Dear Englishtown Borough,

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. This request is for invoices only at this time.

Records requested:

A. All invoices from the following lawyers who represented Englishtown Borough regarding "Francisco v. Cooke".

1. Plosia Cohen LLC and
2. Joseph D. Youssouf, Esq.

Date Range: January 1, 2021 to November 26, 2024

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.

We are also seeking any payments made from the Borough of Englishtown to the attorneys representing:

DANIEL FRANCISCO, ORI
KATZIN, and FIREARMS
POLICY COALITION, INC.,

Please provide the manner of payment and the party that paid the attorneys. For example: "Defendant Peter S. Cooke, Jr. in his official capacity as Chief of Police of the Borough of Englishtown Police shall pay to Plaintiffs' Counsel the amount of $3,000 pursuant to 42 U.S.C. § 1988 within 60 days hereof." Who provided the payment and when was it paid?

Yours faithfully,

Anonymous

Dear Englishtown Borough,

Sincere apologies for submitting this request prior to Thanksgiving! I understand these things may take some time -- we were not paying attention to the calendar.

It is totally understood these matter take time to research and make copies.

Please let me know your progress.

Happy Thanksgiving.

Yours faithfully,

Anonymous

Dear Englishtown Borough,

Hello -- Our Organization would like to know the status of this request. The legal bills should be easy to scan and post.

Please provide an update.

Yours faithfully,

Anonymous

Dear Englishtown Borough,

Our Organization wants to know why you have not responded to our repeated emails for the billing records pertaining to law suit filed by Daniel Francisco against Ex-Chief Peter S. Cooke of Englishtown.

Had we appeared at your office, you would have been required to produce them upon request.

We highly recommend you respond to this request or we will have to take legal action.

Yours faithfully,

Anonymous

Dear Englishtown Borough,

Could you please provide to me the requested records regarding "All Invoices From Plosia Cohen LLC and/or Joseph D. Youssouf, Esq. For "Francisco v. Cooke" Suit and any JIF Settlement.

Yours faithfully,

Anonymous

Dear Englishtown Borough,

I am still waiting on the legal bills I requested.

Please let me know why this is taking so long.

Yours faithfully,

Anonymous

Dear Clerk,

Thank you for sending the invoices. I noticed there were no invoices for 2021 through 2023. I should have clarified that.

-- Please go back to the files and pull "All Invoices From Plosia Cohen LLC and Joseph D. Youssouf, Esq. For "Francisco v. Cooke" Suit and JIF Settlement."

-- Could you please include the following dates: January 1, 2021 - February 1, 2025.

I am grateful for your assistance, as it was disclosed in August 2021 Daniel Francisco and ex-chief Cooke failed to inform the borough attorney of Englishtown and governing body of Francisco's suit that was filed through the Firearms Policy Coalition's (FPC).

- We do know Francisco tried to sue for damages, but a motion filed by Plosia Cohen LLC blocked Francisco's attempt. There are no pay-outs to look for in that area to look for at this time.

- We do know that Francisco's suit resulted in at least $5,000.00 in legal costs to Englishtown taxpayers from August 2021 to December 2022.

- It is unknown how much more Daniel Francisco's suit cost taxpayers between January 2023 - December 2024. We are estimating it could be at least another $5,000.00

- According to the final consent decree, ex-chief Peter S. Cooke, Jr. was ordered: "Defendant Peter S. Cooke, Jr. in his official capacity as Chief of Police of the Borough of Englishtown Police shall pay to Plaintiffs' Counsel the amount of $3,000 pursuant to 42 U.S.C. § 1988 within 60 days hereof."

- Here is the link to the final decree: https://assets.nationbuilder.com/firearm....

- Here is the exact page location ordering Cooke to pay $3,000.00: "Case 3:21-cv-14575-GC-DEA Document 62 Filed 07/11/24 Page 5 of 9 PageID: 165"

- The disbursement of the $3,000.00 payment remains unconfirmed. It is unclear whether if Cooke made the payment personally or if it was covered by Englishtown Borough and the JIF.. Clarification regarding the funding source is required. Confirmation cannot be sought from Cooke, as his arrest on charges of conspiracy, computer crime, and shoplifting resulted in the suspension without pay and access to his files.

If you cannot locate the records, please ask Daniel Francisco. Francisco publicly stated "It's not the town being sued, so I couldn't have described it that way. They aren't named, It's the decision of Chief Cooke in his capacity, and we are friends." Given nature of their friendship, Francisco likely possesses text message communications with Cooke which could clarify the financial transactions.

Thank you again for you assistance with this matter.

Yours sincerely,

Anonymous

Dear Clerk,

Thanks for the response. A couple of questions:

1) How do you accept payment?

2) Why can't the records be put into an excel file? You can then filter out anything that is marked "Francisco v. Cooke". Copy and paste the results into a new file. Save it. You're done. Total time: 15 minutes.

I don't need to see the actual billing statement -- I just need to see the totals. By the summer of 2022, the bills were at about $5,000.

Please let me know if this helps.

Yours sincerely,

Anonymous

Dear Clerk,

Our organization rejects your claim that there is attorney-client information in the invoices we are requesting.

We will file a complaint with the GRC.

Thank you assistance.

Yours sincerely,

Anonymous

Dear Clerk,

We have learned the primary Borough Clerk has resigned. Is anyone monitoring this account?

Yours sincerely,

Anonymous