F. Addressing government suits against disclosure.

The California Supreme Court has held that an agency may not initiate a declaratory relief action to determine its obligation to disclose records to a member of the public. Filarsky v. Superior Court, 28 Cal. 4th 419, 426, 121 Cal. Rptr. 2d 844, 49 P.3d 194 (2002). Whether third parties may initiate an action to bar disclosure of public records has not been decided. Id. (declining to address issue); see also Teamsters Local 856 v. Priceless, LLC, 112 Cal. App. 4th 1500, 1508 n.6, 5 Cal. Rptr. 3d 847 (2004)(recognizing unresolved nature of issue but expressing no opinion on it).