IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Charles Picarella Jr., :

Petitioner :

: No. 93 C.D. 2021

v. :

: Submitted: July 16, 2021

Department of Corrections :

(Office of Open Records), :

Respondent :

BEFORE: HONORABLE P. KEVIN BROBSON, President Judge

HONORABLE PATRICIA A. McCULLOUGH, Judge

HONORABLE ELLEN CEISLER, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION 

BY JUDGE McCULLOUGH FILED: December 30, 2021

Charles Picarella Jr., pro se, petitions for review of the January 8, 2021 

Final Determination of the Office of Open Records (OOR), which granted in part and 

denied in part Picarella’s appeal of the Department of Corrections’ (Department) 

partial denial of his Right-to-Know Law (RTKL)1request. We affirm.

Picarella is an inmate at the State Correctional Institution at Mahanoy. 

On October 1, 2020, Picarella filed a RTKL request with the Department, seeking:

Any and all records related to the criteria used by the 

Department to determine whether a prisoner incarcerated 

within the Department will receive a positive or negative 

recommendation for parole when such determination is 

submitted to the Pennsylvania Board of Probation and 

1 Act of February 14, 2008, P.L. 6, 65 P.S. §§67.101-67.3104.
2

Parole,[2]including but not limited to quantitative scoring 

instruments.

(OOR Final Determination at 1-2.) 

On October 26, 2020, the Department granted Picarella access to several 

Department policies, but partially denied Picarella’s request with respect to certain 

sections of Department Policy 11.5.1. The Department contended that disclosure of 

those sections of the policy would jeopardize personal security and public safety, and 

that they are thus exempt from disclosure under section 708(b)(1)(ii)3and (b)(2)4 of 

the RTKL, 65 P.S. §67.708(b)(1)(ii), (b)(2).5 

On November 24, 2020, Picarella appealed to the OOR. On December 

16, 2020, the Department submitted a position statement, in which it reiterated its 

stated grounds for denial with respect to the withheld sections of Policy 11.5.1. In 

2 The Pennsylvania Board of Probation and Parole was renamed the Pennsylvania Parole 

Board by sections 15 and 16.1 of the Act of December 18, 2019, P.L. 776. See sections 6101 and 

6111(a) of the Prisons and Parole Code, as amended, 61 Pa.C.S. §§6101, 6111(a).

3 Section 708(b)(1)(ii) of the RTKL exempts from disclosure a record which “would be 

reasonably likely to result in a substantial and demonstrable risk of physical harm to or the personal 

security of an individual.” 65 P.S. §67.708(b)(1)(ii). We refer to this exemption herein as the 

“personal security exemption.”

4 Section 708(b)(2) of the RTKL exempts from disclosure a “record maintained by an 

agency in connection with the military, homeland security, national defense, law enforcement or 

other public safety activity that, if disclosed, would be reasonably likely to jeopardize or threaten 

public safety or preparedness or public protection activity . . . .” 65 P.S. §67.708(b)(2). We refer to 

this exemption herein as the “public safety exemption.”

5 The Department initially contended that the relevant sections of the policy were 

additionally exempt from disclosure under section 708(b)(16) and (b)(17), 65 P.S. §67.708(b)(16), 

(b)(17), because they relate to criminal and noncriminal investigations. However, the Department 

did not develop this position on appeal to the OOR, so the OOR deemed the Department’s argument 

waived in that regard. (OOR Final Determination at 2 n.3.) This exemption is not at issue in the 

instant appeal.
3

support, the Department submitted an affidavit of Denise Wood, the Department’s 

Records Administrator. Ms. Wood described the relevant material as follows:

The responsive record[] to Mr. Picarella’s request is 

Department Policy 11.5.1 on Records Office Operations, 

specifically Sections 1, 2, 5, 6, and 9.

***

The requested Sections of 11.5.1 are confidential policy and 

are not made available to the public. . . .

The requested Sections of 11.5.1 are confidential to protect 

against manipulation by inmates and/or their accomplices in 

the general public.

The confidential Sections of policy 11.5.1 are maintained 

by the Department in connection with its official law 

enforcement function of supervising the incarceration of 

inmates in a safe and secure manner.

Section 1 of 11.5.1 (Processing of Receptions)[] exists as 

part of the Department’s law enforcement authority to aid 

staff with a variety of inmate reception situations to ensure 

that inmates are being properly committed to the 

Department and classified appropriately.

