Undisclosed LLC, a producer investigating a prior murder case for a legal documentary podcast, sought copies of court-reporter audio recordings from hearings and the trial. The trial court denied the request, and the Supreme Court of Georgia granted discretionary review to interpret Uniform Superior Court Rule 21 and the common-law right of access that the rule preserved. The court held that the rule’s reference to court records did not make every court-reporter tape a public record. At common law and when Rule 21 was adopted, court records meant materials filed with the court. The recordings sought by Undisclosed were not themselves filed records, and a transcript of the proceedings already existed. The court therefore affirmed the denial of access to the tapes. The opinion distinguished an earlier decision involving a judge’s public comments made in open court when no case record existed. A special concurrence argued that the earlier decision should instead be overruled.