All available documentation regarding a BOE member's ethics complaint
Dear Collingswood Board of Education,
Please accept this electronic request for public records made under OPRA and the common law right of access. I am not required to fill out an official form or use a particular software platform to submit my request per NJSA 47:1A-6(f), which states that an email from a requestor including all of the information required on the adopted form shall suffice in place of a completed form as a valid government record request.
I HAVE NOT been convicted of any indictable offense under the laws of New Jersey, any other state, or the United States.
I WILL NOT use the requested government records for a commercial purpose.
I AM NOT seeking records in connection with a legal proceeding.
Records requested: All documentation related to the ethics complaint filed against Collingswood B.O.E. member Meghan Mikulski and the use of district funds to pay for any related legal services.
My preferred delivery method for response(s) to this request is by E-mail as attachments. Please confirm you have received this request. If you are not the custodian of records, please forward my request to that person and provide their email address to me for future reference.
Thank you.
I am currently away from the office. Should you require immediate
assistance, please contact Maria Tessing at 856-962-5702 ext. 9004.
Thank you
--
Beth Ann Coleman , MPA, QPA, RSBA
Assistant Superintendent for Business and Operations
Collingswood and Oaklyn Public Schools
200 Lees Avenue
Collingswood NJ 08108
P-856-962-5700
F- 856-962-5723
To Whom it May Concern,
I am the Solicitor for the Collingswood Board of Education. On behalf of
the Custodian of Records, the Custodian will need additional time to
respond to your OPRA request received on October 13, 2025
Joseph F. Betley | Shareholder | Co-Chair, School Law Department
CAPEHART || SCATCHARD
A T T O R N E Y S A T L A W
New Jersey - Pennsylvania - New York
8000 Midlantic Dr, Ste 300S
Post Office Box 5016
Mount Laurel, NJ 08054
[1][email address]
856-234-6800 Phone
856-914-2075 Direct
856-235-2786 Fax
[2]Web | [3]Bio | [4]LinkedIn | [5]Blog
Confidentiality Note: This transmission is intended only for the
addressee, and may contain privileged and/or confidential information from
the law firm of Capehart & Scatchard, P.A. If you are not the intended
recipient, please do not use, disseminate, or copy this material. If you
have received this transmission in error, please notify us immediately by
telephone, return this transmission, and delete or destroy any copies.
References
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1. mailto:[email address]
2. http://www.capehart.com/
3. file:///tmp/
4. https://www.linkedin.com/in/joe-betley-5...
5. http://www.capehart.com/publications/fea...
I apologize for the previous email. I hit “send” too soon. The Custodian
does need more time. I will get back to you with a more detailed response
and specific date for when the OPRA response will be due.
Joseph F. Betley | Shareholder | Co-Chair, School Law Department
CAPEHART || SCATCHARD
A T T O R N E Y S A T L A W
New Jersey - Pennsylvania - New York
8000 Midlantic Dr, Ste 300S
Post Office Box 5016
Mount Laurel, NJ 08054
[1][email address]
856-234-6800 Phone
856-914-2075 Direct
856-235-2786 Fax
[2]Web | [3]Bio | [4]LinkedIn | [5]Blog
Confidentiality Note: This transmission is intended only for the
addressee, and may contain privileged and/or confidential information from
the law firm of Capehart & Scatchard, P.A. If you are not the intended
recipient, please do not use, disseminate, or copy this material. If you
have received this transmission in error, please notify us immediately by
telephone, return this transmission, and delete or destroy any copies.
From: Joseph F. Betley <[email address]>
Sent: Tuesday, October 14, 2025 2:31 PM
To: [OPRA #82035 email]
Subject: Collingswood Board of Education
To Whom it May Concern,
I am the Solicitor for the Collingswood Board of Education. On behalf of
the Custodian of Records, the Custodian will need additional time to
respond to your OPRA request received on October 13, 2025
Joseph F. Betley | Shareholder | Co-Chair, School Law Department
CAPEHART || SCATCHARD
A T T O R N E Y S A T L A W
New Jersey - Pennsylvania - New York
8000 Midlantic Dr, Ste 300S
Post Office Box 5016
Mount Laurel, NJ 08054
[6][email address]
856-234-6800 Phone
856-914-2075 Direct
856-235-2786 Fax
[7]Web | Bio | [8]LinkedIn | [9]Blog
Confidentiality Note: This transmission is intended only for the
addressee, and may contain privileged and/or confidential information from
the law firm of Capehart & Scatchard, P.A. If you are not the intended
recipient, please do not use, disseminate, or copy this material. If you
have received this transmission in error, please notify us immediately by
telephone, return this transmission, and delete or destroy any copies.
