C. Court-derived exclusions, common law prohibitions, recognized privileges against disclosure.

See Section II. B. above, discussing deliberative process exemption. In the case of Rosenthal v. Hansen, 34 Cal. App. 3d 754, 757, 761, 110 Cal. Rptr. 257 (1973), the court imposed a judicially created "reasonableness" standard to restrict access to public records where the request for a seven-volume, loose-leaf workbook was found to be voluminous. In a similar vein, the Court in American Civil Liberties Union Foundation v. Deukmejian, 32 Cal. 3d 440, 452-53, 186 Cal. Rptr. 235, 651 P.2d 822 (1982), held that where a public agency can substantiate that a voluminous request, involving extensive segregation of exempt from non-exempt materials, would impose an unwarranted burden on the agency's resources, the public interest in nondisclosure outweighs the public interest in disclosure. See also Cal. First Amendment Coalition v. Superior Court, 67 Cal. App. 4th 159, 166, 78 Cal. Rptr. 2d 847 (1998) ("A clearly framed request which requires an agency to search an enormous volume of data for a 'needle in the haystack' or, conversely, a request which compels the production of a huge volume of material may be objectionable as unduly burdensome.[citations omitted] Records requests, however, inevitably impose some burden on government agencies. An agency is obligated to comply so long as the record can be located with reasonable effort."); cf. CBS Broad. Inc. v. Superior Court, 91 Cal. App. 4th 892, 909, 110 Cal. Rptr. 2d 889 (2001) (rejecting as untenable position that costs in amount of $43,000 to compile accurate list of individuals granted criminal conviction exemption to work in licensed child day care facilities was valid reason for nondisclosure).