Dear North Bergen Township,

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.

Records requested:

RECORDS REQUESTED
1. Complete existing redacted and public-release copy of amended filing of Notice of Tort Claim and Supplemental Narrative in Support of Notice of Tort Claim filed on March 25, 2026.

This 155-page record was submitted by Captain Jorge Sestan-Raposo and acknowledged as received by the Township on March 25, 2026. This record was then forwarded to the Joint Insurance Fund. The Township of North Bergen created an identical document with appropriate redactions and approved its release. This was done so under the legal guidance of Attorney Kirstin Bohn, an attorney working under the auspices of Chasan Lamparello Mallon and Casppuzzo and functions as the Township’s subject-matter specialist for OPRA and right to know related matters. Bohn approved or authorized the release of the document after 10-15 redactions were made, a Vaughn Index was generated, bates numbering was created, and Bohn reviewed it in its entirety prior to approving it for release. The fact Township Attorney Thomas Kobin and Police Commissioner Allen Pascual illegally refused to release the document, the public has a right to inspect is of no substance. The moment the Township of North Bergen made, maintained and kept the document on file during official business as the Township of North Bergen, it’s a record that must be released and I can guarantee with confidence on appeal the Government Records Council will such document must be released.

SCOPE OF THE REQUEST

This request seeks one specifically identified, existing records. It does not ask the custodian to investigate the truth of the allegations, answer interrogatories, create a chronology, or compile information from unrelated files.
This submission of request does not duplicate a pending request. This is a request for the public-release copy. It materially clarifies and narrows the requested records, and it also asserts an independent common-law basis for access.

OPRA BASIS FOR ACCESS

The requested amended filing and receipt exchange were received and maintained by the Township during its official claims-handling functions. They therefore fall within OPRA’s definition of a government record.
This request seeks the claimant-submitted filing that was redacted and approved for public release.

INDEPENDENT COMMON-LAW RIGHT OF ACCESS

The same record is independently requested under New Jersey’s common-law right of access.
The amended filing is a writing filed with and maintained by a public office as the memorial of an official claim’s submission and its receipt. Both the requester’s legally recognized interest and the public interest substantially favor access. See N.J.S.A. 47:1A-8 and Loigman v. Kimmelman, 102 N.J. 98, 104–05, 112–13 (1986).
Even records exempt from disclosure under OPRA may remain subject to fact-sensitive common-law balancing. See Rivera v. Union County Prosecutor’s Office, 250 N.J. 124, 143–48 (2022).

SUBSTANTIAL PUBLIC-OVERSIGHT INTEREST

The amended filing that was redacted and prepared for public release, memorializes allegations concerning senior municipal and police officials, political-fundraising pressure, the integrity of official police reports and work records, the administration of Internal Affairs, the preservation and evaluation of evidence, alleged retaliation and discriminatory or hostile treatment of Hispanic employees, and the independence and consistency of the Township’s legal and public-records functions.

WHY THE BALANCE FAVORS A REDACTED RELEASE

The request is confined to one claimant-authored filing, that is a already-existing public release copy approved by Ms. Bohn after approximately 10-15 redactions were made to protect concrete confidentiality interests and personnel records while preserving the record’s substantial public-accountability value.

PRIOR PROCESSING AND CONSISTENCY

The requester is aware based on previous releases involving previous officers (Alex Guzman, Michael Derin Jr., Michael Derin, Christopher Bowen, and Rasheed Siyam), the Township releases these records regardless of its contents. In those tort-claim filings, the Township released them after targeted redactions. Any legitimate confidentiality concerns in this document was already addressed with the appropriate redactions, which is the practice of the Township of North Bergen.

REQUESTED PRODUCTION AND RESPONSE

1. Please produce the responsive records in their existing native electronic format or as a complete, searchable PDF preserving the original page and attachment order. Delivery may only be through the OPRA Machine portal. Since the record already exists I don’t authorize any costs.

ATTRIBUTION AND STATUS OF THE ALLEGATIONS

The matters summarized below are allegations asserted in the amended filing or identified related submissions.
They are summarized solely to explain the public interest in access. They are not presented as adjudicated findings, and the records custodian is not being asked to determine their truth.

1. Political-fundraising pressure and alleged search for a recording device

The filing alleges retired Deputy Chief William D. Lyons pressured the claimant to purchase Mayor’s Ball tickets and imposed a deadline while on duty and within Township of North Bergen property used for day-to-day operation of the police department to facilitate the sale of politically motivated events. When claimant sought relief as a whistle blower, and reported this to retired Deputy Chief Gerald Sanzari, Sanzari responded in conducting a strip search of claimant for recording devices. This request seeks the claimant’s formal account of those allegations, not an investigative file.