References
Visible links
1. mailto:[email address]
2. http://www.capehart.com/
3. file:///tmp/
4. https://www.linkedin.com/in/joe-betley-5...
5. http://www.capehart.com/publications/fea...
6. mailto:[email address]
7. http://www.capehart.com/
8. https://www.linkedin.com/in/joe-betley-5...
9. http://www.capehart.com/publications/fea...
Dear Joseph F. Betley,
Thank you for your attention to this matter. I am just checking in to see if any information about the ethics complaint has become available. Thank you.
Yours sincerely,
Collingswood Resident
Dear Joseph F. Betley,
I wanted to followup and see if it would be possible to receive the documents related to this request by Tuesday, October 21, 2025.
I am hoping to receive all complaints, invoices, receipts, emails, and any other correspondence or documentation related to this matter since September 2024.
Yours sincerely,
Collingswood Resident
Dear Collingswood Resident,
Thank you for clarifying the OPRA request that the Custodian of Records
for the Collingswood School District received on October 13, 2025. For
clarity, the initial OPRA request contained the following:
All documentation related to the ethics complaint filed against
Collingswood B.O.E. member Meghan Mikulski and the use of district funds
to pay for any related legal services.
On October 14, 2025, I sent you an email stating:
“I am the Solicitor for the Collingswood Board of Education. On behalf of
the Custodian of Records, the Custodian will need additional time to
respond to your OPRA request received on October 13, 2025.”
Later that same day, I sent a follow up email:
“I apologize for the previous email. I hit “send” too soon. The Custodian
does need more time. I will get back to you with a more detailed response
and specific date for when the OPRA response will be due.”
You responded to my emails on October 17, 2025, at 12:22 pm with the
following:
“Thank you for your attention to this matter. I am just checking in to see
if any information about the ethics complaint has become available. Thank
you.”
Subsequently, you sent another email that same day at 2:57 pm that
clarified your OPRA request:
“I am hoping to receive all complaints, invoices, receipts, emails, and
any other correspondence or documentation related to this matter since
September 2024.” You also requested “to receive the documents related to
this request by Tuesday, October 21, 2025.”
Thank you for the clarification on the time period of the initial OPRA
request as being September 2024 to the time of your OPRA request on
October 13, 2025.
The Custodian of records construes your reference to “complaints” as any
ethics complaints filed against Board Member Meghan Mikulski since
September 1, 2024. This is a valid OPRA request.
The Custodian of records construes your references to “invoices” and
“receipts” as related to any payment of District funds for legal services
related to the any ethics complaints filed against Ms. Mikulski from
September 1, 2024, to October 13, 2025. This is a valid OPRA request.
Concerning your request for emails, this is an invalid OPRA request. The
Custodian of Records cannot respond to this request in its current form.
Any request under OPRA for emails must identify the email address with a
specific job title or accounts to be searched. Further, the request would
require the Custodian of Records to conduct research and the collection of
information from the contents of government records.
As to your request for “any other correspondence or documentation related
to this matter,” as well as your request for “any information about the
ethics complaint,” these are not valid OPRA requests. The above request is
overly broad, and vague. OPRA allows access to records, not information.
Benigno v. N.J. Off. Of the State Comptroller, No. A-1467-22, 2024 N.J.
Super. Unpub. LEXIS 637, at 11 (App. Div. 2024), and “is not intended as a
research tool litigants may use to force government officials to identify
and siphon useful information. MAG Entertainment, LLC v. Division of
Alcoholic Beverage Control, 375 N.J. Super. 534, 546 (App. Div. 2005). A
request must identify with reasonable clarity the documents sought. Bent
v. Stafford Police Department, 381 N.J. Super. 30, 37 (App. Div. 2005). A
request that fails to identify a specific government record is invalid.
