Parker Poe ORR Cost Schedule
Period Feb. 28 – Mar. 20, 2025 · Issuing counsel Sherry H. Culves (Partner, Parker Poe Adams & Bernstein LLP) on behalf of Bibb County School District · Responding to Open Records Requests from three categorically distinct requester categories · Theme Template exemption-basket refusal / cost estimate
Legal shorthand used here: ORR = Open Records Request. ORA = Georgia Open Records Act. BCSD = Bibb County School District. FERPA = Family Educational Rights and Privacy Act. O.C.G.A. = Official Code of Georgia Annotated. § = “section”; et seq. is Latin for “and following”. PPAB = Parker Poe Adams & Bernstein (a reference used on the firm’s internal document identifiers).
What is this page?
This page indexes four Parker Poe responses — three cost estimates and one full denial — issued by BCSD’s outside counsel during a fourteen-day window in late February and mid-March 2025. All four share a structural template: the same signing attorney, the same drafter initials, the same statutory exemption basket, and the same document-delivery process.
The responses went to three categorically distinct requester categories, which is what makes them interesting as a record: journalist (through the open AG mediation), civic-parent (Kerry Hatcher’s three March 2025 ORRs), and internal-staff (two Alex II teachers filing a February 28, 2025 ORR for personnel records on their own colleagues). BCSD’s later denial letter to Hatcher characterized this pattern as a “coordinated” records-request effort. What that characterization refers to factually is this fourteen-day, three-category window.
The schedule
| ORR subject | Requester category | Filed | Parker Poe response | Estimate / disposition | PPAB ref | |
|---|---|---|---|---|---|---|
| Alex II teacher personnel records | Two Alex II teachers (internal-staff) | 2025-02-28 | 2025-03-05 | $1,590.00 (40 hrs @ $40.00/hr) — pre-payment required (>$500 threshold) | — | Response |
| JH Settlement records (four-item scope) | Kerry Hatcher (civic-parent) | 2025-03-11 | 2025-03-14 | Full denial on FERPA grounds — see dedicated page | — | Denial letter |
| LEO Calls for Service at Alex II | Kerry Hatcher (civic-parent) | 2025-03-12 | 2025-03-20 | $459.42 (10 hrs @ $47.12/hr) | 12129867v2 | Response |
| 1st Grade Disruptions emails | Kerry Hatcher (civic-parent) | 2025-03-15 | 2025-03-20 | $153.83 (4 hrs @ $41.02/hr) | 12129772v2 | Response |
A fifth ORR in the same window is deliberately omitted from this schedule. Hatcher’s March 14, 2025 United Way of Central GA ORR received a cost estimate from Parker Poe (March 20, 2025; $317.91 / 8 hrs at $41.02/hr) but the request was canceled by the requester before a final production or denial. Because the request never reached a dispositive outcome, it does not carry the same refusal-pattern weight as the four entries above and is omitted here to avoid misrepresenting the record.
The template
The three cost-estimate responses (teacher ORR, LEO Calls, 1st Grade) share a signature across multiple dimensions:
- Same signing attorney: Sherry H. Culves, Partner, Parker Poe (with drafter initials “SHC/jw” on each document).
- Same exemption basket cited: O.C.G.A. § 50-18-71(b)(1)(A); § 50-18-71(j); § 50-18-72(a)(1), (4), (8), (20), (21), (25), (37), (41), (42); § 20-2-210(e).
- Same prepayment requirement: where the estimate exceeds $500, prepayment is required before production begins.
- Same delivery method: ShareFile portal.
- Same form of payment: cash, certified check, or money order; no personal checks or digital payment.
- Same silence clause: 30-day silence from the requester = withdrawn.
- Same production timeline: approximately three weeks from payment confirmation.
The March 14 denial letter to Hatcher is procedurally different — it is a full FERPA-based denial, not a cost estimate — but it cites a subset of the same exemption basket and is signed by the same attorney. One reconciliation note: the O.C.G.A. § 50-18-72(a)(25) citation appears on the cost-estimate responses listed above but does not appear on the March 14 FERPA denial letter, which narrows its exemption list to the federal-confidentiality and FERPA-carve-out provisions directly relevant to a student-records refusal.
Why this pattern matters for Melody v. BCSD
Three observations from this schedule bear on the pending litigation:
1. The § 99.3 “requester-knowledge” theory is category-agnostic in its deployment but category-specific in its evidence. BCSD’s FERPA refusal of Hatcher’s JH-settlement request (the March 14 denial letter) cites Hatcher’s status as an Alex II parent and his own advocacy website as the factual predicate for a “reasonable belief” that the requester knows the student’s identity. The other three responses in the same window are cost estimates rather than FERPA denials — but they are processed through the same counsel, the same exemption basket, and the same template, which supports the view that BCSD’s refusal posture during this period was programmatic, not requester-specific.
2. The rate differentiation across responses is small but consistent. The teacher ORR was billed at $40.00/hour (HR/records custodian time), the civic-parent ORRs at $41.02/hour (administrative-records custodian time), and the LEO Calls ORR at $47.12/hour (sworn-officer dispatch time). These differences track custodian class, not requester identity. The consistency of the hourly structure across categories is part of the “template” evidence.
3. Redactions without articulated justification. Produced records delivered in response to these ORRs (in cases where production actually occurred) included redactions that were not accompanied by statutory citations or field-level justifications in the response letters themselves. That is a pattern observation, not a Melody case claim. Readers interested in the redaction-pattern thread can follow it at kerryhatcher.com — it is outside the scope of the Melody litigation and this archive does not develop it further.
Read the originals
- Alex II teacher ORR response (Mar. 5, 2025) — $1,590 cost estimate
- BCSD Denial Letter to Hatcher (Mar. 14, 2025) — FERPA denial (see dedicated page)
- LEO Calls for Service response (Mar. 20, 2025) — $459.42 cost estimate
- 1st Grade Disruptions response (Mar. 20, 2025) — $153.83 cost estimate
Part of the Pre-Litigation Record · Civil Action No. 2025-CV-083495 · Bibb County Superior Court