OAG 89-69, at p. 3. The most closely analogous open records decision bearing on this issue is OAG 91-161. In that decision, the requester sought access to the report prepared by the chairman and vice chairman of the University of Louisville's Board of Trustees representing the Board's annual evaluation of the University's president along with supporting documentation. At issue was a three page typewritten document which was prepared as an aid to the chairman in summarizing the evaluation to the full board. We rejected the requester's argument that this document was incorporated into the Board's final report, thereby forfeiting its preliminary characterization when it was used by the chairman in making his presentation to the full board.
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. The typed and handwritten notes at issue in this appeal are more closely akin to work papers used by a public officer in hammering out official action than records reflecting that official action. Under the Open Records Act, the public is entitled to inspect records reflecting the official action taken, in this case the Findings of Fact adopted by the Lexington-Fayette Urban County Council, and not the work papers used in arriving at that action.