MAG Entertainment, Bent v. Stafford Police Department, 381 N.J. Super. 30
(App. Div. 2005) and Schuler v. Borough of Bloomsbury, GRC Complaint No.
2007-151 (February 2009).
The Custodial of Records will respond to the aspects of your OPRA request
that are considered valid as set forth above. As noted in my previous
email, the Custodian will need additional time to reply to these requests,
particularly as to the request for invoices/receipts related to District
funds spent on the ethics charge against Ms. Mikulski. The Custodian will
need until October 31, 2025, to reply, which is a reasonable time
extension.
Thank you.
Joseph F. Betley | Shareholder | Co-Chair, School Law Department
CAPEHART || SCATCHARD
A T T O R N E Y S A T L A W
New Jersey - Pennsylvania - New York
8000 Midlantic Dr, Ste 300S
Post Office Box 5016
Mount Laurel, NJ 08054
[1][email address]
856-234-6800 Phone
856-914-2075 Direct
856-235-2786 Fax
[2]Web | [3]Bio | [4]LinkedIn | [5]Blog
Confidentiality Note: This transmission is intended only for the
addressee, and may contain privileged and/or confidential information from
the law firm of Capehart & Scatchard, P.A. If you are not the intended
recipient, please do not use, disseminate, or copy this material. If you
have received this transmission in error, please notify us immediately by
telephone, return this transmission, and delete or destroy any copies.
References
Visible links
1. mailto:[email address]
2. http://www.capehart.com/
3. file:///tmp/
4. https://www.linkedin.com/in/joe-betley-5...
5. http://www.capehart.com/publications/fea...
Dear Collingswood Resident,
Thank you for clarifying the OPRA request that the Custodian of Records
for the Collingswood School District received on October 13, 2025. For
clarity, the initial OPRA request contained the following:
All documentation related to the ethics complaint filed against
Collingswood B.O.E. member Meghan Mikulski and the use of district funds
to pay for any related legal services.
On October 14, 2025, I sent you an email stating:
“I am the Solicitor for the Collingswood Board of Education. On behalf of
the Custodian of Records, the Custodian will need additional time to
respond to your OPRA request received on October 13, 2025.”
Later that same day, I sent a follow up email:
“I apologize for the previous email. I hit “send” too soon. The Custodian
does need more time. I will get back to you with a more detailed response
and specific date for when the OPRA response will be due.”
You responded to my emails on October 17, 2025, at 12:22 pm with the
following:
“Thank you for your attention to this matter. I am just checking in to see
if any information about the ethics complaint has become available. Thank
you.”
Subsequently, you sent another email that same day at 2:57 pm that
clarified your OPRA request:
“I am hoping to receive all complaints, invoices, receipts, emails, and
any other correspondence or documentation related to this matter since
September 2024.” You also requested “to receive the documents related to
this request by Tuesday, October 21, 2025.”
Thank you for the clarification on the time period of the initial OPRA
request as being September 2024 to the time of your OPRA request on
October 13, 2025.
The Custodian of records construes your reference to “complaints” as any
ethics complaints filed against Board Member Meghan Mikulski since
September 1, 2024. This is a valid OPRA request.
The Custodian of records construes your references to “invoices” and
“receipts” as related to any payment of District funds for legal services
related to the any ethics complaints filed against Ms. Mikulski from
September 1, 2024, to October 13, 2025. This is a valid OPRA request.
Concerning your request for emails, this is an invalid OPRA request. The
Custodian of Records cannot respond to this request in its current form.
Any request under OPRA for emails must identify the email address with a
specific job title or accounts to be searched. Further, the request would
require the Custodian of Records to conduct research and the collection of
information from the contents of government records.
As to your request for “any other correspondence or documentation related
to this matter,” as well as your request for “any information about the
ethics complaint,” these are not valid OPRA requests. The above request is
overly broad, and vague. OPRA allows access to records, not information.
Benigno v. N.J. Off. Of the State Comptroller, No. A-1467-22, 2024 N.J.
Super. Unpub. LEXIS 637, at 11 (App. Div. 2024), and “is not intended as a
research tool litigants may use to force government officials to identify
and siphon useful information. MAG Entertainment, LLC v. Division of
Alcoholic Beverage Control, 375 N.J. Super. 534, 546 (App. Div. 2005). A
request must identify with reasonable clarity the documents sought. Bent
v. Stafford Police Department, 381 N.J. Super. 30, 37 (App. Div. 2005). A
request that fails to identify a specific government record is invalid.
