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PR 18-02 Lombardo v. Town of Westerly Violation

The Complainant alleged the Town of Westerly violated the APRA when it denied his request for "all public documents concerning the Master Agreement between the Town of Westerly, Rhode Island and Westerly Local #503, International Brotherhood of Police Officers July 1, 2016 to June 30, 2019." The Town exempted numerous documents under R.I. Gen. Laws 38-2-2(4)(H) claiming they related to reports and statements of strategy or negotiation involving labor negotiations and collective bargaining, as well as R.I. Gen. Laws 38-2-2(4)(K), as such drafts or revisions constitute preliminary drafts, notes, impressions, working papers." Although documents related to the negotiation process are exempt from public disclosure, see Providence Journal v. Convention Center Authority, 774 A.2d 40 (R.I. 2001), based upon this Department's in camera review, we determined there are five documents (eight pages) that were deemed by the Town to be responsive that this Department did not believe fell within the purview of R.I. Gen. Laws 38-2-2(4)(K) or (H). This Department directed the Town to release these documents within ten (10) business days.

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