Dear Sussex County Community College,

Please accept this electronic request for public records made under the New Jersey Open Public Records Act (OPRA) and the common law right of access. As mandated by N.J.S.A. 47:1A‑6(f), I am not required to complete an official form or use any proprietary platform—this email, which contains all required information, constitutes a valid and enforceable government record request.

I HEREBY CERTIFY under penalty of N.J.S.A. 2C:28‑3 that I have not been convicted of any indictable offense under the laws of New Jersey, any other state, or the United States.
I FURTHER CERTIFY that the records sought herein will not be used for any commercial purpose, and are not being requested in connection with any legal proceeding.
Please be advised that the prompt and complete production of these records is required by law. The College’s failure to comply, delay, or improper denial will be treated as presumptive evidence of institutional noncompliance and may be referred to oversight authorities, the Middle States Commission on Higher Education (MSCHE), and, if necessary, judicial enforcement. Please note this request is a public record and all responses from SCCC will be deemed public record.

Records requested:

I hereby demand the immediate production of the following records relating to former President Jon Connolly’s possession of an alleged firearm on SCCC property, all policy authorizations, the College’s response, and law‑enforcement communications. Unless otherwise stated, the scope is November 1, 2015 to present (with incident‑specific items focusing through January 1, 2023 through March 27, 2025):

1. Complete, current, and historical copies of Policy 600.02 (Weapons on Campus) and Policy 600.03 (Weapons on Campus—Authorization to Carry for Retired Police Officers), including revision history, Board approvals/resolutions, redlines, and effective dates since 2015; all training materials, policy acknowledgments, and attestations signed by employees and trustees.

2. All written authorizations, permits, approvals, waivers, letters, or emails purporting to authorize Jon Connolly to possess, carry, store, or transport any firearm and/or weapon on SCCC property; all drafts/unsigned versions and any presidential or designee approvals under Policies 600.02/600.03 (or any similar situated related policies); and any documents reflecting RPO (Retired Police Officer) eligibility, if claimed.

3. The RPO (Red Flag / Extreme Risk Protective Order Act of 2018 (N.J.S.A. 2C:58-20 et seq.) authorization roster/log covering 2020–present: for each authorized individual, produce name, position, dates of authorization, written authorization, RPO credential details, scope of duties, and any revocations/suspensions.

4. All internal communications (emails, texts, messages, memos) discussing whether Jon Connolly qualified for any exception to Policy 600.02/600.03, including any proposal or discussion and any legal analysis regarding authorization requirements, this request includes but is not limited to emails.

5. All SCCC records reflecting admissions, statements or complaints by SCCC staff faculty and/or student faculty that Jon Connolly possessed a firearm during the January 1, 2023 - March 27, 2025 period and removed it when that matter was “over,” including notes, emails, texts, or summaries memorializing such statements, including any complaint or audio submission sent to the College Board of Trustees by any member of staff, including but not limited to, James Gaddy, Jason Boehm, Marianne Sharpe.

6. All records relating to the February 2024 entry and/or search of Jon Connolly’s office by SCCC personnel, including but not limited to:

6a. The full names, job titles, and institutional affiliations of all involved participants involved in the search for Jon Connolly’s firearm (such as Keith Festa, Stacey Caputo, Gayle Carrick);

6b. The stated purpose of the entry/search and the legal, regulatory, or administrative authority under which it was conducted per SCCC’s own policies;

6c. Any and all video or audio recordings, regardless of device, medium, or storage format, including but not limited to the recording publicly identified by SCCC the Chief Operating Officer, James Gaddy, as the “Stacey Caputo video” showcasing the search for the firearm that was made on or around February 8, 2024, in proximity to Jon Connolly’s office, and any recording under any alternative file name, identifier, or storage location;

6d. Any communication by Gayle Carrick that discloses the following terms “search”, “friend”, “trustee”, including any other communications sent by Gayle Carrick, to any SCCC official and/or agent, on or around February 8, 2024.

6e. All other photographs, videos, taken during, in preparation for, or subsequent to the entry/search;

6f. Any incident reports, security reports, internal memoranda, or other written or electronic documentation referencing, describing, or arising from the entry/search.
This request expressly includes, without limitation, responsive materials created, stored, or transmitted on institutional devices, personal devices (including cellphones), removable media, or cloud-based storage accounts used for any official or work-related purpose by SCCC personnel.

7. All risk/wellness/safety assessments or evaluations performed in connection with the firearm issue, including referrals, recommendations, and follow‑up actions related to Jon Connolly, including disciplinary actions from the college board.

8. Board of Trustees materials (2015–present) in which weapons policies or the Connolly firearm matter were discussed: agendas, Board packets, minutes (open and executive), executive‑session resolutions/certifications, notes, and audio/video recordings, including any public comment that mentions “Connolly”, “Gun”, “Firearm”, “Danger”, “Carry”.

9. Communications with Board Chair Kurt Gewecke and College Board of Trustees concerning the firearm issue, including any direction to “follow policy,” to inform/not inform specific parties, to keep the matter internal, or to contact/not contact law enforcement. If such email addresses have been deleted / purged, please certify in writing.

