Carolyn Conboy, Fund Administrator

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:

Complete copies of Resolutions EC25-39 and EC25-41, including all attachments, exhibits, memoranda, engagement letters, and any documents incorporated by reference.

All "EUS Certification – Defense Attorneys" resolutions and attachments for calendar years 2023, 2024, and 2025, including any lists of approved defense firms or panel counsel.

All engagement letters, retainer agreements, appointment letters, or correspondence between SIF, D&H Alternative Risk Solutions, or any claims administrator and McGivney, Kluger, Clark & Intoccia, P.C., from January 1, 2023 to present.

All invoices, billing statements, or payment vouchers submitted by or paid to McGivney, Kluger, Clark & Intoccia, P.C. referencing:
the Town of Newton, and/or
any of its police officers (including but not limited to Steven Van Nieuwland, Steven Siek, Eric Soroka, and Judy Torres), and/or
any matter referencing “Coffey”, “Coffey v. Newton,” or “Coffey v. Sussex County.”

All SIF claim notes, internal memoranda, emails, or communications relating to the selection or appointment of special counsel for any claim arising from or relating to Plaintiff Lee Coffey.

All documents reflecting conflict-of-interest analysis, ethics review, or recusal considerations pertaining to:
Thomas S. Russo, in his role as Town Manager of Newton and Chair of the SIF Executive Committee; and
Ronald L. Tappan, in his role as Sussex County Administrator and SIF Trustee.

Please provide the full voting record, roll-call sheets, sign-in sheets, attendance logs, and any documents reflecting votes cast by Executive Committee members for Resolutions EC25-39 and EC25-41, including but not limited to:
The roll-call vote identifying each member’s vote;

Any attendance certification;

Any memoranda or internal correspondence distributed to Executive Committee members prior to the vote;

Any attachments identifying the litigation matter or the name of the appointed special counsel.”

My preferred delivery method for response(s) to this request is by E-mail as attachments. 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.

This request seeks non-privileged government records. To the extent SIF asserts any privilege, OPRA requires production of a privilege log describing the withheld materials with sufficient specificity.

Thank you for your prompt attention.

Sincerely,
Regulatory Compliance.