Links.

For those continuing to read and review this Blog, its full electronic address and Uniform Resource Locator (URL), as you already know, is:
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Please feel free to bookmark and save these additional URLs, and use them as needed.

Thank you for your support of this Blog and the cause of "Unhand Piermont!" Together we will repopulate Piermont Village Hall with public officials who are actually ethical, responsible, and competent.

Zap Three Times.

 
Law Office of John J. Tormey III, Esq.
John J. Tormey III, PLLC
1636 Third Avenue, PMB 188
New York, New York  10128  USA
(212) 410-4142 (phone)
(212) 410-2380 (fax)
jtormey@optonline.net

https://www.tormey.org
 
REQUEST UNDER THE NEW JERSEY OPEN PUBLIC RECORDS ACT (“OPRA”)
 
Tuesday, January 7, 2025

 
VIA U.S. MAIL and E-MAIL:
OAG.Records@njoag.gov
Office of the New Jersey Attorney General

Records Custodian
25 South Market Street (PO Box 081)
Trenton, New Jersey  08625  USA

VIA U.S. MAIL and E-MAIL:
TuckerP@dca.lps.state.nj.us
Philameana Tucker, Executive Director
Board of Examiners of Electrical Contractors
P.O. Box 45006
Newark, New Jersey  07101  USA
 
VIA U.S. MAIL and E-MAIL:
TuckerP@dca.njoag.gov
Philameana Tucker, Executive Director
Board of Examiners of Electrical Contractors
P.O. Box 45042
Newark, New Jersey  07101  USA
 
VIA U.S. MAIL
Philameana Tucker, Executive Director
Board of Examiners of Electrical Contractors
124 Halsey Street #6
Newark, New Jersey  07102  USA
 
Re:                 
(Plenary) City of Elizabeth, Liquor Retail License No.: 2004-33-227-001
Business: “Front Street Smokehouse & Saloon, Inc.” – (908) 354-1818 – www.frontstreetsmokehouse.com
Location: One South Front Street, Elizabeth, New Jersey 07206 USA (Elizabeth Avenue and Front Street).
Possible Aliases: a/k/a “Lava Lounge”, f/k/a “South Seas Bar”.
Principal: Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA.
Principal: Philip Costanza, 523 3^rd Avenue, Elizabeth, New Jersey 07202 USA.
Principal: Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.

Dear Ms. Tucker, and Colleagues:
 
I am an attorney in New York. I am a citizen and resident of the Town of Orangetown, and the County of Rockland. Under the New Jersey Open Public Records Act (“OPRA”), P.L. 2001, c. 404, N.J.S.A. 47:1A-1 et seq.:
https://nj.gov/opra/
https://www.nfoic.org/new-jersey-sample-OPRA-request
https://en.wikipedia.org/wiki/Open_Public_Records_Act
… request is hereby made that your office provide to this, my law office, full and complete copies of each and every document and other item of material (collectively, “Records”) which may be at all responsive to the following itemized and specific OPRA requests:
 
1. Time-Frame. I am seeking all Records reflecting, referencing, or otherwise relating to the above-referenced bar, restaurant, businesses, location, and/or individuals from January 1, 2000 forward to the present day.
 
2. The Restaurant And Bar. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “Front Street Smokehouse & Saloon, Inc.” of Elizabeth, New Jersey, including without limitation any of the following more specific types of matters:
 
Electrical matters, electrical licensing matters, electrical contracting matters, health, safety and welfare matters, the Electrical Contractors Licensing Act of 1962, electrical licensure, electrical permitting, business permitting, business permitting renewals, business licensing, business licensing renewals, whistleblower protections, working conditions, workplace health, workplace safety, police calls or visits, fire calls or visits, EMS calls or visits, other emergency calls or visits, economic development, film permits, sewers, utilities, public works, engineering, stormwater, tax accounting, tax control, tax assessments, tax collections, construction, licensing, planning, zoning, city ordinances, public health, environmental health, solid waste, garbage, recycling, refuse, and any other environmental matters, Americans With Disabilities Act (ADA) compliance, apprenticeships, child labor, collective bargaining, Consumer Credit Protection Act (CCPA), discrimination, employee benefits, Employee Retirement Income Security Act (ERISA), Fair Labor Standards Act (FLSA), Family And Medical Leave Act (FMLA), firing, hiring, Immigration And Nationality Act (INA), New Jersey Sanitary Code (NJSC), independent contractor arrangements, internships, layoffs, maternity leave, paternity leave, minimum wage standards, nonimmigrant workers, overtime, pay equivalency, pensions, personal service agreements, postering, recordkeeping, right to work matters, tips, underpayments, unemployment insurance, unfair labor practices, unionization, visas, wages, wage garnishment, workers’ compensation.
 
