Dear Avon-by-the-sea Borough,

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-6(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. Copies of any/all Leases and/or Agreements, between The Borough of Avon-By-The-Sea and ALL Hospitality, LLC and/or LIAM MOLONEY, including any amendments thereof, related to 600 Ocean Avenue (the “Property”).

2. Copies of all documents reflecting payments made to The Borough of Avon-By-The-Sea by ALL Hospitality, LLC and/or LIAM MOLONEY, including, but not limited to, Lease payments/Rent Payments;

3. Copies of all documents reflecting monies reimbursed and/or paid by The Borough of Avon-By-The-Sea to Defendants ALL Hospitality, LLC and/or LIAM MOLONEY, for any alleged capital improvements, repairs, or upgrades to the Property, including documents submitted by Defendants ALL Hospitality, LLC and/or LIAM MOLONEY for such reimbursement(s). This request includes copies of any and all communications, text messages, emails, written correspondence by and between Defendants All Hospitality, LLC and/or LIAM MOLONEY and The Borough of Avon-By-The-Sea concerning any such reimbursements;

4. Copies of all Request for Proposals (“RFPs”) and completed Bid Proposals submitted by ALL Hospitality, LLC and/or LIAM MOLONEY to Avon-By-The Sea and/or the State of New Jersey in order to participate in the bidding process to operate a restaurant at the premises that had formerly been Avon Pavilion, located at 600 Ocean Avenue, Avon-By-The-Sea, New Jersey;

5. Copies of all documents/records/forms that Defendants ALL Hospitality, LLC and/or LIAM MOLONEY submitted/provided to the Borough of Avon-By-The-Sea in order to participate in the bidding process to operate a restaurant at the premises that had formerly been Avon Pavilion, located at 600 Ocean Avenue, Avon-By-The-Sea, New Jersey. This request would include, but not be limited to, the following forms, which may have been required for bidding:

a. Business Registration Certification from the Division of Revenue

b. Ownership Disclosure Statement – State-supplied form

c. Affirmative Action Employee Report – State-supplied form

d. Certification where services will be performed – State-supplied form

e. Acknowledgment that payments to vendors are subject to set-off for outstanding taxes – State-supplied form

f. Copies of any lists and explanations of pending litigation, administrative actions, etc. – State-supplied form

6. Copies of any and all records/documents reflecting communications between the Borough of Avon-By-The-Sea (its employees, staff, representatives, and/or agents) and Defendants ALL Hospitality, LLC, LIAM MOLONEY, and/or CARMEN MOLONEY with regard to the Property; and

7. Copies of any and all records/documents concerning any Violations issued to Defendants ALL Hospitality, LLC and/or LIAM MOLONEY regarding the Property and/or for Defendants’ non-performance of the Lease. This request includes copies of any and all communications, text messages, emails, and/or written correspondence.

My preferred delivery method for response(s) to this request is by E-mail as attachments. (EMAIL [email address] and [email address])
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,
Angelique Yonkauske
Paralegal to Patrick J. Whalen, Esquire