Discovery Request for GOAA Documents (2021-09-28) — Complaint - Wall v. CDC

Summary

Exhibit 1 in Wall v. CDC, case 6:21-cv-00975-PGB-DCI, filed 09/28/21 as Document 153-1: an email sent September 6, 2021 by plaintiff Lucas Wall to counsel for the Greater Orlando Aviation Authority (GOAA) titled Discovery Request for GOAA Documents. Unless GOAA agrees to a consent decree ending its mask mandate at Orlando International Airport or cross-claims against the federal defendants, Wall requests documents under Rule 34 to prove his claim that GOAA illegally established and enforces the mandate. The requests cover the mandate's timeline and legal authority, meetings and records on exemptions for passengers with disabilities, complaints about violations and about the requirement, guidance to employees and tenants, and compliance with Fla. Stat. § 252.38(4)(c). The email is signed /s/ Lucas Wall.

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EXHIBIT 1

Case 6:21-cv-00975-PGB-DCI   Document 153-1   Filed 09/28/21   Page 1 of 3 PageID 4867

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From:
Lucas Wall <lucas.wall@yahoo.com>
Sent:
Monday, September 6, 2021 7:59 AM
To:
Gerber, Dan; Culley, Sally; Delaney, Patrick; Hill, Suzanne
Subject:
Wall v. CDC -- Discovery Request for GOAA Documents
Dear counsel:

Unless your client, Greater Orlando Aviation Authority (“GOAA”), agrees to quickly enter into a consent decree to
immediately terminate its mask mandate for all passengers at Orlando International Airport and/or file a cross-claim
against the Federal Defendants, my position is that discovery is now available since this case is exempt from a Case
Management Report and scheduling order.

Therefore, I issue this discovery request pursuant to Fed.R.Civ.P. 34 for documents necessary to prove my claims in the
Complaint that GOAA illegally established and enforces a mask mandate.

I request production of the following documents, preferably in electronic PDF format:

1. A timeline of GOAA’s establishment of a mask mandate, supported by documents requested below. When did GOAA
first adopt a mask mandate? Who adopted it? What legal authority was cited for the mask mandate? Was it approved by
the board of directors? How has the mask mandate changed, if at all, since its original adoption? What date did GOAA
first place signs on airport property indicating it was enforcing a mask mandate? What date, if any, were these signs
changed to reflect a new policy about masks? Please include other key dates such as enforcement guidance issued to
GOAA personnel, etc.

2. All documents including but not limited to memorandums, notes, minutes, call transcripts, and lists of meeting dates
and attendees (in person, telephone, videoconference, and other forms of meetings) concerning any GOAA mask
mandate, proposed mask mandate, and consideration of exemptions for passengers with disabilities who can’t tolerate
covering their sources of oxygen. Please identify all participants in these meetings, calls, videoconferences, etc. by name,
title, and organization represented if not GOAA.

3. All documents similar to those enumerated in #2 related to GOAA’s consultation with disability-rights advocates, both
individuals and organizations, concerning mask requirements. Please identify all participants in these consultations by
name, title, and organization represented (or self for individuals).

4. All reports received by GOAA from its employees, passengers, airline tenants and employees, car-rental tenants and
employees, retail/restaurant tenants and employees, other tenants and employees, and all others in 2020 and 2021
concerning alleged passenger and employee violations of the mask mandate. Please indicate at minimum name of
complainant; name and contact information (mailing address, e-mail address, and/or telephone number) of passenger or
employee alleged to be in violation; date and location of incident; description of incident; and what action GOAA took on
the complaint (also specify whether GOAA reported the incident to the Transportation Security Administration for all
complaints received on Feb. 1, 2021, and thereafter).

5. All documents received by GOAA in 2020 and 2021 concerning passengers complaining about GOAA’s mask
requirement. Include all contact information provided by the complainant such as mailing address, e-mail address, and/or
telephone number. Include all correspondence GOAA sent to the complainant.

6. The current version of GOAA’s mask mandate including date approved by the board of directors.

7. All documents concerning GOAA’s communication of its mask mandate to its employees and tenants including
enforcement guidance and training.

8. All documents concerning GOAA’s policies on accommodating passengers with disabilities including but not limited to
notices issued to its employees and tenants on how to address passengers who can’t medically tolerate wearing a face
covering.

9. All documents related to GOAA’s compliance with Fla. Stat. § 252.38(4)(c) including but not limited to the date upon
Case 6:21-cv-00975-PGB-DCI   Document 153-1   Filed 09/28/21   Page 2 of 3 PageID 4868

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which GOAA’s board of directors first approved an emergency mask mandate pursuant to this statute; the dates upon
which GOAA’s board of directors renewed the emergency mask mandate (at least every seven days pursuant to the
statute); the date upon which the emergency mask mandate expires (not to exceed 42 days from date of first enactment
pursuant to the statute); and all memorandums, notes, minutes, call transcripts, and lists of meeting dates and attendees
(in person, telephone, videoconference, and other forms of meetings) related to all board actions taken pursuant to
emergency mask mandates adopted pursuant to the statute.

Rule 34 requires a response within 30 days. If you believe it will take more than 30 days to produce the requested
documents and information, please provide an estimate of how long it's expected for GOAA to comply. Thank you.

Pursuant to Fed.R.Civ.P. 26(g), I certify that to the best of my knowledge, information, and belief formed after a
reasonable inquiry that this request is: A) consistent with the rules and warranted by existing law or by a nonfrivolous
argument for extending, modifying, or reversing existing law, or for establishing new law; B) not interposed for any
improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation; and C)
neither unreasonable nor unduly burdensome or expensive.

/s/ Lucas Wall
Lucas Wall, plaintiff
435 10th St., NE
Washington, DC 20002
Telephone: 202-351-1735
E-Mail: Lucas.Wall@yahoo.com

Case 6:21-cv-00975-PGB-DCI   Document 153-1   Filed 09/28/21   Page 3 of 3 PageID 4869

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