Dear Records Custodian,

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-5(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.

I am writing to formally request access to the following Internal Affairs records concerning Chief Joshua M. Moline of the Woodbury Heights Police Department, pursuant to the common law right of access to public records:

• Internal Affairs Report: The comprehensive document detailing the investigation into the alleged misconduct.

• Internal Affairs Synopsis: A summary outlining the key findings and conclusions of the investigation.

• Internal Affairs Findings: The official determinations regarding the allegations and any recommendations for disciplinary action.

Legal Basis for Disclosure:
The New Jersey Supreme Court, in Rivera v. Union County Prosecutor’s Office, 250 N.J. 124 (2022), established that while Internal Affairs records are exempt from disclosure under the Open Public Records Act (OPRA), they may be accessible under the common law right of access when the public’s interest in disclosure outweighs the need for confidentiality.

The Court outlined several factors to consider in this balancing test:

1. Nature and Seriousness of the Misconduct: Allegations of aggravated assault, particularly involving domestic violence, are grave and raise profound concerns about the conduct of a law enforcement leader.

2. Whether the Misconduct Was Substantiated: Information regarding the outcome of the internal investigation is essential to assess the validity of the allegations and the appropriateness of any actions taken.

3. Discipline Imposed: Understanding any disciplinary measures enforced provides insight into the accountability mechanisms within the department.

4. Nature of the Official’s Position: As Chief of Police, Chief Moline holds a position of significant authority and public trust, amplifying the public’s interest in his conduct.

5. Public Interest in Disclosure: Transparency in this matter is crucial to uphold public confidence in law enforcement and ensure that any misconduct is appropriately addressed.

Applying these factors, the public’s interest in disclosure is compelling. The allegations involve serious misconduct by a high-ranking official, and transparency is essential to maintain trust in law enforcement.

Request:
I respectfully request the release of the aforementioned Internal Affairs records concerning Chief Joshua M. Moline, with appropriate redactions to protect personal privacy where necessary. This disclosure will serve the public interest by promoting transparency and accountability within our law enforcement agencies.

Thank you for your attention to this matter. I look forward to your prompt response.

Dear Gloucester County Prosecutor's Office,

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

I am writing to request an internal review of Gloucester County Prosecutor's Office's handling of my OPRA request 'Chief Moline IA Report'.

AS OF 04/26/2025, NO RESPONSE has been received from this Office since an out of office notice. Please acknowledge this request.

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

Yours faithfully,

fratlaw