MAG Entertainment, Bent v. Stafford Police Department, 381 N.J. Super. 30
(App. Div. 2005) and Schuler v. Borough of Bloomsbury, GRC Complaint No.
2007-151 (February 2009).
The Custodial of Records will respond to the aspects of your OPRA request
that are considered valid as set forth above. As noted in my previous
email, the Custodian will need additional time to reply to these requests,
particularly as to the request for invoices/receipts related to District
funds spent on the ethics charge against Ms. Mikulski. The Custodian will
need until October 31, 2025, to reply, which is a reasonable time
extension.
Thank you.
Joseph F. Betley | Shareholder | Co-Chair, School Law Department
CAPEHART || SCATCHARD
A T T O R N E Y S A T L A W
New Jersey - Pennsylvania - New York
8000 Midlantic Dr, Ste 300S
Post Office Box 5016
Mount Laurel, NJ 08054
[1][email address]
856-234-6800 Phone
856-914-2075 Direct
856-235-2786 Fax
[2]Web | [3]Bio | [4]LinkedIn | [5]Blog
Confidentiality Note: This transmission is intended only for the
addressee, and may contain privileged and/or confidential information from
the law firm of Capehart & Scatchard, P.A. If you are not the intended
recipient, please do not use, disseminate, or copy this material. If you
have received this transmission in error, please notify us immediately by
telephone, return this transmission, and delete or destroy any copies.
References
Visible links
1. mailto:[email address]
2. http://www.capehart.com/
3. file:///tmp/
4. https://www.linkedin.com/in/joe-betley-5...
5. http://www.capehart.com/publications/fea...
Dear Joseph F. Betley,
Thank you for clarifying.
Are you able to send materials as they become available? I'd rather receive some items more quickly instead of waiting for everything all at once.
For emails, are you able to provide any emails related to an ethics violation/complaint to or from the following Board Members Meghan Mikulski, Regan Kaiden, Christine Sheridan Celia, Roger Chu, Mary Saverino, Matthew Craig, Richard Taibi, Kelly Maia, Kate Seltzer, Sarah Sherman, or Christopher Dilkus as well as District staff Superintendent Fredrick H. McDowell or Business Adminstrator Beth Ann Coleman.
Yours sincerely,
Collingswood Resident
Dear Sir/Madam,
As you are aware, this office serves as the Solicitor for the Collingswood
Board of Education. On behalf of Beth Ann Coleman, the Custodian of
Records, I am responding to your October 13, 2025, OPRA request for the
following information:
1. any “invoices” or “receipts” related to any payment of District funds
for legal services related to any ethics complaints filed against Ms.
Mikulski from September 1, 2024, to October 13, 2025.
Please see the attached document containing purchase orders and bills
responsive to your request.
We are reviewing other documents responsive to your request, which will be
transmitted to you shortly once our review is complete.
Best Regards,
Robert W. Steere | Associate | School Law
CAPEHART || SCATCHARD
A T T O R N E Y S A T L A W
New Jersey - Pennsylvania - New York
8000 Midlantic Dr, Ste 300S
Post Office Box 5016
Mount Laurel, NJ 08054
[1][email address]
856-234-6800 Phone
856-477-8505 Direct
856-235-2786 Fax
[2]Web | [3]Bio
Confidentiality Note: This transmission is intended only for the
addressee, and may contain privileged and/or confidential information from
the law firm of Capehart & Scatchard, P.A. If you are not the intended
recipient, please do not use, disseminate, or copy this material. If you
have received this transmission in error, please notify us immediately by
telephone, return this transmission, and delete or destroy any copies.
References
Visible links
1. mailto:[email address]
2. http://www.capehart.com/
3. file:///tmp/
Dear Sir/Madam,
As you are aware, this office serves as the Solicitor for the Collingswood
Board of Education. Yesterday this office produced documents responsive to
the following request:
• any “invoices” or “receipts” related to any payment of District funds
for legal services related to any ethics complaints filed against Ms.
Mikulski from September 1, 2024, to October 13, 2025.
