The California Public Records Act ("CPRA"), Government Code section 7920.000 et. seq., generally requires that state and local agencies produce qualifying public records in their possession. In City of San Jose v. Superior Court ("San Jose"), 2 Cal.5th 608 (2017), the California Supreme Court held that public records on personal electronic devices ("PEDs") of City employees and officials may be subject to disclosure under CPRA. In other words, a record may be disclosable public record even if it is contained on a personal cellular phone or e-mail account.