The New York's Freedom of Information Law [FOIL] requiring that documents requested pursuant Public Officers Law §89(3)(a) be "reasonably described" serves to enable an agency to locate and identify records in question and places the initial burden on the person or entity making a FOIL request to provide a reasonable description of the record[s] sought for this purpose. In the event the custodian of the record denies a FOIL request on this ground, the custodian bears the burden of establishing that the description[s] were insufficient for purposes of locating and identifying the document[s] sought. Click on the URL below to access this decision posted on the Internet:
https://www.nycourts.gov/reporter/3dseries/2023/2023_00015.htm