Dear New Jersey Attorney General's Office,

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:

1. [Authorization for County Counsel Representation of the Surrogate]

Description: Any official "Declination of Representation," "Authorization of Outside Counsel," indemnification waiver, or administrative memorandum issued by the Office of the Attorney General to the Union County Counsel's Office (specifically including Moshood Muftau, Esq. or Bruce Bergen, Esq.) or the Union County Surrogate, legally authorizing Union County Counsel to represent the Surrogate in lieu of the Attorney General in the matter of The Estate of Nadia Romanov (Union County Docket S-8455).

Date Range: January 1, 2025 to Present.

2. [AOC Request for OAG Representation / Intake Records]

Description: The formal administrative "Request for Representation," intake transmittal, or internal routing memorandum submitted by the Administrative Office of the Courts (AOC) (including Susanna J. Morris, Esq. or Meryl G. Nadler, Esq.) to the Office of the Attorney General formally requesting legal defense or the assignment of a Deputy Attorney General to respond to the subpoena duces tecum issued to the AOC on January 6, 2026.

Date Range: January 6, 2026 to January 13, 2026.

3. [Administrative Case Assignment: DAG Maria A. Rojas]

Description: The official administrative "Case Assignment Memorandum," "Matter Opening Form," or internal OAG docketing record formally assigning Deputy Attorney General Maria A. Rojas to represent the Administrative Office of the Courts as a Non-Party in the Romanov matter.

Clarification: I am strictly seeking the administrative intake record showing the date of assignment, the requesting agency, and the matter name. I am explicitly NOT seeking privileged legal analysis.

Date Range: January 1, 2026 to January 13, 2026.

4. [Domain-Targeted Transmittals: The October 2, 2025 Court Order]

Description: All emails, transmittals, or correspondence sent or received by DAG Maria A. Rojas that yield a responsive result to the following exact Boolean search string:

("October 2" OR "Oct 2") AND "Order" AND ("@hillwallack.com" OR "@ucnj.org" OR "@njcourts.gov")

Notice regarding Scope: This specifically captures the administrative transmission of a publicly filed Court Order between the OAG and external third-party law firms (Hill Wallack), county agencies (Union County), or the Judiciary. This is an administrative transmittal, not privileged legal advice.

Date Range: October 2, 2025 to January 13, 2026.

5. [Domain-Targeted Communications: OAG & DHS/OPG]

Description: All emails or electronic correspondence sent or received by DAG Maria A. Rojas that yield a responsive result to the following exact Boolean search string:

("Romanov" OR "S-8455" OR "S8455") AND ("@dhs.nj.gov" OR "@dhs.state.nj.us")

Notice regarding Scope: This captures coordination between the OAG and the Department of Human Services/Office of the Public Guardian regarding this docket.

Date Range: August 1, 2025 to Present.

II. PREEMPTIVE LEGAL DIRECTIVES & COMPLIANCE REQUIREMENTS
1. Mandatory Search Audit Trail
For the requested digital database and email searches in Items 4 and 5, the custodian must provide the exact Boolean search strings or domains entered into the system, along with the precise date, timestamp, and numerical hit count the search yielded. Failure to provide this metadata will be logged as a failure to conduct a "reasonably calculated search" and as direct evidence of an arbitrary denial.

2. Preclusion of Attorney-Client Privilege (Administrative Representation & Transmittals)
Pursuant to established New Jersey case law, administrative documents establishing the fact of legal representation, the assignment of counsel, waivers of conflict, and the transmittal of non-privileged, docketed court orders to third parties are administrative business records. They do not constitute substantive legal advice or confidential communications.

3. Mandatory Duty to Seek Clarification (Preclusion of Delay Tactics)
If the custodian determines that any portion of this request is unclear, or if the exact name of an internal OAG intake form differs from the description above, the custodian has an affirmative legal duty to promptly seek clarification pursuant to N.J.S.A. 47:1A-5(g).

Format Requested: Please provide all records in electronic format (PDF) via email or secure download link.

My preferred delivery method for response(s) to this request is by E-mail as attachments. Please confirm you have received this request. If you are not the custodian of records, please forward my request to that person and provide their email address to me for future reference.

Yours faithfully,

Andrew Khazanovich

Dear New Jersey Attorney General'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 New Jersey Attorney General's Office's handling of my OPRA request 'OPRA Request - Authorization'.

I am in receipt of the March 27, 2026 disposition of Request C251037, which denied the request in its entirety under Denial Code 01 ("Not Made, Maintained, Filed or Received by Division") and directed me to refile with the Division of Law. This letter is a written request for internal review and reconsideration of that disposition, and for statutory compliance, prior to my initiation of review before the Government Records Council or the Superior Court. I reserve all rights under OPRA and the common law right of access. A parallel refiling with the Division of Law has been or will be made without waiver as to C251037. [ppl-ai-file-upload.s3.amazonaws](https://ppl-ai-file-upload.s3.amazonaws....)

