Dear Records Custodian Wendy Fullem / College Counsel Katharine Fina

Pursuant to the New Jersey Open Public Records Act, N.J.S.A. 47:1A-1 et seq., and the common-law right of access, I respectfully request copies of the following government records maintained by Sussex County Community College concerning the College’s accreditation review by the Middle States Commission on Higher Education (“MSCHE”), including any Self-Study, Supplemental Information Report, follow-up response, Verification of Compliance submission, or related response submitted to MSCHE or MSCHE evaluators.
For purposes of this request, “MSCHE” includes the Middle States Commission on Higher Education, its staff, peer evaluators, evaluation team members, Commission representatives, legal/regulatory staff, and any individual or entity acting on MSCHE’s behalf.

For purposes of this request, the “August 2023 bomb-threat incident” means the incident occurring on or about August 22–23, 2023 involving a bomb threat and/or threats to kill or harm a Sussex County Community College employee, campus evacuation, campus lockdown or closure, delayed opening, emergency alerts, law-enforcement search or response, and/or the apprehension or arrest of former SCCC student Karl Taguinod.

Please produce the following records:

1. All records, submissions, exhibits, charts, attachments, PDFs, appendices, narratives, tables, spreadsheets, or supporting materials submitted by SCCC to MSCHE that mention, reference, describe, summarize, classify, report, omit after internal discussion, or otherwise concern the August 2023 bomb-threat incident.

2. All records reflecting whether SCCC disclosed, reported, summarized, categorized, or included the August 2023 bomb-threat incident in any MSCHE Self-Study, Supplemental Information Report, SIR response, Verification of Compliance response, Standard II response, Standard VII response, institutional complaint chart, student-complaint chart, faculty/staff-complaint chart, safety/security response, campus-security response, or follow-up response.

3. All records reflecting any decision, discussion, instruction, recommendation, draft, revision, approval, or internal communication concerning whether the August 2023 bomb-threat incident should be included in, excluded from, summarized in, or omitted from any materials submitted to MSCHE.

4. All versions, drafts, redlines, tracked-change documents, internal working copies, final copies, and submitted copies of any MSCHE response, SIR response, self-study material, follow-up response, complaint chart, Verification of Compliance material, Standard II material, or Standard VII material that includes or should reasonably have included institutional complaint, campus safety, security, threat, emergency-response, student-conduct, or law-enforcement-related records from August 2023.

5. All institutional complaint charts, student-complaint charts, faculty/staff-complaint charts, complaint logs, complaint summaries, complaint spreadsheets, or complaint-response materials submitted to MSCHE from January 1, 2025 to the present, including but not limited to any materials prepared in response to MSCHE follow-up questions dated March 5, 2026.

6. All records identifying the source data, offices, custodians, departments, personnel, databases, folders, email accounts, or record repositories searched or consulted by SCCC when preparing any complaint chart, complaint log, safety/security response, or institutional-integrity response submitted to MSCHE.

7. All communications between SCCC and MSCHE from January 1, 2025 to the present concerning institutional complaints, student complaints, faculty complaints, staff complaints, campus safety, campus security, threat assessment, emergency response, Clery Act reporting, police involvement, law-enforcement response, Standard II, Standard VII, Verification of Compliance, or the August 2023 bomb-threat incident.

8. All communications among SCCC administrators, trustees, employees, consultants, counsel, accreditation liaisons, or outside reviewers from January 1, 2025 to the present concerning whether the August 2023 bomb-threat incident was required to be disclosed to MSCHE.

9. All records submitted to MSCHE concerning SCCC’s August 22–23, 2023 campus evacuation, lockdown, delayed opening, closure, emergency alerts, Rave alerts, campus-safety response, law-enforcement coordination, police reports, criminal complaints, or public statements related to the August 2023 bomb-threat incident.

10. All records reflecting SCCC’s internal classification of the August 2023 bomb-threat incident for accreditation, complaint, student-conduct, campus-security, Clery Act, safety, emergency-management, risk-management, insurance, or Board-reporting purposes.

11. All records reflecting whether the August 2023 bomb-threat incident was included in or excluded from any record set, packet, upload, portal submission, exhibit binder, document index, evidence inventory, or accreditation file provided to MSCHE or made available to the MSCHE evaluation team.

12. All document indexes, evidence inventories, upload logs, portal-submission logs, file lists, SharePoint folders, Google Drive folders, Box folders, OneDrive folders, accreditation-room indexes, or similar records showing the materials SCCC uploaded, transmitted, or made available to MSCHE or its evaluation team in connection with the 2025–2026 accreditation review.

