Dear Records Custodian,

Statutory Request
This is a request for government records under the New Jersey Open Public Records Act (OPRA), N.J.S.A. 47:1A-1 et seq., as amended effective September 3, 2024. This request seeks access to existing records only and does not require the creation of new documents. If access is denied in whole or in part, please identify the specific statutory exemption for each withholding and produce all reasonably segregable non-exempt portions.

Records Requested
Please provide existing structured records maintained by the Monmouth County Municipal Joint Insurance Fund concerning the Borough of Matawan for the period January 1, 2017 through the date the search is conducted, limited to the following records or database fields as they exist.

1. Lawsuit and litigation claim identifiers
Loss runs, claim runs, or claims system exports identifying lawsuits or litigation claims involving the Borough of Matawan, including the following fields to the extent they exist:

* Claim or matter name
* Claim number
* Coverage line
* Court or venue
* Docket number
* Date opened
* Current status
* Date closed or disposition field

2. Financial fields tied to lawsuits and litigation claims
For each lawsuit or litigation claim involving Matawan:

* Indemnity payment amounts and payment dates
* Defense or expense payment amounts and payment dates
* Total paid fields
* Indemnity reserve, expense reserve, and total reserve fields
* Reserve history or reserve change fields with dates, if maintained
* Settlement amount fields and settlement payment dates, if maintained
* Subrogation or recovery amount fields and recovery dates, if maintained

3. Deductible and retention fields
For each lawsuit or litigation claim involving Matawan:

* Deductible, self-insured retention, or retention amount fields
* Fields reflecting whether a deductible or retention was applied or billed

4. Premium, rate, and assessment records for Matawan
Structured records or billing system exports reflecting:

* Annual premiums or contributions billed to the Borough of Matawan
* Experience rating, loss-sensitive, or similar rating factor fields used for Matawan
* Assessments, supplemental bills, or extraordinary assessments billed to Matawan
* Credits, dividends, return premiums, or refunds issued to Matawan

5. Deductible and retention schedules by coverage year
Schedules or structured records identifying deductible or self-insured retention amounts applicable to the Borough of Matawan by coverage year, including any increases reflected in the record.

Scope and Format
If responsive information is maintained in a claims, finance, or underwriting database, please produce a direct export of the responsive fields in a reasonably usable electronic format such as CSV or XLSX. This request is limited to records as maintained and does not request narrative summaries, analysis, or the creation of new compilations.

Redactions and Segregability
If any portion of a record is exempt from disclosure, please redact only the exempt portion and produce the remainder. For each redaction or withholding, please identify the specific OPRA exemption relied upon.

Response Deadline and Deemed Denial
OPRA requires a response within seven business days of receipt. Failure to grant access or properly request a lawful extension within that period constitutes a deemed denial.

Fees and Delivery
Please provide records electronically by email or secure download link. If a special service charge is asserted, please provide an itemized explanation in advance.

Rolling Production
If records are voluminous, please produce them on a rolling basis as they become available.

United States Citizen Rights
The requester is a citizen of the United States exercising civil rights under state and federal law, including the right to petition government and equal treatment. No rights are waived. OPRA does not require state or local residency.

Requester Certification
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 records for a commercial purpose.
I am not seeking records in connection with a legal proceeding.

Thank you,

John Certo

Mr. Stokes,

I acknowledge receipt on January 5, 2026 of your notice extending the response date for my OPRA request submitted on December 23, 2025 to close of business on January 23, 2026, based solely on the statement that there is a voluminous number of documents.

Under N.J.S.A. 47:1A-5(i), access to government records must be granted or denied as soon as possible, but not later than seven business days. While I understand that a larger number of responsive records may require additional time for search and review, the characterization of the request as “voluminous” does not, by itself, justify withholding records that are already identified and non privileged, nor does it relieve the custodian of the duty to provide access as records become reasonably available.

I do not affirmatively consent to a blanket month long extension and I do not waive any right to contest delay. However, I will not at this time object further to the revised date provided that responsive, non privileged records are produced on a rolling basis as they are located and reviewed, rather than withheld for a single production at the end of the extension period, and that only the time reasonably necessary to complete that process is taken.

In particular, to the extent there are readily identifiable, non privileged records associated with litigation that concluded during the fourth quarter of 2025, such as fully executed settlement agreements and final filed court documents, I request that those records be produced promptly and not delayed until January 23, 2026.

For any records ultimately withheld in whole or in part, please identify each record withheld, state the specific legal basis for the denial in accordance with N.J.S.A. 47:1A-5(g), and provide redacted copies where only portions of a record are claimed to be privileged or exempt. If no responsive records exist for any portion of my request, please provide a certification of non existence that describes the searches conducted and the locations checked.

All of my rights under N.J.S.A. 47:1A-1 et seq. are expressly reserved.

Thank you for your attention to this request.

John Certo

Dear Records Custodian Stokes,

As of today, no records have been produced in response to my OPRA request dated December 23, 2025.

In your January 5, 2026 correspondence, you asserted an extension based on volume. In my January 6, 2026 response, I expressly did not consent to a blanket extension and accepted the revised date only on the condition that responsive, non-exempt records be produced on a rolling basis as they became reasonably available.

No rolling production has occurred.

Under N.J.S.A. 47:1A-5(i), access to government records must be granted as soon as possible. The complete absence of production during an asserted extension period constitutes a denial of access. Accordingly, the request is now deemed denied.

This correspondence serves as formal notice that I will proceed with enforcement. All rights under N.J.S.A. 47:1A-1 et seq. are expressly reserved.

United States Citizen Rights
The requester is a citizen of the United States exercising civil rights under state and federal law, including the right to petition government and equal treatment. No rights are waived. OPRA does not require state or local residency.

Requester Certification
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 records for a commercial purpose.
I am not seeking records in connection with a legal proceeding.

Sincerely,

John Certo

Mr. Stokes,

Thank you for the response and the attachments. It will take me time to review all the attachments due to my admission to NY-Presbyterian/Weill Cornell Medical Center on January 22, 2026. Unfortunately I do not have a discharge date.

Regards,

John Certo