Telephone call logs are not specifically addressed in the statute, but they should fall within the definition of "public record," which includes "all books, papers, maps, photographs, cards, tapes, recordings, or other documentary materials regardless of physical form characteristics prepared, owned, or used in the possession of, or retained by a public body." D.C. The court’s decision turned in large part on the unfocused nature of the request, which sought “all City-reimbursed telephone records of all City Council members over a one-year period.” Id. at 480. The court stated that disclosure of the telephone numbers of individuals with whom council members have spoken “‘was the functional equivalent of revealing the substance or direction’ of the judgment and mental processes of the City Council member.” Id. (quoting Times Mirror Co. For example, one California appellate court has held that telephone numbers contained in otherwise disclosed cell phone, home phone and hotel bills of city council members were properly withheld under the deliberative process privilege within the catchall exemption of Section 7922.000 of the Government Code. Telephone records are generally public absent specific circumstances justifying their withholding.
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