To: Municipal Clerk, Mansfield Township

Dear Records Custodian:

Pursuant to the Open Public Records Act, N.J.S.A. 47:1A-1 et seq., I request access to and copies of the complete public record relating to the litigation matter identified as:

• Sosis v. Township of Mansfield Committee and Dena Hrebenak
• Claim No. KY21K2654751
• Any related insurance claim, defense file, appeal file, settlement file, or coverage file arising from that matter.

CERTIFICATIONS:

I HAVE NOT been convicted of any indictable offense under the l
aws 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.

REQUEST SPECIFICS & REASON FOR REQUEST:

I have compared the Township’s response to my September 16, 2022 OPRA request with the response to my March 3, 2026 OPRA request and found major differences in the records produced. The productions appear materially inconsistent and suggest that substantial responsive records were omitted from one or both responses. This request is intended to obtain the full and complete file.

Please provide all records from January 1, 2021 through present, including but not limited to:

1. All invoices, billing statements, itemized time entries, narratives, legal bills, e-billing submissions, monthly statements, and payment requests from any attorney, law firm, carrier counsel, special counsel, or defense counsel relating to this matter.

2. All purchase orders, vouchers, resolutions, authorizations, claim approvals, check registers, wire records, EFT records, cancelled checks, and records of payment relating to this matter.

3. All records concerning the Township’s deductible, retention, self-insured retention, co-pay, or first-dollar contribution, including the documented $10,000 payment tied to Claim No. KY21K2654751.

4. All correspondence with or from:

• Statewide Insurance Fund
• ACE American Insurance Company
• Chubb
• any joint insurance fund
• any third-party administrator
• any claims adjuster
• any defense counsel relating to this matter.

5. The complete claim file, excluding only legitimately privileged attorney work product or privileged communications, with a privilege log identifying each withheld item by date, sender, recipient, general subject matter, and privilege asserted.

6. All pleadings, motions, briefs, orders, transcripts, appeal papers, settlement communications, mediation records, and litigation status reports maintained by the Township.

7. All emails, letters, memoranda, or internal communications between Township officials, employees, committee members, clerk staff, insurance representatives, and counsel concerning this matter.

8. All records reflecting total sums paid, reserved, reimbursed, indemnified, written off, adjusted, or incurred in connection with this matter.

9. Any records responsive to prior requests that were withheld, overlooked, misfiled, maintained by another custodian, or not previously produced.

If any portion of this request is denied, please identify each withheld record and state the specific statutory basis for denial. If records are maintained by another custodian, fund, insurer, administrator, or counsel on behalf of the Township, please forward this request or identify the proper custodian in writing.

Electronic production is preferred.

This request concerns public expenditures and publicly backed litigation costs. It should be construed with that public interest in mind.

Sincerely,
William N. Sosis

Dear Township Clerk,
The three- week extension request is accepted.
I ask the the "complete" litigation file be made available on or before May 22, 2026.
Yours sincerely,
Bill Sosis

5/18/2026 12:13:48 PM

Dear Ms. Barras,

I write concerning my April 22, 2026 OPRA request seeking the complete litigation and claim file relating to Sosis v. Township of Mansfield Committee and Dena Hrebenak, Claim No. KY21K2654751.

The Township requested and received a three-week extension based upon the alleged “voluminous” nature of the request and represented that responsive records would be produced on or before May 22, 2026. Yet after weeks of delay, the Township still has not produced the complete file. Instead, the May 15, 2026 response states that records from Chubb America and defense counsel remain under “internal review.”

Even more troubling, the overwhelming majority of what was actually produced consists of my own filings, my own OPRA requests, already-known documents, and internal forwarding emails asking insurers and attorneys whether they possess records.

That is not a complete litigation file.

The current delay becomes even harder to justify when viewed against the Township’s prior responses involving the same litigation. On March 29, 2026, I submitted another OPRA request specifically seeking invoices, payment records, vouchers, purchase orders, and legal bills connected to the same Sosis litigation matters. The Township again requested an extension due to the alleged “voluminous nature” of the request. However, on April 21, 2026, the Township produced records that clearly demonstrate these materials already existed within Township possession or control, including invoices, legal billing statements, purchase orders, and payment records from Lavery, Selvaggi & Cohen concerning the Sosis litigation. Those records included detailed billing entries, references to OPRA matters, settlement discussions, appeal work, insurance-related communications, and municipal processing/payment records. In other words, the Township has already demonstrated that responsive litigation billing and payment materials are retrievable and producible when it chooses to produce them. That makes the present delay, partial production, and shifting explanations increasingly difficult to reconcile with OPRA’s requirement of prompt access to government records.

At this point, the pattern appears less like administrative delay and more like institutional stonewalling of a lawful public records request concerning publicly funded litigation expenditures.

The Township cannot avoid its statutory obligations by outsourcing records to insurers, defense counsel, administrators, or third-party representatives acting on the Township’s behalf. Public records do not lose their character merely because they are physically maintained by outside entities retained to defend the Township using public or publicly backed funds.

The Township also cannot satisfy OPRA by reproducing records already in the requestor’s possession while withholding or indefinitely delaying substantial categories of responsive records specifically requested.

I have now waited since March 29, 2026 for the complete file after agreeing to the Township’s requested extension in good faith. Instead of a complete production, I have received partial records, circular referrals, and open-ended references to unspecified “internal review” by third parties.

Please advise immediately:

- What categories of responsive records remain outstanding;

- The exact dates the Township requested records from Chubb, Statewide Insurance Fund, and defense counsel;

- Whether the Township has directed those entities to expedite production;

- Whether litigation invoices, payment records, reserve records, claim handling materials, correspondence, and internal communications are being withheld;

- Whether a privilege log will be produced for withheld records; and

- The exact date by which the Township will complete production.

If any records are being withheld, please identify each withheld record and state the precise statutory basis for denial as required under OPRA.

Sincerely,
William N. Sosis