prisoner invoked the Public Records Act to obtain records of the Department of Correction's internal investigation into the murder. Id. at 165-66. Acknowledging that no statute specifically exempted these records from disclosure, the Appman Court nonetheless held that Rule 16(a)(2) exempted from disclosure under the Public Records Act all “open” criminal investigative files that “are relevant to pending or contemplated criminal action.” Id. at 166. In so holding, the Appman Court stressed that the Rules of Criminal Procedure “became effective ... upon the [Gjovernor’s approval of a joint resolution of the [Ljegislature adopting the rules,” a procedure nearly identical to the procedure by which statutes are enacted, and emphasized t (Tenn.Ct.App.2004), perm. appeal denied (Tenn.2005) (<HOLDING>); Arnold, 19 S.W.3d at 786 (holding that the
holding that the public records act does not mandate disclosure of documents sealed by a protective order entered pursuant to the tennessee rules of civil procedure holding that draft pleadings are not subject to public records disclosure holding that the public records act does not mandate disclosure of records protected by tennessee rule of criminal procedure 16 recognizing that intent of public records act is to provide all citizens with access to the records of all public governmental bodies holding that personnel records or conduct investigative records regarding police officers are exempt from disclosure under virginias freedom of information act which exempts personnel records from disclosure