The request invalid under OPRA as it fails to specify the subject of the emails sought. The Government Records Council (“GRC”) has established specific criteria deemed necessary under OPRA to request an e-mail communication. See Elcavage v. West
Milford Twp. (Passaic), GRC Complaint No. 2009-08 (Apr. 8, 2010) (stating that a proper request for email correspondence must contain “(1) the content and/or subject of the e-mail, (2) the specific date or range of dates during which the e-mail was transmitted or the emails were transmitted, and (3) a valid e-mail request must identify the sender and/or the recipient thereof”).
In May 2024, the Legislature amended OPRA to incorporate the standard set forth in Elcavage into the statute by specifically requiring requests for correspondence to “identify a specific job title or accounts to be searched, a specific subject matter, and [be] confined to a reasonable time period.”  See N.J.S.A. 47:1A-5(g) (amended effective September 4, 2024).

Should you wish to provide more specific information (i.e. specific date or range of dates) please resubmit a new OPRA.

-----Original Message-----
From: Anonymous Resident <[OPRA #93685 email]>
Sent: Thursday, July 23, 2026 8:05 PM
To: Nicole Castellucci <[Clark Township request email]>
Subject: EXTERNAL- OPRA request - Toll Records for Vehichle

CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

Dear Clark 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:

We would like toll records or copies of EZ Pass bills for the car with license plate of MG94384

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.

Yours faithfully,

Anonymous Resident

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[OPRA #93685 email]

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