Section 1 describes the Department’s policy and procedure 

for a variety of receptions such as initial receptions, parole 

violators, [out-of-state] parole violators, community parole 

center program, county prison transfers, return from 

authorized temporary absence, inter-facility transfer, 

detentioners, interstate corrections compact receptions, bail 

returns, . . . return of inmate following re-trial or resentence, and escape returns.

***

Additionally, the 11.5.1 Section 1 outlines how staff should 

handle sentence computation and re-computations.
4

Section 2 of 11.5.1 (Releases)[] exists as part of the 

Department’s law enforcement authority to aid staff with a 

variety of inmate release situations to ensure that inmates 

are properly being released and nothing else is holding the 

inmate from being released.

Section 2 describes the Department’s policy and procedure 

for a variety of releases, such as[] final discharge maximum 

expiration, state parole, [sex offenders], parole violator 

pending with a federal sentence, county parole, release for 

serious illness, bail, release pursuant to executive clemency, 

vacated and modified sentences and convictions, temporary 

absences, authorized temporary absence, inter-facility 

transfers, Community Corrections Center transfers, 

temporary transfers, Immigration and Customs 

Enforcement, and transfers for county prison housing.

***

Additionally, . . . Section 2 outlines how staff should handle 

sentence computation errors and erroneous release of a 

prisoner or an inmate that is held past sentence completion 

date.

Section 5 of 11.5.1 (Detainers)[] exists as part of the 

Department’s law enforcement authority to aid staff with a 

variety of inmate detainer situations to ensure that inmates 

are being properly detained by the Department in 

accordance with the required authorization.

***

Section 5 describes the Department’s policy and procedure 

for when different detainers are lodged or removed against 

inmates including procedures surrounding interstate 

agreement on detainers.

For any type of detainer received, a Department employee 

is required to complete a sentence status change and a 

detainer action letter.

***
5

Additionally, Section 5 outlines how staff should handle 

situations in which a jurisdiction requests extradition of an 

inmate but records indicate that the inmate has more than 

one detainer lodged against him.

Section 6 of 11.5.1 (Inmate Records System/Movement 

Reports)[] exists as part of the Department’s law 

enforcement authority to aid staff with timely and 

accurately reporting information regarding a facility’s 

inmate population.

Section 6 describes the Department’s policy and procedure 

for computer entries regarding inmate movement and 

location, specifically information pertaining to an inmate’s 

status, location, movement, etc.

Section 6 outlines how staff should handle entries as it 

relates to inmate movements regarding transfers to medical, 

transfers from medical, furloughs, release/discharge from 

custody, and vacated convictions/sentences, as well as other 

situations pertaining to inmate movements.

Section 9 of 11.5.1 (Outside Clearance, SIP/SIP Conversion 

& Rebuttable Parole)[] describes the Department’s policy 

and procedure as it relates to the review process for outside 

assignments, RRRI eligibility, SIP/SIP conversion 

eligibility, and rebuttable parole eligibility.

***

Given the nature of the information contained within the 

requested Sections of 11.5.1, the successful manipulation 

thereof would lead to the release of an inmate prior to the 

date of his or her release.

(Certified Record (C.R.) Item 4 (paragraph numbers omitted); see also OOR Final 

Determination at 6-8.) Ms. Wood additionally explained that Sections 1, 2, and 9 of 

the policy include a checklist that a Department employee is required to complete 

before taking any action under those sections.
6

As to the reasons that disclosure of the relevant portions of the cited 

policy would present risks to security, Ms. Wood attested:

The Department has had inmates, even without the 

assistance of this policy, successfully forge sentencing 

documentation and escape prison prior to their appropriate 

release date.

Technological advances have made the Department’s job 

increasingly more difficult to fight against forged 

documents that appear authentic, thereby heightening the 

necessity for the Department to protect against the release 

of policies and procedures that can be manipulated in 

furtherance of the creation of fraudulent documentation that 

facilitates the unintended and early release of an inmate.

***

If the general public or an inmate was aware of procedures 

that the Department utilizes when receiving and releasing

inmates, it is reasonable that the procedures and/or 

documents could be manipulated leading to an inmate being 

released before he or she is permitted.

The Department relies on sentencing documentation from 

governmental agencies that provide sentencing information 

or warrant/detainer information for the Department’s 

inmates.

