Resolutions EC25-39 / EC25-41, Defense Counsel Appointments, Claim File Materials, and Engagement Letters
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.
Dear “Regulatory Compliance”:
You have submitted an OPRA request through the mechanism of the OPRAMachine using the name of “Regulatory Compliance”. We are unable to identify any properly constituted entity under that name.
Furthermore, you have represented that you have not been convicted of any crime but other OPRA requests seeking similar, related documents, have been submitted by an individual for whom there is extant evidence that individual has been convicted of a crime and may be a fugitive from justice.
Also, you have represented that this matter is not being used in connection with litigation. We know from other OPRA requests that have already been responded to, information supplied in those requests and other sources, that there is litigation against Sussex County, Sussex County Community College, the Town of Newton, and other individuals that appear related to this request and may be subject to various discovery limitations, which have not and cannot be identified at this time
In addition, you have represented that your request is not for commercial purposes. Unfortunately, the vague name used as the requester’s name, and the fact that no identifiable entity has submitted the request, makes it impossible to determine whether there is some contemplated commercial use for this information.
Unfortunately, because of the apparent misrepresentations and confusion created by your request, it cannot be fulfilled at this time. If a proper request is submitted, it will be responded to in the appropriate way.
Sincerely,
Caroline Conboy
Fund Administrator
Statewide Insurance Fund
1 Sylvan Way
Parsippany, New Jersey 07054
862-260-2055
-----Original Message-----
From: Regulatory Compliance <[OPRA #83880 email]>
Sent: Monday, December 1, 2025 2:45 PM
To: Caroline Conboy <[SIFNJ request email]>
Subject: OPRA request - Resolutions EC25-39 / EC25-41, Defense Counsel Appointments, Claim File Materials, and Engagement Letters
[You don't often get email from [OPRA #83880 email]. Learn why this is important at https://aka.ms/LearnAboutSenderIdentific... ]
[External]
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.
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