FOLLOW THE PAPER TRAIL.

Please produce:

• All body-worn camera recordings and individual video or audio segments associated with the incident, including recordings made by Deputy Miguel Bittony, Sgt. Savannah Benally, and any other MCSO personnel who were present, responded, assisted, supervised, reviewed, or otherwise participated in the incident or investigation.
• All other electronic recordings associated with the incident that are maintained or held by MCSO.
• All photographs, digital images, audio files, video files, and other electronic evidence associated with the incident.

For every responsive recording or electronic evidence file, please produce all existing WatchGuard or other recording-system metadata, including:

• original filenames;
• creation dates and times;
• recording start and stop times;
• upload and synchronization dates and times;
• device identifiers;
• camera identifiers;
• user identifiers;
• recording identifiers;
• event or case associations;
• classifications and tags;
• retention classifications; and
• other system-generated metadata associated with the responsive file.

Please produce all existing audit logs, event histories, access histories, or other system records reflecting any:

• access;
• viewing;
• playback;
• downloading;
• exporting;
• copying;
• sharing;
• redaction;
• digital obscuring;
• editing;
• conversion;
• reclassification;
• case association;
• deletion;
• retention change;
• restoration;
• preservation; or
• other handling

of any responsive recording, electronic evidence file, or derivative thereof.

This includes records identifying the date, time, user, account, device, or system associated with any such action where that information exists.

Please produce all existing:

• device-assignment records;
• upload or synchronization logs;
• transfer logs;
• docking-station records;
• error logs;
• failure logs;
• exception records; and
• other system records

concerning the cameras, recording devices, docking stations, upload processes, synchronization processes, or electronic evidence associated with this incident.

Please produce all existing:

• export manifests;
• export histories;
• redaction-project records;
• redaction logs;
• digital-obscuring records;
• derivative-file records;
• conversion records;
• copying records; and
• other records identifying when, how, or by whom a copy, export, redacted version, digitally obscured version, converted version, or other derivative of responsive electronic evidence was created.

Where the system identifies the source file from which a derivative was generated, please include that existing information.

Please produce all:

• evidence logs;
• digital-evidence records;
• property or evidence records;
• chain-of-custody records;
• evidence numbers;
• case-association records;
• transfer records;
• upload records;
• synchronization records;
• receipt records; and
• disposition records

concerning electronic or physical evidence associated with this incident.

Please produce all existing:

• photographs;
• digital images;
• supplemental reports;
• field notes;
• handwritten notes;
• electronic notes;
• statements;
• interview records;
• evidence records;
• investigative records; and
• other investigative materials

associated with the incident.

Please produce all existing records reflecting any:

• supervisory review;
• supervisory approval;
• administrative review;
• quality-control review;
• case review;
• evidence review;
• body-worn camera review;
• report review; or
• other review

of the investigation, recordings, reports, evidence, officer conduct, or handling of this incident.

Please produce all existing records reflecting decisions, recommendations, discussions, or review concerning:

• arrest;
• non-arrest;
• citation;
• release;
• investigative classification;
• probable cause;
• further investigation;
• suspect disposition;
• referral to another agency;
• referral to a prosecuting authority;
• case closure; or
• any other disposition of the matter.

Please produce any policies, procedures, directives, general orders, manuals, bulletins, or training materials in effect on July 16, 2026 that governed the:

• creation;
• activation;
• uploading;
• synchronization;
• storage;
• retention;
• access;
• review;
• export;
• redaction;
• digital obscuring;
• deletion;
• preservation; or
• handling

of body-worn camera recordings applicable to personnel involved in this incident.

Please also produce any policies, procedures, directives, general orders, manuals, bulletins, or training materials in effect on July 16, 2026 governing:

• digital-evidence preservation;
• chain of custody;
• supervisory review of body-worn camera evidence;
• missing or incomplete recordings;
• failed uploads;
• recording interruptions;
• evidence retention; or
• documentation of technical problems.

