In Tribune-Review Publishing Co. v. Westmoreland County Housing Authority, 574 Pa. 661, 833 A.2d 112 (2003), a housing authority refused to provide a newspaper with access to a confidential settlement agreement between a former employee and the authority's liability insurer in a civil rights action. The authority argued that it did not authorize or sign the document at issue, nor did it ever see or possess the document, but that the attorney for its insurer possessed it. Our Supreme Court held that "lack of possession of an existing writing by the public entity at the time of a request pursuant to the [Law] is not, by itself, determinative of ... whether the writing is a 'public record' subject to disclosure. A writing is within the ambit of the [Law] if it is subject to the control of the agency." Tribune-review, 574 Pa. at 671, 833 A.2d at 118. If the preparation of a writing, such as a litigation settlement document, by an attorney for an agency or by an attorney-in-fact for the agency's insurer is not viewed as preparation by the agency, any public entity could thwart disclosure required by the Law by having an attorney or an insurer's attorney prepare every writing that the public entity wishes to keep confidential. Id.