Date: June 11, 2026

VIA EMAIL AND CERTIFIED MAIL

Wendy Fullem, Records Custodian
Sussex County Community College
1 College Hill Road
Newton, NJ 07860

Re: Follow-Up OPRA and Common-Law Request – August 22–23, 2023 Bomb-Threat Incident (Karl Taguinod) and MSCHE-Related Records

CC (for informational purposes):

Katharine Fina, Esq., College Counsel
President Dr. Cory Homer
New Jersey Government Records Council

Dear Ms. Fullem:

This letter follows your June 3, 2026 response to my May 12, 2026 OPRA request. In that response, Sussex County Community College ("SCCC" or the "College") denied numerous request items as overly broad and produced complaint-log records that contain no apparent reference to the August 22–23, 2023 bomb-threat incident involving former student Karl Taguinod.

I am writing with additional information concerning that incident and to submit a revised and more narrowly tailored request for identifiable government records relating to whether the incident was reported, discussed, evaluated, or referenced in connection with accreditation matters involving the Middle States Commission on Higher Education ("MSCHE").

I. Publicly Available Evidence Concerning the August 2023 Incident

Records obtained from the Sussex County Prosecutor's Office indicate that criminal charges were filed against Karl Taguinod arising from events occurring on or about August 22–23, 2023.

According to the criminal complaint, the charges included:

• False Public Alarm, N.J.S.A. 2C:33-3a(1)(a);
• Threatening Arson to Cause Evacuation, N.J.S.A. 2C:12-3a; and
• Terroristic Threats, N.J.S.A. 2C:12-3b.

The complaint further states, in relevant part, that the conduct at issue resulted in the evacuation and lockdown of the Sussex County Community College campus.

These records indicate that the incident involved a significant campus-safety event requiring law-enforcement response.

II. Basis for Follow-Up Request

The College's June 3, 2026 response did not identify records addressing whether the August 2023 incident was reported to, discussed with, or considered in connection with MSCHE accreditation obligations.

Given the documented campus evacuation and lockdown described in the criminal complaint, records concerning whether the incident was evaluated for accreditation-reporting purposes would reasonably be expected to exist if the matter was considered in connection with MSCHE requirements, institutional reporting obligations, campus-safety assessments, or accreditation review processes.

To address the College's prior overbreadth concerns, the requests below are limited to identifiable categories of records, defined subject matter, and specific date ranges.

III. Revised and Narrowed Request for Government Records

Pursuant to the Open Public Records Act, N.J.S.A. 47:1A-1 et seq., and the common-law right of access, I request the following records:

1. Accreditation Submissions Referencing the Incident

Any MSCHE self-study report, Self-Study Design document, Standards Implementation Report (SIR), Verification of Compliance submission, monitoring report, substantive response, supplemental submission, accreditation narrative, or similar accreditation-related document prepared, transmitted, or submitted between August 22, 2023 and the date this request is processed that contains any reference to:

• Karl Taguinod;
• the August 22–23, 2023 incident;
• bomb threat;
• false public alarm;
• threat to commit arson;
• terroristic threat;
• evacuation; or
• lockdown.

2. Campus Safety Materials Provided to MSCHE

Any report, memorandum, summary, presentation, assessment, spreadsheet, incident review, compliance document, or supporting material transmitted to MSCHE between August 1, 2023 and December 31, 2023 that addresses:

• campus safety incidents;
• emergency response events;
• threat assessments;
• violent-threat investigations;
• student conduct matters involving threats of violence; or
• complaints relating to campus safety.

3. Communications Between SCCC and MSCHE

Email correspondence, letters, accreditation-portal communications, transmittal messages, or attachments exchanged between SCCC personnel and MSCHE representatives from August 22, 2023 through the date this request is processed that contain any of the following terms:

• "Karl Taguinod"
• "bomb threat"
• "false public alarm"
• "terroristic threat"
• "evacuation"
• "lockdown"
• "2C:33-3"
• "2C:12-3"

4. Internal Records Concerning Potential MSCHE Disclosure

Email correspondence, memoranda, meeting minutes, agenda materials, accreditation working-group records, Board materials, briefing documents, or accreditation-planning records dated August 22, 2023 through December 31, 2024 that discuss whether the August 22–23, 2023 incident should be reported, disclosed, referenced, summarized, or otherwise included in materials provided to MSCHE.

For purposes of locating responsive records, offices reasonably likely to possess such records include:

• Office of the President;
• Accreditation Liaison Officer;
• Office of Student Affairs;
• Public Safety Department;
• Office of College Counsel; and
• personnel assigned accreditation-related responsibilities.

5. Existing Records Reflecting Whether Disclosure Occurred

Any existing record sufficient to show whether the August 22–23, 2023 incident was disclosed to MSCHE, including:

• transmittal correspondence;
• accreditation submission logs;
• compliance-tracking records;
• acknowledgment communications;
• accreditation-status reports; or
• records reflecting the contents of materials transmitted to MSCHE.

6. Withheld Records Index

For each responsive record withheld in whole or in part, please provide a privilege log or index identifying:

• date;
• author;
• recipient(s);
• record type;
• general subject matter; and
• the specific statutory, regulatory, common-law, or privilege basis asserted for withholding.

IV. Common-Law Right of Access

To the extent the College contends that any requested record is exempt from disclosure under OPRA, I also request consideration under the common-law right of access.

The records sought concern a documented campus-safety incident that reportedly resulted in an evacuation and lockdown of the College campus. Disclosure bears directly upon matters of public concern, including campus safety, institutional accountability, accreditation compliance, and the manner in which significant safety events are evaluated and reported by public institutions of higher education.

V. Certification if No Records Are Located

If the College contends that no responsive records exist for any item above, please provide a certification from the records custodian identifying:

• the offices searched;
• the custodians consulted;
• the search methods used; and
• the basis for concluding that no responsive records were located.

VI. Request for Timely Response

Please produce the responsive records, provide a privilege log for withheld records, or identify the legal basis for any denial within the time required by OPRA.

Nothing in this letter should be construed as a waiver of rights arising from my May 12, 2026 request, any related OPRA claims, or any rights available under the common-law right of access.

Please be advised that copies of this request are being provided to the Middle States Commission on Higher Education ("MSCHE") and the United States Department of Education for informational and oversight purposes. This notice is provided solely to ensure transparency regarding matters involving campus safety, institutional reporting, and accreditation-related compliance. Nothing in this correspondence should be construed as a waiver of any rights available under OPRA, the common-law right of access, or other applicable law.

Thank you for your attention to this matter.

Very truly yours,
Harry Langer, Esq.

Dear Sussex County Community College,

Please pass this on to the person who conducts Open Public Records Act reviews.

I am writing to request an internal review of Sussex County Community College's handling of my OPRA request 'Request before Legal Action - SCCC'.

A full history of my OPRA request and all correspondence is available on the Internet at this address: https://opramachine.com/request/request_...

Yours faithfully,
Harry Langer Esq

Dear Sussex County Community College,

Please pass this on to the person who conducts Open Public Records Act reviews.

A full history of my OPRA request and all correspondence is available on the Internet at this address: https://opramachine.com/request/request_...

Yours faithfully,
Harry Langer Esq