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•A majority may not, outside <br />a meeting, use a series of <br />communications to discuss, <br />deliberate, or take action <br />on any item of business <br />Government Transparency Laws –Brown Act <br />B. Brown Act—Avoiding “Serial Meetings” <br />–Does not prevent employees and officials from <br />engaging in separate conversations outside <br />of a meeting provided that the comments or <br />positions of other members are not <br />communicated