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PR 16-17 Chiaradio v. Town of Westerly - No Violation

The Complainant alleged the Town violated the APRA when it denied part of her APRA request, which sought copies of itemized invoices from two (2) law firms that were engaged to represent the Town. Based upon the evidence presented, the Town provided the Complainant with redacted copies of the invoices. Rhode Island General Laws 38-2-2(4)(A)(I)(a) exempts from public disclosure "all records relating to a client/attorney relationship." Upon this Department's in camera review of the legal invoices, we conclude the redacted narratives contained information related to the client/attorney relationship and that these portions are not reasonably segregable. Indeed, the Town has already provided the reasonably segregable portions of the legal bills with the attorney narratives redacted. We found no violation.

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