Dear Cranford 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:
I would like a copy of all use of force reports from January 1, 2025 through April 1, 2026

I would like a copy of the ada coordinators paycheck from March 2, 2026 through April 1, 2026

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,

William Bailey

Dear Clerk,

I am glad you received the request, the payroll check is an immediate access item, I trust I will receive today by the close of business today, have a blessed day.

Yours sincerely,

William Bailey

Dear Donahue, Patricia,

April 24, 2026

Township Clerk / Custodian of Records Township Administration Department [Township Address]

RE: REBUTTAL TO OPRA DISPOSITION – REQUEST FOR ADA COORDINATOR PAYROLL RECORDS (MARCH 2, 2025 – APRIL 1, 2026)

To the Custodian of Records and the Township Solicitor:

I am writing this formal response to your correspondence regarding my Open Public Records Act (OPRA) request for the payroll records of the Township’s ADA Coordinator. Your response, stating that the “Administration Department currently handles all Township complaints,” is not only a non-responsive evasion of a valid OPRA request but also suggests a systemic failure of the Township to comply with mandatory federal and state civil rights obligations.

I. Violation of the New Jersey Open Public Records Act (OPRA)

Under N.J.S.A. 47:1A-1 et seq., the Township is required to provide access to government records. Specifically, N.J.S.A. 47:1A-10 explicitly mandates that "an individual's name, title, position, salary, payroll record, length of service, date of separation and the reason therefor, and the amount and type of any pension received shall be a government record."

By directing me to a general "Administration Department" email instead of providing the specific payroll records of a designated "ADA Coordinator," you have failed to fulfill your statutory duty. If the Township does not have a designated ADA Coordinator, you must state so affirmatively under certification. If such a person exists, their payroll records for the requested period are public records, and your failure to produce them constitutes a "knowing and willful" violation of OPRA, subject to the assessment of attorney’s fees and civil penalties.

II. Mandates Under Federal Law (ADA Title II)

The Township’s assertion that the “Administration Department” handles complaints is legally insufficient. Under Title II of the Americans with Disabilities Act (ADA), specifically 28 C.F.R. § 35.107(a):

"A public entity that employs 50 or more persons shall designate at least one employee to coordinate its efforts to comply with and carry out its responsibilities under this part..."

The law requires the designation of a specific person, not a nameless department. This coordinator is responsible for investigating grievances and ensuring the Township provides equal access to services. In Chisolm v. McManimon, 275 F.3d 255 (3d Cir. 2001), the Court emphasized that public entities in this jurisdiction are strictly bound by the procedural and substantive requirements of Title II. The lack of a designated, identifiable coordinator is a per se violation of federal law for any municipality of qualifying size.

III. The New Jersey Law Against Discrimination (LAD)

Furthermore, the New Jersey Law Against Discrimination (LAD), N.J.S.A. 10:5-1 et seq., is one of the most stringent civil rights statutes in the nation. The New Jersey Supreme Court has repeatedly held that the LAD is to be liberally construed to eradicate the "cancer of discrimination." Cedeno v. Montclair State Univ., 163 N.J. 473 (2000).

Failure to designate a specific individual to handle ADA/LAD accommodations creates a barrier to access, effectively denying residents with disabilities their right to petition the government. By failing to provide a payroll record for an ADA Coordinator, the Township is essentially admitting that it lacks the infrastructure required to prevent discrimination in public accommodations, as mandated under N.J.A.C. 13:13-3.1.

IV. Legal Precedent Regarding Municipal Responsibility

In the matter of K.M. ex rel. Bright v. Tustin Unified Sch. Dist., 725 F.3d 1088, the court reaffirmed that public entities must take proactive steps to ensure communication with individuals with disabilities is as effective as communication with others. A faceless "Administration Department" email box does not meet the "effective communication" or "reasonable modification" standards required when a resident needs to interact with an actual human being tasked with compliance.

FINAL DEMAND

The Township's response is a transparent attempt to obfuscate the fact that it may be in violation of federal and state mandates. You are hereby demanded to:

Produce the specific payroll records (inclusive of name, title, and salary) for any individual(s) who held the title or performed the primary functions of "ADA Coordinator" from March 2, 2025, through April 1, 2026.
Affirmatively state if no such designated position exists, so that I may properly file the appropriate grievances with the U.S. Department of Justice (DOJ) and the New Jersey Division on Civil Rights.

Be advised that under the OPRA statute, a prevailing party is entitled to reasonable attorney's fees. If this matter is not resolved via the production of the requested records within forty-eight (48) hours, I will seek immediate judicial intervention in the Superior Court of New Jersey.

Govern yourselves accordingly.

Respectfully submitted,

William Bailey

Dear Stiansen, Thomas,

I don't want the summaries I want the actual use of force reports that are filled out on each incident.

Yours sincerely,

William Bailey