Dear Records Custodian:

Please accept this electronic request for government records made under the Open Public Records Act, N.J.S.A. 47:1A-1 et seq., and, to the extent applicable, the common law right of access.

This request is submitted by email in lieu of the agency’s form pursuant to N.J.S.A. 47:1A-5(f). An email or letter containing all information required on the adopted form is sufficient as a valid OPRA 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.

This request pertains to pending federal litigation, namely COFFEY v. SUSSEX COUNTY COMMUNITY COLLEGE et al., No. 2:25-cv-01264 (D.N.J.), only insofar as it seeks records maintained by the Statewide Insurance Fund concerning the Town of Newton and any related claim, defense, indemnity, reserve, payment, or coverage matter. To the best of my knowledge, the records requested below are not presently the subject of any court order or pending discovery request.

For the period January 1, 2025 to present, I request electronic copies of the following identifiable government records maintained by the Statewide Insurance Fund relating to that matter:

Records sufficient to identify the relevant claim number or claim numbers, date opened, insured entity, coverage line, claim status, and assigned claims personnel.

Records sufficient to show the total sums reserved, paid, billed, reimbursed, indemnified, adjusted, or incurred in connection with that matter.

All invoices, billing statements, itemized legal bills, e-billing submissions, and payment requests submitted by defense counsel, carrier counsel, or other attorneys relating to that matter.

All records reflecting payment of legal fees, costs, expenses, settlements, judgments, or indemnity amounts relating to that matter.

All insurance agreements, coverage records, declarations, excess or umbrella coverage records, indemnity agreements, and other records sufficient to identify any policy, fund coverage, or agreement that may provide a defense to, reimburse, or satisfy all or part of any judgment, settlement, or litigation expense relating to that matter.

All tender letters, claim notices, reservation-of-rights letters, coverage position letters, excess notices, and similar non-privileged claim-handling or coverage communications relating to that matter.

Any settlement agreement, release, or record sufficient to show whether settlement authority has been requested, granted, denied, or modified in connection with that matter, if any such record exists.

For avoidance of doubt, this request seeks only records that have been made, maintained, kept on file, or received by the Statewide Insurance Fund in the course of its official business.

My preferred delivery method is by email attachment, in PDF format or native electronic format where available.

If any portion of this request is denied, withheld, or redacted, please:
identify each withheld or redacted record with reasonable specificity;
state the specific statutory basis for each denial or redaction; and
produce all reasonably segregable non-exempt portions.

If any responsive records are maintained by another custodian, administrator, or affiliated entity on behalf of the Fund, please forward this request accordingly or identify the proper custodian in writing.

Please confirm receipt of this request.

Yours faithfully,
Harry Langer Esq