
>
> Aggregation. You say you aggregated my clarification responses and an
> additional same-day request. List each request you aggregated and provide
> separate line-item estimates per request. A clarification response is not
> itself a new “request,” and aggregation should not inflate costs across
> discrete requests. See § 552.261(e).
>
> Phased production to cut costs (my election). Proceed in phases, starting
> with OGC/PIO custodians (Staugaard, Wall) for Oct 3–31, 2025 using the
> terms: “Kevin Bass,” “kbassphiladelphia,” “Preservation Notice,” “P3,”
> “SPPCC,” “professionalism.” After Phase-1 lands, we’ll scope Phase-2
> (Registrar/Student Life/IT). Re-estimate Phase-1 only.
>
> Inspection to minimize charges. For Phase-1, I elect on-site or remote
> inspection of electronic records in native format where feasible (§
> 552.272), unless you specifically identify required
> programming/manipulation (with task detail). If programming is necessary,
> itemize it and use the programmer rate.
>
> Rolling production required. Promptly produce any responsive records not
> subject to your AG request and any clearly public/segregable information
> now, while your AG brief is pending. See § 552.221; ORD-664 (2000).
>
> Deposit posture. Given the defects in TTUS’s Nov 3 estimate and the
> magnitude of the proposed deposit, I will not remit any funds unless and
> until TTUS provides a § [REDACTED – PARTIAL-PHONE]-compliant written itemized statement that
> sets out task-level hours and rates (search/collection,
> compilation/duplication, redaction—identifying any mandatory
> confidentiality—and any programming/manipulation, if applicable) and
> identifies less-costly alternatives. I am invoking my rights under §
> 552.269 and will seek Attorney General review of the estimate. For clarity,
> the 10-business-day withdrawal provision in § [REDACTED – PARTIAL-PHONE](d) is triggered only
> by a compliant itemized statement with the required notices; any attempt to
> treat this request as withdrawn before such a statement issues is improper.
> Likewise, any deposit request under § 552.263(a) must follow and be based
> on a compliant § [REDACTED – PARTIAL-PHONE] itemized statement. I also elect inspection where
> it reduces charges, consistent with § 552.272.
>
> Please confirm receipt and provide a date/time for initial rolling
> production of non-exempt material. Also send the revised, itemized Phase-1
> estimate within 3 business days, so I can respond within the statute’s
> window.
>
> Kevin Bass PhD MS
>
> Phone: *[REDACTED – PHONE]*
>
>
>
>
>
> On Mon, Nov 3, 2025 at 4:51 PM Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
> wrote:
>
> Good Afternoon,
>
>
>
> Texas Tech University System (TTUS) is in receipt of your responses to our
> clarifications/narrowings and your additional request received on October
> 20, 2025. The responses and request are attached herein.  Due to our
> receipt of your responses and request on the same calendar day, we are
> treating them as a single request for the purposes of calculating costs as
> permitted under the Texas Government Code.
>
>
>
> We must also note that while our correspondences sought to clarify or
> narrow the scope of your requests, your subsequent responses have generally
> served to broaden them. As such, we have determined that complying with the
> request will result in the imposition of a charge that exceeds
> $40. Therefore, the following statement is provided pursuant to sections
> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>
>
>
>    1. The requested information is not currently available in a form
>    suitable for public release, and since the request involves manipulation of
>    data, documents are not feasible to retrieve, will result in substantial
>    interference with ongoing operations and can only be provided at a cost
>    that covers the manipulation of data and other costs, you are entitled to
>    an estimate of the costs and time to provide the information in the
>    requested form.
>
>
>
> Therefore, the itemized statement of estimated charges is:
>
>
>
> Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25
>
> *Overhead @ 20% =                            $ 644.85             *
>
>
> *Estimated Total Cost =                     $3,869.10*
>
>
>
>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>    providing you with an alternative, less expensive method of obtaining some
>    of the requested information.  An alternative method would be to narrow
>    your request by eliminating some of the data requested, such as narrowing
>    the date range or information requested. It may also be less expensive to
>    view the documents here at the office.
>
>
>
>    3. *Your request will be considered automatically withdrawn if you do
>    not notify us in writing and within 10 (ten) business days from the date of
>    this statement that you:*
>
>
>
>    1. Accept the estimated charges and will pay them.  Because your
>       request is over $100.00, you are required to either deposit $1,934.55 (50%
>       of the estimated costs) or provide TTUS with a bond for the total estimated
>       cost. *Please note that pursuant to §552.263(e), your request will
>       be considered received when we receive your payment.  Additionally, if you
>       fail to pay within 10 business days, your request will be considered
>       withdrawn pursuant to §552.263(f).*
>       2. Are modifying the request (state the modification); or
>       3. Have sent a complaint to the Office of the Attorney General of
>       Texas alleging that you have been overcharged for a copy of public
>       information.
>
>
>
>    4. You may choose to respond by email to me at bronte.staugaard@ttu.edu,
>    regular mail (1508 Knoxville Ave., Ste. 301 Box 42021, Lubbock, Tx
>    79409-2021), or in person to Ste. 301 of the Texas Tech University System
>    Building, located at 1508 Knoxville Ave., Ste. 301, Lubbock, Tx
>    79409-2021.
>
>
>
>    5. Your check, money order, or bond must be made payable to: Texas
>    Tech University System.
>
>
>
>    6. If we determine that a change in estimated charges will exceed the
>    amount in this written itemized statement by 20%, we will send you an
>    updated written itemized statement. As noted above, the same response
>    requirements are imposed on you once an updated itemized statement is sent.
>
>
>
>    7. TTUS expects it to take approximately 2 weeks to complete this
>    request at current workloads.
>
>
>
> Finally, some of the documents or information that you have requested may
> be withheld under State law.  Therefore, if you choose to pay the deposit,
> we may request an Attorney General Open Records Decision (“ORD”) seeking to
> withhold some documents or information pursuant to the Texas Public
> Information Act.  Texas Government Code § 552.001, et seq.  Once the
> Attorney General makes a decision regarding the public disclosure of these
> documents, TTUS will make those documents that are determined by the
> Attorney General to be public, if any, available for inspection or copying.
>
>
>
> Sincerely,
>
> Brontë C. Staugaard
>
> Assistant General Counsel
>
> Texas Tech University System
>
> (806) [REDACTED – PARTIAL-PHONE]
>
>
>
> This communication, including any attachments, originates from an Attorney
> and may contain confidential information and is intended only for the
> individual or entity to whom it is addressed. Any review, dissemination, or
> copying of this communication by anyone other than the intended recipient
> is strictly prohibited. If you are not the intended recipient, please
> contact the sender by reply e-mail, delete and destroy all copies of the
> original message.
>
>
>
>
>
>

Counsel Staugaard — for clarity, the $1,934.55 paid on Nov 13 was the 50%
deposit for TTUS’s Nov 3 copy estimate and must not be applied to the
Nov 18 “viewing” estimate. I have submitted a §552.269 cost complaint
regarding the Nov 18 estimate; this serves as my §[REDACTED – PARTIAL-PHONE](b)(3) response,
so the request is not withdrawn. Please schedule an inspection (or provide
the §552.221(c) active‑use/storage certification with an appointment date),
and if you contend programming/manipulation is required, issue the §552.231
statement with task, staff category, time, and cost. Please also provide a
simple statement of account showing deposits held and what estimate each
deposit is tied to.
Kevin Bass PhD MS
Phone: *[REDACTED – PHONE]*


On Wed, Nov 19, 2025 at 12:38 PM Kevin Bass <kbassphiladelphia@gmail.com>
wrote:

