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 552.2615 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 §552.2615 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  Your request will be considered automatically withdrawn if you do not notify us in writing and within 10 (ten) business days from the date of this statement that you: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) 742-2155

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]

Hello, thanks for your 10/17 note.



To move quickly and keep costs low, I clarify:

People (5): Eric Bentley; Ronny Wall; William Webster; Amanda McSween;

Beverly Muñoz.

Where: university email only (no Teams/Slack/texts for now).

Dates: 6/1/2023 → present.

Terms (OR): “Kevin Norris Bass” OR “Kevin Bass” OR kbassphiladelphia@

OR trespass OR dismissal OR appeal OR SDS OR ADA OR accommodation.

Priority first: final decision letters; final hearing/appeal outcomes;

any Criminal Trespass Warning; any final reports/sanctions.

Segregate‑and‑release: please release non‑exempt portions immediately

on a rolling basis.

Format: native email (.eml/.pst) with full headers/attachments, PDFs

for final docs; electronic only. If volume is heavy, a quick

headers/index export first (existing export) is fine; then staged

content.

Schedule: if you can’t produce within 10 business days, send the

written date/time for the first batch and the staged production

schedule you’re using.

Existing artifacts (existing only): content‑search job details (job

ID, query, date/time run, target mailboxes, export report/item

counts); any export receipts/checksums; the search‑definition

snapshot; any custodian hold/acknowledgment emails;

message‑trace/transport‑rule hits for my address/keywords; the

request/ticket log (ID + timestamps) and any production schedule. If

your search touched PublicInfo@, Registrar@, OGC/OpenRecords@,

Student.Life@, or DOME@, please include final emails/attachments from

those boxes.

Costs: proceed Phase‑1 up to $40; before exceeding, send a refreshed

itemized estimate.

Receipt & deadlines: sent Mon Oct 20, 2025 at 8:00 AM CT; please

confirm you treat Oct 20 as the date of receipt. Based on that: Day‑10

= Mon Nov 3, 2025; Day‑15 = Mon Nov 10, 2025. If you consider Oct 20 a

non‑business day or are suspending under a catastrophe notice, please

attach the designation/notice so I can adjust. I’m happy to further

narrow after a quick hit‑count/index.



Kevin Bass PhD MS

Phone: [REDACTED – HOME-PHONE]



On Fri, Oct 17, 2025 at 5:01 PM Staugaard, Bronte

<Bronte.Staugaard@ttu.edu> wrote:

>

> Good Afternoon,

>

>

>

> Texas Tech University System (TTUS) is in receipt of your Texas Public Information Act request below/attached.  However, TTUS seeks to discuss with you how the scope of your request might be narrowed and/or clarified pursuant to Texas Government Code § 552.222(b).  TTUS requests that you narrow or clarify the scope of your request as follows:

>

>

>

> Your request for all “Communications, memoranda, notes, meeting agendas/minutes, tasking directives, and decision records” is overly broad. In order for us to identify and locate potentially responsive information, we ask that you please clarify your request by identifying the specific document(s) you are seeking. For example, you may wish to clarify that you are seeking the final dismissal letter or the final decision of the Appeals Panel.

> Further, because your request identifies over two dozen custodians or custodian groups across numerous departments and asks for a search of multiple communication platforms (including email, Teams, and personal messaging applications), the search required to locate potentially responsive records could be extensive. This process may require significant manual review by multiple departments and complex searches by departments before any information could be released. This necessary process could result in significant costs to you.

> As such, you may wish to consider narrowing the scope of your request to reduce these potential costs. For example, you could limit your request by doing the following:

>

> Prioritize Custodians: Limit your request to the 3-5 most critical custodians you believe hold the primary decision-making records.

> Specify Document Types: Instead of all communications and notes, you could request specific final determination documents, such as the official Criminal Trespass Warning notice, the final report from the professionalism proceedings, or the final dismissal hearing decision.

> Provide Keywords: To help focus the search of electronic communications across numerous platforms, you could provide a limited set of specific search terms.

