3. 911 tapes.

The Committee on Open Government has expressed the opinion that 911 tapes can be viewed as records compiled in the ordinary course of business and as such, should generally be subject to disclosure. Comm. Open Gov't, FOIL-AO-3734 (1985); FOIL-AO-3540 (1984). See New York Times Co. v. City of New York Fire Dep't, 4 N.Y.3d 477, 796 N.Y.S.2d 302 (2005) (emergency 911 calls made in connection with terrorist attacks on September 11, 2001, are subject to disclosure under FOIL to the extent that the words recorded are those of public employees and of eight deceased individuals whose survivors sought disclosure, but must be redacted to delete the words of other callers to 911).