> Hello Counsel Staugaard,
>
> This confirms my request remains an inspection request and is not a
> request for copies at this time. No explanation of purpose is required;
> please treat this request uniformly under the Act.
>
> 1) Inspection first (no copies yet).
> I elect to inspect the responsive records. Please set a date and hour for
> in‑person inspection within a reasonable time (or certify active
> use/storage and give the inspection appointment date) as required by Tex.
> Gov’t Code §552.221(c)–(d). Please also comply with §552.221(a)’s
> requirement to *promptly* produce non‑contested records “as soon as
> possible.” If the records are ready sooner, please just confirm a time and
> the location. In the meantime, please begin rolling production of any
> portions that are readily available now. If you contend any portion is in
> active use or storage, please identify those records and provide the
> certification required by §552.221(c) together with the appointment date.
>
> 2) Electronic records: no charge to inspect absent
> programming/manipulation + §552.231 statement.
> For information that exists in an electronic medium, access for inspection
> may not be charged unless you must perform programming or manipulation of
> data. If you believe that is required, please send the written §552.231
> statement that (a) says the data is not available in the requested form,
> (b) describes the form in which it is available, (c) lists any
> contracts/services needed, and (d) gives the estimated cost and time—within
> the statute’s 20‑day window (30 with notice). If the only reason
> programming is needed is to convert records into a different format, I will
> accept the information in the form in which it is currently available to
> avoid programming charges under §552.231(d). For clarity, routine keyword
> searches/filters are not “programming or manipulation”; if you contend
> otherwise, please identify the specific script/process.
>
> 3) Your “viewing” estimate / paper inspection.
> The itemized estimate you sent frames this as “viewing as per your
> request.” For paper records, a deposit for inspection is allowed only in
> the narrow §552.271(c)–(d) scenarios. For ≥16 FTEs: the records must be
> older than five years or fill six+ archival boxes and exceed five hours to
> prepare. For <16 FTEs: three years/three boxes/two hours. Please confirm
> whether your estimate rests on §552.271(c)–(d), and if so, identify which
> prong(s) apply. Otherwise, inspection should be scheduled without these
> charges.
>
> 4) Deposit = copies only.
> You note a deposit received on November 13, 2025. Under §552.263(e), when
> a deposit is properly required, a request for a copy is considered
> “received” on the date the deposit arrives. That rule does not convert an
> inspection into a copy request. Please apply or hold my deposit for any
> copies I later select after inspection, or refund any excess after copy
> fulfillment.
>
> 5) Estimates > $40 must be compliant.
> Any estimate over $40 must comply with §[REDACTED – PARTIAL-PHONE] and 1 TAC §70.7 (full
> itemization; notice of less‑costly options; clear response instructions;
> and an updated statement if the estimate will exceed the original by ≥20%).
> Please ensure any future estimate includes those elements.
>
> 6) What you cannot charge.
> Time for attorney/legal review to decide what to withhold is not a
> recoverable cost. If included in your labor math, please remove it. Please
> also confirm that overhead will not be applied to inspection where no
> inspection charge is permitted. See 1 TAC §70.3(d)(3).
>
> 7) Clarification and timing.
> To avoid unnecessary delay, the request is sufficiently clear as stated.
> If you believe any discrete item is unclear, please identify it
> specifically in a single clarification request and also identify the
> portions you already understand and will produce now. Consistent with *City
> of Dallas v. Abbott* (2010), any AG‑ruling deadline would run from any
> clarification only for the clarified portion; clarification cannot be used
> to extend deadlines indefinitely.
>
> 8) Aggregation / “large‑requestor” policy.
> Please do not aggregate separate‑day requests for cost purposes
> (§552.261(e)). If you intend to apply a “large requestor” policy under
> §552.275, please provide the adopted policy and my cumulative hour ledger
> for this fiscal period.
>
> 9) If you intend to seek an AG ruling.
> If you believe any information is excepted, please timely request a
> decision under §552.301. Otherwise, the information is presumed public
> under §552.302, and non‑contested portions should be released promptly.
> Also, please send me the copy of your written comments to the ORD by the
> 15th business day, as §552.301(e‑1) requires (redacted if your comments
> would reveal the substance of the records).
>
> 10) Scheduling windows.
> For scheduling, I am available to inspect this week during normal business
> hours. My preferred times (Central) are:
> • Wednesday, November 19, 2025: 1:00–5:00 PM
> • Thursday, November 20, 2025: 1:00–5:00 PM
> • Friday, November 21, 2025: 1:00–5:00 PM
> If those are not workable, I can also be available:
> • Monday, November 24, 2025: 1:00–5:00 PM
> • Tuesday, November 25, 2025: 1:00–5:00 PM
> If another weekday afternoon is more convenient, please propose it and I
> will accommodate.
>
> 11) Time for examination.
> Once you make records available, I will complete my review within
> §552.225’s 10‑business‑day window, with any needed written extension.
>
> 12) Segregability & marking of redactions.
> Please release all reasonably segregable, non‑excepted portions and
> identify each redaction by specific statutory authority.
>
> 13) Third‑party notice (if applicable).
> If you invoke §552.305 for proprietary/third‑party interests, please make
> timely notice and let me know the date notices went out.
>
> 14) Preservation.
> Please preserve all potentially responsive records, including ESI, during
> processing. Willful destruction or alteration is an offense under §552.351.
>
> 15) Requestor equipment during inspection.
> I plan to use a phone or portable scanner for copies of non‑confidential
> pages during inspection, consistent with OAG guidance; if you contend this
> would be disruptive or would expose confidential content on mixed pages,
> please identify the specific constraint.
>
> For avoidance of doubt, this message is my timely response under
> §[REDACTED – PARTIAL-PHONE](b) to your November 18, 2025 estimate: I do not accept the quoted
> “viewing” labor charge for inspection; I do not withdraw my request; and I
> am requesting a cost‑compliant itemization and, if programming is claimed,
> a §552.231 statement. Nothing in this email narrows, modifies, or withdraws
> the scope of my request.
>
> Cost‑complaint notice: For completeness, this message also serves as my
> written response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](b)(3) to your November
> 18, 2025 itemized estimate. I have submitted a written cost complaint to
> the Office of the Attorney General under § 552.269 regarding the estimate’s
> charge of 118.64 hours of “viewing” at $15/hour for electronic inspection
> without a § 552.231 programming statement. My request is not withdrawn or
> narrowed. I continue to elect inspection and ask that you proceed promptly
> under §§ 552.221 and 552.272; if you contend programming/manipulation is
> required, please issue the written § 552.231 statement within the statutory
> window.
>
> Best,
>
> Kevin Bass PhD MS
> Phone: *[REDACTED – PHONE]*
>
>
> On Tue, Nov 18, 2025 at 4:56 PM Staugaard, Bronte <
> Bronte.Staugaard@ttu.edu> wrote:
>
>> Good Afternoon,
>>
>>
>>
>> Texas Tech University System (TTUS) is in receipt of your responses to
>> our estimate and your request to inspect the responsive records below. As
>> we previously pointed out, our correspondences sought to clarify or narrow
>> the scope of your requests; however, your subsequent responses generally
>> served to broaden them.
>>
>>
>>
>> Additionally, we received your deposit of $1,934.55 on November 13, 2025,
>> relating to the cost estimate provided on November 3, 2025. However, we
>> also noted your November 4, 2025, response to the cost estimate wherein you
>> requested to inspect the records in person. To ensure we proceed correctly,
>> please confirm if you would prefer to inspect the documentation or be
>> provided copies. Please be advised that, some of the documents or
>> information that you have requested may be withheld under State law. As
>> such, even if a deposit is made, we may request an Attorney General Open
>> Records Decision (“ORD”) seeking to withhold some documents or
>> information pursuant to the Texas Public Information Act.  Texas Government
>> Code § 552.001, et seq.  Once the Attorney General makes a decision
>> regarding the public disclosure of these documents, TTUS will make those
>> documents that are determined by the Attorney General to be public, if any,
>> available for inspection or copying.
>>
>>
>>
>> In response to your request to inspect, we have determined that complying
>> with the request will result in the imposition of a charge that exceeds
>> $40. Therefore, the following statement is provided pursuant to sections
>> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>
>>
>>
>>    1. The requested information is not currently available in a form
>>    suitable for public release, and since the request involves manipulation of
>>    data, documents are not feasible to retrieve, will result in substantial
>>    interference with ongoing operations and can only be provided at a cost
>>    that covers the manipulation of data and other costs, you are entitled to
>>    an estimate of the costs and time to provide the information in the
>>    requested form.
>>
>>
>>
>> Therefore, the itemized statement of estimated charges is:
>>
>>
>>
>> *Labor 118.64 hrs. @ $15/hr. =           $ 1,779.60*
>>
>> *Estimated Total Cost =                     $1,779.60*
>>
>>
>>
>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>    providing you with an alternative, less expensive method of obtaining some
>>    of the requested information.  An alternative method would be to narrow
>>    your request by eliminating some of the data requested, such as narrowing
>>    the date range or information requested. It is usually less expensive to
>>    view the documents here at the office; however, this estimate is for the
>>    cost of viewing as per your request.
>>
>>
>>
>>    3. *Your request will be considered automatically withdrawn if you do
>>    not notify us in writing and within 10 (ten) business days from the date of
>>    this statement that you:*
>>
>>
>>
>>    1. Accept the estimated charges and will pay them.  Because your
>>       request is over $100.00, you are required to either deposit $889.80 (50% of
>>       the estimated costs) or provide TTUS with a bond for the total estimated
>>       cost. *Please note that pursuant to §552.263(e), your request will
>>       be considered received when we receive your payment.  Additionally, if you
>>       fail to pay within 10 business days, your request will be considered
>>       withdrawn pursuant to §552.263(f).*
>>       2. Are modifying the request (state the modification); or
>>       3. Have sent a complaint to the Office of the Attorney General of
>>       Texas alleging that you have been overcharged for a copy of public
>>       information.
>>
>>
>>
>>    4. You may choose to respond by email to me at
>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste. 301
>>    Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the Texas
>>    Tech University System Building, located at 1508 Knoxville Ave., Ste.
>>    301, Lubbock, Tx 79409-2021.
>>
>>
>>
>>    5. Your check, money order, or bond must be made payable to: Texas
>>    Tech University System.
>>
>>
>>
>>    6. If we determine that a change in estimated charges will exceed the
>>    amount in this written itemized statement by 20%, we will send you an
>>    updated written itemized statement. As noted above, the same response
>>    requirements are imposed on you once an updated itemized statement is sent.
>>
>>
>>
>>    7. TTUS expects it to take approximately 3 weeks to complete this
>>    request at current workloads.
>>
>>
>>
>> Sincerely,
>>
>> Brontë C. Staugaard
>>
>> Assistant General Counsel
>>
>> Texas Tech University System
>>
>> (806) [REDACTED – PARTIAL-PHONE]
>>
>>
>>
>> This communication, including any attachments, originates from an
>> Attorney and may contain confidential information and is intended only for
>> the individual or entity to whom it is addressed. Any review,
>> dissemination, or copying of this communication by anyone other than the
>> intended recipient is strictly prohibited. If you are not the intended
>> recipient, please contact the sender by reply e-mail, delete and destroy
>> all copies of the original message.
>>
>>
>>
>> Sincerely,
>>
>> Brontë C. Staugaard
>>
>> Assistant General Counsel
>>
>> Texas Tech University System
>>
>> (806) [REDACTED – PARTIAL-PHONE]
>>
>>
>>
>> This communication, including any attachments, originates from an
>> Attorney and may contain confidential information and is intended only for
>> the individual or entity to whom it is addressed. Any review,
>> dissemination, or copying of this communication by anyone other than the
>> intended recipient is strictly prohibited. If you are not the intended
>> recipient, please contact the sender by reply e-mail, delete and destroy
>> all copies of the original message.
>>
>>
>>
>>
>>
>> *From:* Kevin Bass <kbassphiladelphia@gmail.com>
>> *Sent:* Tuesday, November 4, 2025 8:00 AM
>> *To:* Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
>> *Subject:* Re: Cost Estimate Regarding Responses to TTUS's
>> Clarifications/Narrowings and Additional Request Received on 10.20.2025
>>
>>
>>
>> This email originated outside TTU. Please exercise caution
>> <https://askit.ttu.edu/phishing>!
>>
>>
>>
>> Brontë,
>>
>> This is my timely response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](d).
>>
>> Itemization required. Please issue a corrected, fully itemized estimate
>> that breaks out and supports, by task and rate:
>>
>>    1.
>>    2.
>>    3. Search/collection time (by custodian
>>    4. and data source),
>>    5.
>>    6.
>>    7.
>>    8.
>>    9. Compilation/duplication time,
>>    10.
>>    11.
>>    12.
>>    13.
>>    14. Redaction time (identify the specific
>>    15. mandatory confidentiality provisions), and
>>    16.
>>    17.
>>    18.
>>    19.
>>    20. Any programming/manipulation tasks
>>    21. (use programmer rate and describe the steps).
>>    22. Explicitly exclude attorney
>>    23. review and AG-brief preparation time. See § [REDACTED – PARTIAL-PHONE]; 1 TAC §
>>    70.3(d)(3)–(4), (e). Also confirm overhead ≤ 20% of allowable labor and
>>    note the 20% update rule (issue a new written estimate if actual charges
>>    will exceed the prior estimate by ≥20%).
>>    24.
>>
>> “Programming/manipulation” basis. Your email says the request “involves
>> manipulation of data.” Identify which tasks require programming (coding) or
>> manipulation (human reordering/decoding) as used in the Act, and quantify
>> those hours separately. Using built-in e-discovery/search tools is not
>> “programming.” Inspection of electronic records may not be charged unless
>> programming/manipulation is required (§ 552.272).
>>
>> Aggregation. You say you aggregated my clarification responses and an
>> additional same-day request. List each request you aggregated and provide
>> separate line-item estimates per request. A clarification response is not
>> itself a new “request,” and aggregation should not inflate costs across
>> discrete requests. See § 552.261(e).
>>
>> Phased production to cut costs (my election). Proceed in phases, starting
>> with OGC/PIO custodians (Staugaard, Wall) for Oct 3–31, 2025 using the
>> terms: “Kevin Bass,” “kbassphiladelphia,” “Preservation Notice,” “P3,”
>> “SPPCC,” “professionalism.” After Phase-1 lands, we’ll scope Phase-2
>> (Registrar/Student Life/IT). Re-estimate Phase-1 only.
>>
>> Inspection to minimize charges. For Phase-1, I elect on-site or remote
>> inspection of electronic records in native format where feasible (§
>> 552.272), unless you specifically identify required
>> programming/manipulation (with task detail). If programming is necessary,
>> itemize it and use the programmer rate.
>>
>> Rolling production required. Promptly produce any responsive records not
>> subject to your AG request and any clearly public/segregable information
>> now, while your AG brief is pending. See § 552.221; ORD-664 (2000).
>>
>> Deposit posture. Given the defects in TTUS’s Nov 3 estimate and the
>> magnitude of the proposed deposit, I will not remit any funds unless and
>> until TTUS provides a § [REDACTED – PARTIAL-PHONE]-compliant written itemized statement that
>> sets out task-level hours and rates (search/collection,
>> compilation/duplication, redaction—identifying any mandatory
>> confidentiality—and any programming/manipulation, if applicable) and
>> identifies less-costly alternatives. I am invoking my rights under §
>> 552.269 and will seek Attorney General review of the estimate. For clarity,
>> the 10-business-day withdrawal provision in § [REDACTED – PARTIAL-PHONE](d) is triggered only
>> by a compliant itemized statement with the required notices; any attempt to
>> treat this request as withdrawn before such a statement issues is improper.
>> Likewise, any deposit request under § 552.263(a) must follow and be based
>> on a compliant § [REDACTED – PARTIAL-PHONE] itemized statement. I also elect inspection where
>> it reduces charges, consistent with § 552.272.
>>
>> Please confirm receipt and provide a date/time for initial rolling
>> production of non-exempt material. Also send the revised, itemized Phase-1
>> estimate within 3 business days, so I can respond within the statute’s
>> window.
>>
>> Kevin Bass PhD MS
>>
>> Phone: *[REDACTED – PHONE]*
>>
>>
>>
>>
>>
>> On Mon, Nov 3, 2025 at 4:51 PM Staugaard, Bronte <
>> Bronte.Staugaard@ttu.edu> wrote:
>>
>> Good Afternoon,
>>
>>
>>
>> Texas Tech University System (TTUS) is in receipt of your responses to
>> our clarifications/narrowings and your additional request received on
>> October 20, 2025. The responses and request are attached herein.  Due to
>> our receipt of your responses and request on the same calendar day, we are
>> treating them as a single request for the purposes of calculating costs as
>> permitted under the Texas Government Code.
>>
>>
>>
>> We must also note that while our correspondences sought to clarify or
>> narrow the scope of your requests, your subsequent responses have generally
>> served to broaden them. As such, we have determined that complying with the
>> request will result in the imposition of a charge that exceeds
>> $40. Therefore, the following statement is provided pursuant to sections
>> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>
>>
>>
>>    1. The requested information is not currently available in a form
>>    suitable for public release, and since the request involves manipulation of
>>    data, documents are not feasible to retrieve, will result in substantial
>>    interference with ongoing operations and can only be provided at a cost
>>    that covers the manipulation of data and other costs, you are entitled to
>>    an estimate of the costs and time to provide the information in the
>>    requested form.
>>
>>
>>
>> Therefore, the itemized statement of estimated charges is:
>>
>>
>>
>> Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25
>>
>> *Overhead @ 20% =                            $ 644.85             *
>>
>>
>> *Estimated Total Cost =                     $3,869.10*
>>
>>
>>
>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>    providing you with an alternative, less expensive method of obtaining some
>>    of the requested information.  An alternative method would be to narrow
>>    your request by eliminating some of the data requested, such as narrowing
>>    the date range or information requested. It may also be less expensive to
>>    view the documents here at the office.
>>
>>
>>
>>    3. *Your request will be considered automatically withdrawn if you do
>>    not notify us in writing and within 10 (ten) business days from the date of
>>    this statement that you:*
>>
>>
>>
>>    1. Accept the estimated charges and will pay them.  Because your
>>       request is over $100.00, you are required to either deposit $1,934.55 (50%
>>       of the estimated costs) or provide TTUS with a bond for the total estimated
>>       cost. *Please note that pursuant to §552.263(e), your request will
>>       be considered received when we receive your payment.  Additionally, if you
>>       fail to pay within 10 business days, your request will be considered
>>       withdrawn pursuant to §552.263(f).*
>>       2. Are modifying the request (state the modification); or
>>       3. Have sent a complaint to the Office of the Attorney General of
>>       Texas alleging that you have been overcharged for a copy of public
>>       information.
>>
>>
>>
>>    4. You may choose to respond by email to me at
>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste. 301
>>    Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the Texas
>>    Tech University System Building, located at 1508 Knoxville Ave., Ste.
>>    301, Lubbock, Tx 79409-2021.
>>
>>
>>
>>    5. Your check, money order, or bond must be made payable to: Texas
>>    Tech University System.
>>
>>
>>
>>    6. If we determine that a change in estimated charges will exceed the
>>    amount in this written itemized statement by 20%, we will send you an
>>    updated written itemized statement. As noted above, the same response
>>    requirements are imposed on you once an updated itemized statement is sent.
>>
>>
>>
>>    7. TTUS expects it to take approximately 2 weeks to complete this
>>    request at current workloads.
>>
>>
>>
>> Finally, some of the documents or information that you have requested may
>> be withheld under State law.  Therefore, if you choose to pay the deposit,
>> we may request an Attorney General Open Records Decision (“ORD”) seeking to
>> withhold some documents or information pursuant to the Texas Public
>> Information Act.  Texas Government Code § 552.001, et seq.  Once the
>> Attorney General makes a decision regarding the public disclosure of these
>> documents, TTUS will make those documents that are determined by the
>> Attorney General to be public, if any, available for inspection or copying.
>>
>>
>>
>> Sincerely,
>>
>> Brontë C. Staugaard
>>
>> Assistant General Counsel
>>
>> Texas Tech University System
>>
>> (806) [REDACTED – PARTIAL-PHONE]
>>
>>
>>
>> This communication, including any attachments, originates from an
>> Attorney and may contain confidential information and is intended only for
>> the individual or entity to whom it is addressed. Any review,
>> dissemination, or copying of this communication by anyone other than the
>> intended recipient is strictly prohibited. If you are not the intended
>> recipient, please contact the sender by reply e-mail, delete and destroy
>> all copies of the original message.
>>
>>
>>
>>
>>
>>

Counsel Staugaard,

I’m writing to provide a courtesy copy of a supplemental cost complaint I
submitted today to the Office of the Attorney General under Tex. Gov’t Code
§ 552.269 regarding TTUS’s November 3 and November 18, 2025 cost estimates
for my October 3 and October 20, 2025 TPIA requests. The supplemental
filing was submitted in Service Request No. OR-25-053696-CC.