>

>

>

> Please simply respond to this request and let us know if you are willing to narrow/clarify the scope of your request in the manner suggested or in some other manner.  Please note that we may be required to send some information to the Texas Attorney General for review prior to release.  That process could take 2-3 months.  TTUS is required to inform you that if you do not respond to this request for narrowing/clarification within 61 days from the date of this request, your request will be considered withdrawn.

>

>

>

> Sincerely,

>

> Brontë C. Staugaard

>

> Assistant General Counsel

>

> Texas Tech University System

>

> (806) 742-2155

>

>

>

> 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.

>

>

>

> -----Original Message-----

>

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

>

> Sent: Thursday, October 2, 2025 5:30 PM

>

> To: Public Info <publicinfo@ttu.edu>

>

> Cc: Bentley, Eric <Eric.Bentley@ttu.edu>; Wall, Ronny <Ronny.Wall@ttu.edu>

>

> Subject: TPIA Request — TTUHSC Proceedings re Kevin Norris Bass (06/01/2023–present)

>

>

>

> [You don't often get email from kbassphiladelphia@gmail.com. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]

>

>

>

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

>

>

>

>

>

> Subject: TPIA Request – Proceedings/Communications (June 1, 2023 – October 2, 2025)

>

>

>

> Public Information Officer,

>

>

>

> Please find attached my TPIA request regarding proceedings/communications re Kevin Norris Bass for June 1, 2023 – October 2, 2025. Electronic delivery and rolling production are preferred.

>

>

>

> Fee cap/waiver: If estimated costs exceed $100, please provide an itemized estimate before proceeding; I request waiver/reduction under § 552.267.

>

>

>

> If any portion is unclear or unduly burdensome, please identify the burden with specificity and propose narrowing consistent with Tex.

>

> Gov't Code §§ 552.222 and 552.267.

>

>

>

> Kevin Bass PhD MS

>

> Phone: [REDACTED – HOME-PHONE]

Hello—thanks for your 10/17 note. To move quickly and keep costs low, I clarify:



Scope (my records only):

final notices/decisions placing or clearing any transcript hold; Registrar ↔ Financial Aid emails about my transcript/holds; and the final SIS entry/screen or export actually relied on for the decision (not a full audit log).



Where: email only for communications (Registrar office account + FinancialAid office account + any of the five named custodians where they were sender/recipient); PDFs/exports for the final notices/decisions/SIS “final” screen or letter.



Dates: 2/1/2024 → present.



Segregate‑and‑release: please release non‑exempt portions immediately on a rolling basis.



Format: native email (.eml/.pst) w/ full headers/attachments; PDFs/exports for finals; electronic delivery only. If volume is heavy, a quick headers/index export first (existing export) is fine, then staged content.



Schedule: if you cannot produce within 10 business days, please send the required written date/time for the first batch and the staged production schedule you’re using.



Existing artifacts (existing only):

– content‑search job details (Purview/Exchange: job ID, query string, date/time run, targeted mailboxes, export report/item counts),

– any export receipts/checksums,

– the search‑definition snapshot used (mailbox list, date filters),

– any custodian hold/acknowledgment emails already issued,

– message‑trace/transport‑rule hits for my address/keywords (to reveal functional/shared mailboxes touched),

– the ticket/queue record (ID + timestamps) and any production schedule already drafted.



Policy finals: if the decision letters reference a policy, please include the final policy in force at that time (PDF, finals only).



Privacy: I exclude other students’ info and accept redactions.



Costs: proceed Phase‑1 up to $40; before exceeding, send a refreshed itemized estimate. Delivery is electronic only.



Receipt & deadlines: Sent Mon Oct 20, 2025 at 8:00 AM CT—please confirm you treat Oct 20 as the receipt date. Based on that: Day‑10 = Mon Nov 3, 2025; Day‑15 = Mon Nov 10, 2025.

If you consider Oct 20 a non‑business day or are suspending under a catastrophe notice, please attach that designation/notice so I can adjust. I’m happy to further narrow after a quick hit‑count/index.



