The City of East Providence denied the Complainant's APRA request basing its denial on its conclusion that "the documents you requested were from a meeting of individuals which does not constitute an agency or public body as defined by R.I.G.L. §38-2-2." This denial has absolutely no basis in law and other than the conclusory sentence, the City makes no effort in its denial or in its response to this Department to explain the legal basis for this denial. As such, this Department directed that the City respond to the APRA request in a manner consistent with the APRA and this finding, and that the City provide a supplemental response to this Department addressing why the violation that we have found should not be considered a "knowing and willful" or "reckless" violation, subjecting the City to monetary penalties.