I don't know, but I suspect that it is not unusual. Nor is it improper. And in this case it is obvious from the substance of the note that that is exactly what occurred. He rejects Mr. Cullinan's argument that because the note appeared on an invoice that was approved and paid by the City, it cannot be preliminary. Not every paper in the office of a public agency is a public record subject to public inspection.
Many papers are simply work papers which are exempted because they are preliminary drafts and notes.
Such preliminary drafts and notes and preliminary memoranda are part of the tools which a public employee or officer uses in hammering out official action within the function of his office. They are expressly exempted by the Open Records Law and may be destroyed or kept at will and are not subject to public inspection. OAG 78-626, at p. 2. In OAG 88-85 we considered the underlying purpose of these exemptions. Consequently recommendations and opinions expressed by a subordinate to a superior should not be subject to public scrutiny.