Kevin Bass PhD MS

Phone: [REDACTED – HOME-PHONE]





On Fri, Oct 17, 2025 at 5:01 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 Texas Public Information Act request attached/below.  However, TTUS seeks to discuss with you how the scope of your request might be narrowed and/or clarified pursuant to Texas Government Code § 552.222(b).  TTUS requests that you narrow or clarify the scope of your request as follows:







   1.   Your requests for all “Audit logs, system notes, and tasking entries documenting transcript processing or hold removal decisions,” “Student Business Services/Bursar ledger entries and adjustments” and “Enrollment reporting records” are broad and could encompass a vast number of records from multiple administrative systems and students. This process could result in significant costs to you. In order for us to identify and locate potentially responsive information, we ask that you please clarify your request by identifying the specific document(s) you are seeking or limit this request to records and decisions related to you.

   2.   Further, your request for all internal communications between four separate administrative units, plus the extraction of system-level audit logs and full financial ledger details, involves multiple complex information systems, the process to locate and compile these records may be extensive and could result in significant costs to you.

   3.   Please consider narrowing the scope of your request to reduce these potential costs. For example, you could limit your request by doing the following:



   *    Specify Communications: Limit your request for communications to one or two custodians concerning your account status.

   *    Request Final Documents: Instead of all “Audit logs, system notes, and tasking entries documenting transcript processing or hold removal decisions,” “Student Business Services/Bursar ledger entries and adjustments” and “Enrollment reporting records”, you could request the official notice of the financial hold placed on your account.

   *    Limit the Timeframe for documents and logs.



   4.   Additionally, because your request seems to include your student records, we require additional information to verify your identity. As such, please provide us with the following:



   *    A copy of your driver’s license or other government issued photo ID.







   Please simply respond to this request and let us know if you are willing to narrow/clarify the scope of your request in the manner suggested or in some other manner.  Please note that we may be required to send some information to the Texas Attorney General for review prior to release.  That process could take 2-3 months.  TTUS is required to inform you that if you do not respond to this request for narrowing/clarification within 61 days from the date of this request, your request will be considered withdrawn.







   Sincerely,



   Brontë C. Staugaard



   Assistant General Counsel



   Texas Tech University System



   (806) 742-2155







   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.



















   -----Original Message-----



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



   Sent: Thursday, October 2, 2025 5:31 PM



   To: Public Info <publicinfo@ttu.edu<mailto:publicinfo@ttu.edu>>



   Cc: Bentley, Eric <Eric.Bentley@ttu.edu<mailto:Eric.Bentley@ttu.edu>>; Wall, Ronny <Ronny.Wall@ttu.edu<mailto:Ronny.Wall@ttu.edu>>



   Subject: TPIA Request — Transcript/Title IV Records (02/01/2024–present)







   [You don't often get email from kbassphiladelphia@gmail.com<mailto:kbassphiladelphia@gmail.com>. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]







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











   Subject: TPIA Request – Transcript/Title IV-Related Records (February 1, 2024 – October 2, 2025)







   Public Information Officer,







   Attached is my TPIA request seeking policy/process and case-level records related to transcript issuance and Title IV obligations.



   Electronic delivery and rolling production requested.







   Fee cap/waiver: If costs exceed $100, please provide an itemized estimate beforehand; I request waiver/reduction under § 552.267.







   Thank you.







   Kevin Bass PhD MS



   Phone: [REDACTED – HOME-PHONE]



Hello—clarifying to make this simple and fast:



Identify the year (quick lookup, existing records only):



Please identify the academic year in which I would have been in P3

(MSCI-5120/6120) based on your existing records (e.g., program

map/catalog for my cohort, Registrar’s one-line certification, or

Student Affairs/ DOME cohort schedule). No other students’ info is

requested or needed—a one-line confirmation or a pointer to the

program map is sufficient.



Two ways to proceed (choose whichever is faster):



Option A (preferred): After you identify the AY of my P3 year, produce

the final P3 materials for that AY (see list below).



Option B (fallback to avoid delay): While you confirm the AY, produce

finals for AY 2014-15 and AY 2015–16 now and then tell me which of

those aligns with my P3 year. If only one of those AYs applies, just

say which.



