It appears that confidentiality was expected in the handling of these documents, and that attempts were made to insure that the information contained therein was protected from general disclosure. Thus, DOI also affirmatively satisfied the third part of the test. We affirm its decision to withhold these records on this basis. The majority of the documents withheld by DOI consisted of preliminary drafts, notes, and email transmissions. 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.
Yellow pads can be filled with outlines, notes, drafts and doodlings which are unceremoniously thrown in the wastebasket or which may in certain cases be kept in a desk drawer for future reference. 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. OAG 78-626, p. 2. We find that the records identified in items one and two of Ms. Pearce s original response to Mr. Rowe s request can properly be characterized as notes. These handwritten notes of employee interviews represent a brief record written down to aid the memories of Mr. Donahue and Ms. Dickinson, and are in the nature of the tools used in hammering out official action rather than the official action itself.