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Opinion Letter No. 96-03
August 12, 1996
Access to Deputy Attorney General Timesheets
The OIP concluded that segregated timesheets of deputy
attorneys general, which only reveal the time
spent investigating a complaint of an open meetings law violation,
are open for public inspection and
copying. Although the timesheets contained descriptions of the legal
work performed on the
investigation, this information was not being requested. Accordingly,
neither the attorney-client
privilege nor the work product doctrine applied as confidentiality
laws which, under section
92F-13(4), Hawaii Revised Statutes, would allow these specific timesheets
to be withheld from the
public.
The OIP also concluded that disclosure of the timesheets
would not reasonably be expected
to interfere with any law enforcement proceedings because the statute
of limitations for open meetings
law violations has already ended and there was no prospective or
contemplated enforcement
proceeding. Therefore, disclosure of the timesheets would not frustrate
a legitimate government
function under section 92F-13(3), Hawaii Revised Statutes. However,
the OIP noted there may be
instances when disclosure of timesheets would interfere with enforcement
proceedings.
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