Fact that a police officer resigned before the conclusion of his termination hearing did not render the complaint which gave rise to the termination hearing “preliminary materials,” which were not subject to public disclosure under the Kentucky Open Records Act, KRS 61.878. Palmer v. Driggers, 60 S.W.3d 591, 2001 Ky. App. LEXIS 1165 (Ky. Ct. App. 2001).
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