13. All records identifying the SCCC personnel responsible for preparing, reviewing, approving, uploading, certifying, or transmitting SCCC’s MSCHE submissions, including any submissions addressing Standard II, Standard VII, Verification of Compliance, institutional complaints, student complaints, faculty/staff complaints, campus safety, or campus security.

14. All records, communications, or attachments concerning MSCHE’s March 2026 follow-up questions to SCCC, including the request for records of student complaints and faculty/staff complaints, the College’s response, and all supporting materials used to prepare that response.

15. All records reflecting whether SCCC treated the August 2023 bomb-threat incident as a student complaint, employee complaint, campus-safety complaint, threat report, disciplinary matter, law-enforcement matter, conduct matter, institutional complaint, or non-complaint for purposes of MSCHE reporting.

16. All records, communications, notes, meeting minutes, memoranda, or drafts concerning the omission, non-inclusion, non-reporting, or non-disclosure of the August 2023 bomb-threat incident from any MSCHE complaint chart, complaint log, self-study response, SIR response, follow-up response, or evidence submission.

17. All communications between SCCC and any outside counsel, consultant, accreditation consultant, risk manager, insurance representative, public-relations advisor, or county official concerning whether or how to disclose the August 2023 bomb-threat incident to MSCHE.

18. All Board of Trustees materials, committee materials, administrative memoranda, cabinet notes, President’s Office records, campus-safety records, or accreditation-team records from August 22, 2023 to the present concerning the August 2023 bomb-threat incident and its relevance to MSCHE accreditation, institutional complaints, campus security, emergency management, or institutional integrity.

19. All records showing any SCCC public statement, Facebook post, website post, press release, media response, parent/student notice, employee notice, or emergency alert concerning the August 2023 bomb-threat incident that was submitted to, withheld from, considered for submission to, or discussed in connection with MSCHE.

20. All records reflecting any certification, attestation, assurance, transmittal letter, cover letter, or representation made by SCCC to MSCHE concerning the completeness, accuracy, truthfulness, or reliability of the College’s self-study, SIR response, follow-up response, complaint charts, or evidence submissions.

The date range for this request is August 22, 2023 through the present, unless a narrower date range is expressly stated above.

Please search, at minimum, the records of the following offices, personnel, and repositories, to the extent records are maintained there:

Office of the President;
President Dr. Cory Homer;
former President Jon Connolly;
Board of Trustees records;
Board Chair and Trustee communications concerning MSCHE;
Office of Institutional Effectiveness / Accreditation;
MSCHE accreditation liaison or self-study co-chairs;
Student Affairs;
Human Resources;
Campus Safety and Security;
Dean of Students / student-conduct records;
Communications / public-relations office;
Information Technology records concerning accreditation uploads or document portals;
records custodian Wendy Fullem;
any SCCC email accounts, shared drives, SharePoint sites, OneDrive folders, Google Drive folders, Box folders, accreditation portals, document indexes, or evidence rooms used for MSCHE submissions.

This request includes emails and attachments. Please include communications sent to, from, copied to, or blind-copied to SCCC employees, trustees, MSCHE personnel, consultants, counsel, or outside advisors where responsive records are maintained by SCCC.
Suggested search terms include, but are not limited to:

“bomb threat”; “bomb”; “threat”; “threats to kill”; “kill”; “Karl Taguinod”; “Taguinod”; “Sparta”; “evacuation”; “lockdown”; “campus closure”; “delayed opening”; “Morris County Jail”; “terroristic threats”; “law enforcement”; “police”; “campus safety”; “campus security”; “emergency alert”; “Rave”; “August 22”; “August 23”; “MSCHE”; “Middle States”; “SIR”; “Supplemental Information Report”; “Self-Study”; “Standard II”; “Standard VII”; “Verification of Compliance”; “complaint chart”; “student complaints”; “faculty complaints”; “staff complaints”; “institutional complaints”; “follow-up questions”; and “March 5, 2026.”

I request that responsive records be produced electronically by email or secure download link in their native electronic format where available, including metadata where reasonably maintained. For spreadsheets, please provide the native spreadsheet format rather than a flattened PDF where possible.

If any portion of a responsive record is claimed to be exempt, please redact only the exempt portion and produce the remainder. For each withheld or redacted record, please provide a privilege log or denial index identifying the record, date, author, recipient, general subject matter, statutory basis for withholding, and an explanation sufficient to permit review of the claimed exemption.

