The city manager cannot invoke the working papers exemption to protect draft budget proposals. Because those documents are routinely generated pursuant to another law, which characterizes them as the city council's property, during the ordinary course of business, they are subject to mandatory disclosure under FOIA.
once city council members acted on a report that was arguably part of the city manager's working papers, any exempt status is lost and the document becomes part of the public record.
Inquiries as to the status of e-mail under the Freedom of Information Act, charges for electronic records, the working papers exemption, assessment of fees for producing a requested record, the meaning of 'reasonable specificity'
Materials that would nonetheless be official records standing alone may become exempt correspondence if they are transmitted to a qualified office as a letter.
Letters exchanged between an institution of higher learning and a law firm representing a university student are not exempt as work product compiled for use specifically for litigation.
General fund revenue estimates prepared by the governor's advisory boards are considered working papers of the governor; Governor's budget advisory boards must follow FOIA's meeting requirements.
Newsletters prepared by county administrator summarizing issues to be discussed at the next board of supervisors meeting are official records open to the public, even if some of the topics are the proper subject of a closed meeting.
