3. 911 tapes.

In Bowling v. Brandenburg, 37 S.W.3d 785 (Ky.App. 2000), the Kentucky Court of Appeals affirmed a lower court decision that a 911 call was not subject to the ORA because of the personal privacy exception in Ky. Rev. Stat. 61.878(1)(a). However, in a later unpublished case, the court of appeals found that a 911 call was subject to the ORA, because, unlike Bowling, “the 911 caller was neither an alleged victim of domestic violence nor subject to future threats from the alleged domestic violence perpetrator.” Marshall County v. Paxton Media Group, No. 2008-CA-001100MR, (Ky. Ct. App. 2009). See also 10-ORD-221.