The information is reviewed in-depth prior to an inmate 

being released or moved for any reason.

The Department reviews available criminal databases to 

determine if an inmate has active warrants or detainers 

beyond the documentation the Department possesses.

If the inmates are aware of the specific records and 

documentation that the Department reviews, they could 

manipulate records to lead to an early release.
7

As was indicated earlier, inmates have successfully forged 

what appear to be authentic records and have been 

erroneously released from our custody.

If an inmate was aware of the administrative steps and 

documentation that is reviewed by the Department prior to 

their movement, transfer[,] or release, the inmate or an 

outside accomplice could generate credible forgeries that 

would lead to an improper release.

The release of an inmate prior to the completion of his 

sentence or being paroled would pose a reasonable risk to 

the public.

The Department houses violent criminals that are mandated 

by law to serve at least their minimum sentences before 

being considered for parole.

If an inmate escaped prison prior to his proper expiration, 

law enforcement would be placed at greater risk in the 

performance of their duties because they would be tasked 

with locating an individual that was erroneously released.

Also, the public would be unnecessarily placed at risk 

because an inmate was erroneously released from prison 

after successfully manipulating sentencing records.

***

While the Department currently receives forged documents 

from inmates and their families, that number would only 

increase if the information contained in the requested 

Sections of 11.5.1 are released to the public.

In addition, inmates are reasonably likely to retaliate against 

staff who they know have made unfavorable reports or 

decisions regarding their incarceration. It is reasonably 

likely that if an inmate is aware of the identity of the 

individual who is responsible for that inmate receiving an 

unfavorable evaluation/decision, that individual will be the 

target of harassment, threats, or physical harm.
8

Disclosure of these records could result in staff being less 

likely to record sensitive information or prevent staff from 

being candid because of the fear that an inmate will see 

their subjective remarks.

If staff fails to accurately report information[,] it could lead 

to less than candid recommendations to the Parole Board, 

which ultimately could place society’s security in a worse 

situation if an inmate was paroled when he or she should 

not have been.

(C.R. Item 4 (paragraph numbers omitted; emphasis in original); see also OOR Final 

Determination at 8-10.)

Placing the Department’s position within the context of the RTKL, Ms. 

Wood ultimately opined that disclosure of the requested records would be 

“reasonably likely to result in a substantial and demonstrable risk of physical harm to, 

or the personal security of, institution staff, inmates, and/or the general public,” and

would be “reasonably likely to threaten public safety [and] compromise the 

Department’s public protection activities and function of maintaining order and 

control of inmates.” (C.R. Item 4.) These assertions invoked the personal security 

and public safety exemptions under the RTKL. See supra notes 2 & 3.

In considering Picarella’s appeal, the OOR appeals officer first rejected 

the Department’s suggestion that Picarella failed to specifically address the stated 

grounds for denial of his request, and that his appeal was therefore deficient under 

section 1101(a)(1) of the RTKL, 65 P.S. §67.1101(a)(1) (requester’s appeal “shall 

state the grounds upon which the requester asserts that the record is a public 

record . . . and shall address any grounds stated by the agency for delaying or denying 

the request”). The OOR appeals officer noted that Picarella did not use the OOR’s 

standard appeal form, and he did not address each of the Department’s stated reasons 

for denial, but he did assert that the requested records are public and that the 
9

Department’s denial contained only “generic” and “boilerplate” language that failed 

to establish a legitimate rationale for denying his request. (OOR Final Determination 

at 5.) The OOR appeals officer concluded that the form of Picarella’s appeal was 

sufficient for purposes of section 1101(a)(1) of the RTKL, and accordingly proceeded 

to its merits. Id.

On the substance of Picarella’s appeal, the OOR appeals officer noted 

that a declaration of agency staff made under penalty of perjury is competent 

evidence to sustain the agency’s burden to establish an exemption from disclosure. 

Id. at 10 (citing Sherry v. Radnor Township School District, 20 A.3d 515, 520-21 (Pa. 

Cmwlth. 2011); Moore v. Office of Open Records, 992 A.2d 907, 909 (Pa. Cmwlth. 

2010)). Moreover, the OOR appeals officer stated that, in the absence of evidence of 

bad faith, the averments contained in the declaration should be accepted as true. Id.

