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Although the former employees alleged that the general manager’s production of the disciplinary action forms in response to a record request was actionable because, at least as to two employees, the forms contained untrue statements about the employees acting dishonestly when they examined confidential information on the employer’s computer system without permission following one of the employee’s discharge, the general manager’s decisions to discharge the employees were not conditional and did not need the board of directors’  approval; the general manager had the authority to terminate employees, and the terminations represented his final action. That the discharges could potentially have been set aside by the board during the grievance hearing did not transform the disciplinary action forms into preliminary drafts, notes, or correspondence. Burgess v. Paducah Area Transit Auth., 387 Fed. Appx. 538, 2010 FED App. 0421N, 2010 U.S. App. LEXIS 14384 (6th Cir. Ky. 2010).
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