Please accept this as my request for government records under both OPRA and the common law right of access. Thank you very much for your commitment to transparent government.

BACKGROUND:

In response to a recent request, the Town of Dover informed me that the following five (there were seven in total but I am interested in only five) police employees separated from their employment during 2022:

1. Officer Ilmi Bojkovic was terminated 12/15/2022
2. Special Officer Charles J Campbell resigned on 02/20/2022
3. Officer Alexander Echevarria resigned on 10/31/2022
4. Officer Dakota R. Keyworth resigned on 01/07/2022
5. Sergeant Anthony G. Liguori Jr. took early retirement on 12/31/2022.

Of particular concern is Officer Bojkovic's termination, as it was not included in Attorney General Platkin's "Major Discipline Reporting" for the period of January 1, 2022, to December 31, 2022, which can be found at www.nj.gov/oag/iapp/docs/Major%20Discipl.... The Town of Dover is listed among the "Agencies Without Major Discipline" in the Attorney General's report.

In Paragraph 1 below, I am requesting internal affairs investigation reports related to the conduct that led to Officer Bojkovic's termination. Considering the factors established by the New Jersey Supreme Court in Rivera v. Union Cnty. Prosecutor's Office, I believe that the public has a significant interest in understanding the circumstances surrounding this termination.

Regarding the first factor, "the nature and seriousness of the misconduct," I am unaware of the specific misconduct as it was not included in the 2022 Major Discipline Report. However, I recognize that it must have been serious since it resulted in termination.

Regarding the second factor, "whether the alleged misconduct was substantiated," it can be inferred that the misconduct was substantiated, given the decision to terminate Officer Bojkovic's employment.

Regarding the third factor, "the nature of the discipline imposed," termination represents the most severe form of discipline.

Regarding the fourth factor, "the nature of the official's position," Officer Bojkovic had been a member of the police department for seven years prior to his termination.

Regarding the fifth factor, "the individual's record of misconduct," Officer Bojkovic had previously faced allegations in a lawsuit where it was claimed that he restrained Cyprian Luke while another officer assaulted him. After being on paid leave for a year, Officer Bojkovic was reinstated to his position ("Dover police officers reinstated after year on paid leave for violent arrest," by Jessie Gomez, Morristown Daily Record, June 17, 2020).

In relation to the other officers, the Town's 2022 Internal Affairs Summary Report's first page (2022 Snapshot) indicates that five officers "separated while IA pending." It is likely that some of the officers listed as numbers 2 through 5 above are included in this category. If this is the case, it is probable that separation agreements exist, outlining the terms of their departures. These documents could provide the public with insight into the circumstances surrounding their resignations or decision to take early retirement.

RECORDS REQUESTED:

1. All internal affairs investigation reports underlying the decision to terminate Ilmi Bojkovic.

2. For Charles J Campbell, any separation, termination or other agreement that sets forth the term and conditions of this separation from employment. Also, I would like his letter of resignation.

3. For Alexander Echevarria, any separation, termination or other agreement that sets forth the term and conditions of this separation from employment. Also, I would like his letter of resignation.

4. For Dakota R. Keyworth, any separation, termination or other agreement that sets forth the term and conditions of this separation from employment. Also, I would like his letter of resignation.

5. For Anthony G. Liguori, Jr., any separation, termination or other agreement that sets forth the term and conditions of this separation from employment.