Libertarians for Transparent Gov't v. Gov't Records Council

CURRIER, J.A.D.

*87This appeal requires us to decide if draft minutes prepared for a public body's approval and adoption must be provided in response to a request under the Open Public Records Act (OPRA), N.J.S.A. 47:1A-1 to -13. The Government Records Council (GRC or Council) denied the Libertarians For Transparent Government's OPRA request for unapproved minutes. The trial judge held the draft minutes were "deliberative material," and therefore exempt from OPRA's disclosure requirements. Because draft minutes are a preliminary document subject to revision, they remain "deliberative material"…