(citing McGowan v. Pennsylvania Department of Environmental Protection, 103 

A.3d 374, 382-83 (Pa. Cmwlth. 2014)). The OOR therefore relied upon Ms. Wood’s 

affidavit as it concerned the substantive exemptions from disclosure at issue.

With regard to the applicable exemptions, the OOR appeals officer

observed that the personal security exemption requires the agency to show: (1) a 

“reasonable likelihood” of (2) a “substantial and demonstrable risk” to a person’s 

security. Id. at 6 (citing Delaware County v. Schaefer ex rel. The Philadelphia 

Inquirer, 45 A.3d 1149, 1156 (Pa. Cmwlth. 2012)); see 65 P.S. §67.708(b)(1)(ii). A 

“reasonable likelihood,” the OOR noted, requires “more than speculation or 

conjecture . . . .” (OOR Final Determination at 6 (quoting California Borough v. 

Rothey, 185 A.3d 456, 468 (Pa. Cmwlth. 2018)).) A “substantial and demonstrable 

risk,” the OOR noted, is one that is “actual or real and apparent.” Id. (quoting 
10

Borough of Pottstown v. Suber-Aponte, 202 A.3d 173, 180 (Pa. Cmwlth. 2019)) 

(emphasis omitted). 

Relying upon Ms. Wood’s “detailed, non-conclusory declaration,” the 

OOR appeals officer concluded that numerous withheld sections of Policy 11.5.1 

relate to a “law enforcement or public safety activity,” and Ms. Wood’s averments 

demonstrated that “disclosure of the withheld portions of Policy 11.5.1 would be 

reasonably likely to result in fraudulent manipulation of the inmate processing, 

release, detainer, movement and parole eligibility procedures, which could lead to 

inappropriate placement or inadvertent release of inmates.” Id. at 12. Specifically, 

the OOR appeals officer concluded that Sections 1, 2, 5, and 9 fell within the public 

safety exemption of the RTKL, because their disclosure would threaten public safety 

or a public protection activity. In the alternative, the OOR appeals officer reasoned 

that disclosure of those sections of the policy could result in the inmate population 

learning the identity of Department staff who participate in the process of assessing 

parole eligibility and release procedures, which would create a reasonable likelihood 

of a substantial and demonstrable risk to those Department staff members, thus 

falling within the personal security exemption. Id. at 12-13. 

However, with regard to Section 6 of Policy 11.5.1, the OOR appeals 

officer observed that the Department’s evidence established only that it concerned the 

policy and procedure for making “computer entries” relating to inmate movement and 

location. Id. at 13. Because these procedures were described as “essentially 

administrative tasks” relating to computer entry procedures, the OOR appeals officer

concluded that the Department failed to demonstrate any inherent risk in disclosure of 

that portion of the policy. Id. Ms. Wood’s explanation of the sort of risks that 

disclosure of the other withheld sections would present, the OOR appeals officer 
11

opined, did not “convey the risks related to the disclosure [of] computer entry 

procedures.” Id. Accordingly, the OOR reasoned that, with respect to Section 6 of 

the policy, the Department failed to establish the personal security or public safety 

exemptions from disclosure.

The OOR appeals officer thus granted Picarella’s appeal in part, and 

required the Department to provide him with Section 6 of Policy 11.5.1. With respect 

to the remaining sections of the policy, the OOR appeals officer denied Picarella’s 

appeal. Picarella then sought further review in this Court.6

Picarella explains that he desires access to the relevant records because 

he wishes to understand the procedures pursuant to which Department personnel 

determine whether an inmate will receive a positive or negative recommendation for 

parole, and that access to such records will foster accountability for such actions. 

(Picarella’s Br. at 5.) Picarella primarily contends that, pursuant to Ms. Wood’s 

description of the sections of the policy that were withheld, “[n]one of these 

sections . . . contain the records sought by Picarella relating to parole 

recommendation criteria used by the Department.” Id. He further suggests that we 

should not consider the asserted consequences that Ms. Wood suggested would 

follow from disclosure because “none of the cited policy [sections] seem to contain 

the records being sought by Picarella.” Id. at 7. In this regard, Picarella appears to 

suggest that the sections of the policy at issue were not relevant to his request in the 

first place.

