November 3, 2025

Records Custodian
Sussex County Community College
One College Hill Road
Newton, NJ 07860

Re: Open Public Records Act Request – SAIF Coverage, and Post-Incident Policy Actions

Dear Records Custodian:

Pursuant to the New Jersey Open Public Records Act (“OPRA”), N.J.S.A. 47:1A-1 et seq., and the strong presumption of access reaffirmed in Burnett v. County of Bergen, 198 N.J. 408 (2009), I hereby demand access to and copies of the following government records held by Sussex County Community College (“SCCC”). As the Supreme Court held in Asbury Park Press v. County of Monmouth, 406 N.J. Super. 1 (App. Div. 2009), any ambiguity in scope must be resolved in favor of disclosure, and exemptions must be narrowly construed.

This request arises in direct connection with the ongoing federal civil rights litigation *Coffey v. Sussex County Community College et al.*, Civ. No. 2:25-cv-01264 (D.N.J.), now pending before the U.S. District Court for the District of New Jersey. SCCC is hereby placed on notice that these materials are directly relevant to the federal case record concerning alleged retaliation, due process violations, institutional cover-up, and insurance-based conflicts of interest involving the School Alliance Insurance Fund (“SAIF”) and other risk pools.

1. Board of Trustees Meetings and Related Materials
All Board of Trustees meeting materials, including agendas, minutes, resolutions, audio/video recordings, and any exhibits or attachments—for all meetings held January 1, 2022 through the present in which any of the following were discussed or referenced: Lee Coffey, Jon Connolly, Connolly’s office search, campus security, firearm possession, or any issue related to administrative discipline, whistleblower complaints, or retaliation. Include both open and closed session materials and all attachments. This encompasses discussions of SCCC’s SAIF coverage, claim reserves, legal defense coordination, or Board communications with SAIF administrators or counsel.

2. Internal Reports, Complaints, and Investigative Records
All non-privileged internal reports, summaries, correspondence, or investigative files created, received, or maintained by SCCC relating to Lee Coffey’s allegations or complaints, including incident reports, internal investigations, or memoranda concerning the events giving rise to *Coffey v. SCCC*. Include records referencing or documenting complaints by or concerning SCCC personnel such as COO James Gaddy, HR Coordinator Marianne Sharpe, staff member Jason Boehm, or any other SCCC employee regarding former President Jon Connolly or institutional misconduct. Include all mp3 or other audio files submitted in connection with such complaints or investigations. These materials bear directly on institutional knowledge, pattern, and notice under *Monell v. Dep’t of Soc. Servs.*, 436 U.S. 658 (1978), as pleaded in the federal action.

3. External Correspondence and Inter-Agency Communications
All communications, including emails, memoranda, letters, and reports, exchanged between SCCC trustees, administrators, or counsel and any external entity, including but not limited to: (a) the Sussex County Board of County Commissioners; (b) the Sussex County Prosecutor’s Office; (c) the Newton Police Department; (d) the New Jersey Office of the Secretary of Higher Education, the State Department of Education, or Middle States Commission on Higher Education; and (e) any insurance provider, coverage counsel, or adjuster, including SAIF, the Statewide Insurance Fund (SIF), Highland Claim Services, and affiliated law firms. The scope includes all communications regarding coverage determinations, claim reserves, defense coordination, or indemnification under SAIF policies relating to the Coffey matter. This includes, but is not limited to, emails referencing claim number assignments, reserve authorizations, meeting minutes of the SAIF Board, and correspondence involving SAIF counsel or account managers.

4. SAIF Documentation and Risk Management Records
All records maintained or received by SCCC regarding its membership in the School Alliance Insurance Fund (SAIF) from January 1, 2022 through the present, including copies of policy declarations, certificates of coverage, risk management manuals, and any claims, reserves, or litigation reports referring to or arising from *Coffey v. SCCC*. Include communications between SCCC, SAIF, and Highland Claim Services regarding liability evaluation, coverage determinations, or coordination of defense counsel. Produce any Board resolutions or minutes approving SAIF participation, deductible allocations, or retention of outside counsel connected to this matter.

5. Policies, Procedures, and Post-Incident Revisions
All policies, procedures, or resolutions adopted or revised on or after February 1, 2023 concerning: (a) Title IX compliance; (b) campus security and safety protocols; (c) firearm/weapons restrictions on campus; or (d) complaint-handling and whistleblower protection. Include any revisions linked to Coffey’s allegations or the Connolly-Gaddy firearm incident, including Policy No. 600.03 – Weapons on Campus, Resolution No. AP09232025-4, and supporting legal memoranda, redlines, or Board correspondence evidencing post-incident reforms.

Production Requirements and Legal Notice

Format: All electronic records shall be produced in native format (e.g., .msg/.pst, .xlsx, .docx, .pdf with metadata intact). Flattened or image-only PDFs are non-compliant under *Bent v. Stafford Police Dep’t*, 381 N.J. Super. 30 (App. Div. 2005). For audio/video materials, produce the original format (.mp3, .wav, .mp4) with metadata and checksum verification (SHA-256 or MD5 hash) to confirm file integrity.

Redactions: If any record is withheld or redacted, provide a privilege/withholding log identifying the record, author, recipient(s), date, and specific statutory exemption relied upon, as required by *Paff v. Galloway Twp.*, 229 N.J. 340 (2017). Blanket or conclusory denials are improper.

Preservation: You are hereby placed on **formal litigation notice** to preserve all responsive materials, including emails, recordings, backups, devices, and cloud archives. Destruction or alteration of responsive materials may constitute spoliation subject to sanction under *Mason v. City of Hoboken*, 196 N.J. 51 (2008), and obstruction of justice under federal discovery rules.

Timeframe: Pursuant to N.J.S.A. 47:1A-5(i), a complete response is due within seven (7) business days. Failure to respond constitutes a deemed denial.

Partial Disclosure: If any portion is legitimately exempt, produce all segregable non-exempt material and cite the precise statutory subsection supporting each withholding.

Fees: Provide an itemized written estimate in advance; excessive or unsupported charges will be challenged.

Delivery: Transmit all records electronically via secure download link or SFTP, with an accompanying production index identifying each file’s name, custodian, date, and checksum verification.

This request is made for public-interest and litigation-related purposes concerning taxpayer-funded insurance mechanisms, institutional governance, and evidentiary preservation in ongoing federal proceedings. It is not for commercial use.

Failure to comply fully and in good faith may expose SCCC and its officers to civil penalties under N.J.S.A. 47:1A-11 for knowing, willful, and unreasonable denials and entitle the requester to attorney’s fees and costs under N.J.S.A. 47:1A-6. All rights are expressly reserved to pursue enforcement before the Government Records Council, the Superior Court, and to file notice with the U.S. District Court in *Coffey v. Sussex County Community College et al.*

Yours faithfully,
Sussex Watch Network (SWN)

Dear Sussex County Community College,

This correspondence serves as a courteous follow-up regarding the Open Public Records Act (OPRA) request previously submitted through the OPRAmachine platform. Please confirm whether the request has been received and advise on its current processing status or estimated completion date pursuant to N.J.S.A. 47:1A-5(i).

If the request has been denied in whole or in part, kindly provide the specific legal basis for such denial in accordance with N.J.S.A. 47:1A-6, including the name and title of the custodian responsible for the decision.

We respectfully request acknowledgment of this follow-up and any updates regarding fulfillment or required clarifications.

Thank you for your attention to this matter.

Yours faithfully,
Sussex Watch Network (SWN)