Irwin v. Onondaga County Res. Recovery Agency, 895 N.Y.S.2d 262 (N.Y. App. Div. 2010)

Key Insight: Appellate court modified amended order of the lower court and granted plaintiff?s petition to compel production of certain electronically stored photographs and the associated ?system? metadata in response to plaintiff?s FOIL request; court was careful to limit scope of holding to the present case such that the opinion did not address ?the issue concerning whether and when metadata of any nature is subject to disclosure under the CPLR? (Civil Practice Law Rules)

Nature of Case: Freedom of Information request

Electronic Data Involved: Electronically stored photographs and associated “system” metadata