To whom it may concern:

The Central Regional School District Board of Education received your
email containing your OPRA Request on August 51, 2025.  I, as the Board’s
Records Custodian, received your Request on that date as well.  The
seven-business daytime frame to provide a response to your Request expires
on Tuesday, August 26, 2025.  This response is being sent within that time
frame.

OPRA defines a “government record” of a public entity as “any paper,
written or printed book, document, drawing, map, plan, photograph,
microfilm, data processed or image processed document, information stored
or maintained electronically or by sound-recording or in a similar device,
or any copy thereof, that has been made, maintained or kept on file in the
course of his or its official business …”  N.J.S.A. 47:1A-1.1. 
Accordingly, the Board is required to produce only those records which it
maintains in the official course of business and which are not otherwise
exempt from production.  Pursuant to the definition of a government
record, a public entity is not required by OPRA to research information
and/or create records that do not exist in response to OPRA requests.  See
e.g., Mag Entertainment, LLC v. Division of Alcoholic Beverage Control,
375 N.J. Super 537 (App. Div. March 2005). 

Under OPRA the Board is required to produce only those records which it
maintains in the official course of business, and it is not required to
create records in order to provide a response to a Request.  In that
regard, the Board does not have a responsive record listing all of the law
firms that provided legal services during the requested period.

With respect to the remainder of the Request, it would require the Board
to search, compile, review, and make necessary redactions to potentially
hundreds of pages of legal invoices over the span of the fourteen (14)
month time range stated in the Request.  The sheer volume of documents
that would potentially be responsive would have to be identified,
reviewed, potentially redacted in order to protect against the disclosure
of any confidential student or staff information and any information
protected by the attorney-client privilege, and then compiled in an effort
to respond to your Request would substantially disrupt the operations of
the school district. It would involve a breadth, generality, and
complexity of review which will necessitate substantial assessment and
preliminary inquiry by the Custodian of Records and/or the reassignment of
other Board employees, none of whom are assigned by the Board for solely
such tasks. In addition, given the time of year, many Board employees may
not be available due to planned vacations, time-off, and/or assignment to
other tasks critical to upcoming start of the new school year. 
Accordingly, the Board objects to and is denying the request for all
invoices or billing records submitted during the requested period because
these requests are overly burdensome and would be disruptive to District
operations.

In light of the substantial disruption to district operations, the Board
proposes as a reasonable solution that you narrow the time range for
documents in the Request to a period of six months or less.  This would be
without prejudice to your ability to resubmit additional requests for
records within other periods of time with sufficient intervals in between
those Requests so that district personnel would be able to respond without
substantial disruption to the district’s operations.

If you do not accept the reasonable solutions proposed by the Board, with
no counter-proposal for a reasonable solution, then the Board will have no
choice but to deny that portion of the Request as causing substantial
disruption to the operations of the Central Regional School District.

Since the Request noted above was submitted anonymously, you are
prohibited from instituting a proceeding in either the Superior Court of
New Jersey or with the Government Records Council to challenge the
decision by the District to deny immediate or any other
access.  See N.J.S.A. 47:1A-5 and N.J.S.A. 47:1A-6.  You may contact the
GRC by toll-free telephone at 866-850-0511, by mail at P.O. Box 819,
Trenton, NJ 08625, or by e-mail at [1][email address], or at their
website at [2]www.state.nj.us/grc to verify this.  The GRC can also answer
other questions about the law.

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Attached are the legal invoices you requested. The first 2 documents are
from our General Legal Counsel, Comegno Law group. The last document is
from other law firms.Thank you.

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