<Because the e-mail was sent from an officer's AKO e-mail instead of his "official" Army e-mail, he did not have to produce the e-mail under the FOIA.>

These "personal email account" situations remind me of past practices when very upper management would take paper files home to work on (or use as research to author a publication) and then kept them home.  I have worked many an inventory where state and local government files were found in personal garages, attics, basements, and even car trunks.  Since FOIA did not exist back then, the issue rarely came to light, but an electronic version of this practice now exists in many government agencies and it is a FOIA response problem.

Ginny Jones 
(Virginia A. Jones, CRM, FAI) 
Records Manager 
Information Technology Division 
Newport News Dept. of Public Utilities 
Newport News, VA 
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