Final documents only (no drafts):



P3 syllabus, grading rubric, official policies/procedures, and faculty

guidance/training decks that were actually in force for the relevant

AY.



If applicable, the final committee/department approval memo (as

adopted) for those items.



Where finals live (existing only):



The final PDFs themselves and/or the final SharePoint/OneDrive

location where those finals are stored (final folder/path only).



Segregate-and-release: Please release non-exempt portions immediately

on a rolling basis; don’t hold back non-exempt items pending other

review.



Format: PDFs for finals; electronic delivery only. If finals are in a

repository/LMS, exporting the final PDF is fine (no version history or

student submissions needed).



Schedule: If you can’t produce within 10 business days, please send

the required written date/time for the first batch and the staged

production schedule you’re using.



Process artifacts (existing only):



the search instruction you sent (who/when/locations),



any hit-count/summary already produced,



the ticket/log ID + timestamps, and any production schedule already drafted.



Privacy: No student PII sought; I accept redactions.



Costs: Please proceed Phase-1 up to $40; before exceeding, send a

refreshed itemized estimate. Delivery is electronic only.



Receipt & deadlines: Sent Mon Oct 20, 2025 at 8:00 AM CT—please

confirm you treat Oct 20 as the receipt date. Based on that: Day-10 =

Mon Nov 3, 2025; Day-15 = Mon Nov 10, 2025.



If you consider Oct 20 a non-business day or are suspending under a

catastrophe notice, please attach the designation/notice so I can

adjust. I’m happy to further narrow after a quick hit-count/index.





Kevin Bass PhD MS

Phone: [REDACTED – HOME-PHONE]

On Fri, Oct 17, 2025 at 5:01 PM Staugaard, Bronte

<Bronte.Staugaard@ttu.edu> wrote:

>

> Good Afternoon,

>

>

>

> Texas Tech University System (TTUS) is in receipt of your Texas Public Information Act request below/attached.  However, TTUS seeks to discuss with you how the scope of your request might be narrowed and/or clarified pursuant to Texas Government Code § 552.222(b).  TTUS requests that you narrow or clarify the scope of your request as follows:

>

>

>

> First, your request does not specify a specific academic year, which may require us to search for all such records since the inception of the P3 curriculum. This necessary process could result in significant costs to you.

> Further, your request for “faculty guidance” and “administrative correspondence” concerning P3 requirements is broad and unclear. In order for us to identify and locate potentially responsive information, we ask that you clarify what specific types of correspondence or “faculty guidance” you are seeking. For example, you could clarify your request by specifying a particular document and custodian, or by providing a few keywords to search within a specific academic year.

> Additionally, a search for all internal correspondence and “faculty guidance”, without clarification/narrowing, could require a manual review of thousands of documents to locate responsive records. This necessary process could result in significant costs to you.

> As such, you may wish to consider narrowing the scope of your request to reduce these potential costs and allow us to identify and locate potentially responsive information. For example, you could limit your request by doing the following:

>

> Provide the Academic Years of interest: Please specify a relevant timeframe for your request, specifically a particular academic year (e.g., 2023-2024).

> Request Final Documents: Limit your request to a version of the P3 syllabi, policy, and/or rubric for a specified academic year.

>

> Specify Correspondence: Instead of all "administrative correspondence," you could specify a particular document and custodian, or provide a few keywords to search within a specific academic year.

>

>

>

> Please simply respond to this request and let us know if you are willing to narrow/clarify the scope of your request in the manner suggested or in some other manner.  Please note that we may be required to send some information to the Texas Attorney General for review prior to release.  That process could take 2-3 months.  TTUS is required to inform you that if you do not respond to this request for narrowing/clarification within 61 days from the date of this request, your request will be considered withdrawn.

>

>

>

> Sincerely,

>

> Brontë C. Staugaard

>

> Assistant General Counsel

>

> Texas Tech University System

>

> (806) 742-2155

>

>

>

> 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.

