Dear North Bergen Township,

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

1. Complete amended filing "Notice of Tort Claim" and “Supplemental Narrative in Support of Notice of Tort Claim,” — 155 pages. The complete Township-held copy of the record identified in the claimant's retained project copy as [3:25:26 Notice of Tort Claim - Amended Filing.pdf], submitted by Jorge A. Sestan-Raposo and acknowledged received by the Township on March 25, 2026 that was reviewed and approved for release by Township Attorney Kirsten Bohn after approximately 10-15 redactions were made, a Vaughn index was created and bates numbering was generated. The production should include every exhibit, appendix, enclosure, and attachment that formed part of that submission, in original order.

This submission of request is not intended to duplicate a pending request. It materially clarifies and narrows the record by exact filename, page count, filing components, receipt date, identified transmittal exchange, and request for any already-existing release copy hcreated, held and maintained by the Township of North Bergen. It also states an independent common-law basis. Please also decide the common-law request independently.

Substantial public-oversight interest

The amended filing that was redacted and prepared for public release memorializes allegations concerning senior municipal and police officials; political-fundraising pressure; integrity of official police reports and work records; administration of Internal Affairs; preservation and evaluation of evidence; alleged retaliation and discriminatory or hostile treatment; and the independence and consistency of the Township's legal and public-records functions.

Why the balance favors at the already created redacted public-release copy

The matters below are allegations asserted in the amended filing or identified related submissions. They are summarized to explain the public interest in access. They are not presented as adjudicated findings, and the custodian is not asked to determine their truth.

1. Political-fundraising pressure and alleged search for a recording device. The filing alleges retired Deputy Chief William Lyons pressured the claimant to purchase Mayor's Ball tickets and imposed a deadline, and that when relief was sought with retired Deputy Chief Gerald Sanzari he mandated Captain Raposo prove he was not wearing a recording device and conducted a strip search of his person behind closed doors in his office. This was reported to DeptuyChief David Corbisiero who at the time was Captain Raposo's supervisor.

2. Integrity of an official police memorandum and preservation of evidence. The filing describes a 2022— incident n which retired Deputy Chief David Corbisiero ordered Lieutenant Edgar Mendez to direct Detective Christopher Orellana to add events that did not occur to an official report which was the basis of an internal affairs investigation. Orellanas's original report and two subsequent reports were destroyed and shredded and Department CCTV captured the vent. Orellana objected and later gave sworn Internal Affairs testimony, that he was pressured into filing a false report against Captain Raposo, the report used as the basis of the investigation was not true as to the events on how they occurred and was created under duress of retaliation. Orellana informed Deputy Chief Corbisiero who spearheaded the internal affairs investigation that the entire incident was captured on CCTV. The same CCTV Orellana presented to Captain Raposo, who also reported the event.

3. Deputy Chief David Corbisiero weaponized the Internal Affairs Function for the North Bergen Police Department since he became the commander in 2024. The filing alleges retired Deputy Chief David Corbisiero initiated a meritless Internal Affairs matter, attempted to blame Sergeant Indira Cabrera, for its initiation similar to how he allegedly manipulated Lieutenant Edgar Mendez and later shifted responsibility to Chief Robert Farley (witness) and Captain Victor Queiro (witness) to avoid being exposed. Lieutenant Santiago Hernandez attempted to shield his boss, Deputy Chief David Corbisiero during these events and also blamed the sergeant. After the meeting, Lieutenant Hernandez acknowledged Deputy Chief Corbisiero targeted Captain Raposo while in the presence of Chief Farley and Captain Victor Queiro. The "broker" Eric Weyand facilitated Deputy Chief David Corbisiero's retirement by explaining to him he should retire to avoid public scrutiny and make everything go away after Deputy Chief David Corbisiero met with Police Commissioner twice at the school. Deputy Chief David Corbisiero retired on March 1, 2026, just 7 days after he was exposed for manipulating data and the internal affairs process with now internal affairs investigation against him as evident in the recent summary and conclusion report request which indicated no investigation commenced even though Commissioner Allen Pascual, Township Attorney Thomas Kobin, Chief Robert Farley, Captain Victor Queiro, Lieutenant Santiago Hernandez and Sergeant Eric Weyand all had knowledge of Deputy Chief David Corbisiero potential criminal wrongdoing and administrative misconduct.

4. Internal Affairs structure, disparate treatment of Hispanic officers, and supervisory accountability. The filing alleges hostile or discriminatory treatment affecting Hispanic department members, including Sergeant Cabrera. The February 2, 2024 assignment in Personnel Order 24-022 placed Deputy Chief David Corbisiero as commander of the Internal Affairs unit and identified as Hernandez, Sergeant Gleny Henry, and Investigator Eric Weyand as his subordinates even though Deputy Chief David Corbisiero had sustained findings of disparate treatment of Hispanic officers and additional falsified investigations raising supervisory-accountability concerns.

5. Official-record integrity after notice of anticipated litigation. The filing and a related April 19, 2026 submission allege later changes to workday or timekeeping records after notice of anticipated litigation. While reporting the misconduct to Chief Farley he decided to leave the vehicle after being on speaker phone with Captain Raposo on Captain Queiro's phone to maintain his plausible deniability and easily forgetful memory.

6. Municipal legal advice, independence, and public-records administration. Related materials allege non-neutral decision-making by Township Attorney Thomas R. Kobin, including advice concerning Assemblyman Larry Wainstein at Township housing properties. Township Attorney has repeatedly provided inaccurate information especially his unqualified definition of solicitation and refusal to provide guidance on appropriate enforcement with motive to obstruct, impair and prevent Assemblyman Wainstein from meeting with his constituents to offer services. Township Attorney Thomas Kobin also refused to release the original tort claim on orders from Police Commissioner Allen Pascual after Township Attorney Kirstin Bohn reviewed and approved a redacted public release copy for dissemination. Bohn is the Township's subject-matter specialist for OPRA related matters.

7. Why disclosure serves the public. The subject matter concerns senior officials, Internal Affairs and record integrity, alleged political pressure, discrimination and retaliation, and taxpayer-funded legal and OPRA administration. A redacted release would let the public evaluate what was formally alleged and received while protecting legitimate confidential interests.

My preferred delivery method for response(s) to this request is on this OPRA Machine portal. 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,

Alicia Raposo