This request is not limited to records physically stored in one office. It includes all responsive government records made, maintained, kept on file, or received in the course of official business by SCCC, regardless of whether located in email, cloud storage, accreditation portals, shared drives, local drives, archived folders, or paper files.

If SCCC contends that any portion of this request is unclear, overbroad, or requires clarification, please identify the specific portion at issue and produce all reasonably identifiable responsive records not subject to that objection.

For purposes of the common-law right of access, the public interest in disclosure is substantial. These records concern a public community college’s representations to its federally recognized accreditor regarding campus safety, institutional complaints, emergency response, institutional integrity, and the completeness of accreditation materials submitted in connection with continued accreditation and public funding eligibility.

I am not seeking records for a commercial purpose.

Thank you.

Very truly yours,
Harry Lagner.

Dear Sussex County Community College,

Please pass this on to the person who conducts Open Public Records Act reviews.

I am writing to request an internal review of Sussex County Community College's handling of my OPRA request 'August 22–23, 2023 Bomb-Threat Reporting to MSCHE / Response Records'.

A full history of my OPRA request and all correspondence is available on the Internet at this address: https://opramachine.com/request/august_2...

Yours faithfully,
Harry Langer Esq

Good morning Wendy,

Please issue an update on my latest request.

Dear Wendy Fullem,

Per law, today would be the last day to respond to my recent OPRA request. Please issue an update today when available.

A full history of my OPRA request and all correspondence is available on the Internet at this address: https://opramachine.com/request/opra_req...

Yours faithfully,
Harry Langer Esq

Dear Ms. Fullem:

I write to respectfully request an update concerning the above-referenced OPRA request, which SCCC acknowledged on May 21, 2026, and for which the College stated that it anticipated providing a further response on or before June 19, 2026.

After reviewing SCCC’s prior production of more than 3,000 pages of MSCHE-related materials, it appears that the College did not include the August 22–23, 2023 bomb-threat incident in the responsive accreditation materials previously produced. That omission is difficult to reconcile with the public record. The incident was not obscure, private, or speculative; it involved a campus threat, law-enforcement response, closure/delayed-opening issues, and public-facing institutional statements.

It is also my understanding that the public link through which those materials were previously accessible was later deleted or disabled. That is, of course, SCCC’s choice. But the underlying materials, correspondence, and public-record history remain publicly available through OPRAmachine and other public sources. In other words, the disappearing-link approach does not make the underlying record disappear.

Given the subject matter of this request, I remain concerned that Sussex County Community College is not operating with the level of candor, transparency, and institutional honesty required of a public college—particularly where the records concern the College’s representations to the Middle States Commission on Higher Education regarding campus safety, institutional complaints, emergency response, and accreditation-related disclosures.

Those concerns have been referred to Middle States for its awareness and review. The request seeks records directly relevant to whether SCCC fully and accurately disclosed the August 22–23, 2023 bomb-threat incident and related institutional-integrity issues in connection with its MSCHE accreditation materials.

Please provide an update on the status of the College’s review, including whether SCCC still expects to provide its further response on or before June 19, 2026. If the College anticipates any additional delay, please identify the reason for that delay, the categories of records already located, and the date by which production will be made.

Nothing in this correspondence should be construed as narrowing, withdrawing, or modifying the pending OPRA and common-law request.

Very truly yours,

Harry Langer Esq.

Dear Sussex County Community College,

Please pass this on to the person who conducts Open Public Records Act reviews.

I am writing to request an internal review of Sussex County Community College's handling of my OPRA request 'August 22–23, 2023 Bomb-Threat Reporting to MSCHE / Response Records'.

A full history of my OPRA request and all correspondence is available on the Internet at this address: https://opramachine.com/request/august_2...

Yours faithfully,
Harry Langer Esq.

Date: June 8, 2026

VIA EMAIL AND CERTIFIED MAIL
Wendy Fullem, Records Custodian
Sussex County Community College
1 College Hill Road
Newton, NJ 07860

Re: Follow-Up OPRA & Common-Law Request – August 22–23, 2023 Bomb-Threat Incident (Karl Taguinod) – Production of MSCHE-Related Records

CC (for informational purposes):
Katharine Fina, Esq., College Counsel
President Dr. Cory Homer
New Jersey Government Records Council

Dear Ms. Fullem,

This formal letter follows your June 3, 2026 response to my May 12, 2026 OPRA request. In that response, you denied 18 of 20 categories as “overly broad” and produced only routine complaint logs that conspicuously omit any reference to the August 22–23, 2023 bomb-threat incident involving former student Karl Taguinod.

