Dear Public Records Officer,

Pursuant to the Washington State Public Records Act (RCW 42.56), I respectfully request access to the following records, beginning from the date of the first signed agreement between the City of Seattle and Friends of Waterfront Park to the present.

 
1. Communications

Please provide all written or electronic communications—including emails, text messages, internal memos, Teams/Slack messages, and other correspondence—between:

City of Seattle personnel, including staff from:

Seattle Police Department (SPD)
Seattle Center, including its Emergency Services Unit (ESU)
Seattle Parks and Recreation
Office of the Mayor
Seattle Office of Civil Rights
Department of Neighborhoods
Special Events Office
And any employee, contractor, volunteer, agent, or representative of Friends of Waterfront Park (also referred to as Friends of Waterfront Seattle or Friends of the Waterfront).

The communications should include discussion of:

Street performers, buskers, musicians, magicians, or other public entertainers
Use of amplifiers, sound equipment, speaker volume, or noise complaints
Enforcement of park rules, public conduct codes, trespass warnings, or removals
First Amendment activity, expressive conduct, or protected speech in public spaces
Coordination or deployment of security, ambassador, or enforcement personnel
Event permitting, programming, public gatherings, or crowd management
 
2. Agreements and Contracts

Please provide all contracts, memoranda of understanding (MOUs), service-level agreements, and grant agreements between the City of Seattle and Friends of Waterfront Park, including all amendments and renewals.

 
3. Policies, Training Materials, and Protocols

Please provide all internal manuals, policies, standard operating procedures, training materials, or enforcement protocols issued to:

Seattle Police Department (SPD)
Seattle Center ESU officers or staff
Seattle Center management
Seattle Parks enforcement personnel
Private security, ambassador teams, or other personnel working with Friends of Waterfront Park
These materials should relate to:

Interactions with performers or members of the public
Procedures for issuing trespass warnings or enforcing exclusions
Guidance on sound equipment enforcement or performance “disruption”
Recognition and handling of constitutionally protected First Amendment activity
 
4. Format and Compliance

Please provide all responsive records in electronic format, preferably as searchable PDFs or text files.

If any portion of this request is denied or redacted, please cite the specific exemption under RCW 42.56 and provide a brief written explanation for each.

 
5. Purpose of Request – Constitutional Accountability

This request is made for the purpose of evaluating whether the enforcement of park rules, restrictions on expressive conduct, and delegated authority to Friends of Waterfront Park, Seattle Center ESU, and affiliated personnel are being carried out in a manner consistent with the First and Fourteenth Amendments of the U.S. Constitution.

Specifically, this includes vetting whether enforcement actions or delegated authority infringe on protected speech, involve viewpoint discrimination, are applied unequally, or lack due process protections required under constitutional law.

This evaluation is especially relevant in light of case law including Berger v. City of Seattle, Hague v. CIO, and Marsh v. Alabama.

 
Thank you for your prompt attention to this request.

Sincerely,
Clive Hayward