In a special action to compel the City of Phoenix to produce public records, the court rejected the plaintiff’s argument that metadata was necessary to determine whether the produced notes were backdated and for authentication purposes. “The metadata was not made by Conrad in ‘pursuance of a duty.’ It was generated only as a by-product of his use of a computer. Additionally, the purpose of the metadata was not to ‘disseminate information to the public’ or ‘to serve as a memorial of an official transaction for public reference.’ Similarly, Conrad was not ‘required by law’ to create or maintain metadata about his notes nor was he required to create or maintain such data ‘to serve as a memorial and evidence of something written, said or done.’ Conrad’s obligations, if any, to provide written documentation of Lake’s performance, consisted of memorializing his notes, whether by computer or other medium. He was not legally obligated to make a record of the filename, to record the name of the computer on which the document was created, to identify the server he may have accessed, to note when the file was accessed or modified, or to identify when it was printed. There is no question that metadata includes information reflecting certain transactions that occur in connection with the use of a computer. The transaction recorded by Conrad, however, was not the metadata created by the computer. Rather, the transaction he recorded was his supervisory notes relating to Lake.” See Lake v. City of Phoenix, No.07-1415, 2009 WL 73256 (Ariz. App. Div. 1, Jan. 13, 2009).