Expos RICO complaint — filename date (2000) vs metadata date (2002)

Date noted: 2026-05-19 (backfilled into discrepancies/ during Pass A; originally flagged in data-layer audit) Noted by: claude/cowork-fidelity-audit-2026-05-19 Document: documents/franchise-finance/2000_filing_expos-minority-owners-rico-complaint.md → renamed 2002-07-16_filing_expos-minority-owners-rico-complaint.md on resolution Status: needs_review (no change from this note)

2026-05-19 RESOLUTION (Pass C follow-through, claude/cowork-pass-c-followthrough-2026-05-19)

The discrepancy is resolved via direct PDF inspection. The filing date is July 16, 2002, in the U.S. District Court for the Southern District of Florida.

Evidence (all from the PDF itself, SHA256 db79f94cfde975fa9c82b1b4eabf7bf20acaee68e1fa69a95a50c1d4c73ca5ba):

1. PDF metadata Subject field reads: "July 16, 2002 Complaint (baseball racketeering suit)".
2. PDF CreationDate: Tue Jul 16 11:55:57 2002 EDT (the Acrobat Distiller 4.05 / Microsoft Word LaserWriter file was created the morning of the filing).
3. Substantive allegations: the complaint repeatedly alleges defendant misrepresentations "during May through December 2000", "during February and March of 2001", and "during 2001" (¶¶ throughout the lead-up to Count VI). A complaint dated July 16, 2000 cannot allege 2001 facts; the substantive content is incompatible with a year-2000 filing.
4. Court (PDF p. 1): "UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF FLORIDA. Case No.: ____________-CIV-" — case-number line blank on the filing copy, consistent with a pre-clerk-stamp filing-copy PDF.
5. Signature block (PDF p. 45): reads "Dated: July 16, 2000, Miami, Florida" — this is a clerical typo against the document's own internal evidence above. The four other independent pieces of evidence (PDF Subject, PDF CreationDate, substantive 2001 allegations, court) all point to July 16, 2002.

Note: the prior WANTLIST entry's claim that the complaint was "filed 2000, not 2002 as originally entered" had it inverted — it was the filename's 2000 prefix and the signature-line typo that were wrong, not the metadata's 2002.

Actions applied on resolution:

• Filename renamed 2000_filing_expos-minority-owners-rico-complaint.{pdf,md} → 2002-07-16_filing_expos-minority-owners-rico-complaint.{pdf,md} per NAMING.md §2.1. Old filename preserved in file.previous_filenames. SHA256 of the PDF unchanged.
• Metadata date upgraded from "2002" (year precision) to "2002-07-16" (day precision); date_precision year → day.
• Metadata parties corrected to reflect the actual case caption: 14 Canadian corporate plaintiffs (BMO Nesbitt Burns, BCE, Cascades, Esarbee Investments, Fairmont Hotel & Resorts, Fédération des Caisses Desjardins du Québec, Fonds de Solidarité des Travailleurs du Québec, Freemark Holdings, Loblaws, M&S Sports, Provigo, Telemedia Communications, 98362 Canada Inc., 114114 Canada Inc.); 7 named defendants (Jeffrey H. Loria, David Samson, Allan "Bud" Selig, the Office of the Commissioner of Baseball, Robert DuPuy, Baseball Expos GP Inc., Baseball Expos L.P.). The prior "Stephen Bronfman, Avie Bennett" plaintiff listing was inferred from training-data knowledge and is not in the actual complaint caption.
• Metadata jurisdiction corrected from "likely D. Mass. or S.D.N.Y. — to confirm via content review" to "U.S. District Court for the Southern District of Florida".
• Metadata title, short_title, citation, abstract, key_provisions, quoted_excerpts, notes, and body prose updated to reflect the document as actually filed (the case is BMO Nesbitt Burns Inc., et al. v. Loria, et al., S.D. Fla., complaint filed July 16, 2002).
• INDEX row updated (date column 2000 → 2002-07-16; slug; row note).
• WANTLIST entry corrected.
• Cross-references in documents/stadiums-and-relocation/2004_agreement_washington-dc-baseball-stadium-agreement.md and documents/franchise-finance/2002_statement_commissioner-on-expos-minority-partners.md updated.

Status: this discrepancy is resolved. The document remains at needs_review overall (single source — SABR Box — and the in-PDF verification this pass is a one-source-self-check, not a STANDARDS.md §2.4 two-source confirmation; full substantive content review of the 45-page complaint is still pending).

The discrepancy

• Filename date prefix: 2000_filing_expos-minority-owners-rico-complaint
• Metadata date field: "2002", date_precision: "year"
• INDEX.md row: R | 2000 | ... — INDEX matches filename, not metadata

Per NAMING.md §2.1, the filename date must match the metadata date_precision. Here the filename year and metadata year disagree on the value itself, not just the precision. WANTLIST.md notes the filing date was 2000, not 2002 — so the filename is likely correct and the metadata's date: "2002" is likely wrong.

WANTLIST.md line 113 explicitly says: "complaint filed 2000, not 2002 as originally entered." So this discrepancy was identified at acquisition time but never reconciled in the metadata itself.

Verification path

The actual filing date should be verifiable from:

• The complaint document itself (PDF p. 1 should show the filing date stamp)
• The court docket if the case is on PACER (the case was filed in S.D.N.Y.; minority owner partnerships)
• Contemporary news coverage of the filing

Suggested remediation (not done in this pass)

1. Open the PDF and check the filing date stamp.
2. If 2000 is correct (as WANTLIST indicates): update metadata date to "2000" or a more precise date if visible on the filing stamp. Filename and INDEX would then match metadata.
3. If 2002 is correct: rename the file from 2000_filing_* to 2002_filing_* per NAMING.md §5, preserving the old filename in file.previous_filenames. Update INDEX accordingly.

This is a content-verification task, not a structural one. Not blocking — the document is at needs_review status anyway, where verbatim verification is pending.

Cross-references

• Metadata file: documents/franchise-finance/2000_filing_expos-minority-owners-rico-complaint.md
• WANTLIST.md line 113 (acknowledgment of the original mis-dating)
• Related: all 4 Pass A discrepancy notes from 2026-05-19