The attachments mirror what I sent to the Attorney General:

A supplemental § 552.269 complaint letter describing why I believe the
November 3 and November 18 estimates are not compliant with § [REDACTED – PARTIAL-PHONE], §
552.263, and the cost rules.

Exhibit A – TTUS Cost Estimate & Responses (Nov. 3–19, 2025), which
compiles the email thread between your office and me regarding the initial
cost estimate, my November 4 inspection election, my November 13 deposit
(tendered under protest), the November 18 “viewing” estimate, and my
November 19 responses and cost-complaint notice.

Exhibit B – Original TPIA Requests and Clarifications, consisting of the
October 3 metadata-based TPIA requests and the October 20 “Records Showing
How You Handled My Requests (Existing Process Docs Only)” request that TTUS
aggregated for the estimates.

Exhibit C-1 – 2025-11-19_Supporting_Docs.pdf (the previously submitted
supporting emails and documents related to the November 3 and November 18
estimates).

Exhibit C-2 –
2025-10-20_PIA_Records_Showing_Handling_Existing_Process_Docs.docx (the
October 20, 2025 “Records Showing How You Handled My Requests (Existing
Process Docs Only)” TPIA request), resubmitted so TTUS has the same
process-docs request that is before the Attorney General.

This correspondence is for notice only. It does not withdraw or narrow any
of my TPIA requests, and it does not change my election to inspect
electronic records where that is less costly. As in my prior emails, I am
asking TTUS either to issue a fully itemized, task-level estimate that
complies with § [REDACTED – PARTIAL-PHONE] and the cost rules, or to proceed with inspection
under §§ 552.221 and 552.272 while the Attorney General reviews the
challenged charges.

I remain willing to work in good faith on any reasonable narrowing or
phased production that materially reduces costs while preserving access to
the core records.

Best regards,

Kevin Bass PhD MS
Phone: *[REDACTED – PHONE]*


On Wed, Nov 19, 2025 at 3:36 PM Kevin Bass <kbassphiladelphia@gmail.com>
wrote:

> Counsel Staugaard — for clarity, the $1,934.55 paid on Nov 13 was the 50%
> deposit for TTUS’s Nov 3 copy estimate and must not be applied to the
> Nov 18 “viewing” estimate. I have submitted a §552.269 cost complaint
> regarding the Nov 18 estimate; this serves as my §[REDACTED – PARTIAL-PHONE](b)(3) response,
> so the request is not withdrawn. Please schedule an inspection (or provide
> the §552.221(c) active‑use/storage certification with an appointment date),
> and if you contend programming/manipulation is required, issue the §552.231
> statement with task, staff category, time, and cost. Please also provide a
> simple statement of account showing deposits held and what estimate each
> deposit is tied to.
> Kevin Bass PhD MS
> Phone: *[REDACTED – PHONE]*
>
>
> On Wed, Nov 19, 2025 at 12:38 PM Kevin Bass <kbassphiladelphia@gmail.com>
> wrote:
>
>> Hello Counsel Staugaard,
>>
>> This confirms my request remains an inspection request and is not a
>> request for copies at this time. No explanation of purpose is required;
>> please treat this request uniformly under the Act.
>>
>> 1) Inspection first (no copies yet).
>> I elect to inspect the responsive records. Please set a date and hour for
>> in‑person inspection within a reasonable time (or certify active
>> use/storage and give the inspection appointment date) as required by Tex.
>> Gov’t Code §552.221(c)–(d). Please also comply with §552.221(a)’s
>> requirement to *promptly* produce non‑contested records “as soon as
>> possible.” If the records are ready sooner, please just confirm a time and
>> the location. In the meantime, please begin rolling production of any
>> portions that are readily available now. If you contend any portion is in
>> active use or storage, please identify those records and provide the
>> certification required by §552.221(c) together with the appointment date.
>>
>> 2) Electronic records: no charge to inspect absent
>> programming/manipulation + §552.231 statement.
>> For information that exists in an electronic medium, access for
>> inspection may not be charged unless you must perform programming or
>> manipulation of data. If you believe that is required, please send the
>> written §552.231 statement that (a) says the data is not available in the
>> requested form, (b) describes the form in which it is available, (c) lists
>> any contracts/services needed, and (d) gives the estimated cost and
>> time—within the statute’s 20‑day window (30 with notice). If the only
>> reason programming is needed is to convert records into a different format,
>> I will accept the information in the form in which it is currently
>> available to avoid programming charges under §552.231(d). For clarity,
>> routine keyword searches/filters are not “programming or manipulation”; if
>> you contend otherwise, please identify the specific script/process.
>>
>> 3) Your “viewing” estimate / paper inspection.
>> The itemized estimate you sent frames this as “viewing as per your
>> request.” For paper records, a deposit for inspection is allowed only in
>> the narrow §552.271(c)–(d) scenarios. For ≥16 FTEs: the records must be
>> older than five years or fill six+ archival boxes and exceed five hours to
>> prepare. For <16 FTEs: three years/three boxes/two hours. Please confirm
>> whether your estimate rests on §552.271(c)–(d), and if so, identify which
>> prong(s) apply. Otherwise, inspection should be scheduled without these
>> charges.
>>
>> 4) Deposit = copies only.
>> You note a deposit received on November 13, 2025. Under §552.263(e), when
>> a deposit is properly required, a request for a copy is considered
>> “received” on the date the deposit arrives. That rule does not convert an
>> inspection into a copy request. Please apply or hold my deposit for any
>> copies I later select after inspection, or refund any excess after copy
>> fulfillment.
>>
>> 5) Estimates > $40 must be compliant.
>> Any estimate over $40 must comply with §[REDACTED – PARTIAL-PHONE] and 1 TAC §70.7 (full
>> itemization; notice of less‑costly options; clear response instructions;
>> and an updated statement if the estimate will exceed the original by ≥20%).
>> Please ensure any future estimate includes those elements.
>>
>> 6) What you cannot charge.
>> Time for attorney/legal review to decide what to withhold is not a
>> recoverable cost. If included in your labor math, please remove it. Please
>> also confirm that overhead will not be applied to inspection where no
>> inspection charge is permitted. See 1 TAC §70.3(d)(3).
>>
>> 7) Clarification and timing.
>> To avoid unnecessary delay, the request is sufficiently clear as stated.
>> If you believe any discrete item is unclear, please identify it
>> specifically in a single clarification request and also identify the
>> portions you already understand and will produce now. Consistent with *City
>> of Dallas v. Abbott* (2010), any AG‑ruling deadline would run from any
>> clarification only for the clarified portion; clarification cannot be used
>> to extend deadlines indefinitely.
>>
>> 8) Aggregation / “large‑requestor” policy.
>> Please do not aggregate separate‑day requests for cost purposes
>> (§552.261(e)). If you intend to apply a “large requestor” policy under
>> §552.275, please provide the adopted policy and my cumulative hour ledger
>> for this fiscal period.
>>
>> 9) If you intend to seek an AG ruling.
>> If you believe any information is excepted, please timely request a
>> decision under §552.301. Otherwise, the information is presumed public
>> under §552.302, and non‑contested portions should be released promptly.
>> Also, please send me the copy of your written comments to the ORD by the
>> 15th business day, as §552.301(e‑1) requires (redacted if your comments
>> would reveal the substance of the records).
>>
>> 10) Scheduling windows.
>> For scheduling, I am available to inspect this week during normal
>> business hours. My preferred times (Central) are:
>> • Wednesday, November 19, 2025: 1:00–5:00 PM
>> • Thursday, November 20, 2025: 1:00–5:00 PM
>> • Friday, November 21, 2025: 1:00–5:00 PM
>> If those are not workable, I can also be available:
>> • Monday, November 24, 2025: 1:00–5:00 PM
>> • Tuesday, November 25, 2025: 1:00–5:00 PM
>> If another weekday afternoon is more convenient, please propose it and I
>> will accommodate.
>>
>> 11) Time for examination.
>> Once you make records available, I will complete my review within
>> §552.225’s 10‑business‑day window, with any needed written extension.
>>
>> 12) Segregability & marking of redactions.
>> Please release all reasonably segregable, non‑excepted portions and
>> identify each redaction by specific statutory authority.
>>
>> 13) Third‑party notice (if applicable).
>> If you invoke §552.305 for proprietary/third‑party interests, please make
>> timely notice and let me know the date notices went out.
>>
>> 14) Preservation.
>> Please preserve all potentially responsive records, including ESI, during
>> processing. Willful destruction or alteration is an offense under §552.351.
>>
>> 15) Requestor equipment during inspection.
>> I plan to use a phone or portable scanner for copies of non‑confidential
>> pages during inspection, consistent with OAG guidance; if you contend this
>> would be disruptive or would expose confidential content on mixed pages,
>> please identify the specific constraint.
>>
>> For avoidance of doubt, this message is my timely response under
>> §[REDACTED – PARTIAL-PHONE](b) to your November 18, 2025 estimate: I do not accept the quoted
>> “viewing” labor charge for inspection; I do not withdraw my request; and I
>> am requesting a cost‑compliant itemization and, if programming is claimed,
>> a §552.231 statement. Nothing in this email narrows, modifies, or withdraws
>> the scope of my request.
>>
>> Cost‑complaint notice: For completeness, this message also serves as my
>> written response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](b)(3) to your November
>> 18, 2025 itemized estimate. I have submitted a written cost complaint to
>> the Office of the Attorney General under § 552.269 regarding the estimate’s
>> charge of 118.64 hours of “viewing” at $15/hour for electronic inspection
>> without a § 552.231 programming statement. My request is not withdrawn or
>> narrowed. I continue to elect inspection and ask that you proceed promptly
>> under §§ 552.221 and 552.272; if you contend programming/manipulation is
>> required, please issue the written § 552.231 statement within the statutory
>> window.
>>
>> Best,
>>
>> Kevin Bass PhD MS
>> Phone: *[REDACTED – PHONE]*
>>
>>
>> On Tue, Nov 18, 2025 at 4:56 PM Staugaard, Bronte <
>> Bronte.Staugaard@ttu.edu> wrote:
>>
>>> Good Afternoon,
>>>
>>>
>>>
>>> Texas Tech University System (TTUS) is in receipt of your responses to
>>> our estimate and your request to inspect the responsive records below. As
>>> we previously pointed out, our correspondences sought to clarify or narrow
>>> the scope of your requests; however, your subsequent responses generally
>>> served to broaden them.
>>>
>>>
>>>
>>> Additionally, we received your deposit of $1,934.55 on November 13,
>>> 2025, relating to the cost estimate provided on November 3, 2025. However,
>>> we also noted your November 4, 2025, response to the cost estimate wherein
>>> you requested to inspect the records in person. To ensure we proceed
>>> correctly, please confirm if you would prefer to inspect the documentation
>>> or be provided copies. Please be advised that, some of the documents or
>>> information that you have requested may be withheld under State law. As
>>> such, even if a deposit is made, we may request an Attorney General Open
>>> Records Decision (“ORD”) seeking to withhold some documents or
>>> information pursuant to the Texas Public Information Act.  Texas Government
>>> Code § 552.001, et seq.  Once the Attorney General makes a decision
>>> regarding the public disclosure of these documents, TTUS will make those
>>> documents that are determined by the Attorney General to be public, if any,
>>> available for inspection or copying.
>>>
>>>
>>>
>>> In response to your request to inspect, we have determined that
>>> complying with the request will result in the imposition of a charge that
>>> exceeds $40. Therefore, the following statement is provided pursuant to
>>> sections [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>>
>>>
>>>
>>>    1. The requested information is not currently available in a form
>>>    suitable for public release, and since the request involves manipulation of
>>>    data, documents are not feasible to retrieve, will result in substantial
>>>    interference with ongoing operations and can only be provided at a cost
>>>    that covers the manipulation of data and other costs, you are entitled to
>>>    an estimate of the costs and time to provide the information in the
>>>    requested form.
>>>
>>>
>>>
>>> Therefore, the itemized statement of estimated charges is:
>>>
>>>
>>>
>>> *Labor 118.64 hrs. @ $15/hr. =           $ 1,779.60*
>>>
>>> *Estimated Total Cost =                     $1,779.60*
>>>
>>>
>>>
>>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>>    providing you with an alternative, less expensive method of obtaining some
>>>    of the requested information.  An alternative method would be to narrow
>>>    your request by eliminating some of the data requested, such as narrowing
>>>    the date range or information requested. It is usually less expensive to
>>>    view the documents here at the office; however, this estimate is for the
>>>    cost of viewing as per your request.
>>>
>>>
>>>
>>>    3. *Your request will be considered automatically withdrawn if you
>>>    do not notify us in writing and within 10 (ten) business days from the date
>>>    of this statement that you:*
>>>
>>>
>>>
>>>    1. Accept the estimated charges and will pay them.  Because your
>>>       request is over $100.00, you are required to either deposit $889.80 (50% of
>>>       the estimated costs) or provide TTUS with a bond for the total estimated
>>>       cost. *Please note that pursuant to §552.263(e), your request
>>>       will be considered received when we receive your payment.  Additionally, if
>>>       you fail to pay within 10 business days, your request will be considered
>>>       withdrawn pursuant to §552.263(f).*
>>>       2. Are modifying the request (state the modification); or
>>>       3. Have sent a complaint to the Office of the Attorney General of
>>>       Texas alleging that you have been overcharged for a copy of public
>>>       information.
>>>
>>>
>>>
>>>    4. You may choose to respond by email to me at
>>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste.
>>>    301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the
>>>    Texas Tech University System Building, located at 1508 Knoxville
>>>    Ave., Ste. 301, Lubbock, Tx 79409-2021.
>>>
>>>
>>>
>>>    5. Your check, money order, or bond must be made payable to: Texas
>>>    Tech University System.
>>>
>>>
>>>
>>>    6. If we determine that a change in estimated charges will exceed
>>>    the amount in this written itemized statement by 20%, we will send you an
>>>    updated written itemized statement. As noted above, the same response
>>>    requirements are imposed on you once an updated itemized statement is sent.
>>>
>>>
>>>
>>>    7. TTUS expects it to take approximately 3 weeks to complete this
>>>    request at current workloads.
>>>
>>>
>>>
>>> Sincerely,
>>>
>>> Brontë C. Staugaard
>>>
>>> Assistant General Counsel
>>>
>>> Texas Tech University System
>>>
>>> (806) [REDACTED – PARTIAL-PHONE]
>>>
>>>
>>>
>>> This communication, including any attachments, originates from an
>>> Attorney and may contain confidential information and is intended only for
>>> the individual or entity to whom it is addressed. Any review,
>>> dissemination, or copying of this communication by anyone other than the
>>> intended recipient is strictly prohibited. If you are not the intended
>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>> all copies of the original message.
>>>
>>>
>>>
>>> Sincerely,
>>>
>>> Brontë C. Staugaard
>>>
>>> Assistant General Counsel
>>>
>>> Texas Tech University System
>>>
>>> (806) [REDACTED – PARTIAL-PHONE]
>>>
>>>
>>>
>>> This communication, including any attachments, originates from an
>>> Attorney and may contain confidential information and is intended only for
>>> the individual or entity to whom it is addressed. Any review,
>>> dissemination, or copying of this communication by anyone other than the
>>> intended recipient is strictly prohibited. If you are not the intended
>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>> all copies of the original message.
>>>
>>>
>>>
>>>
>>>
>>> *From:* Kevin Bass <kbassphiladelphia@gmail.com>
>>> *Sent:* Tuesday, November 4, 2025 8:00 AM
>>> *To:* Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
>>> *Subject:* Re: Cost Estimate Regarding Responses to TTUS's
>>> Clarifications/Narrowings and Additional Request Received on 10.20.2025
>>>
>>>
>>>
>>> This email originated outside TTU. Please exercise caution
>>> <https://askit.ttu.edu/phishing>!
>>>
>>>
>>>
>>> Brontë,
>>>
>>> This is my timely response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](d).
>>>
>>> Itemization required. Please issue a corrected, fully itemized estimate
>>> that breaks out and supports, by task and rate:
>>>
>>>    1.
>>>    2.
>>>    3. Search/collection time (by custodian
>>>    4. and data source),
>>>    5.
>>>    6.
>>>    7.
>>>    8.
>>>    9. Compilation/duplication time,
>>>    10.
>>>    11.
>>>    12.
>>>    13.
>>>    14. Redaction time (identify the specific
>>>    15. mandatory confidentiality provisions), and
>>>    16.
>>>    17.
>>>    18.
>>>    19.
>>>    20. Any programming/manipulation tasks
>>>    21. (use programmer rate and describe the steps).
>>>    22. Explicitly exclude attorney
>>>    23. review and AG-brief preparation time. See § [REDACTED – PARTIAL-PHONE]; 1 TAC §
>>>    70.3(d)(3)–(4), (e). Also confirm overhead ≤ 20% of allowable labor and
>>>    note the 20% update rule (issue a new written estimate if actual charges
>>>    will exceed the prior estimate by ≥20%).
>>>    24.
>>>
>>> “Programming/manipulation” basis. Your email says the request “involves
>>> manipulation of data.” Identify which tasks require programming (coding) or
>>> manipulation (human reordering/decoding) as used in the Act, and quantify
>>> those hours separately. Using built-in e-discovery/search tools is not
>>> “programming.” Inspection of electronic records may not be charged unless
>>> programming/manipulation is required (§ 552.272).
>>>
>>> Aggregation. You say you aggregated my clarification responses and an
>>> additional same-day request. List each request you aggregated and provide
>>> separate line-item estimates per request. A clarification response is not
>>> itself a new “request,” and aggregation should not inflate costs across
>>> discrete requests. See § 552.261(e).
>>>
>>> Phased production to cut costs (my election). Proceed in phases,
>>> starting with OGC/PIO custodians (Staugaard, Wall) for Oct 3–31, 2025 using
>>> the terms: “Kevin Bass,” “kbassphiladelphia,” “Preservation Notice,” “P3,”
>>> “SPPCC,” “professionalism.” After Phase-1 lands, we’ll scope Phase-2
>>> (Registrar/Student Life/IT). Re-estimate Phase-1 only.
>>>
>>> Inspection to minimize charges. For Phase-1, I elect on-site or remote
>>> inspection of electronic records in native format where feasible (§
>>> 552.272), unless you specifically identify required
>>> programming/manipulation (with task detail). If programming is necessary,
>>> itemize it and use the programmer rate.
>>>
>>> Rolling production required. Promptly produce any responsive records not
>>> subject to your AG request and any clearly public/segregable information
>>> now, while your AG brief is pending. See § 552.221; ORD-664 (2000).
>>>
>>> Deposit posture. Given the defects in TTUS’s Nov 3 estimate and the
>>> magnitude of the proposed deposit, I will not remit any funds unless and
>>> until TTUS provides a § [REDACTED – PARTIAL-PHONE]-compliant written itemized statement that
>>> sets out task-level hours and rates (search/collection,
>>> compilation/duplication, redaction—identifying any mandatory
>>> confidentiality—and any programming/manipulation, if applicable) and
>>> identifies less-costly alternatives. I am invoking my rights under §
>>> 552.269 and will seek Attorney General review of the estimate. For clarity,
>>> the 10-business-day withdrawal provision in § [REDACTED – PARTIAL-PHONE](d) is triggered only
>>> by a compliant itemized statement with the required notices; any attempt to
>>> treat this request as withdrawn before such a statement issues is improper.
>>> Likewise, any deposit request under § 552.263(a) must follow and be based
>>> on a compliant § [REDACTED – PARTIAL-PHONE] itemized statement. I also elect inspection where
>>> it reduces charges, consistent with § 552.272.
>>>
>>> Please confirm receipt and provide a date/time for initial rolling
>>> production of non-exempt material. Also send the revised, itemized Phase-1
>>> estimate within 3 business days, so I can respond within the statute’s
>>> window.
>>>
>>> Kevin Bass PhD MS
>>>
>>> Phone: *[REDACTED – PHONE]*
>>>
>>>
>>>
>>>
>>>
>>> On Mon, Nov 3, 2025 at 4:51 PM Staugaard, Bronte <
>>> Bronte.Staugaard@ttu.edu> wrote:
>>>
>>> Good Afternoon,
>>>
>>>
>>>
>>> Texas Tech University System (TTUS) is in receipt of your responses to
>>> our clarifications/narrowings and your additional request received on
>>> October 20, 2025. The responses and request are attached herein.  Due to
>>> our receipt of your responses and request on the same calendar day, we are
>>> treating them as a single request for the purposes of calculating costs as
>>> permitted under the Texas Government Code.
>>>
>>>
>>>
>>> We must also note that while our correspondences sought to clarify or
>>> narrow the scope of your requests, your subsequent responses have generally
>>> served to broaden them. As such, we have determined that complying with the
>>> request will result in the imposition of a charge that exceeds
>>> $40. Therefore, the following statement is provided pursuant to sections
>>> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>>
>>>
>>>
>>>    1. The requested information is not currently available in a form
>>>    suitable for public release, and since the request involves manipulation of
>>>    data, documents are not feasible to retrieve, will result in substantial
>>>    interference with ongoing operations and can only be provided at a cost
>>>    that covers the manipulation of data and other costs, you are entitled to
>>>    an estimate of the costs and time to provide the information in the
>>>    requested form.
>>>
>>>
>>>
>>> Therefore, the itemized statement of estimated charges is:
>>>
>>>
>>>
>>> Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25
>>>
>>> *Overhead @ 20% =                            $ 644.85             *
>>>
>>>
>>> *Estimated Total Cost =                     $3,869.10*
>>>
>>>
>>>
>>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>>    providing you with an alternative, less expensive method of obtaining some
>>>    of the requested information.  An alternative method would be to narrow
>>>    your request by eliminating some of the data requested, such as narrowing
>>>    the date range or information requested. It may also be less expensive to
>>>    view the documents here at the office.
>>>
>>>
>>>
>>>    3. *Your request will be considered automatically withdrawn if you
>>>    do not notify us in writing and within 10 (ten) business days from the date
>>>    of this statement that you:*
>>>
>>>
>>>
>>>    1. Accept the estimated charges and will pay them.  Because your
>>>       request is over $100.00, you are required to either deposit $1,934.55 (50%
>>>       of the estimated costs) or provide TTUS with a bond for the total estimated
>>>       cost. *Please note that pursuant to §552.263(e), your request
>>>       will be considered received when we receive your payment.  Additionally, if
>>>       you fail to pay within 10 business days, your request will be considered
>>>       withdrawn pursuant to §552.263(f).*
>>>       2. Are modifying the request (state the modification); or
>>>       3. Have sent a complaint to the Office of the Attorney General of
>>>       Texas alleging that you have been overcharged for a copy of public
>>>       information.
>>>
>>>
>>>
>>>    4. You may choose to respond by email to me at
>>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste.
>>>    301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the
>>>    Texas Tech University System Building, located at 1508 Knoxville
>>>    Ave., Ste. 301, Lubbock, Tx 79409-2021.
>>>
>>>
>>>
>>>    5. Your check, money order, or bond must be made payable to: Texas
>>>    Tech University System.
>>>
>>>
>>>
>>>    6. If we determine that a change in estimated charges will exceed
>>>    the amount in this written itemized statement by 20%, we will send you an
>>>    updated written itemized statement. As noted above, the same response
>>>    requirements are imposed on you once an updated itemized statement is sent.
>>>
>>>
>>>
>>>    7. TTUS expects it to take approximately 2 weeks to complete this
>>>    request at current workloads.
>>>
>>>
>>>
>>> Finally, some of the documents or information that you have requested
>>> may be withheld under State law.  Therefore, if you choose to pay the
>>> deposit, we may request an Attorney General Open Records Decision (“ORD”)
>>> seeking to withhold some documents or information pursuant to the Texas
>>> Public Information Act.  Texas Government Code § 552.001, et seq.  Once the
>>> Attorney General makes a decision regarding the public disclosure of these
>>> documents, TTUS will make those documents that are determined by the
>>> Attorney General to be public, if any, available for inspection or copying.
>>>
>>>
>>>
>>> Sincerely,
>>>
>>> Brontë C. Staugaard
>>>
>>> Assistant General Counsel
>>>
>>> Texas Tech University System
>>>
>>> (806) [REDACTED – PARTIAL-PHONE]
>>>
>>>
>>>
>>> This communication, including any attachments, originates from an
>>> Attorney and may contain confidential information and is intended only for
>>> the individual or entity to whom it is addressed. Any review,
>>> dissemination, or copying of this communication by anyone other than the
>>> intended recipient is strictly prohibited. If you are not the intended
>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>> all copies of the original message.
>>>
>>>
>>>
>>>
>>>
>>>

