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PR 17-55 Hartley v. Coventry Fire District Violation Found

The Complainant alleged that the Fire District violated the APRA when it withheld a tape recording of a public meeting pursuant to R.I. Gen. Laws 38-2-2(4)(K) as a "draft[.]" Because the tape recording contained no mental impressions and did not otherwise fall within Exemption (K), we found that the recording did not constitute a "draft[.]" We also did not find the Fire District's policy arguments persuasive. Accordingly, we found that the Fire District violated the APRA when it failed to release the tape recording. However, we did not find a willful and knowing, or reckless violation. The Fire District was directed to disclose the tape recording.

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