mr. pilpal do you have something to help us through this? >> looking at the december 5th transmitter there was a finding of willful violation, the language is not as precise as it could be in regards to ginsberg and ballard, but a failure to comply with the order and presumably a violation. and i would also note on the page 5, 1 a, 1 a and d make some distinction between willful and non-willful violation and later on in your determination, that distinction is lost. so, i think that you could further delineate between miss ballard and miss gong. and mr. buell on this. >> okay. well, in my view, i would think that my view is that miss gong's failure to comply was willful, it certainly would be non-willful as well. it would still be a violation in my view. with, mr. buell, i don't frankly don't see the violation, it appears to me that he searched and did not find the documents and i don't find the deleting of the documents that he had to be problematic even if that were relevant to our discussion. and at least as it relates to the sunshine viol

mr. pilpal said the purpose of the sunshine ordinance when it was on the ballot was not to deal with the records retention issue but disclosure of documents that have been retained. we have a separate chapter of the admin code that deals with record retentions and i think that probably answers the question. >> in light of that, the way that i preliminary would come out was that there was a violation with respect to the failure to provide the records by the end of the next business day, by miss gong. she had a response, from miss buell, she claims to have gotten a response from mr. buell, miss ballard. sorry there are a lot of people i'm learning about today. and there was a response from miss mcauthor reflecting that mr. buell had done the search and a response from mr. ginsberg as well. but held on to the or did not give the response in a timely fashion when she had them on june 6th. so, there i would find that there was a willful violation of 67.25. i don't think although i am some what surprised i must say that there is not a requirement and frankly, miss ballard, i highly recommend t