**1. Unlawful Anonymous Disposition — Disclose the Acting Custodian.**
The March 27, 2026 receipt was signed only as "OAG Custodian of Records," and the "By ____________" signature block on page 1 was left blank. OPRA defines "custodian of a government record" as the officer designated by formal action of the agency's director or governing body, N.J.S.A. 47:1A-1.1. The designated officer is the accountable decisionmaker under N.J.S.A. 47:1A-5(i) and the named respondent in any action under N.J.S.A. 47:1A-6. The NJ_OPRA portal requires an authenticated custodian user account to enter a disposition; the identity of that user is necessarily captured in the portal's transaction log. Concealing that identity behind an institutional byline obstructs the statutory appeal mechanism. I request (a) the name and title of the designated custodian who entered the disposition of C251037, and (b) the formal designation document establishing that individual's custodial authority. [nj](https://www.nj.gov/grc/public/citizens/C...)

**2. The Denial Is Internally Contradictory — A Parent-Department Custodian Cannot Disclaim a Subordinate Division's Records.**
The disposition's opening line identifies the responding entity as "The Department of Law & Public Safety (L&PS), Office of the Attorney General (OAG)". L&PS is the cabinet-level parent department; both the Office of the Attorney General and the Division of Law are components within L&PS, and the Division of Law is headed by a Director who reports to the Attorney General. Under N.J.S.A. 47:1A-1.1, a "government record" is any record made, maintained, or received by any officer or agency of the State — a definition keyed to the public agency, not to internal sub-units. A custodian who holds himself out as the records officer for L&PS cannot, in the same breath, disclaim records held by a subordinate division of that very department. The denial is internally contradictory on its face: if the custodian's reach is L&PS-wide, the records are within reach; if the custodian's reach is narrower than L&PS, the response should not have been issued on L&PS/OAG letterhead. The statutory remedy for an internal routing issue is forwarding under N.J.S.A. 47:1A-5(h), not denial. [nj](https://www.nj.gov/lps/opra/)

**3. Denial Code 01 Is Legally Insufficient on Its Face.**
The disposition expressly admits: "responsive records, to the extent any such records may exist, would be within the possession of the Division of Law, which is a separate division from the OAG". That is an admission that responsive records exist within L&PS. A sub-departmental boundary is not a statutory exemption and cannot ground a Code 01 denial. The definition of "government record" in N.J.S.A. 47:1A-1.1 is agency-wide and is not partitioned by internal divisional structure. [law.justia](https://law.justia.com/codes/new-jersey/...)

**4. Statutory Duty to Forward or Identify the Custodian.**
The disposition asserts that "Department regulations do not permit me to transfer an OPRA request between divisions or to another public agency". That position is subordinate to the statute. N.J.S.A. 47:1A-5(h) affirmatively requires the receiving officer to forward the request to the proper custodian or direct the requestor to that custodian. Directing me to a generic portal drop-down menu — without identifying the designated Division of Law custodian by name — satisfies neither statutory prong. [ppl-ai-file-upload.s3.amazonaws](https://ppl-ai-file-upload.s3.amazonaws....)

**5. No Item-by-Item Analysis.**
A single blanket Code 01 was applied to five materially distinct items, including DAG Maria A. Rojas's administrative case-assignment records (Item 3) and DAG email correspondence on State infrastructure (Items 4–5). Appellate precedent requires document-by-document / item-by-item justification; blanket denials are inadequate. [njopralaw](https://www.njopralaw.com/?p=40)

**6. No Search Audit Trail for Items 4 and 5.**
Items 4 and 5 were Boolean email searches whose methodology I expressly directed be preserved and disclosed. The disposition provides no search strings actually entered, no system identifier, no timestamp, and no hit count. Absent that metadata, the agency has not demonstrated a reasonably calculated search. [marshalldennehey](https://marshalldennehey.com/articles/nj...)

**7. Implausibility as to DAG Records.**
DAG Maria A. Rojas is, by title, a Deputy Attorney General operating under the Attorney General within L&PS. Her matter-opening records and email correspondence reside on L&PS-controlled State infrastructure. The assertion that the Office of the Attorney General "does not make, maintain, or receive" any records concerning a DAG's case assignment or correspondence cannot be reconciled with the agency-wide definition of "government record" in N.J.S.A. 47:1A-1.1. [nj](https://www.nj.gov/grc/public/citizens/C...)

**8. Duty to Seek Clarification.**
My request expressly invoked N.J.S.A. 47:1A-5 and the custodian's affirmative duty to seek clarification before denial on ambiguity or labeling grounds. The custodian sought no clarification and instead issued a blanket denial. [law.justia](https://law.justia.com/codes/new-jersey/...)

**Action Requested.**
(a) Vacate the denial of C251037; (b) disclose the name and title of the designated custodian who dispositioned the request and produce the formal designation document under N.J.S.A. 47:1A-1.1; (c) re-process each of the five items individually on the merits and, where any item is properly held by a different L&PS sub-unit custodian, forward it pursuant to N.J.S.A. 47:1A-5(h); (d) provide the search audit trail for Items 4 and 5 (exact strings entered, system, timestamp, and hit count); and (e) confirm receipt of this request for review and reconsideration. [marshalldennehey](https://marshalldennehey.com/articles/nj...)

The burden of proving any denial is authorized by law rests with the custodian, N.J.S.A. 47:1A-6. I request a written response within seven (7) business days. [law.justia](https://law.justia.com/codes/new-jersey/...)

Yours faithfully,
Andrew Khazanovich
Jersey City, New Jersey

***

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

Yours faithfully,

Andrew Khazanovich