This annotated example uses semi-fictional information but is based off real-world public records requests that AI Now, Prof. Rashida Richardson, the Center for Constitutional Rights have filed in the past.

January 1, 2022[IH1] 

Re: Freedom of Information Law (FOIL) Request

Dear NYPD Public Records Officer[IH2] :

The Center for Constitutional Rights is filing this request for records pursuant to New York Public Officers Law §§ 84-90[IH3] , to seek information on the New York Police Department’s [IH4] All Seeing Eyes Collector (ASEC) [IH5] reportedly used for collecting and tracking “armed suspects” by the NYPD throughout the city. The NYPD’s use of the ASEC has been recently reported on in the New York Times as well as on National Public Radio, which wrote that the NYPD “uses the ASEC on a daily basis to stop crime before it happens.”[1][IH6] 

The Center for Constitutional Rights requests the following records:

  1. All records including information relating to the algorithm that allows it to determine what individuals are “armed suspects” and/or should be tracked by ASEC within the NYPD, including but not limited to its source code, models, developer documentation, and operator manuals. [7] 
  2. All records relating to the training data used to develop, or train, the algorithm.
  3. All records, including but not limited to documentation or internal communications, about the traits, characteristic, or factors used to develop the data fields in the ASED system.
  4. All records showing the full list of the data fields in the ASED system.[8] 
  5. All records of de-identified input data in the ASED system.
  6. All de-identified records of algorithm outputs, including but not limited to lists of anyone tracked using ASED, broken down by demographic data (race, gender, age), date added to ASED, criminal history, immigration status, whether they have been determined to be a “armed suspect” as well as any other metadata or labels used by the ASED system.[9] 
  7. All records showing how NYPD staff use algorithm outputs to determine whether to take investigative or proactive action against an individual. [10] 
  8. All records of, including communications regarding, audits, internal reviews, or validation studies of the ASED system. [11] 
  9. Any internal policies, practices, procedures, memoranda and training materials for using the ASED system, and for storing, accessing, and sharing data inputs and analysis created by the ASED system. [12] 
  10. Any internal policies, practices, procedures, memoranda and training materials for sharing data inputs and outputs created by the ASED system with entities outside of NYPD, including the FBI, DOJ, ICE or private groups such as the MAGA Boys.[13] 
  11. Any records showing which entities outside of NYPD have accessed, used or requested to use, the System.[14] 
  12. Any records reflecting any agreements for or permission to develop, use, test, or evaluate an algorithmic system used to identify so-called “armed suspects” and services with any third-party vendor or consultants, including Stark Industries and the Law Firm of Ghouliani & Miller. [15] 
  13. Any records referencing the public process preceding the procurement or acquisition of the ASED system, including public meeting agendas or minutes, public notice, analyses, or communications between the NYPD and elected officials or other public servants.[16] 

If possible, please provide requested records in electronic format. Please contact us before retrieving the records so that we can ensure that the retrieved records are in a usable and readable format.

Upon locating the requested documents, please contact us before any reproduction or photocopying and advise us of the actual costs of duplication so that we may decide whether it is necessary to narrow our request. Please notify me in advance if any associated fees are expected to exceed $100. [IH17] 

We would appreciate a response as soon as possible and look forward to hearing from you shortly. Please furnish the requested records to:

Ian Head
Center for Constitutional Rights
666 Broadway, 7th Floor
New York, NY 10012
[email protected][IH18] 


Please treat each individual request as severable from the others and provide responsive records on a rolling basis.

I look forward to your first response to this request within five business days. [IH19] 

Should you deny any portion of this request based on a determination that you are legally exempt from the disclosure requirement with respect to a particular document, please provide me with a written explanation specifically citing the Public Officers Law § 87(2) category [IH20] into which you allege that each document allegedly exempt from disclosure falls. Please articulate particularized and specific justifications for withholding any documents from disclosure. [IH21] 

Additionally, please provide me with the name, e-mail address, mailing address, and facsimile number of the person or body to whom I should direct an administrative appeal of any such potential denial, as well as an explanation of how the appeals process works. [IH22] 


Thank you,


Ian Head