2. Integrity of an official police memorandum and preservation of evidence

The filing describes a 2022 incident in which Lieutenant Edgar Mendez was directed and/or ordered by retired Deputy Chief David Corbisiero to allegedly direct Detective Christopher Orellana to add events on to an official police document that Deputy Chief knowingly had information it did not occur in an attempted coup to falsify an investigation on Captain Raposo after the original report was destroyed and two other submissions were also destroyed and captured on CCTV recordings. When Orellana provided Internal Affairs a statement regarding this alleged criminal conduct, Deputy Chief Corbisiero destroyed the report and allowed the CCTV recordings to over-write themselves, while publicly placing the blame on Lieutenant Mendez. I’m no attorney but I’m sure Lieutenant Mendez and Orellana can testify to this in a deposition or other legal proceeding.

3. Alleged misuse of Internal Affairs in 2026 and disputed attribution

The filing alleges retired Deputy Chief David Corbisiero initiated a meritless Internal Affairs matter on or about January 5, 2026, against Captain Raposo while simultaneously attempted to attribute the initiation of the complaint to Sergeant Indira Cabrera. Lieutenant Hernandez also attempted to shift blame away from Deputy Chief Corbisiero and on to the “sergeant.” Deputy Chief Corbisiero as commander of the internal affairs unit, also worked with members of the internal affairs unit to secretly terminate the investigation as he did in 2022 and avoid being exposed. When Deputy Chief Corbisiero believed he was being discovered for the falsely initiated investigation based on manipulated data, he tried to place the blame on Chief Farley and Captain Victor Queiro, while in the presence of Captain David Dowd and Captain Nicholas Galliano, not understanding Chief Farley, Captain Victor Queiro and Captain Raposo were already communicating and working together to expose Deputy Chief David Corbisiero’s misconduct. I’m sure you the recordings of the meeting when Deputy Chief David Corbisiero, Captain David Dowd, Captain Nicholas Galliano all vouched for Deputy Chief Corbisiero against Chief Farley to Captain Raposo.

It also alleges inconsistent accounts by Lieutenant Santiago Hernandez and relevant knowledge within the police command structure indicating a personnel order identifying Deputy Chief Corbisiero as commander of the Internal Affairs function for the North Bergen Police Department after Deputy Chief Corbisiero himself had a long history of hostile work environment complaints filed and sustained against him by Hispanic officers.

Corbisiero’s publicly reported retirement date was March 1, 2026. A proper inference should be made, Deputy Chief David Corbisiero retired within 7 work days after he learned by the “broker” Eric Weyand and two meetings at the school with Police Commissioner Allen Pascual the evidence against him was overwhelming and he should immediately retire before Deputy Chief Corbisiero risked losing his pension.

4. Internal Affairs structure, equal treatment, and supervisory accountability

As stated, the filing alleges hostile or discriminatory treatment affecting Hispanic members of the Police Department, including Sergeant Indira Cabrera.

It questions the February 2, 2024, assignment made through Personnel Order 24-022, placing Corbisiero over an Internal Affairs unit identified as including Lieutenant Santiago Hernandez, then-Sergeant Gleny Henry, and then-Investigator Eric Weyand.

The filing raises related questions concerning supervisory accountability and the administration of the Internal Affairs function.

5. Integrity of official records following notice of anticipated litigation

The filing and a related April 19, 2026, submission allege that workday or timekeeping records were changed following notice of anticipated litigation. These are the same allegations made by Alex Guzman and Michael Derin Jr in the filing of the lawsuit about a week ago.

6. Municipal legal advice, independence, and public-records administration

Related materials allege non-neutral decision-making by Township Attorney Thomas R. Kobin, including advice concerning Assemblyman Larry Wainstein’s activities at Township housing properties in the Township’s agenda to interfere or interrupt his ability meet with his constituents and offer services.

7. Public interest served by disclosure

The subject matter concerns senior public officials, the administration of Internal Affairs, the integrity of official records, alleged political pressure, discrimination and retaliation, and taxpayer-funded legal and OPRA administration.
Since the document has already been properly redacted, its release would allow the public to evaluate what was formally alleged and received by the Township while protecting legitimate confidential interests.

Yours faithfully,

Alicia Raposo