which reflect the personal opinions of the writer rather than the policy of the agency,’ as well as documents which would ‘inaccurately reflect or prematurely disclose the views of the agency.’ ” Id. at 1119-20 (quoting Coastal States Gas Corp. v. Dep’t of Energy, 617 F.2d 854, 866 (D.C.Cir.1980)). Relying on this same language in Coastal States, at least one court appears to have held that all draft documents are per se deliberative because they are predecisional. See Hamilton Sec. Group Inc. v. Dep’t of Housing and Urban Development, 106 F.Supp.2d 23, 31-32 (D.D.C.2000) (construing Coastal States as a decision that litigants should not “parse” and holding that draft audit reports were privileged). But see Heartwood, Inc. v. U.S. Forest Serv., 431 F.Supp.2d 28, 37-38 (D.D.C.2006) (<HOLDING>). With respect to purely factual information
recognizing application of federal deliberative process privilege to internal state communications holding that internal emails about how to present an agency decision to the public were covered by the deliberative process privilege holding that emails among prosecutors relating to decision not to prosecute were covered by the deliberative process privilege holding that an advisory committees draft ecological assessments were not privileged because they were not deliberative within the meaning of the privilege holding that there is no statutory deliberative process privilege in arizona and declining to create such a privilege under the common law