D. How is e-mail treated?

The CPRA's definition of "writing" includes e-mail: "'Writing' means any handwriting, typewriting, printing, photostating, photographing, photocopying, transmitting by electronic mail or facsimile, and every other means of recording upon any tangible thing any form of communication or representation, including letters, words, pictures, sounds or symbols, or combination thereof, and any record thereby created, regardless of the manner in which the record has been stored." Cal. Gov't Code § 6252(f) (emphasis added). See also San Diego Reader v. Superior Court, 31 Med. L. Rptr. 1890 (Cal. Sup. Ct. 2002) (ruling that e-mail to and from mayor's former press secretary are not exempt from disclosure since e-mail is a government record, since those corresponding with government have diminished expectation of privacy as to e-mail content and address and since public interest in nondisclosure did not clearly outweigh interest in disclosure).