Matter of Bello v. State of New York Department of Law

In Matter of Bello v. State of New York Department of Law (208 A.D.2d 832, 617 N.Y.S.2d 856 [2d Dept 1994]) petitioners sought access, through FOIL, to documents compiled by Cablevision Systems Corporation (Cablevision), and obtained by the New York State Department of Law during the course of a civil investigation. Cablevision intervened in the proceeding, objecting to access to the documents, pursuant to the law enforcement exemption to FOIL. Although the court ruled that Cablevision failed to meet its burden of demonstrating that disclosure of those documents would, in fact, interfere with a law enforcement investigation, it did not discuss the question, at issue here, of whether the provision was applicable to the Law Department's investigation.