Hi Counsel Staugaard,

Earlier today (December 9, 2025), I was informed that the 50% deposit check
for $1,934.55 that I hand-delivered to your office on November 13, 2025 in
response to TTUS’s November 3, 2025 cost estimate was returned by the bank
due to insufficient funds after money had been moved out of that account.
The non-payment was inadvertent.

On November 13, 2025, I timely tendered that 50% deposit within ten
business days of the November 3 estimate. To immediately cure the bank’s
return of that check and avoid any argument that my requests were
“withdrawn” under Gov’t Code § 552.263(f), today, December 9, 2025, I *will
hand-deliver* a replacement check in the same amount, $1,934.55, payable to
Texas Tech University System, together with a replacement cover letter.

As explained in the attached cover letter, this replacement 50% deposit is
tendered UNDER PROTEST. It does not narrow or modify the scope of my
existing TPIA requests. It is intended to maintain and continue the deposit
that was timely tendered on November 13, 2025, and to cure the bank’s
return of that check. My requests should not be treated as withdrawn; this
simply ensures that the deposit requirement remains satisfied.

Please apply this replacement deposit under the same Phase-1 sequencing
described in my November 13 cover letter (Title IX/Student-Conduct finals,
P3 professionalism finals for AY 2022–23 and AY 2023–24,
Transcript/Title-IV finals, existing handling/process artifacts, and
relevant retention/hold policies under § 552.022(a)). I am continuing to
pursue a cost complaint under Gov’t Code § 552.269 regarding the November 3
estimate; that complaint and this deposit should not suspend TTUS’s duty to
promptly produce non-excepted records on a rolling basis.

If there is any lawful returned-check processing fee associated with the
bank’s return of the original check, please itemize it and send me an
invoice so that I can address it promptly.

Please confirm in writing that you have received and applied this
replacement deposit and confirm the date/time for the first Phase-1 release.

For your convenience, I have attached a copy of the replacement cover
letter and a photo of the replacement check.

