Dear Clark Township,

This is a request for public records made under OPRA and the common law right of access. I am not required to fill out an official form. Please acknowledge receipt of this message.
Records requested:

- All invoices submitted by the law firm of Triarsi, Betancourt, Wukovits and Dugan for billing purposes to the Township of Clark from 4/15/20 to date, for all services rendered to the Township of Clark, its officials, employees and others in reference to Antonio Manata or his attorney;
- All of the Township's Purchases Orders in reference to the above mentioned billing records.
Yours faithfully.

Thank you

C.T.C

Dear Miriam Stone,

I am seeking the following clarifications on the response your office provided:

- Please confirm all the redacted information from the provided documents does not pertain to services provided and billed by Triarsi, Betancourt, Wokovits and Dugan law firm to the Township of Clark in reference to Antonio Manata
- Please confirm the Township of Clark is not in possession of any invoices received from Triarsi, Betancourt, Wokovits and Dugan law firm for any services in reference to Antonio Manata between 4/15/20 and 10/18/21, with the exception of one event dated 7/14/21,

Yours sincerely,

C.T.C

Dear Mr. Varady

We received your response letter dated 7/1/22 but unfortunately it only addressed one of the two clarification requests. The clarification not addressed is the following:

- Please confirm the Township of Clark is not in possession of any invoices received from Triarsi, Betancourt, Wukovits and Dugan law firm for any services in reference to Antonio Manata between 4/15/20 and 10/18/21, with the exception of one event dated 7/14/22

We would like to give the Township of Clark another opportunity to be fully transparent and compliant with the OPRA. We are in possession of records provided by other government agencies that show the TWBD law firm was involved in numerous other instances while representing the Township of Clark and its employees. Those instances all involve or are related to Antonio Manata, but they are not listed in the records of billing invoices the Township of Clark previously released as part of our original request. We doubt very much the TBWD law firm did not bill the Township of Clark for those numerous interactions since, based on other previously released billing records, that firm bills for simpler tasks, such as reading emails.

We would like to believe the Township of Clark wishes to be fully transparent and possibly forgot about or overlooked the rest of the invoices, which we are asking to be released without delay. We know we do not have to remind you that the Township of Clark, with your legal representation, recently settled two matters in Superior Court for improperly refusing to release and improperly redacting public records. The failure to release to remainder of the records will result in our legal team filing another complaint in Superior Court and again showing how the Township of Clark refuses access to public records.

I would also like to take this opportunity to address the comment in your letter, specifically "IF YOU HAVE ANY QUESTIONS, PLEASE RESPOND DIRECTLY TO ME..." Let me start by stating the use of CAPS, as if you were "yelling" or giving me orders, is unnecessary and very unprofessional or you. I must tell you that I do not work for you and do not have to follow any orders you decide to give me. My responsibility is to file the OPRA requests to the Custodian of Records, who, as per the Government Records Council, "in a municipal government, the custodian will be the municipal clerk". By the Township of Clark hiring your law firm to review all the OPRA requests and the records prior to being released, it only changes the Township's procedures and not my responsibility on who to submit my requests to and who to respond to. If you wish to be responded to directly, then you should email me directly instead of doing so thru your paralegal. Since I am obtaining the responses from Ms. Stone, that is who I am obligated to respond to.

Since you are contracted and being paid by a public entity, you are a public official and must act accordingly. I suggest you make yourself familiar with the Township of Clark's Employee Manual, which is also for contracted parties, which you should of acknowledged receiving a copy of.

Yours sincerely,

C.T.C