Please produce all existing records concerning any recording or other electronic evidence associated with this incident that was not created, activated, uploaded, synchronized, retained, located, preserved, or produced as ordinarily expected.

This includes existing records reflecting:

• attempted creation or activation;
• attempted upload or synchronization;
• storage;
• access;
• retention;
• export;
• redaction;
• deletion;
• corruption;
• loss;
• technical failure;
• recovery;
• restoration; or
• other disposition.

Please produce all existing:

• retention classifications;
• scheduled retention dates;
• scheduled deletion dates;
• preservation flags;
• evidence holds;
• litigation or legal holds;
• manual retention changes;
• deletion-prevention settings; and
• other records reflecting how long responsive recordings or electronic evidence were scheduled or directed to remain available.

Please produce all internal emails, messages, memoranda, correspondence, or other communications concerning the:

• body-worn camera recordings;
• electronic evidence;
• investigation;
• reports;
• physical or digital evidence;
• supervisory review;
• suspect disposition;
• charging or referral;
• preservation;
• retention;
• redaction;
• post-charge disclosure status; or
• handling of records

associated with this incident.

Please produce all responsive records originating with another agency or entity that were transmitted to, received by, forwarded to, copied to, downloaded by, incorporated into a case file by, or are otherwise maintained or held by MCSO in connection with this incident.

This request does not require MCSO to obtain new records from another agency or entity.

Criminal charges arising from this incident were filed on September 10, 2026.

NMSA 1978, § 14-2-1.2(A)(2) addresses specified information concerning individuals “accused but not charged with a crime” before charges are filed. Because charges have now been filed, please evaluate all responsive law-enforcement records under the disclosure rules applicable after filing of the criminal charges.

Please do not continue to withhold, redact, or digitally obscure information based solely upon § 14-2-1.2(A)(2) or any other legal authority whose applicability to that information was expressly limited to the period before charges were filed.

This request expressly includes the underlying records from which previously redacted, obscured, or derivative copies were produced.

Where information in a responsive record was previously redacted or digitally obscured solely because the accused individual had not yet been charged, please reproduce the responsive record from the underlying source under the disclosure rules applicable after charges were filed.

If any redaction or digital obscuring remains, please identify the independent legal authority that continues to authorize that withholding after charges were filed.

Nothing in this paragraph requests disclosure of information that remains lawfully subject to redaction or withholding under an independently applicable statute, rule, privilege, court order, or other lawful authority.

To avoid unnecessary disclosure of civilian private contact information, this request is expressly narrowed as follows:

I do not request disclosure of the complainant’s private residential street address, personal telephone number, personal email address, driver’s-license number, Social Security number, financial-account information, or other protected personal identifier information.

I likewise do not request disclosure of private residential addresses, personal telephone numbers, personal email addresses, or protected personal identifier information belonging to non-law-enforcement civilian witnesses, including the Greyhound driver.

Those specific items may remain obscured in copies produced in response to this request.

This voluntary limitation of the request does not concede that each such item would independently be exempt from disclosure under IPRA, does not authorize withholding of any other responsive information, and does not authorize withholding a record merely because one of these items appears within it.

Please segregate the identified information and produce the nonexempt remainder.

I also note that the responsive records were recently accessed in connection with this matter. Accordingly, they should already be readily identifiable and available for review, segregation, and production without the need for a new broad or speculative search.

For electronic records, I specifically request production in electronic format pursuant to NMSA 1978, § 14-2-9(B), in the file format in which each responsive electronic record exists at the time of this request.

Where metadata, audit histories, event histories, logs, or other responsive information exist as separate electronic records, this request includes those records themselves and not merely screenshots, printouts, summaries, or visual representations of the underlying information.

Where responsive records exist in a native exportable electronic format, please provide the existing electronic record rather than converting it to a less informative format where reasonably possible under IPRA.