Thank you,
Kevin Bass
Kevin Bass PhD MS
Phone: *[REDACTED – PHONE]*


On Wed, Nov 26, 2025 at 10:29 PM Kevin Bass <kbassphiladelphia@gmail.com>
wrote:

> Counsel Staugaard,
>
> I’m writing to provide a courtesy copy of a supplemental cost complaint I
> submitted today to the Office of the Attorney General under Tex. Gov’t Code
> § 552.269 regarding TTUS’s November 3 and November 18, 2025 cost estimates
> for my October 3 and October 20, 2025 TPIA requests. The supplemental
> filing was submitted in Service Request No. OR-25-053696-CC.
>
> The attachments mirror what I sent to the Attorney General:
>
> A supplemental § 552.269 complaint letter describing why I believe the
> November 3 and November 18 estimates are not compliant with § [REDACTED – PARTIAL-PHONE], §
> 552.263, and the cost rules.
>
> Exhibit A – TTUS Cost Estimate & Responses (Nov. 3–19, 2025), which
> compiles the email thread between your office and me regarding the initial
> cost estimate, my November 4 inspection election, my November 13 deposit
> (tendered under protest), the November 18 “viewing” estimate, and my
> November 19 responses and cost-complaint notice.
>
> Exhibit B – Original TPIA Requests and Clarifications, consisting of the
> October 3 metadata-based TPIA requests and the October 20 “Records Showing
> How You Handled My Requests (Existing Process Docs Only)” request that TTUS
> aggregated for the estimates.
>
> Exhibit C-1 – 2025-11-19_Supporting_Docs.pdf (the previously submitted
> supporting emails and documents related to the November 3 and November 18
> estimates).
>
> Exhibit C-2 –
> 2025-10-20_PIA_Records_Showing_Handling_Existing_Process_Docs.docx (the
> October 20, 2025 “Records Showing How You Handled My Requests (Existing
> Process Docs Only)” TPIA request), resubmitted so TTUS has the same
> process-docs request that is before the Attorney General.
>
> This correspondence is for notice only. It does not withdraw or narrow any
> of my TPIA requests, and it does not change my election to inspect
> electronic records where that is less costly. As in my prior emails, I am
> asking TTUS either to issue a fully itemized, task-level estimate that
> complies with § [REDACTED – PARTIAL-PHONE] and the cost rules, or to proceed with inspection
> under §§ 552.221 and 552.272 while the Attorney General reviews the
> challenged charges.
>
> I remain willing to work in good faith on any reasonable narrowing or
> phased production that materially reduces costs while preserving access to
> the core records.
>
> Best regards,
>
> Kevin Bass PhD MS
> Phone: *[REDACTED – PHONE]*
>
>
> On Wed, Nov 19, 2025 at 3:36 PM Kevin Bass <kbassphiladelphia@gmail.com>
> wrote:
>
>> Counsel Staugaard — for clarity, the $1,934.55 paid on Nov 13 was the 50%
>> deposit for TTUS’s Nov 3 copy estimate and must not be applied to the
>> Nov 18 “viewing” estimate. I have submitted a §552.269 cost complaint
>> regarding the Nov 18 estimate; this serves as my §[REDACTED – PARTIAL-PHONE](b)(3) response,
>> so the request is not withdrawn. Please schedule an inspection (or provide
>> the §552.221(c) active‑use/storage certification with an appointment date),
>> and if you contend programming/manipulation is required, issue the §552.231
>> statement with task, staff category, time, and cost. Please also provide a
>> simple statement of account showing deposits held and what estimate each
>> deposit is tied to.
>> Kevin Bass PhD MS
>> Phone: *[REDACTED – PHONE]*
>>
>>
>> On Wed, Nov 19, 2025 at 12:38 PM Kevin Bass <kbassphiladelphia@gmail.com>
>> wrote:
>>
>>> Hello Counsel Staugaard,
>>>
>>> This confirms my request remains an inspection request and is not a
>>> request for copies at this time. No explanation of purpose is required;
>>> please treat this request uniformly under the Act.
>>>
>>> 1) Inspection first (no copies yet).
>>> I elect to inspect the responsive records. Please set a date and hour
>>> for in‑person inspection within a reasonable time (or certify active
>>> use/storage and give the inspection appointment date) as required by Tex.
>>> Gov’t Code §552.221(c)–(d). Please also comply with §552.221(a)’s
>>> requirement to *promptly* produce non‑contested records “as soon as
>>> possible.” If the records are ready sooner, please just confirm a time and
>>> the location. In the meantime, please begin rolling production of any
>>> portions that are readily available now. If you contend any portion is in
>>> active use or storage, please identify those records and provide the
>>> certification required by §552.221(c) together with the appointment date.
>>>
>>> 2) Electronic records: no charge to inspect absent
>>> programming/manipulation + §552.231 statement.
>>> For information that exists in an electronic medium, access for
>>> inspection may not be charged unless you must perform programming or
>>> manipulation of data. If you believe that is required, please send the
>>> written §552.231 statement that (a) says the data is not available in the
>>> requested form, (b) describes the form in which it is available, (c) lists
>>> any contracts/services needed, and (d) gives the estimated cost and
>>> time—within the statute’s 20‑day window (30 with notice). If the only
>>> reason programming is needed is to convert records into a different format,
>>> I will accept the information in the form in which it is currently
>>> available to avoid programming charges under §552.231(d). For clarity,
>>> routine keyword searches/filters are not “programming or manipulation”; if
>>> you contend otherwise, please identify the specific script/process.
>>>
>>> 3) Your “viewing” estimate / paper inspection.
>>> The itemized estimate you sent frames this as “viewing as per your
>>> request.” For paper records, a deposit for inspection is allowed only in
>>> the narrow §552.271(c)–(d) scenarios. For ≥16 FTEs: the records must be
>>> older than five years or fill six+ archival boxes and exceed five hours to
>>> prepare. For <16 FTEs: three years/three boxes/two hours. Please confirm
>>> whether your estimate rests on §552.271(c)–(d), and if so, identify which
>>> prong(s) apply. Otherwise, inspection should be scheduled without these
>>> charges.
>>>
>>> 4) Deposit = copies only.
>>> You note a deposit received on November 13, 2025. Under §552.263(e),
>>> when a deposit is properly required, a request for a copy is considered
>>> “received” on the date the deposit arrives. That rule does not convert an
>>> inspection into a copy request. Please apply or hold my deposit for any
>>> copies I later select after inspection, or refund any excess after copy
>>> fulfillment.
>>>
>>> 5) Estimates > $40 must be compliant.
>>> Any estimate over $40 must comply with §[REDACTED – PARTIAL-PHONE] and 1 TAC §70.7 (full
>>> itemization; notice of less‑costly options; clear response instructions;
>>> and an updated statement if the estimate will exceed the original by ≥20%).
>>> Please ensure any future estimate includes those elements.
>>>
>>> 6) What you cannot charge.
>>> Time for attorney/legal review to decide what to withhold is not a
>>> recoverable cost. If included in your labor math, please remove it. Please
>>> also confirm that overhead will not be applied to inspection where no
>>> inspection charge is permitted. See 1 TAC §70.3(d)(3).
>>>
>>> 7) Clarification and timing.
>>> To avoid unnecessary delay, the request is sufficiently clear as stated.
>>> If you believe any discrete item is unclear, please identify it
>>> specifically in a single clarification request and also identify the
>>> portions you already understand and will produce now. Consistent with *City
>>> of Dallas v. Abbott* (2010), any AG‑ruling deadline would run from any
>>> clarification only for the clarified portion; clarification cannot be used
>>> to extend deadlines indefinitely.
>>>
>>> 8) Aggregation / “large‑requestor” policy.
>>> Please do not aggregate separate‑day requests for cost purposes
>>> (§552.261(e)). If you intend to apply a “large requestor” policy under
>>> §552.275, please provide the adopted policy and my cumulative hour ledger
>>> for this fiscal period.
>>>
>>> 9) If you intend to seek an AG ruling.
>>> If you believe any information is excepted, please timely request a
>>> decision under §552.301. Otherwise, the information is presumed public
>>> under §552.302, and non‑contested portions should be released promptly.
>>> Also, please send me the copy of your written comments to the ORD by the
>>> 15th business day, as §552.301(e‑1) requires (redacted if your comments
>>> would reveal the substance of the records).
>>>
>>> 10) Scheduling windows.
>>> For scheduling, I am available to inspect this week during normal
>>> business hours. My preferred times (Central) are:
>>> • Wednesday, November 19, 2025: 1:00–5:00 PM
>>> • Thursday, November 20, 2025: 1:00–5:00 PM
>>> • Friday, November 21, 2025: 1:00–5:00 PM
>>> If those are not workable, I can also be available:
>>> • Monday, November 24, 2025: 1:00–5:00 PM
>>> • Tuesday, November 25, 2025: 1:00–5:00 PM
>>> If another weekday afternoon is more convenient, please propose it and I
>>> will accommodate.
>>>
>>> 11) Time for examination.
>>> Once you make records available, I will complete my review within
>>> §552.225’s 10‑business‑day window, with any needed written extension.
>>>
>>> 12) Segregability & marking of redactions.
>>> Please release all reasonably segregable, non‑excepted portions and
>>> identify each redaction by specific statutory authority.
>>>
>>> 13) Third‑party notice (if applicable).
>>> If you invoke §552.305 for proprietary/third‑party interests, please
>>> make timely notice and let me know the date notices went out.
>>>
>>> 14) Preservation.
>>> Please preserve all potentially responsive records, including ESI,
>>> during processing. Willful destruction or alteration is an offense under
>>> §552.351.
>>>
>>> 15) Requestor equipment during inspection.
>>> I plan to use a phone or portable scanner for copies of non‑confidential
>>> pages during inspection, consistent with OAG guidance; if you contend this
>>> would be disruptive or would expose confidential content on mixed pages,
>>> please identify the specific constraint.
>>>
>>> For avoidance of doubt, this message is my timely response under
>>> §[REDACTED – PARTIAL-PHONE](b) to your November 18, 2025 estimate: I do not accept the quoted
>>> “viewing” labor charge for inspection; I do not withdraw my request; and I
>>> am requesting a cost‑compliant itemization and, if programming is claimed,
>>> a §552.231 statement. Nothing in this email narrows, modifies, or withdraws
>>> the scope of my request.
>>>
>>> Cost‑complaint notice: For completeness, this message also serves as my
>>> written response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](b)(3) to your November
>>> 18, 2025 itemized estimate. I have submitted a written cost complaint to
>>> the Office of the Attorney General under § 552.269 regarding the estimate’s
>>> charge of 118.64 hours of “viewing” at $15/hour for electronic inspection
>>> without a § 552.231 programming statement. My request is not withdrawn or
>>> narrowed. I continue to elect inspection and ask that you proceed promptly
>>> under §§ 552.221 and 552.272; if you contend programming/manipulation is
>>> required, please issue the written § 552.231 statement within the statutory
>>> window.
>>>
>>> Best,
>>>
>>> Kevin Bass PhD MS
>>> Phone: *[REDACTED – PHONE]*
>>>
>>>
>>> On Tue, Nov 18, 2025 at 4:56 PM Staugaard, Bronte <
>>> Bronte.Staugaard@ttu.edu> wrote:
>>>
>>>> Good Afternoon,
>>>>
>>>>
>>>>
>>>> Texas Tech University System (TTUS) is in receipt of your responses to
>>>> our estimate and your request to inspect the responsive records below. As
>>>> we previously pointed out, our correspondences sought to clarify or narrow
>>>> the scope of your requests; however, your subsequent responses generally
>>>> served to broaden them.
>>>>
>>>>
>>>>
>>>> Additionally, we received your deposit of $1,934.55 on November 13,
>>>> 2025, relating to the cost estimate provided on November 3, 2025. However,
>>>> we also noted your November 4, 2025, response to the cost estimate wherein
>>>> you requested to inspect the records in person. To ensure we proceed
>>>> correctly, please confirm if you would prefer to inspect the documentation
>>>> or be provided copies. Please be advised that, some of the documents or
>>>> information that you have requested may be withheld under State law. As
>>>> such, even if a deposit is made, we may request an Attorney General Open
>>>> Records Decision (“ORD”) seeking to withhold some documents or
>>>> information pursuant to the Texas Public Information Act.  Texas Government
>>>> Code § 552.001, et seq.  Once the Attorney General makes a decision
>>>> regarding the public disclosure of these documents, TTUS will make those
>>>> documents that are determined by the Attorney General to be public, if any,
>>>> available for inspection or copying.
>>>>
>>>>
>>>>
>>>> In response to your request to inspect, we have determined that
>>>> complying with the request will result in the imposition of a charge that
>>>> exceeds $40. Therefore, the following statement is provided pursuant to
>>>> sections [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>>>
>>>>
>>>>
>>>>    1. The requested information is not currently available in a form
>>>>    suitable for public release, and since the request involves manipulation of
>>>>    data, documents are not feasible to retrieve, will result in substantial
>>>>    interference with ongoing operations and can only be provided at a cost
>>>>    that covers the manipulation of data and other costs, you are entitled to
>>>>    an estimate of the costs and time to provide the information in the
>>>>    requested form.
>>>>
>>>>
>>>>
>>>> Therefore, the itemized statement of estimated charges is:
>>>>
>>>>
>>>>
>>>> *Labor 118.64 hrs. @ $15/hr. =           $ 1,779.60*
>>>>
>>>> *Estimated Total Cost =                     $1,779.60*
>>>>
>>>>
>>>>
