were realized — without any substantive reasoning or even a reference to the reports. Id. at 185-86, 95 S.Ct. 1491. Moreover, the Board was in no way bound by the reports’ recommendations, nor the reasoning contained therein; the reports were simply prepared for t . 22 (D.C.Cir.1983) (noting that “[i]f the agency merely carried out the recommended decision without explaining its decision in writing, we could not be sure that the memoranda accurately reflected the decisionmaker’s thinking”). Courts have similarly honored the deliberative process privilege where an agency has only casually referred to a document, because a casual reference to a privileged document does not necessarily imply that an agency agrees with the reasoning contained in those documents. See Tigue, 312 F.3d at 81 (<HOLDING>); Access Reports v. Dep’t of Justice, 926 F.2d
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 two minor references to a document protected by the deliberative process privilege were insufficient to establish adoption or incorporation holding that there is no statutory deliberative process privilege in arizona and declining to create such a privilege under the common law holding that emails among prosecutors relating to decision not to prosecute were covered by the deliberative process privilege