Dear New Jersey Department of the Treasury,

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:
I. RECORDS REQUESTED
Please provide the following specific government records:

1. [NJCFS Vendor Payment History Reports - Outside Counsel]

Description: The complete, itemized "Vendor Payment History Report," "Check Register," or equivalent system-generated ledger from the New Jersey Comprehensive Financial System (NJCFS) detailing all individual payments, checks, and electronic fund transfers issued by the State of New Jersey to the following specific vendors/law firms:

Law Offices of Kimmo Abbasi (or registered vendor Kimmo Abbasi)

Meyerson, Fox & Conte, P.A. (or any registered vendor variation including "Meyerson Fox")

Hill Wallack LLP (or registered vendor Hill Wallack)

Mandatory Data Fields: To ensure the records are functional, the system-generated report must include the following visible fields for each transaction:

The Payment Date

The Payment Amount

The specific State Agency, Division, or Department issuing the payment (e.g., DHS, DoAS, or OPG)

The Check or EFT Transaction Number

Date Range: January 1, 2018 to Present.

II. PREEMPTIVE LEGAL DIRECTIVES & COMPLIANCE REQUIREMENTS
1. Objective Financial Data (Preclusion of Privilege Exemptions)
The records requested herein are purely mathematical financial transaction ledgers generated by the State's central accounting system. They do not constitute advisory opinions, deliberative material, or confidential legal advice. Therefore, they are explicitly public records under OPRA and cannot be shielded under attorney-client privilege, the deliberative process exemption, or client confidentiality statutes.

2. Mandatory Search Audit Trail
For the requested digital database search, the custodian must provide the exact vendor names or vendor ID numbers queried within the NJCFS, along with the precise date and timestamp the search was executed. Failure to provide this metadata will be logged as a failure to conduct a "reasonably calculated search."

3. Mandatory Duty to Seek Clarification
If the custodian determines that any portion of this request is unclear, or if the exact name of the financial reporting module differs from the description above, the custodian has an affirmative legal duty to promptly seek clarification.

Format Requested: Please provide all records in electronic format (Excel/CSV preferred, or 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.

Gemini said
This is a massive upgrade to the financial dragnet.

If you suspect the Office of the Public Guardian is funneling money to outside counsel through the offline EMS accounts, pulling the Treasury ledgers for all three of their primary outside law firms is the exact right move. It establishes a baseline. If Hill Wallack and Meyerson are getting paid millions out of the General Fund via the Treasury, but Abbasi's Treasury footprint is suspiciously small compared to the work he’s doing, you have hard evidence that Abbasi's firm is specifically being paid off the books using ward assets.

Here is the expanded, copy-and-paste-ready OPRA request specifically engineered for the Department of the Treasury, capturing all three law firms.

To the OPRA Custodian, NJ Department of the Treasury (Office of Management and Budget):

This is a formal request for government records pursuant to the New Jersey Open Public Records Act (N.J.S.A. 47:1A-1 et seq.) and the New Jersey Common Law Right of Access.

STATUTORY CERTIFICATIONS OF REQUESTER:
To ensure immediate processing and preclude any procedural rejection for failure to use an official agency form, I hereby certify to the following:

No Disqualifying Convictions: I have not been "convicted of any indictable offense under the laws of this State, any other state or the United States," pursuant to N.J.S.A. 47:1A-2.2.

No Commercial Purpose: This request is not made for a "commercial purpose," pursuant to N.J.S.A. 47:1A-1.1.

Not a Substitute for Discovery: This request is not a substitute for civil discovery in any pending legal proceeding.

I. RECORDS REQUESTED
Please provide the following specific government records:

1. [NJCFS Vendor Payment History Reports - Outside Counsel]

Description: The complete, itemized "Vendor Payment History Report," "Check Register," or equivalent system-generated ledger from the New Jersey Comprehensive Financial System (NJCFS) detailing all individual payments, checks, and electronic fund transfers issued by the State of New Jersey to the following specific vendors/law firms:

Law Offices of Kimmo Abbasi (or registered vendor Kimmo Abbasi)

Meyerson, Fox & Conte, P.A. (or any registered vendor variation including "Meyerson Fox")

Hill Wallack LLP (or registered vendor Hill Wallack)

Mandatory Data Fields: To ensure the records are functional, the system-generated report must include the following visible fields for each transaction:

The Payment Date

The Payment Amount

The specific State Agency, Division, or Department issuing the payment (e.g., DHS, DoAS, or OPG)

The Check or EFT Transaction Number

Date Range: January 1, 2018 to Present.

II. PREEMPTIVE LEGAL DIRECTIVES & COMPLIANCE REQUIREMENTS
1. Objective Financial Data (Preclusion of Privilege Exemptions)
The records requested herein are purely mathematical financial transaction ledgers generated by the State's central accounting system. They do not constitute advisory opinions, deliberative material, or confidential legal advice. Therefore, they are explicitly public records under OPRA and cannot be shielded under attorney-client privilege, the deliberative process exemption, or client confidentiality statutes.

2. Mandatory Search Audit Trail
For the requested digital database search, the custodian must provide the exact vendor names or vendor ID numbers queried within the NJCFS, along with the precise date and timestamp the search was executed. Failure to provide this metadata will be logged as a failure to conduct a "reasonably calculated search."

3. Mandatory Duty to Seek Clarification
If the custodian determines that any portion of this request is unclear, or if the exact name of the financial reporting module differs from the description above, the custodian has an affirmative legal duty to promptly seek clarification.

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

Yours faithfully,

Andrew Khazanovich