>>>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>>>    providing you with an alternative, less expensive method of obtaining some
>>>>    of the requested information.  An alternative method would be to narrow
>>>>    your request by eliminating some of the data requested, such as narrowing
>>>>    the date range or information requested. It is usually less expensive to
>>>>    view the documents here at the office; however, this estimate is for the
>>>>    cost of viewing as per your request.
>>>>
>>>>
>>>>
>>>>    3. *Your request will be considered automatically withdrawn if you
>>>>    do not notify us in writing and within 10 (ten) business days from the date
>>>>    of this statement that you:*
>>>>
>>>>
>>>>
>>>>    1. Accept the estimated charges and will pay them.  Because your
>>>>       request is over $100.00, you are required to either deposit $889.80 (50% of
>>>>       the estimated costs) or provide TTUS with a bond for the total estimated
>>>>       cost. *Please note that pursuant to §552.263(e), your request
>>>>       will be considered received when we receive your payment.  Additionally, if
>>>>       you fail to pay within 10 business days, your request will be considered
>>>>       withdrawn pursuant to §552.263(f).*
>>>>       2. Are modifying the request (state the modification); or
>>>>       3. Have sent a complaint to the Office of the Attorney General
>>>>       of Texas alleging that you have been overcharged for a copy of public
>>>>       information.
>>>>
>>>>
>>>>
>>>>    4. You may choose to respond by email to me at
>>>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste.
>>>>    301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the
>>>>    Texas Tech University System Building, located at 1508 Knoxville
>>>>    Ave., Ste. 301, Lubbock, Tx 79409-2021.
>>>>
>>>>
>>>>
>>>>    5. Your check, money order, or bond must be made payable to: Texas
>>>>    Tech University System.
>>>>
>>>>
>>>>
>>>>    6. If we determine that a change in estimated charges will exceed
>>>>    the amount in this written itemized statement by 20%, we will send you an
>>>>    updated written itemized statement. As noted above, the same response
>>>>    requirements are imposed on you once an updated itemized statement is sent.
>>>>
>>>>
>>>>
>>>>    7. TTUS expects it to take approximately 3 weeks to complete this
>>>>    request at current workloads.
>>>>
>>>>
>>>>
>>>> Sincerely,
>>>>
>>>> Brontë C. Staugaard
>>>>
>>>> Assistant General Counsel
>>>>
>>>> Texas Tech University System
>>>>
>>>> (806) [REDACTED – PARTIAL-PHONE]
>>>>
>>>>
>>>>
>>>> This communication, including any attachments, originates from an
>>>> Attorney and may contain confidential information and is intended only for
>>>> the individual or entity to whom it is addressed. Any review,
>>>> dissemination, or copying of this communication by anyone other than the
>>>> intended recipient is strictly prohibited. If you are not the intended
>>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>>> all copies of the original message.
>>>>
>>>>
>>>>
>>>> Sincerely,
>>>>
>>>> Brontë C. Staugaard
>>>>
>>>> Assistant General Counsel
>>>>
>>>> Texas Tech University System
>>>>
>>>> (806) [REDACTED – PARTIAL-PHONE]
>>>>
>>>>
>>>>
>>>> This communication, including any attachments, originates from an
>>>> Attorney and may contain confidential information and is intended only for
>>>> the individual or entity to whom it is addressed. Any review,
>>>> dissemination, or copying of this communication by anyone other than the
>>>> intended recipient is strictly prohibited. If you are not the intended
>>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>>> all copies of the original message.
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> *From:* Kevin Bass <kbassphiladelphia@gmail.com>
>>>> *Sent:* Tuesday, November 4, 2025 8:00 AM
>>>> *To:* Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
>>>> *Subject:* Re: Cost Estimate Regarding Responses to TTUS's
>>>> Clarifications/Narrowings and Additional Request Received on 10.20.2025
>>>>
>>>>
>>>>
>>>> This email originated outside TTU. Please exercise caution
>>>> <https://askit.ttu.edu/phishing>!
>>>>
>>>>
>>>>
>>>> Brontë,
>>>>
>>>> This is my timely response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](d).
>>>>
>>>> Itemization required. Please issue a corrected, fully itemized estimate
>>>> that breaks out and supports, by task and rate:
>>>>
>>>>    1.
>>>>    2.
>>>>    3. Search/collection time (by custodian
>>>>    4. and data source),
>>>>    5.
>>>>    6.
>>>>    7.
>>>>    8.
>>>>    9. Compilation/duplication time,
>>>>    10.
>>>>    11.
>>>>    12.
>>>>    13.
>>>>    14. Redaction time (identify the specific
>>>>    15. mandatory confidentiality provisions), and
>>>>    16.
>>>>    17.
>>>>    18.
>>>>    19.
>>>>    20. Any programming/manipulation tasks
>>>>    21. (use programmer rate and describe the steps).
>>>>    22. Explicitly exclude attorney
>>>>    23. review and AG-brief preparation time. See § [REDACTED – PARTIAL-PHONE]; 1 TAC §
>>>>    70.3(d)(3)–(4), (e). Also confirm overhead ≤ 20% of allowable labor and
>>>>    note the 20% update rule (issue a new written estimate if actual charges
>>>>    will exceed the prior estimate by ≥20%).
>>>>    24.
>>>>
>>>> “Programming/manipulation” basis. Your email says the request “involves
>>>> manipulation of data.” Identify which tasks require programming (coding) or
>>>> manipulation (human reordering/decoding) as used in the Act, and quantify
>>>> those hours separately. Using built-in e-discovery/search tools is not
>>>> “programming.” Inspection of electronic records may not be charged unless
>>>> programming/manipulation is required (§ 552.272).
>>>>
>>>> Aggregation. You say you aggregated my clarification responses and an
>>>> additional same-day request. List each request you aggregated and provide
>>>> separate line-item estimates per request. A clarification response is not
>>>> itself a new “request,” and aggregation should not inflate costs across
>>>> discrete requests. See § 552.261(e).
>>>>
>>>> Phased production to cut costs (my election). Proceed in phases,
>>>> starting with OGC/PIO custodians (Staugaard, Wall) for Oct 3–31, 2025 using
>>>> the terms: “Kevin Bass,” “kbassphiladelphia,” “Preservation Notice,” “P3,”
>>>> “SPPCC,” “professionalism.” After Phase-1 lands, we’ll scope Phase-2
>>>> (Registrar/Student Life/IT). Re-estimate Phase-1 only.
>>>>
>>>> Inspection to minimize charges. For Phase-1, I elect on-site or remote
>>>> inspection of electronic records in native format where feasible (§
>>>> 552.272), unless you specifically identify required
>>>> programming/manipulation (with task detail). If programming is necessary,
>>>> itemize it and use the programmer rate.
>>>>
>>>> Rolling production required. Promptly produce any responsive records
>>>> not subject to your AG request and any clearly public/segregable
>>>> information now, while your AG brief is pending. See § 552.221; ORD-664
>>>> (2000).
>>>>
>>>> Deposit posture. Given the defects in TTUS’s Nov 3 estimate and the
>>>> magnitude of the proposed deposit, I will not remit any funds unless and
>>>> until TTUS provides a § [REDACTED – PARTIAL-PHONE]-compliant written itemized statement that
>>>> sets out task-level hours and rates (search/collection,
>>>> compilation/duplication, redaction—identifying any mandatory
>>>> confidentiality—and any programming/manipulation, if applicable) and
>>>> identifies less-costly alternatives. I am invoking my rights under §
>>>> 552.269 and will seek Attorney General review of the estimate. For clarity,
>>>> the 10-business-day withdrawal provision in § [REDACTED – PARTIAL-PHONE](d) is triggered only
>>>> by a compliant itemized statement with the required notices; any attempt to
>>>> treat this request as withdrawn before such a statement issues is improper.
>>>> Likewise, any deposit request under § 552.263(a) must follow and be based
>>>> on a compliant § [REDACTED – PARTIAL-PHONE] itemized statement. I also elect inspection where
>>>> it reduces charges, consistent with § 552.272.
>>>>
>>>> Please confirm receipt and provide a date/time for initial rolling
>>>> production of non-exempt material. Also send the revised, itemized Phase-1
>>>> estimate within 3 business days, so I can respond within the statute’s
>>>> window.
>>>>
>>>> Kevin Bass PhD MS
>>>>
>>>> Phone: *[REDACTED – PHONE]*
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> On Mon, Nov 3, 2025 at 4:51 PM Staugaard, Bronte <
>>>> Bronte.Staugaard@ttu.edu> wrote:
>>>>
>>>> Good Afternoon,
>>>>
>>>>
>>>>
>>>> Texas Tech University System (TTUS) is in receipt of your responses to
>>>> our clarifications/narrowings and your additional request received on
>>>> October 20, 2025. The responses and request are attached herein.  Due to
>>>> our receipt of your responses and request on the same calendar day, we are
>>>> treating them as a single request for the purposes of calculating costs as
>>>> permitted under the Texas Government Code.
>>>>
>>>>
>>>>
>>>> We must also note that while our correspondences sought to clarify or
>>>> narrow the scope of your requests, your subsequent responses have generally
>>>> served to broaden them. As such, we have determined that complying with the
>>>> request will result in the imposition of a charge that exceeds
>>>> $40. Therefore, the following statement is provided pursuant to sections
>>>> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>>>
>>>>
>>>>
>>>>    1. The requested information is not currently available in a form
>>>>    suitable for public release, and since the request involves manipulation of
>>>>    data, documents are not feasible to retrieve, will result in substantial
>>>>    interference with ongoing operations and can only be provided at a cost
>>>>    that covers the manipulation of data and other costs, you are entitled to
>>>>    an estimate of the costs and time to provide the information in the
>>>>    requested form.
>>>>
>>>>
>>>>
>>>> Therefore, the itemized statement of estimated charges is:
>>>>
>>>>
>>>>
>>>> Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25
>>>>
>>>> *Overhead @ 20% =                            $ 644.85             *
>>>>
>>>>
>>>> *Estimated Total Cost =                     $3,869.10*
>>>>
>>>>
>>>>
>>>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>>>    providing you with an alternative, less expensive method of obtaining some
>>>>    of the requested information.  An alternative method would be to narrow
>>>>    your request by eliminating some of the data requested, such as narrowing
>>>>    the date range or information requested. It may also be less expensive to
>>>>    view the documents here at the office.
>>>>
>>>>
>>>>
>>>>    3. *Your request will be considered automatically withdrawn if you
>>>>    do not notify us in writing and within 10 (ten) business days from the date
>>>>    of this statement that you:*
>>>>
>>>>
>>>>
>>>>    1. Accept the estimated charges and will pay them.  Because your
>>>>       request is over $100.00, you are required to either deposit $1,934.55 (50%
>>>>       of the estimated costs) or provide TTUS with a bond for the total estimated
>>>>       cost. *Please note that pursuant to §552.263(e), your request
>>>>       will be considered received when we receive your payment.  Additionally, if
>>>>       you fail to pay within 10 business days, your request will be considered
>>>>       withdrawn pursuant to §552.263(f).*
>>>>       2. Are modifying the request (state the modification); or
>>>>       3. Have sent a complaint to the Office of the Attorney General
>>>>       of Texas alleging that you have been overcharged for a copy of public
>>>>       information.
>>>>
>>>>
>>>>
>>>>    4. You may choose to respond by email to me at
>>>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste.
>>>>    301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the
>>>>    Texas Tech University System Building, located at 1508 Knoxville
>>>>    Ave., Ste. 301, Lubbock, Tx 79409-2021.
>>>>
>>>>
>>>>
>>>>    5. Your check, money order, or bond must be made payable to: Texas
>>>>    Tech University System.
>>>>
>>>>
>>>>
>>>>    6. If we determine that a change in estimated charges will exceed
>>>>    the amount in this written itemized statement by 20%, we will send you an
>>>>    updated written itemized statement. As noted above, the same response
>>>>    requirements are imposed on you once an updated itemized statement is sent.
>>>>
>>>>
>>>>
>>>>    7. TTUS expects it to take approximately 2 weeks to complete this
>>>>    request at current workloads.
>>>>
>>>>
>>>>
>>>> Finally, some of the documents or information that you have requested
>>>> may be withheld under State law.  Therefore, if you choose to pay the
>>>> deposit, we may request an Attorney General Open Records Decision (“ORD”)
>>>> seeking to withhold some documents or information pursuant to the Texas
>>>> Public Information Act.  Texas Government Code § 552.001, et seq.  Once the
>>>> Attorney General makes a decision regarding the public disclosure of these
>>>> documents, TTUS will make those documents that are determined by the
>>>> Attorney General to be public, if any, available for inspection or copying.
>>>>
>>>>
>>>>
>>>> Sincerely,
>>>>
>>>> Brontë C. Staugaard
>>>>
>>>> Assistant General Counsel
>>>>
>>>> Texas Tech University System
>>>>
>>>> (806) [REDACTED – PARTIAL-PHONE]
>>>>
>>>>
>>>>
>>>> This communication, including any attachments, originates from an
>>>> Attorney and may contain confidential information and is intended only for
>>>> the individual or entity to whom it is addressed. Any review,
>>>> dissemination, or copying of this communication by anyone other than the
>>>> intended recipient is strictly prohibited. If you are not the intended
>>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>>> all copies of the original message.
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>

