The ORA thus imposes a duty upon "agencies" to produce or to provide access to public records upon a proper request. See OCGA § 50-18-71 (b) (1); Campaign for Accountability v. Consumer Credit Research Foundation, 303 Ga. 828, 830 (2), 815 S.E.2d 841 (2018) ("Government agencies therefore have a duty to disclose public records unless relieved of that duty by a specific exemption or court order.").Gonzalez has not challenged the form of the requests, the method by which they were submitted to her as the custodian of records for her office, or whether the records sought were public records under the ORA.

And, relatedly, "courts should avoid a statutory construction that will render some of the statutory language mere surplusage." Thornton v. State , 310 Ga. 460, 469 (3), 851 S.E.2d 564 (2020) (citation and punctuation omitted); see also Campaign for Accountability v. Consumer Credit Research Found. , 303 Ga. 828, 832 (2), 815 S.E.2d 841 (2018). If OCGA § 16-9-93 (b) (2) is as broad as the State suggests, "obstructing" and "interrupting" become entirely surplusage and redundant; in such an event, the relevant text would need to list only "interfering."