Citing Madeiros v New York State Educ. Dept., 30 NY3d 67, the Appellate Division held that the fact that the custodian of records demanded under color of New York State's Freedom of Information Law chose to task an outside law firm with investigation of employee complaints does not mean that custodian had no reasonable basis for invoking the law enforcement exemption as the exemption "does not apply solely to records compiled for law enforcement purposes in connection with criminal investigations."
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