Counsel Staugaard,

Attachments added here.
Kevin Bass PhD MS
Phone: *[REDACTED – PHONE]*


On Tue, Dec 9, 2025 at 3:51 PM Kevin Bass <kbassphiladelphia@gmail.com>
wrote:

> Hi Counsel Staugaard,
>
> Earlier today (December 9, 2025), I was informed that the 50% deposit
> check for $1,934.55 that I hand-delivered to your office on November 13,
> 2025 in response to TTUS’s November 3, 2025 cost estimate was returned by
> the bank due to insufficient funds after money had been moved out of that
> account. The non-payment was inadvertent.
>
> On November 13, 2025, I timely tendered that 50% deposit within ten
> business days of the November 3 estimate. To immediately cure the bank’s
> return of that check and avoid any argument that my requests were
> “withdrawn” under Gov’t Code § 552.263(f), today, December 9, 2025, I *will
> hand-deliver* a replacement check in the same amount, $1,934.55, payable
> to Texas Tech University System, together with a replacement cover letter.
>
> As explained in the attached cover letter, this replacement 50% deposit is
> tendered UNDER PROTEST. It does not narrow or modify the scope of my
> existing TPIA requests. It is intended to maintain and continue the deposit
> that was timely tendered on November 13, 2025, and to cure the bank’s
> return of that check. My requests should not be treated as withdrawn; this
> simply ensures that the deposit requirement remains satisfied.
>
> Please apply this replacement deposit under the same Phase-1 sequencing
> described in my November 13 cover letter (Title IX/Student-Conduct finals,
> P3 professionalism finals for AY 2022–23 and AY 2023–24,
> Transcript/Title-IV finals, existing handling/process artifacts, and
> relevant retention/hold policies under § 552.022(a)). I am continuing to
> pursue a cost complaint under Gov’t Code § 552.269 regarding the November 3
> estimate; that complaint and this deposit should not suspend TTUS’s duty to
> promptly produce non-excepted records on a rolling basis.
>
> If there is any lawful returned-check processing fee associated with the
> bank’s return of the original check, please itemize it and send me an
> invoice so that I can address it promptly.
>
> Please confirm in writing that you have received and applied this
> replacement deposit and confirm the date/time for the first Phase-1 release.
>
> For your convenience, I have attached a copy of the replacement cover
> letter and a photo of the replacement check.
>
> Thank you,
> Kevin Bass
> Kevin Bass PhD MS
> Phone: *[REDACTED – PHONE]*
>
>
> On Wed, Nov 26, 2025 at 10:29 PM Kevin Bass <kbassphiladelphia@gmail.com>
> wrote:
>
>> Counsel Staugaard,
>>
>> I’m writing to provide a courtesy copy of a supplemental cost complaint I
>> submitted today to the Office of the Attorney General under Tex. Gov’t Code
>> § 552.269 regarding TTUS’s November 3 and November 18, 2025 cost estimates
>> for my October 3 and October 20, 2025 TPIA requests. The supplemental
>> filing was submitted in Service Request No. OR-25-053696-CC.
>>
>> The attachments mirror what I sent to the Attorney General:
>>
>> A supplemental § 552.269 complaint letter describing why I believe the
>> November 3 and November 18 estimates are not compliant with § [REDACTED – PARTIAL-PHONE], §
>> 552.263, and the cost rules.
>>
>> Exhibit A – TTUS Cost Estimate & Responses (Nov. 3–19, 2025), which
>> compiles the email thread between your office and me regarding the initial
>> cost estimate, my November 4 inspection election, my November 13 deposit
>> (tendered under protest), the November 18 “viewing” estimate, and my
>> November 19 responses and cost-complaint notice.
>>
>> Exhibit B – Original TPIA Requests and Clarifications, consisting of the
>> October 3 metadata-based TPIA requests and the October 20 “Records Showing
>> How You Handled My Requests (Existing Process Docs Only)” request that TTUS
>> aggregated for the estimates.
>>
>> Exhibit C-1 – 2025-11-19_Supporting_Docs.pdf (the previously submitted
>> supporting emails and documents related to the November 3 and November 18
>> estimates).
>>
>> Exhibit C-2 –
>> 2025-10-20_PIA_Records_Showing_Handling_Existing_Process_Docs.docx (the
>> October 20, 2025 “Records Showing How You Handled My Requests (Existing
>> Process Docs Only)” TPIA request), resubmitted so TTUS has the same
>> process-docs request that is before the Attorney General.
>>
>> This correspondence is for notice only. It does not withdraw or narrow
>> any of my TPIA requests, and it does not change my election to inspect
>> electronic records where that is less costly. As in my prior emails, I am
>> asking TTUS either to issue a fully itemized, task-level estimate that
>> complies with § [REDACTED – PARTIAL-PHONE] and the cost rules, or to proceed with inspection
>> under §§ 552.221 and 552.272 while the Attorney General reviews the
>> challenged charges.
>>
>> I remain willing to work in good faith on any reasonable narrowing or
>> phased production that materially reduces costs while preserving access to
>> the core records.
>>
>> Best regards,
>>
>> Kevin Bass PhD MS
>> Phone: *[REDACTED – PHONE]*
>>
>>
>> On Wed, Nov 19, 2025 at 3:36 PM Kevin Bass <kbassphiladelphia@gmail.com>
>> wrote:
>>
>>> Counsel Staugaard — for clarity, the $1,934.55 paid on Nov 13 was the
>>> 50% deposit for TTUS’s Nov 3 copy estimate and must not be applied to the
>>> Nov 18 “viewing” estimate. I have submitted a §552.269 cost complaint
>>> regarding the Nov 18 estimate; this serves as my §[REDACTED – PARTIAL-PHONE](b)(3) response,
>>> so the request is not withdrawn. Please schedule an inspection (or provide
>>> the §552.221(c) active‑use/storage certification with an appointment date),
>>> and if you contend programming/manipulation is required, issue the §552.231
>>> statement with task, staff category, time, and cost. Please also provide a
>>> simple statement of account showing deposits held and what estimate each
>>> deposit is tied to.
>>> Kevin Bass PhD MS
>>> Phone: *[REDACTED – PHONE]*
>>>
>>>
>>> On Wed, Nov 19, 2025 at 12:38 PM Kevin Bass <kbassphiladelphia@gmail.com>
>>> wrote:
>>>
>>>> Hello Counsel Staugaard,
>>>>
>>>> This confirms my request remains an inspection request and is not a
>>>> request for copies at this time. No explanation of purpose is required;
>>>> please treat this request uniformly under the Act.
>>>>
>>>> 1) Inspection first (no copies yet).
>>>> I elect to inspect the responsive records. Please set a date and hour
>>>> for in‑person inspection within a reasonable time (or certify active
>>>> use/storage and give the inspection appointment date) as required by Tex.
>>>> Gov’t Code §552.221(c)–(d). Please also comply with §552.221(a)’s
>>>> requirement to *promptly* produce non‑contested records “as soon as
>>>> possible.” If the records are ready sooner, please just confirm a time and
>>>> the location. In the meantime, please begin rolling production of any
>>>> portions that are readily available now. If you contend any portion is in
>>>> active use or storage, please identify those records and provide the
>>>> certification required by §552.221(c) together with the appointment date.
>>>>
>>>> 2) Electronic records: no charge to inspect absent
>>>> programming/manipulation + §552.231 statement.
>>>> For information that exists in an electronic medium, access for
>>>> inspection may not be charged unless you must perform programming or
>>>> manipulation of data. If you believe that is required, please send the
>>>> written §552.231 statement that (a) says the data is not available in the
>>>> requested form, (b) describes the form in which it is available, (c) lists
>>>> any contracts/services needed, and (d) gives the estimated cost and
>>>> time—within the statute’s 20‑day window (30 with notice). If the only
>>>> reason programming is needed is to convert records into a different format,
>>>> I will accept the information in the form in which it is currently
>>>> available to avoid programming charges under §552.231(d). For clarity,
>>>> routine keyword searches/filters are not “programming or manipulation”; if
>>>> you contend otherwise, please identify the specific script/process.
>>>>
>>>> 3) Your “viewing” estimate / paper inspection.
>>>> The itemized estimate you sent frames this as “viewing as per your
>>>> request.” For paper records, a deposit for inspection is allowed only in
>>>> the narrow §552.271(c)–(d) scenarios. For ≥16 FTEs: the records must be
>>>> older than five years or fill six+ archival boxes and exceed five hours to
>>>> prepare. For <16 FTEs: three years/three boxes/two hours. Please confirm
>>>> whether your estimate rests on §552.271(c)–(d), and if so, identify which
>>>> prong(s) apply. Otherwise, inspection should be scheduled without these
>>>> charges.
>>>>
>>>> 4) Deposit = copies only.
>>>> You note a deposit received on November 13, 2025. Under §552.263(e),
>>>> when a deposit is properly required, a request for a copy is considered
>>>> “received” on the date the deposit arrives. That rule does not convert an
>>>> inspection into a copy request. Please apply or hold my deposit for any
>>>> copies I later select after inspection, or refund any excess after copy
>>>> fulfillment.
>>>>
>>>> 5) Estimates > $40 must be compliant.
>>>> Any estimate over $40 must comply with §[REDACTED – PARTIAL-PHONE] and 1 TAC §70.7 (full
>>>> itemization; notice of less‑costly options; clear response instructions;
>>>> and an updated statement if the estimate will exceed the original by ≥20%).
>>>> Please ensure any future estimate includes those elements.
>>>>
>>>> 6) What you cannot charge.
>>>> Time for attorney/legal review to decide what to withhold is not a
>>>> recoverable cost. If included in your labor math, please remove it. Please
>>>> also confirm that overhead will not be applied to inspection where no
>>>> inspection charge is permitted. See 1 TAC §70.3(d)(3).
>>>>
>>>> 7) Clarification and timing.
>>>> To avoid unnecessary delay, the request is sufficiently clear as
>>>> stated. If you believe any discrete item is unclear, please identify it
>>>> specifically in a single clarification request and also identify the
>>>> portions you already understand and will produce now. Consistent with *City
>>>> of Dallas v. Abbott* (2010), any AG‑ruling deadline would run from any
>>>> clarification only for the clarified portion; clarification cannot be used
>>>> to extend deadlines indefinitely.
>>>>
>>>> 8) Aggregation / “large‑requestor” policy.
>>>> Please do not aggregate separate‑day requests for cost purposes
>>>> (§552.261(e)). If you intend to apply a “large requestor” policy under
>>>> §552.275, please provide the adopted policy and my cumulative hour ledger
>>>> for this fiscal period.
>>>>
>>>> 9) If you intend to seek an AG ruling.
>>>> If you believe any information is excepted, please timely request a
>>>> decision under §552.301. Otherwise, the information is presumed public
>>>> under §552.302, and non‑contested portions should be released promptly.
>>>> Also, please send me the copy of your written comments to the ORD by the
>>>> 15th business day, as §552.301(e‑1) requires (redacted if your comments
>>>> would reveal the substance of the records).
>>>>
>>>> 10) Scheduling windows.
>>>> For scheduling, I am available to inspect this week during normal
>>>> business hours. My preferred times (Central) are:
>>>> • Wednesday, November 19, 2025: 1:00–5:00 PM
>>>> • Thursday, November 20, 2025: 1:00–5:00 PM
>>>> • Friday, November 21, 2025: 1:00–5:00 PM
>>>> If those are not workable, I can also be available:
>>>> • Monday, November 24, 2025: 1:00–5:00 PM
>>>> • Tuesday, November 25, 2025: 1:00–5:00 PM
>>>> If another weekday afternoon is more convenient, please propose it and
>>>> I will accommodate.
>>>>
>>>> 11) Time for examination.
>>>> Once you make records available, I will complete my review within
>>>> §552.225’s 10‑business‑day window, with any needed written extension.
>>>>
>>>> 12) Segregability & marking of redactions.
>>>> Please release all reasonably segregable, non‑excepted portions and
>>>> identify each redaction by specific statutory authority.
>>>>
>>>> 13) Third‑party notice (if applicable).
>>>> If you invoke §552.305 for proprietary/third‑party interests, please
>>>> make timely notice and let me know the date notices went out.
>>>>
>>>> 14) Preservation.
>>>> Please preserve all potentially responsive records, including ESI,
>>>> during processing. Willful destruction or alteration is an offense under
>>>> §552.351.
>>>>
>>>> 15) Requestor equipment during inspection.
>>>> I plan to use a phone or portable scanner for copies of
>>>> non‑confidential pages during inspection, consistent with OAG guidance; if
>>>> you contend this would be disruptive or would expose confidential content
>>>> on mixed pages, please identify the specific constraint.
>>>>
>>>> For avoidance of doubt, this message is my timely response under
>>>> §[REDACTED – PARTIAL-PHONE](b) to your November 18, 2025 estimate: I do not accept the quoted
>>>> “viewing” labor charge for inspection; I do not withdraw my request; and I
>>>> am requesting a cost‑compliant itemization and, if programming is claimed,
>>>> a §552.231 statement. Nothing in this email narrows, modifies, or withdraws
>>>> the scope of my request.
>>>>
>>>> Cost‑complaint notice: For completeness, this message also serves as my
>>>> written response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](b)(3) to your November
>>>> 18, 2025 itemized estimate. I have submitted a written cost complaint to
>>>> the Office of the Attorney General under § 552.269 regarding the estimate’s
>>>> charge of 118.64 hours of “viewing” at $15/hour for electronic inspection
>>>> without a § 552.231 programming statement. My request is not withdrawn or
>>>> narrowed. I continue to elect inspection and ask that you proceed promptly
>>>> under §§ 552.221 and 552.272; if you contend programming/manipulation is
>>>> required, please issue the written § 552.231 statement within the statutory
>>>> window.
>>>>
>>>> Best,
>>>>
>>>> Kevin Bass PhD MS
>>>> Phone: *[REDACTED – PHONE]*
>>>>
>>>>
>>>> On Tue, Nov 18, 2025 at 4:56 PM Staugaard, Bronte <
>>>> Bronte.Staugaard@ttu.edu> wrote:
>>>>
>>>>> Good Afternoon,
>>>>>
>>>>>
>>>>>
>>>>> Texas Tech University System (TTUS) is in receipt of your responses to
>>>>> our estimate and your request to inspect the responsive records below. As
>>>>> we previously pointed out, our correspondences sought to clarify or narrow
>>>>> the scope of your requests; however, your subsequent responses generally
>>>>> served to broaden them.
>>>>>
>>>>>
>>>>>
>>>>> Additionally, we received your deposit of $1,934.55 on November 13,
>>>>> 2025, relating to the cost estimate provided on November 3, 2025. However,
>>>>> we also noted your November 4, 2025, response to the cost estimate wherein
>>>>> you requested to inspect the records in person. To ensure we proceed
>>>>> correctly, please confirm if you would prefer to inspect the documentation
>>>>> or be provided copies. Please be advised that, some of the documents or
>>>>> information that you have requested may be withheld under State law. As
>>>>> such, even if a deposit is made, we may request an Attorney General Open
>>>>> Records Decision (“ORD”) seeking to withhold some documents or
>>>>> information pursuant to the Texas Public Information Act.  Texas Government
>>>>> Code § 552.001, et seq.  Once the Attorney General makes a decision
>>>>> regarding the public disclosure of these documents, TTUS will make those
>>>>> documents that are determined by the Attorney General to be public, if any,
