“By its own terms the
State Archives policy precluded the continued destruction of any responsive document of any kind after
the original OSEP records request of January 2000…”
“…Ms. Keene, however,
continued to rely on her own personal definition of ‘ephemeral’ to justify
her failure to keep or produce virtually any documents related to SAIF’s outside
consultants right up until her eventual departure in December
2003.”