10. Communications with College Counsel (including Vito Gagliardi Esq) concerning the firearm matter, the requirement that any authorization be in writing, whether criminal referral was appropriate, and whether/when to contact police. (If privilege is claimed, produce a Vaughn index.)

11. All communications with law‑enforcement, including the Newton Police Department (including any agent) and the Sussex County Prosecutor’s Office (including any agent), regarding the firearm report, office search, any contemplated police response, and any statement/advice that authorization to carry on campus must be in writing; include emails, texts, call logs, notes, and after‑action summaries, including after‑action or internal summary reports documenting SCCC’s decision‑making regarding law‑enforcement contact or non‑referral.

FOR THE LOCATION OF RECORDS:
i. Custodians to be searched (minimum set): Jon Connolly; James Gaddy; Cory Homer; Kurt Gewecke; College/Board Counsel (incl. outside counsel); Stacey Caputo; Keith Festa; Wendy Fullem; Gayle Carrick; SCCC Public Safety/Security leadership; Accreditation Liaison Officer/Michael Bowden; HR Director; any Trustee or employee who communicated with Newton Police or the Sussex County Prosecutor’s Office regarding this matter.

ii. ESI Protocol & Search Terms (non‑exhaustive): Systems: O365/Exchange, Teams/SharePoint/OneDrive, agency‑issued mobile devices, SMS/iMessage/Signal/Telegram/WhatsApp used for College business, voicemail, security VMS, access‑control, and network shares. Date filters: Nov. 1, 2015–Mar. 27, 2025 (incident); Jan. 1, 2023–present (policies/discipline/governance).

iii. Terms: Connolly w/5 (gun OR firearm OR weapon), RPO, 600.02, 600.03, authorization w/5 (writing OR written), written authorization, Newton Police, NPD, Prosecutor, SCPO, VanNieuwland, Gagliardi, Kurt, Board, Lucas, search office, Stacey recorded, video, wellness, Coffey, Lee.

iv. Format & Fees: Produce electronically in native format with metadata (MSG/PST, DOCX, XLSX, MP4/MOV, WAV/M4A). PDFs only where the native format is PDF. Provide a rolling production commencing within seven (7) business days and continuing weekly until complete. No “special service charge” absent a written, specific, pre‑approved extraordinary cost showing.

v. Exemptions / Redactions: If the college withholds or redacts any portion of a record, produce a detailed Vaughn index identifying the record (author, recipient(s), date, subject), the specific statutory exemption/privilege claimed, and a description sufficient to enable judicial review. Redact only the exempt portion and produce the remainder.
If you assert that any responsive records do not exist or no longer exist, provide a sworn Custodian certification detailing the systems searched, custodians contacted, retention schedules applied, dates of destruction, and reasons.

Please confirm receipt and identify the assigned tracking number.

Respectfully submitted,
Garden State Watchdog
A Public Transparency Initiative & Project

Mission Statement:
Garden State Watchdog exists to monitor, investigate, and hold accountable all public officials, agencies, and publicly funded institutions in New Jersey. Through aggressive enforcement of the Open Public Records Act (OPRA), strategic litigation, and independent investigations, Garden State Watchdog compels transparency, exposes corruption, and protects the civil liberties of New Jersey residents.
We believe secrecy breeds abuse, and that an informed public is the strongest defense against government overreach. By demanding openness and lawful conduct, Garden State Watchdog ensures that New Jersey’s government serves the people — openly, honestly, and without exception.

Dear Sussex County Community College,

Please find our query here:

https://opramachine.com/request/weapons_...

Respectfully submitted,
Garden State Watchdog
A Public Transparency Initiative & Project

Mission Statement:
Garden State Watchdog exists to monitor, investigate, and hold accountable all public officials, agencies, and publicly funded institutions in New Jersey. Through aggressive enforcement of the Open Public Records Act (OPRA), strategic litigation, and independent investigations, Garden State Watchdog compels transparency, exposes corruption, and protects the civil liberties of New Jersey residents.
We believe secrecy breeds abuse, and that an informed public is the strongest defense against government overreach. By demanding openness and lawful conduct, Garden State Watchdog ensures that New Jersey’s government serves the people — openly, honestly, and without exception.

Dear Wendy Fullem

Thank you for your response.

We will await a formal answer to our requests.

Respectfully submitted,
Garden State Watchdog
A Public Transparency Initiative & Project

Mission Statement:
Garden State Watchdog exists to monitor, investigate, and hold accountable all public officials, agencies, and publicly funded institutions in New Jersey. Through aggressive enforcement of the Open Public Records Act (OPRA), strategic litigation, and independent investigations, Garden State Watchdog compels transparency, exposes corruption, and protects the civil liberties of New Jersey residents.
We believe secrecy breeds abuse, and that an informed public is the strongest defense against government overreach. By demanding openness and lawful conduct, Garden State Watchdog ensures that New Jersey’s government serves the people — openly, honestly, and without exception.