context: .Few courts have considered the issue of whether personal notes of officials are public records, but the majority have adopted a similar position.
citation_a.signal: see
citation_a.parenthetical: holding employees' personal notes not intended for distribution through usual agency channels are beyond the scope of the federal FOIA
citation_a.sentence: See, e.g., Courier-Journal v. Jones, 895 S.W.2d 6 (Ky.App.1995) (holding . Governor's daily appointment schedule with notes were not subject to state FOIA); In State, ex rel. Mothers Against Drunk Drivers, v. Gosser, 20 Ohio St.3d 30, 485 N.E.2d 706, 710 (1985) (finding judge's personal notes regarding trial and sentencing hearing were not public records); American Fedn. of Govt. Emp., Local 2782 v. United States Dept. of Commerce, 632 F.Supp. 1272 (D.D.C.1986), aff'd 907 F.2d 203 (D.C.Cir.1990) (holding employees' personal notes not intended for distribution through usual agency channels are beyond the scope of the federal FOIA).
citation_b.signal: but cf.
citation_b.parenthetical: allowing inspection of written notes and computations made in course of audit proceedings under state FOIA where court found notes formed a part of the file and inquiry and could have been used for guidance in final audit report
citation_b.sentence: But cf. Tingling v. Lang, 39 Misc.2d 338, 240 N.Y.S.2d 633 (1963) (allowing inspection of written notes and computations made in course of audit proceedings under state FOIA where court found notes formed a part of the file and inquiry and could have been used for guidance in final audit report).