6 Our standard of review of determinations made by OOR appeals officers under the RTKL 

is de novo, and our scope of review is plenary. See Bowling v. Office of Open Records, 75 A.3d 

453, 477 (Pa. 2013).
12

With regard to the substantive exemptions at issue, Picarella asserts that 

disclosure of the policy sections at issue would not create a “reasonable likelihood” 

of a risk to the personal security of Department staff because “prisoners are already 

aware of the identities of the Department staff providing the information being used 

to determine parole recommendations.” Id. at 8. Picarella further contends that 

prisoners are already routinely subject to unfavorable decisions by staff, and the 

Department offered no evidence that prisoners retaliate against staff as a result of 

those decisions. Id. According to Picarella, this further establishes that there is no 

“substantial and demonstrable” risk to Department staff for purposes of the personal 

security exemption. 

As it concerns the public safety exemption, Picarella argues that the 

sections of Policy 11.5.1 at issue in this appeal are not related to a “law enforcement 

or other public safety activity,” because he sought records relating to parole 

recommendation criteria, but Ms. Wood’s declaration does not suggest that the 

pertinent sections of the policy are related to parole recommendations. Picarella 

claims that the “Department, via [Ms. Wood’s declaration,] extensively details other, 

unrelated records, such as reception checklist[s], release checklist[s], and detainer 

verification procedures, that may relate to law enforcement and/or public safety 

activity, but it does not address the records actually being sought by Picarella.” Id. at 

10. Accordingly, Picarella contends that the records at issue do not relate to a “law 

enforcement” or “public safety” activity for purposes of the public safety exemption.

With regard to Ms. Wood’s explanation that disclosure of the sections at 

issue would aid inmates or accomplices in forging documents that would allow 

improper releases, Picarella “stipulates that all of that may be entirely true.” Id. 

However, he contends that the Department failed to produce evidence establishing 
13

that the records that he “actually requested,” i.e., the “parole recommendation 

criteria,” would cause a risk of such forgeries. Id. Picarella contends that the records 

that he “actually requested” would not pose any additional risk of forged documents, 

or otherwise jeopardize public safety.

The Department, for its part, reiterates its position before the OOR and 

contends that the OOR’s Final Determination was correctly decided. With regard to 

Picarella’s argument on appeal—that the sections of Policy 11.5.1 at issue were not 

responsive to his RTKL request—the Department contends that Picarella failed to 

raise this issue before the OOR, and that his argument should not be entertained on 

appeal. (Department’s Br. at 16 n.2.)

The objective of the RTKL is “to empower citizens by affording them 

access to information concerning the activities of their government.” SWB Yankees 

LLC v. Wintermantel, 45 A.3d 1029, 1042 (Pa. 2012). We must “interpret the RTKL 

liberally to effect its purpose—that being, ‘to promote access to official government 

information in order to prohibit secrets, scrutinize actions of public officials, and 

make public officials accountable for their actions.’” Allegheny County Department 

of Administrative Services v. A Second Chance, Inc., 13 A.3d 1025, 1034 (Pa. 

Cmwlth. 2011) (en banc) (quoting Bowling v. Office of Open Records, 990 A.2d 813, 

824 (Pa. Cmwlth. 2010) (en banc) (Bowling I), aff’d, 75 A.3d 453 (Pa. 2013) 

(Bowling II)). Because we construe the law liberally in favor of disclosure, 

“[e]xemptions from disclosure must be narrowly construed due to the RTKL’s 

remedial nature . . . .” Office of the Governor v. Scolforo, 65 A.3d 1095, 1100 (Pa. 

Cmwlth. 2013) (en banc).

Unlike typical cases involving the application of an exemption from 

disclosure, in light of Picarella’s argument to this Court, the issue here is not strictly 
14

whether the OOR correctly applied the personal security or public safety exemptions. 

Indeed, Picarella presently “stipulates” that at least some of the security concerns 

highlighted by the Department are valid, and that disclosure of the information at 

issue would raise the risk of inmates using forged documents to obtain improper 

releases from incarceration. (Picarella’s Br. at 10.) Procedurally, the Department 

denied Picarella access to certain portions of a policy and Picarella appealed that 

denial, but he now contends that the withheld portions of the policy were not relevant 

to his initial request. This raises a question as to why Picarella would be entitled to 

the material at issue if it did not fall within the scope of his request in the first place.

