FOI #26-379 - Subject - UCONN and Wilson Elser
Name - Richard Mardoian
Affiliation -
Pursuant to the Connecticut Freedom of Information Act (FOIA), Chapter 14 of the Connecticut General Statutes, I hereby demand the inspection and electronic production of the public records detailed below.
As the Chief Legal Officer for the University of Connecticut, you are reminded of your statutory obligation to conduct a comprehensive, exhaustive, and good-faith search of all administrative repositories, internal networks, server databases, and specialized ledger systems under your custody and control. Let's not make the Mahon Mistake.
I. Scope of Records Requested
I request any and all records, regardless of physical or digital form, active or generated at any point from April 3, 2019, through the present date, concerning, referencing, or detailing transactions with:
Wilson Elser Moskowitz Edelman & Dicker LLP (inclusive of its regional offices at 100 Pearl St, Hartford, and 1010 Washington Blvd, Stamford, as well as any operational shell, corporate affiliate, or subsidiary entity utilizing the statutory registered agent address of 357 East Center St, Suite 2J, Manchester, CT 06040).
This request specifically encompasses:
1. Procurement & Retention Contracts: All Master Outside Counsel Legal Services Agreements, Task Orders, Retainer Letters, and Conflict of Interest Disclosures/Waivers executing or approving the assignment of legal work or defense panels to said firm.
2. Communications and Metadata: All original electronic mail communications (including .eml/.msg files containing full transport email headers and tracking metadata), text messages, and internal memos between personnel within the UConn Office of the General Counsel and any attorney, representative, or agent of Wilson Elser.
3. Billing, Ledger, & Expenditure Files: All itemized invoices, line-item fee descriptions, transaction tables, and payment approvals issued by UConn or UConn Health to said firm.
II. Production and Technical Specifications
In accordance with Connecticut transparency law and data preservation mandates:
• Native Electronic Formats: All responsive data, spreadsheets, ledger books, and transaction tables MUST be produced in their original electronic format (such as native, unflattened .xlsx or .csv files) to preserve data fields, structural columns, and filtering capability.
• Non-Segregability: If any portion of a requested document is deemed exempt under Conn. Gen. Stat. § 1-210, you are required to redact only the specifically exempt text and release all remaining segregable data and structural headers.
III. Statutory No-Records Certification Mandate
If the University of Connecticut, its Office of the General Counsel, and UConn Health contend that no records, retainer agreements, email correspondence, or financial invoices exist regarding Wilson Elser Moskowitz Edelman & Dicker LLP within the specified timeframe, you are requested to provide a formal, written Certification of No Records.
This certification must explicitly state that a diligent, exhaustive