Dear Custodian of Records:

I am writing to request access to certain records under the New Jersey Open Public Records Act, N.J.S.A. 47:1A-1 et seq., and the common law right of access. This request is prompted by a recent response from the Hudson County Prosecutor’s Office (“HCPO”), dated October 28, 2025, regarding a prior OPRA request on this matter. In that letter, the HCPO indicated it could not release several records related to State v. Jose G. Sanchez, Indictment No. 22-08-00922-I, because they were merely “courtesy copies” of Union City Police Department records. The HCPO explicitly advised that these particular records — including the Union City PD initial incident report, any use-of-force reports, and body/dash camera footage — should be sought directly from the Union City Police Department as the originating agency. Accordingly, I am now directing my request to the Union City Police Department.

Pursuant to OPRA and the common law, please accept this as my formal request for the following records, which pertain to the incident(s) leading to the above-referenced indictment and the arrest of Mr. Sanchez:

1. Initial Police Incident Report (or equivalent “face sheet”) prepared by Union City PD documenting the “who, what, where, and when” of the incident(s) that led to Indictment No. 22-08-00922-I for Jose G. Sanchez. This includes any cover page or report summarizing the incident and parties involved, generated at the time of the incident or arrest.

2. Use of Force Report(s) completed by any Union City PD officer(s) in connection with the arrest of Jose G. Sanchez or the underlying incident(s) related to this case. If force was used or reported during Mr. Sanchez’s apprehension, please provide all such UCPD use-of-force forms or reports.

3. Body Worn Camera (BWC) and/or Mobile Video Recorder (MVR) Footage from Union City PD officers capturing the events of Mr. Sanchez’s arrest or the relevant underlying incident(s). This includes any police body-camera videos and patrol car dash-cam videos that recorded the incident(s) leading up to or including the arrest of Mr. Sanchez.

For each of the above items, please provide the records in electronic form if possible. I prefer to receive digital copies via email (attachments or a download link). If any of the requested video files are too large to transmit by email, I am willing to make alternative arrangements for electronic delivery (such as a secure file transfer or pickup of a DVD/USB drive); however, please let me know in advance if that will be necessary. I agree to pay any reasonable fees for duplication as authorized by law, but please advise me of any fees or special service charges exceeding the ordinary copying costs before incurring them, so that I may approve them as required by N.J.S.A. 47:1A-5(c) and (f).

If you believe any portion of any responsive record is exempt from disclosure, please redact that portion and release the remainder of the record as required by law. OPRA specifically mandates that when a record contains some exempt information, the custodian **“shall delete or excise from a copy of the record that portion which...is exempt from access and shall promptly permit access to the remainder of the record.”** In other words, no record should be withheld in its entirety if only parts of it are exempt. For any denial or redaction, please provide a written index or explanation citing the specific legal basis (statute, regulation, or case law) for each withheld portion. As per OPRA’s requirements, the requester has a right to know the reason for any denial or redaction, and the agency must identify “the legal basis for each redaction” or suppression of information. If an entire document is withheld, kindly confirm whether any portion of it can be segregated and released.

I also request that these records be provided as soon as possible, but in any event, no later than the statutory deadline of seven (7) business days from your receipt of this request (absent a reasonable extension or exceptional circumstance). If the records cannot be made available within 7 business days, OPRA requires that you provide a written response within that timeframe indicating when they will be available and the reason for the delay. I will, of course, consent to a reasonable extension of time if necessary, provided you inform me in writing within the seven-day period. Please communicate any such need for an extension or clarification of the request to me promptly.

To the extent any requested record might not be available under OPRA, or is claimed to be exempt, please also consider this a request under the common law right of access to public records of New Jersey (see N.J.S.A. 47:1A-8). OPRA “shall not be construed as limiting the common law right of access” to government records. Under the common law, if the documents I seek are deemed “public records” (e.g. records made by public officers in the course of official duty) and I, as the requestor, have a legally recognized interest in them, then the law requires disclosure so long as my interest in obtaining the records outweighs the government’s interest in keeping them confidential. I believe I have a legitimate interest in the information surrounding Mr. Sanchez’s arrest and the associated police conduct, and there is significant public interest in transparency regarding these law enforcement records. Unless a specific and compelling need for confidentiality exists that outweighs the public interest in disclosure, the common law right of access would authorize release of these records. If you deny access under OPRA, please explicitly consider this letter as a common-law request and perform the required balancing test, and inform me of your determination under the common law standard.

Finally, please note that I am providing the necessary certification in compliance with OPRA’s requirements. Under penalty of N.J.S.A. 2C:28-3, I certify that I have been convicted of an indictable offense under the laws of New Jersey, any other state, or the United States. I understand that N.J.S.A. 47:1A-2.2 prohibits disclosure of certain records containing personal information about a victim or the victim’s family to anyone convicted of an indictable offense, and this certification is provided to satisfy that statutory prerequisite.

Thank you for your attention to this request. If you require any clarifying information or have any questions, please do not hesitate to contact me at the email address or phone number listed above. I would be happy to assist in clarifying the request, and I respectfully request that you communicate with me promptly if there are any issues so that they may be resolved within the statutory time frame. I look forward to your timely response and to the release of the requested records via electronic delivery.