“Under the RTKL, a requester submits a request that ‘tells the agency 

what records he wants, and the agency responds by either giving the records or 

denying the request by providing specific reasons why the request has been denied.’” 

Pennsylvania Department of Education v. Pittsburgh Post-Gazette, 119 A.3d 1121, 

1124 (Pa. Cmwlth. 2015) (quoting Pennsylvania State Police v. Office of Open 

Records, 995 A.2d 515, 516 (Pa. Cmwlth. 2010)). As the OOR appeals officer noted 

in this case, in response to Picarella’s request, “the Department granted access to 

several Departmental policies including Policy 7.2.1 (Counseling Services), Policy 

11.4.1 (Case Summary)[,] and portions of Department Policy 11.5.1 (Records Office 

Operation).” (OOR Final Determination at 5.) Although the Department granted 

Picarella access to portions of Policy 11.5.1, it denied him access to the portions of 

that policy that it viewed as implicating the personal security and public safety 

exemptions, specifically Sections 1, 2, 5, 6, and 9. Id. It is Picarella’s appeal of that 

partial denial that brought the matter before the OOR, and now before this Court. 

Yet, Picarella now argues that the information in question is not what he “actually 
15

requested.” (Picarella’s Br. at 10.) It follows that Picarella should have no continued 

objection to the Department’s denial of access to that information.

Here, the Department identified the records that it understood to be 

responsive to Picarella’s request, and it granted him access to them, except for the 

portions that it alleged were subject to an exemption from disclosure. The 

Department identified the relevant exemptions and RTKL provisions in its response 

to Picarella’s request. This was in accord with the Department’s duties under the 

RTKL. See section 901 of the RTKL, 65 P.S. §67.901 (“Upon receipt of a written 

request for access to a record, an agency shall make a good faith effort to determine if 

the record requested is a public record, legislative record or financial record and 

whether the agency has possession, custody or control of the identified record, and to 

respond as promptly as possible under the circumstances existing at the time of the 

request.”); section 903 of the RTKL, 65 P.S. §67.903 (if an agency denies access to a 

record in whole or in part, its response shall include the “specific reasons for the 

denial, including a citation of supporting legal authority”). On appeal to the OOR, 

the Department supported its position with the sworn declaration of Ms. Wood, which 

the OOR found to be sufficient and credible evidence supporting the cited 

exemptions. (OOR Final Determination at 10.)

Moreover, we find no error in the OOR appeals officer’s analysis of the 

claimed exemptions. Although Picarella challenges the application of the personal 

security exemption because he asserts that inmates already know when Department 

staff take unfavorable actions against inmates, we note that the record does not 

contain any evidence supporting Picarella’s position in this regard. By contrast, Ms. 

Wood’s affidavit detailed the likelihood that disclosure of the withheld sections of the 

policy at issue would “result in the inmate population knowing the parole eligibility 
16

and release process and the identity of correctional institution staff who participate in 

the process,” which the OOR agreed would pose a substantial and demonstrable risk 

to the personal security of those staff members. (OOR Final Determination at 12-13.) 

More significantly, Picarella does not meaningfully challenge the OOR’s 

application of the public safety exemption. The OOR accepted Ms. Wood’s 

explanation that disclosure of the relevant sections of Policy 11.5.1 would create an 

increased risk that inmates or accomplices could forge documents that would allow 

for erroneous releases, and that such would be reasonably likely to threaten public 

safety and jeopardize the Department’s public protection activity. See 65 P.S. 

§67.708(b)(2). Picarella does not dispute the existence of that risk, but rather claims 

that the sections in question are not relevant to his request. (Picarella’s Br. at 10.) 

Because the public safety exemption alone is sufficient to support the Department’s 

partial denial of Picarella’s request, and because Picarella has not established any 

basis upon which to conclude that the OOR’s application of that exemption was 

erroneous, we find no grounds upon which to grant Picarella relief.

Accordingly, we must affirm the Final Determination of the OOR.

________________________________

PATRICIA A. McCULLOUGH, Judge
IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Charles Picarella Jr., :

Petitioner :

: No. 93 C.D. 2021

v. :

:

Department of Corrections :

(Office of Open Records), :

Respondent :

ORDER

AND NOW, this 30th day of December, 2021, the January 8, 2021 

Final Determination of the Office of Open Records is AFFIRMED.

________________________________

PATRICIA A. McCULLOUGH, Judge