>

>

>

> -----Original Message-----

>

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

>

> Sent: Thursday, October 2, 2025 6:09 PM

>

> To: Public Info <publicinfo@ttu.edu>

>

> Cc: Bentley, Eric <Eric.Bentley@ttu.edu>; Wall, Ronny <Ronny.Wall@ttu.edu>

>

> Subject: TPIA Request — P3 (MSCI-5120/6120) Professionalism Content (AYs requested)

>

>

>

> [You don't often get email from kbassphiladelphia@gmail.com. Learn why this is important at https://aka.ms/LearnAboutSenderIdentification ]

>

>

>

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

>

>

>

>

>

> Subject: TPIA Request – P3 (Non‑FERPA Materials)

>

>

>

> Public Information Officer,

>

>

>

> Attached is my TPIA request for P3 non-student-specific preclinical materials (policies, rubrics, training) maintained by DOME and Dr.

>

> Kendra Rumbaugh. Electronic delivery and rolling production requested.

>

> Fee cap $100 with § 552.267 waiver request.

>

>

>

> Thank you.

>

>

>

> Kevin Bass PhD MS

>

> Phone: [REDACTED – HOME-PHONE]

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


Hello,

Please provide existing records showing how you’re handling my TPIA
requests (original + today’s clarifications): (i) search instruction
to custodians (who/when/terms/systems); (ii) any hit-count/summary
your tool produced; (iii) the ticket/log ID + timestamps and
production schedule; (iv) any letters/notices to the AG
(drafts/final). Electronic, rolling. If not within 10 business days,
please send the written date/time for the first batch. If withholding,
please meet Day-10/Day-15.

Kevin Bass PhD MS
Phone: [REDACTED – HOME-PHONE]

Brontë,

This is my timely response under Tex. Gov’t Code § 552.2615(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 §
   552.2615; 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 § 552.2615-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 § 552.2615(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 § 552.2615 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 – HOME-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
> 552.2615 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 §552.2615 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) 742-2155
>
>
>
> 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 – HOME-PHONE]

Kevin Bass PhD MS
Phone: *[REDACTED – HOME-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 § 552.2615(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
>    § 552.2615; 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 § 552.2615-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 § 552.2615(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 § 552.2615 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 – HOME-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
>> 552.2615 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 §552.2615 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) 742-2155
>>
>>
>>
>> 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 552.2615 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 §552.2615 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) 742-2155



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) 742-2155



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 § 552.2615(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 § 552.2615; 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 § 552.2615-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 § 552.2615(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 § 552.2615 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 – HOME-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 552.2615 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 §552.2615 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) 742-2155



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 §552.2615 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
§552.2615(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 § 552.2615(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 – HOME-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
> 552.2615 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 §552.2615 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) 742-2155
>
>
>
> 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) 742-2155
>
>
>
> 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 § 552.2615(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 § 552.2615; 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 § 552.2615-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 § 552.2615(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 § 552.2615 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 – HOME-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
> 552.2615 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 §552.2615 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) 742-2155
>
>
>
> 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 §552.2615(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 – HOME-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 §552.2615 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
> §552.2615(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 § 552.2615(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 – HOME-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
>> 552.2615 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 §552.2615 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) 742-2155
>>
>>
>>
>> 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) 742-2155
>>
>>
>>
>> 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 § 552.2615(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 § 552.2615; 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 § 552.2615-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 § 552.2615(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 § 552.2615 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 – HOME-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
>> 552.2615 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 §552.2615 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) 742-2155
>>
>>
>>
>> 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 § 552.2615, §
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 § 552.2615 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 – HOME-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 §552.2615(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 – HOME-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 §552.2615 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
>> §552.2615(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 § 552.2615(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 – HOME-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 552.2615 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 §552.2615 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) 742-2155
>>>
>>>
>>>
>>> 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) 742-2155
>>>
>>>
>>>
>>> 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 § 552.2615(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 § 552.2615; 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 § 552.2615-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 § 552.2615(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 § 552.2615 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 – HOME-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
>>> 552.2615 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 §552.2615 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) 742-2155
>>>
>>>
>>>
>>> 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.
>>>
>>>
>>>
>>>
>>>
>>>