inhibit the flow of information to the Governor. “If the law required disclosure of a private meeting between the Governor and a politically unpopular or controversial group, that meeting might never occur.” Times Mirror, 813 P.2d at 251; accord Courier- Journal, 895 S.W.2d at 8 (quoting Times Mirror). Even routine meetings between the Governor and other lawmakers, lobbyists or citizens groups might be inhibited if the meetings wereregularlyrevealed to the public. As the court in Taylor stated: “A lack of candor or an unwillingness to participate in the decision making process is as likely to flow from the compelled disclosure of the fact of consultation as from the disclosure of the content of the consultation.” 409 S.E.2d at 139 (emphasis added); see also Cofield, 913 F. Supp. at 617 (<HOLDING>). The record in this case underscores the
holding that purely factual material may be withheld from disclosure under exemption 5 if that material would expose the deliberative process of an agency holding that internal emails about how to present an agency decision to the public were covered by the deliberative process privilege recognizing application of federal deliberative process privilege to internal state communications holding that where an authorized disclosure is voluntarily made to a nonfederal party whether or not that disclosure is denominated confidential the government waives any claim that the information is exempt from disclosure under the deliberative process privilege holding that agency documents with internal routing notations were exempt from disclosure because such notations may reasonably lead to identification of those individuals involved in the decisionmaking process a result that could chill open and frank discussions within the agency undermining the deliberative process