I now write with newly obtained, publicly available evidence confirming the seriousness of that incident, and to demand that Sussex County Community College (“SCCC”) immediately produce all responsive records—or, if none exist, provide a sworn certification explaining why.

I. New Evidence Confirms the Bomb-Threat Incident Was Real, Violent, and Led to a Campus Evacuation & Lockdown

Internal criminal records obtained from the Sussex County Prosecutor’s Office (maintained on file as Exhibit A) confirm the following:

Criminal complaint (2023-000124) signed by PTL. S. Shawger on August 23, 2023, charging Karl Taguinod with:

False public alarm (N.J.S.A. 2C:33-3a(1)(a))
Threatening arson to cause evacuation (N.J.S.A. 2C:12-3a)
Terroristic threats to kill (N.J.S.A. 2C:12-3b)
Grand jury indictment (No. 24-01-00013-I) returned in 2024
2025 Mental Health Diversion Program agreement

Key facts from the complaint:

“Initiate or circulate a report or warning of an impending explosion knowing the report was false … likely to cause evacuation of a building … specifically by contacting a subject employed by Sussex County Community College, and making threats against security staff, stating that he would ‘blow them straight to heaven’ and stating that he was plotting for the same.”

“Threaten to commit arson with purpose to cause evacuation of a place of assembly, specifically Sussex County Community College … This caused the evacuation and lockdown of the SCCC campus.”

The defendant also sent a Snapchat video stating: “You and all your fucking pig ass, snitch ass, snake bitching homies will fucking die” and “death will be your last experience with me.”

The complaint explicitly confirms that the SCCC campus was evacuated and locked down, constituting a serious third-degree criminal event requiring law enforcement response.

II. The College’s June 3 Response Was Evasive and Incomplete

Your prior response:

Rejected most categories as “overly broad,” despite detailed search terms, custodians, and date ranges
Produced complaint logs containing no reference to:
Karl Taguinod
bomb threats
evacuation or lockdown events in August 2023
Provided no privilege log for withheld records
Failed to address the common-law right of access claim

The College cannot plausibly maintain that no records exist concerning whether a campus-wide bomb threat was disclosed to the Middle States Commission on Higher Education (“MSCHE”), particularly given accreditation obligations.

III. Narrowed Follow-Up Requests

To eliminate any claim of overbreadth, I hereby revise and narrow my request. Please produce the following records, or provide a privilege log identifying any withheld materials:

1. MSCHE Submissions Referencing Incident
All MSCHE Self-Study, SIR, Verification of Compliance submissions, or follow-up responses from August 22, 2023 to present referencing:
bomb threat
Karl Taguinod
false public alarm (2C:33-3)
threat to commit arson (2C:12-3a)
evacuation
lockdown

2. Safety or Complaint Summaries Submitted to MSCHE
Any document submitted to MSCHE summarizing:
student complaints
employee complaints
campus safety incidents
threat assessments
(covering August 1, 2023 – December 31, 2023)

3. SCCC–MSCHE Communications
All emails, portal submissions, and attachments from August 22, 2023 to present containing:
bomb threat
Karl Taguinod
evacuation
lockdown
false public alarm
2C:33-3

4. Internal Discussion of Disclosure
All internal SCCC records (emails, memos, minutes, Board materials) discussing whether the August 2023 incident should be disclosed to MSCHE.

5. Certification Regarding Disclosure
A sworn certification from the College President or Accreditation Liaison Officer stating:
whether the incident was disclosed to MSCHE
if not disclosed, the reason for omission

6. Privilege Log
For any withheld records:
date
author
recipient
subject
exemption claimed
IV. Legal Basis

Under OPRA (N.J.S.A. 47:1A-1 et seq.), records must be produced unless a specific exemption applies. Requests stated with reasonable clarity must be fulfilled.

See Keddie v. Rutgers, 148 N.J. 36 (1997) (common-law access balancing public interest). The public interest here includes campus safety and accreditation integrity.

A general claim of “overbreadth” does not justify refusal where specific search parameters are provided.

V. Demand and Deadline

Please provide all responsive records, a privilege log, or a lawful denial on or before June 19, 2026.
If you fail to comply, I will proceed with:

Filing a Denial of Access Complaint with the New Jersey Government Records Council (GRC)
Seeking relief in the Superior Court of New Jersey under N.J.S.A. 47:1A-6, including attorney’s fees
Referring the matter to MSCHE regarding potential nondisclosure in accreditation submissions
This letter does not waive any rights under the original May 12, 2026 request or applicable common-law claims.

Very truly yours,
Harry Langer Esq.