>>>>> available for inspection or copying.
>>>>>
>>>>>
>>>>>
>>>>> In response to your request to inspect, we have determined that
>>>>> complying with the request will result in the imposition of a charge that
>>>>> exceeds $40. Therefore, the following statement is provided pursuant to
>>>>> sections [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>>>>
>>>>>
>>>>>
>>>>>    1. The requested information is not currently available in a form
>>>>>    suitable for public release, and since the request involves manipulation of
>>>>>    data, documents are not feasible to retrieve, will result in substantial
>>>>>    interference with ongoing operations and can only be provided at a cost
>>>>>    that covers the manipulation of data and other costs, you are entitled to
>>>>>    an estimate of the costs and time to provide the information in the
>>>>>    requested form.
>>>>>
>>>>>
>>>>>
>>>>> Therefore, the itemized statement of estimated charges is:
>>>>>
>>>>>
>>>>>
>>>>> *Labor 118.64 hrs. @ $15/hr. =           $ 1,779.60*
>>>>>
>>>>> *Estimated Total Cost =                     $1,779.60*
>>>>>
>>>>>
>>>>>
>>>>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>>>>    providing you with an alternative, less expensive method of obtaining some
>>>>>    of the requested information.  An alternative method would be to narrow
>>>>>    your request by eliminating some of the data requested, such as narrowing
>>>>>    the date range or information requested. It is usually less expensive to
>>>>>    view the documents here at the office; however, this estimate is for the
>>>>>    cost of viewing as per your request.
>>>>>
>>>>>
>>>>>
>>>>>    3. *Your request will be considered automatically withdrawn if you
>>>>>    do not notify us in writing and within 10 (ten) business days from the date
>>>>>    of this statement that you:*
>>>>>
>>>>>
>>>>>
>>>>>    1. Accept the estimated charges and will pay them.  Because your
>>>>>       request is over $100.00, you are required to either deposit $889.80 (50% of
>>>>>       the estimated costs) or provide TTUS with a bond for the total estimated
>>>>>       cost. *Please note that pursuant to §552.263(e), your request
>>>>>       will be considered received when we receive your payment.  Additionally, if
>>>>>       you fail to pay within 10 business days, your request will be considered
>>>>>       withdrawn pursuant to §552.263(f).*
>>>>>       2. Are modifying the request (state the modification); or
>>>>>       3. Have sent a complaint to the Office of the Attorney General
>>>>>       of Texas alleging that you have been overcharged for a copy of public
>>>>>       information.
>>>>>
>>>>>
>>>>>
>>>>>    4. You may choose to respond by email to me at
>>>>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste.
>>>>>    301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the
>>>>>    Texas Tech University System Building, located at 1508 Knoxville
>>>>>    Ave., Ste. 301, Lubbock, Tx 79409-2021.
>>>>>
>>>>>
>>>>>
>>>>>    5. Your check, money order, or bond must be made payable to: Texas
>>>>>    Tech University System.
>>>>>
>>>>>
>>>>>
>>>>>    6. If we determine that a change in estimated charges will exceed
>>>>>    the amount in this written itemized statement by 20%, we will send you an
>>>>>    updated written itemized statement. As noted above, the same response
>>>>>    requirements are imposed on you once an updated itemized statement is sent.
>>>>>
>>>>>
>>>>>
>>>>>    7. TTUS expects it to take approximately 3 weeks to complete this
>>>>>    request at current workloads.
>>>>>
>>>>>
>>>>>
>>>>> Sincerely,
>>>>>
>>>>> Brontë C. Staugaard
>>>>>
>>>>> Assistant General Counsel
>>>>>
>>>>> Texas Tech University System
>>>>>
>>>>> (806) [REDACTED – PARTIAL-PHONE]
>>>>>
>>>>>
>>>>>
>>>>> This communication, including any attachments, originates from an
>>>>> Attorney and may contain confidential information and is intended only for
>>>>> the individual or entity to whom it is addressed. Any review,
>>>>> dissemination, or copying of this communication by anyone other than the
>>>>> intended recipient is strictly prohibited. If you are not the intended
>>>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>>>> all copies of the original message.
>>>>>
>>>>>
>>>>>
>>>>> Sincerely,
>>>>>
>>>>> Brontë C. Staugaard
>>>>>
>>>>> Assistant General Counsel
>>>>>
>>>>> Texas Tech University System
>>>>>
>>>>> (806) [REDACTED – PARTIAL-PHONE]
>>>>>
>>>>>
>>>>>
>>>>> This communication, including any attachments, originates from an
>>>>> Attorney and may contain confidential information and is intended only for
>>>>> the individual or entity to whom it is addressed. Any review,
>>>>> dissemination, or copying of this communication by anyone other than the
>>>>> intended recipient is strictly prohibited. If you are not the intended
>>>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>>>> all copies of the original message.
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> *From:* Kevin Bass <kbassphiladelphia@gmail.com>
>>>>> *Sent:* Tuesday, November 4, 2025 8:00 AM
>>>>> *To:* Staugaard, Bronte <Bronte.Staugaard@ttu.edu>
>>>>> *Subject:* Re: Cost Estimate Regarding Responses to TTUS's
>>>>> Clarifications/Narrowings and Additional Request Received on 10.20.2025
>>>>>
>>>>>
>>>>>
>>>>> This email originated outside TTU. Please exercise caution
>>>>> <https://askit.ttu.edu/phishing>!
>>>>>
>>>>>
>>>>>
>>>>> Brontë,
>>>>>
>>>>> This is my timely response under Tex. Gov’t Code § [REDACTED – PARTIAL-PHONE](d).
>>>>>
>>>>> Itemization required. Please issue a corrected, fully itemized
>>>>> estimate that breaks out and supports, by task and rate:
>>>>>
>>>>>    1.
>>>>>    2.
>>>>>    3. Search/collection time (by custodian
>>>>>    4. and data source),
>>>>>    5.
>>>>>    6.
>>>>>    7.
>>>>>    8.
>>>>>    9. Compilation/duplication time,
>>>>>    10.
>>>>>    11.
>>>>>    12.
>>>>>    13.
>>>>>    14. Redaction time (identify the specific
>>>>>    15. mandatory confidentiality provisions), and
>>>>>    16.
>>>>>    17.
>>>>>    18.
>>>>>    19.
>>>>>    20. Any programming/manipulation tasks
>>>>>    21. (use programmer rate and describe the steps).
>>>>>    22. Explicitly exclude attorney
>>>>>    23. review and AG-brief preparation time. See § [REDACTED – PARTIAL-PHONE]; 1 TAC §
>>>>>    70.3(d)(3)–(4), (e). Also confirm overhead ≤ 20% of allowable labor and
>>>>>    note the 20% update rule (issue a new written estimate if actual charges
>>>>>    will exceed the prior estimate by ≥20%).
>>>>>    24.
>>>>>
>>>>> “Programming/manipulation” basis. Your email says the request
>>>>> “involves manipulation of data.” Identify which tasks require programming
>>>>> (coding) or manipulation (human reordering/decoding) as used in the Act,
>>>>> and quantify those hours separately. Using built-in e-discovery/search
>>>>> tools is not “programming.” Inspection of electronic records may not be
>>>>> charged unless programming/manipulation is required (§ 552.272).
>>>>>
>>>>> Aggregation. You say you aggregated my clarification responses and an
>>>>> additional same-day request. List each request you aggregated and provide
>>>>> separate line-item estimates per request. A clarification response is not
>>>>> itself a new “request,” and aggregation should not inflate costs across
>>>>> discrete requests. See § 552.261(e).
>>>>>
>>>>> Phased production to cut costs (my election). Proceed in phases,
>>>>> starting with OGC/PIO custodians (Staugaard, Wall) for Oct 3–31, 2025 using
>>>>> the terms: “Kevin Bass,” “kbassphiladelphia,” “Preservation Notice,” “P3,”
>>>>> “SPPCC,” “professionalism.” After Phase-1 lands, we’ll scope Phase-2
>>>>> (Registrar/Student Life/IT). Re-estimate Phase-1 only.
>>>>>
>>>>> Inspection to minimize charges. For Phase-1, I elect on-site or remote
>>>>> inspection of electronic records in native format where feasible (§
>>>>> 552.272), unless you specifically identify required
>>>>> programming/manipulation (with task detail). If programming is necessary,
>>>>> itemize it and use the programmer rate.
>>>>>
>>>>> Rolling production required. Promptly produce any responsive records
>>>>> not subject to your AG request and any clearly public/segregable
>>>>> information now, while your AG brief is pending. See § 552.221; ORD-664
>>>>> (2000).
>>>>>
>>>>> Deposit posture. Given the defects in TTUS’s Nov 3 estimate and the
>>>>> magnitude of the proposed deposit, I will not remit any funds unless and
>>>>> until TTUS provides a § [REDACTED – PARTIAL-PHONE]-compliant written itemized statement that
>>>>> sets out task-level hours and rates (search/collection,
>>>>> compilation/duplication, redaction—identifying any mandatory
>>>>> confidentiality—and any programming/manipulation, if applicable) and
>>>>> identifies less-costly alternatives. I am invoking my rights under §
>>>>> 552.269 and will seek Attorney General review of the estimate. For clarity,
>>>>> the 10-business-day withdrawal provision in § [REDACTED – PARTIAL-PHONE](d) is triggered only
>>>>> by a compliant itemized statement with the required notices; any attempt to
>>>>> treat this request as withdrawn before such a statement issues is improper.
>>>>> Likewise, any deposit request under § 552.263(a) must follow and be based
>>>>> on a compliant § [REDACTED – PARTIAL-PHONE] itemized statement. I also elect inspection where
>>>>> it reduces charges, consistent with § 552.272.
>>>>>
>>>>> Please confirm receipt and provide a date/time for initial rolling
>>>>> production of non-exempt material. Also send the revised, itemized Phase-1
>>>>> estimate within 3 business days, so I can respond within the statute’s
>>>>> window.
>>>>>
>>>>> Kevin Bass PhD MS
>>>>>
>>>>> Phone: *[REDACTED – PHONE]*
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>> On Mon, Nov 3, 2025 at 4:51 PM Staugaard, Bronte <
>>>>> Bronte.Staugaard@ttu.edu> wrote:
>>>>>
>>>>> Good Afternoon,
>>>>>
>>>>>
>>>>>
>>>>> Texas Tech University System (TTUS) is in receipt of your responses to
>>>>> our clarifications/narrowings and your additional request received on
>>>>> October 20, 2025. The responses and request are attached herein.  Due to
>>>>> our receipt of your responses and request on the same calendar day, we are
>>>>> treating them as a single request for the purposes of calculating costs as
>>>>> permitted under the Texas Government Code.
>>>>>
>>>>>
>>>>>
>>>>> We must also note that while our correspondences sought to clarify or
>>>>> narrow the scope of your requests, your subsequent responses have generally
>>>>> served to broaden them. As such, we have determined that complying with the
>>>>> request will result in the imposition of a charge that exceeds
>>>>> $40. Therefore, the following statement is provided pursuant to sections
>>>>> [REDACTED – PARTIAL-PHONE] and 552.263 of the Texas Government Code:
>>>>>
>>>>>
>>>>>
>>>>>    1. The requested information is not currently available in a form
>>>>>    suitable for public release, and since the request involves manipulation of
>>>>>    data, documents are not feasible to retrieve, will result in substantial
>>>>>    interference with ongoing operations and can only be provided at a cost
>>>>>    that covers the manipulation of data and other costs, you are entitled to
>>>>>    an estimate of the costs and time to provide the information in the
>>>>>    requested form.
>>>>>
>>>>>
>>>>>
>>>>> Therefore, the itemized statement of estimated charges is:
>>>>>
>>>>>
>>>>>
>>>>> Labor 214.95 hrs. @ $15/hr. =           $ 3,224.25
>>>>>
>>>>> *Overhead @ 20% =                            $ 644.85             *
>>>>>
>>>>>
>>>>> *Estimated Total Cost =                     $3,869.10*
>>>>>
>>>>>
>>>>>
>>>>>    2. Pursuant to §[REDACTED – PARTIAL-PHONE] of the Texas Government Code, TTUS is
>>>>>    providing you with an alternative, less expensive method of obtaining some
>>>>>    of the requested information.  An alternative method would be to narrow
>>>>>    your request by eliminating some of the data requested, such as narrowing
>>>>>    the date range or information requested. It may also be less expensive to
>>>>>    view the documents here at the office.
>>>>>
>>>>>
>>>>>
>>>>>    3. *Your request will be considered automatically withdrawn if you
>>>>>    do not notify us in writing and within 10 (ten) business days from the date
>>>>>    of this statement that you:*
>>>>>
>>>>>
>>>>>
>>>>>    1. Accept the estimated charges and will pay them.  Because your
>>>>>       request is over $100.00, you are required to either deposit $1,934.55 (50%
>>>>>       of the estimated costs) or provide TTUS with a bond for the total estimated
>>>>>       cost. *Please note that pursuant to §552.263(e), your request
>>>>>       will be considered received when we receive your payment.  Additionally, if
>>>>>       you fail to pay within 10 business days, your request will be considered
>>>>>       withdrawn pursuant to §552.263(f).*
>>>>>       2. Are modifying the request (state the modification); or
>>>>>       3. Have sent a complaint to the Office of the Attorney General
>>>>>       of Texas alleging that you have been overcharged for a copy of public
>>>>>       information.
>>>>>
>>>>>
>>>>>
>>>>>    4. You may choose to respond by email to me at
>>>>>    bronte.staugaard@ttu.edu, regular mail (1508 Knoxville Ave., Ste.
>>>>>    301 Box 42021, Lubbock, Tx 79409-2021), or in person to Ste. 301 of the
>>>>>    Texas Tech University System Building, located at 1508 Knoxville
>>>>>    Ave., Ste. 301, Lubbock, Tx 79409-2021.
>>>>>
>>>>>
>>>>>
>>>>>    5. Your check, money order, or bond must be made payable to: Texas
>>>>>    Tech University System.
>>>>>
>>>>>
>>>>>
>>>>>    6. If we determine that a change in estimated charges will exceed
>>>>>    the amount in this written itemized statement by 20%, we will send you an
>>>>>    updated written itemized statement. As noted above, the same response
>>>>>    requirements are imposed on you once an updated itemized statement is sent.
>>>>>
>>>>>
>>>>>
>>>>>    7. TTUS expects it to take approximately 2 weeks to complete this
>>>>>    request at current workloads.
>>>>>
>>>>>
>>>>>
>>>>> Finally, some of the documents or information that you have requested
>>>>> may be withheld under State law.  Therefore, if you choose to pay the
>>>>> deposit, we may request an Attorney General Open Records Decision (“ORD”)
>>>>> seeking to withhold some documents or information pursuant to the Texas
>>>>> Public Information Act.  Texas Government Code § 552.001, et seq.  Once the
>>>>> Attorney General makes a decision regarding the public disclosure of these
>>>>> documents, TTUS will make those documents that are determined by the
>>>>> Attorney General to be public, if any, available for inspection or copying.
>>>>>
>>>>>
>>>>>
>>>>> Sincerely,
>>>>>
>>>>> Brontë C. Staugaard
>>>>>
>>>>> Assistant General Counsel
>>>>>
>>>>> Texas Tech University System
>>>>>
>>>>> (806) [REDACTED – PARTIAL-PHONE]
>>>>>
>>>>>
>>>>>
>>>>> This communication, including any attachments, originates from an
>>>>> Attorney and may contain confidential information and is intended only for
>>>>> the individual or entity to whom it is addressed. Any review,
>>>>> dissemination, or copying of this communication by anyone other than the
>>>>> intended recipient is strictly prohibited. If you are not the intended
>>>>> recipient, please contact the sender by reply e-mail, delete and destroy
>>>>> all copies of the original message.
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>
>>>>>