We are in the process of reviewing a substantial number of documents
responsive to your other requests for the following information:
• any emails related to an ethics violation/complaint to or from the
following Board Members Meghan Mikulski, Regan Kaiden, Christine
Sheridan Celia, Roger Chu, Mary Saverino, Matthew Craig, Richard
Taibi, Kelly Maia, Kate Seltzer, Sarah Sherman, or Christopher Dilkus
as well as District staff Superintendent Fredrick H. McDowell or
Business Administrator Beth Ann Coleman;
• any ethics complaints filed against Board Member Meghan Mikulski since
September 1, 2024.
We are in the process of reviewing the documents in our possession for
privileged material that is exempt from disclosure under OPRA. We require
more time to complete this process before producing the remaining
documents. Accordingly, we expect to complete your request on or before
Wednesday, November 5, 2025.
Best Regards,
Robert W. Steere | Associate | School Law
CAPEHART || SCATCHARD
A T T O R N E Y S A T L A W
New Jersey - Pennsylvania - New York
8000 Midlantic Dr, Ste 300S
Post Office Box 5016
Mount Laurel, NJ 08054
[1][email address]
856-234-6800 Phone
856-477-8505 Direct
856-235-2786 Fax
[2]Web | [3]Bio
Confidentiality Note: This transmission is intended only for the
addressee, and may contain privileged and/or confidential information from
the law firm of Capehart & Scatchard, P.A. If you are not the intended
recipient, please do not use, disseminate, or copy this material. If you
have received this transmission in error, please notify us immediately by
telephone, return this transmission, and delete or destroy any copies.
References
Visible links
1. mailto:[email address]
2. http://www.capehart.com/
3. file:///tmp/
Dear Sir/Madam,
As you are aware, this office serves as the Solicitor for the Collingswood
Board of Education. On behalf of Beth Ann Coleman, the Custodian of
Records, I am responding to your October 13, 2025, OPRA request for the
following information:
1: emails related to an ethics violation/complaint to or from the
following Board Members Meghan Mikulski, Regan Kaiden, Christine Sheridan
Celia, Roger Chu, Mary Saverino, Matthew Craig, Richard Taibi, Kelly Maia,
Kate Seltzer, Sarah Sherman, or Christopher Dilkus as well as District
staff Superintendent Fredrick H. McDowell or Business Administrator Beth
Ann Coleman.
Answer: See the attached emails responsive to your request. Several of the
emails responsive to this request are exempt from disclosure due to
attorney-client privilege. See N.J.S.A. 47:1A-1.1. Please see the attached
privilege log listing the emails subject to the privilege that have been
withheld. Further, portions of documents which disclose the social
security number, date of birth, personal email address, telephone number,
or home address are exempt from disclosure. See N.J.S.A. 47:1A-1.1.
2: any ethics complaints filed against Board Member Meghan Mikulski since
September 1, 2024.
Answer: See the attached ethics complaint filed against Meghan Mikulski.
Portions of the complaint have been redacted to protect against disclosure
of protected personal information.
3: any “invoices” or “receipts” related to any payment of District funds
for legal services related to any ethics complaints filed against Ms.
Mikulski from September 1, 2024, to October 13, 2025.
Answer: This office partially responded to this request by way of email on
October 30, 2025. By way of further response, see the attached invoices.
See attorney client privilege exemption above.
Thank you,
Robert W. Steere
Robert W. Steere | Associate | School Law
CAPEHART || SCATCHARD
A T T O R N E Y S A T L A W
New Jersey - Pennsylvania - New York
8000 Midlantic Dr, Ste 300S
Post Office Box 5016
Mount Laurel, NJ 08054
[1][email address]
856-234-6800 Phone
856-477-8505 Direct
856-235-2786 Fax
[2]Web | [3]Bio
Confidentiality Note: This transmission is intended only for the
addressee, and may contain privileged and/or confidential information from
the law firm of Capehart & Scatchard, P.A. If you are not the intended
recipient, please do not use, disseminate, or copy this material. If you
have received this transmission in error, please notify us immediately by
telephone, return this transmission, and delete or destroy any copies.
References
Visible links
1. mailto:[email address]
2. http://www.capehart.com/
3. file:///tmp/
Collingswood Resident left an annotation ()
Please post the results publicly on this page as well. Thank you!