It's interesting that the opening analogy in the post uses an Excel spreadsheet as a great way to explain a database. It's such an easy next step to say the way an xls/ods file is saved is a file format but the column layout in the tabs/tables are the schemas. The court (and the city) playing these games is so scary since it is so biased toward all modern government data being covered by FOIA exemptions.
But on the other hand, in all database systems the schema is used to determine how the files are laid out. Although I suppose the same thing could be argued for any data that is stored in a file, excepting that a schema is metadata that determines the organisation of data so it's a bit of a special case.
Arguably, all requests for files could be returned with all of the letters in the document but scrambled in a random order soas to obfuscate the file layout.
