In Manning v. East Tawas, 234 Mich. App. 244; 593 N.W.2d 649 (1999), the defendant city council held a closed session to discuss with the city attorney a prior action by the plaintiffs challenging the council's refusal to approve the plaintiffs' proposed site plan for a recreational vehicle park. The plaintiffs alleged that the closed session violated the OMA and that the city clerk had violated the Freedom of Information Act (FOIA), MCL 15.231 et seq.; MSA 4.1801(1) et seq., by refusing to disclose the minutes of that closed session. Id. at 246. The trial court recognized as partially applicable to the closed session at issue the exemption of subsection 8(e) of the OMA, MCL 15.268(e); MSA 4.1800(18)(e). However, the trial court ordered partial disclosure of the minutes of the session under the FOIA. Id. at 246-247.