This request seeks existing public records and does not ask MCSO to create a new report, compilation, analysis, or explanatory record.

If any responsive record contains both exempt and nonexempt information, please segregate or redact only the information lawfully exempt from disclosure and produce the nonexempt remainder pursuant to NMSA 1978, § 14-2-9.

The presence of information subject to lawful redaction should not result in withholding the responsive record in its entirety where the nonexempt material can be segregated and produced.

For every record, portion of a record, audio segment, video segment, image, data field, or other responsive information withheld, redacted, muted, blurred, blacked out, or otherwise digitally obscured, please identify the specific legal authority relied upon.

Where the asserted authority depended upon the status of the criminal matter or whether charges had been filed, please identify the legal authority supporting continued withholding after September 10, 2026.

If this request or any portion of it is denied, please provide the written explanation required by NMSA 1978, § 14-2-11, including a description of the records sought and the names and titles or positions of each person responsible for the denial.

Please preserve all potentially responsive recordings, original files, native files, metadata, audit histories, logs, event histories, system records, and associated electronic evidence in their existing form pending completion of this request, including records that may otherwise be subject to routine retention, deletion, overwrite, purge, or other disposition.

This preservation request specifically includes underlying source files from which previously produced redacted, obscured, exported, converted, or derivative copies were created.

If another MCSO employee, division, administrator, records custodian, evidence custodian, system administrator, or other custodian maintains responsive records, please promptly forward this request within MCSO to the appropriate custodian and provide any notification required by IPRA.

This request is not directed to the McKinley County Metropolitan Dispatch Authority and does not require MCSO to obtain records from that entity.

It does, however, include responsive dispatch or outside-agency records already received, maintained, held, or possessed by MCSO.

Please provide responsive records on a rolling basis as they are located, reviewed, and become ready for production.

Records that are presently available should not be withheld pending completion of the search or review of other categories. Partial productions may be followed by supplemental productions as additional responsive records become available.

Because substantially related records have been requested previously, responsive records may already have been identified, collected, reviewed, exported, or prepared for production. Accordingly, I request production of presently available responsive records by the close of the next business day where practicable, with additional responsive records produced on a rolling basis thereafter in accordance with IPRA.

Nothing in this request withdraws, narrows, modifies, supersedes, replaces, restarts, or waives any prior pending IPRA request, any response deadline applicable to a prior request, any obligation arising from a prior request, or any right associated with a prior request.

This request should be treated as an additional request for the records described herein, including records affected by the September 10, 2026 filing of criminal charges.

If MCSO considers any portion of this request duplicative of a prior request, please identify the prior request and produce any responsive record that has become subject to production, has changed disclosure status, or has become available since the earlier production or response.

Please provide responsive records electronically.

For files that are too large or otherwise impractical to transmit as ordinary email attachments, my preferred method of delivery is WeTransfer. Please use WeTransfer where practicable. If MCSO is unable to use WeTransfer, please use another comparable electronic file-transfer method rather than defaulting to in-person pickup.

IPRA provides that “any person” may request inspection of public records and does not condition access upon New Mexico residency or the requester’s physical presence within New Mexico. See NMSA 1978, § 14-2-8(A). IPRA also expressly recognizes electronically transmitted written requests. See NMSA 1978, § 14-2-8(F).

Accordingly, the fact that a requester resides or is physically located outside New Mexico should not require in-person pickup, in-person inspection, or physical presence in New Mexico where responsive electronic records can practicably be transmitted electronically.

File size alone should not require physical pickup where a reasonable electronic transfer method is available.

If MCSO believes electronic delivery cannot be provided for a particular responsive record, please identify the record and explain the specific reason electronic delivery is unavailable before requiring an alternative delivery method.

Where ordinary email attachment limits prevent transmission, please use WeTransfer or another reasonable electronic-transfer method where practicable.

If any fee will be charged, please provide an estimate before incurring the fee.