Kentucky State Police violated the Open Records Act, Ky. Rev. Stat. Ann. § 61.870 et seq., by failing to produce its entire Uniform Citation File database when requested by a reporter where the time and manpower required to separate exempt material, standing alone, was not sufficiently clear and convincing evidence to show an unreasonable burden under Ky. Rev. Stat. Ann. § 61.872(6). Moreover, the undisputed evidence noted that the necessary categorical extractions could be performed for $15,000, and electronically separating exempt material was not equivalent to creating a new record given the mandate in Ky. Rev. Stat. Ann. § 61.878(4). Commonwealth v. Courier Journal, 601 S.W.3d 501, 2020 Ky. App. LEXIS 42 (Ky. Ct. App. 2020).
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