3. Liquor License. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to City of Elizabeth, New Jersey liquor Retail License No.: 2004-33-227-001. As a point of reference, Records which I have located thusfar from media sources relating to this liquor Retail License and the bar and restaurant can be found at:
https://unhandpiermont.blogspot.com/2024/12/piermont-mayor-bruce-tuckers-foray-into.html
 
4. The Phone Number. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the phone number of Front Street Smokehouse & Saloon, Inc. identified as: “(908) 354-1818”.
 
5. The Website. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the Internet website of Front Street Smokehouse & Saloon, Inc. identified as:

www.frontstreetsmokehouse.com
 
6. The Location. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the location of One South Front Street, Elizabeth, New Jersey 07206 USA – found at the corner of Elizabeth Avenue and Front Street.
 
7. Lava Lounge. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “Lava Lounge”, an apparent alias of the bar and restaurant.
 
8. South Seas Bar. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “South Seas Bar”, the apparent prior name of a bar at the same location.
 
9. Bruce Edward Tucker. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA. You may recognize this individual’s name, as he currently serves as the Mayor of the Village of Piermont, New York, while at one point apparently maintaining an ownership interest in the subject bar and restaurant in Elizabeth, New Jersey.
 
10. Philip Costanza. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Philip Costanza, 523 3rd Avenue, Elizabeth, New Jersey 07202 USA.
 
11. Bruce L. Kain. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.
 
12. The “Smokehouse Parties” – Possible Types Of Records. Next, for your ease of reference, I will now refer to these following people, places, and businesses, collectively, as, simply, the “The Smokehouse Parties”:
 
- Retail Licensee No.: 2004-33-227-001.
- Front Street Smokehouse & Saloon, Inc.
- One South Front Street, Elizabeth, New Jersey 07206 USA (Elizabeth Avenue and Front Street)
- “Lava Lounge”.
- “South Seas Bar”.
- Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA.
- Philip Costanza, 523 3rd Avenue, Elizabeth, New Jersey 07202 USA.
- Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.
(collectively, “The Smokehouse Parties”).
 
I am seeking, in each case to the extent as may be existing:
 
(a). Incidents. All Records - if any - reflecting, referencing, or otherwise relating to any accidents, incidents, citations, tickets, deficiencies, non-compliance, unsafe conditions, hazardous conditions, other conditions, injuries, “Dram Shop Act” events, recalls, health matters, environmental matters, New Jersey Sanitary Code violations, or other untoward occurrences - including without limitation in connection with any contamination, infection, disease, hygiene problem, food poisoning, other poisoning, other unsanitary condition, transportation, labelling, mis-labelling, air pollution, noise pollution, water pollution, other water quality concerns, ambulance call, EMS call, hospitalization, medical attention, contagion, “spreader” event, epidemic, pandemic, hazardous material, hazardous waste, solid waste, sewage, storage tanks, insecticides, rodenticides, pesticides, garbage, sanitation, pollution, food waste, other waste, or other refuse - at the subject location of “One South Front Street, Elizabeth, New Jersey  07206  USA”, or otherwise relating to The Smokehouse Parties or any of them, whether relating to food processing, preparation, storage, handling, dressing, sale, quality-control, quality-assurance, disposal, personal injuries, or otherwise.
 
(b). Complaints. All Records reflecting, referencing, or otherwise relating to any employee, worker, independent contractor, intern, apprentice, vendor, customer, patron, consumer, resident, citizen, or other complaints about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(c). Inspections. All Records reflecting, referencing, or otherwise relating to any inspections of, or otherwise concerning, the subject location of One South Front Street, Elizabeth, New Jersey 07206 USA, or otherwise relating to The Smokehouse Parties or any of them.
 
(d). Food-Related Or Solid Waste Licenses, Permits, And Renewals. All Records reflecting, referencing, or otherwise relating to any food-related, solid waste, or other licensure, licenses, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(e). Alcohol Licenses, Permits, And Renewals. All Records reflecting, referencing, or otherwise relating to any alcohol-related or other licensure, licenses, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(f). Applications And Renewals. All Records reflecting, referencing, or otherwise relating to any applications or renewals for licenses, permits, or other permissions, of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the applications themselves.
 
(g). “Retail Licenses”, Permits, And Renewals. Specifically, all Records reflecting, referencing, or otherwise relating to any “retail licenses”, licensure, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(h). Adverse Actions Against Licenses Or Permits. All Records reflecting, referencing, or otherwise relating to any license, permit, or other suspensions, cancellations, revocations, or terminations, of or otherwise concerning The Smokehouse Parties or any of them – if any.
 
(i). Proceedings. All Records reflecting, referencing, or otherwise relating to any administrative, legal, or other proceedings about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(j). Claims And Litigations. All Records reflecting, referencing, or otherwise relating to any claims, mediations, arbitrations, or litigations about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(k). Enforcement Actions. All Records reflecting, referencing, or otherwise relating to any enforcement or comparable actions against, about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(l). Fines Or Other Penalties. All Records reflecting, referencing, or otherwise relating to any fines or other penalties assessed against or otherwise imposed upon The Smokehouse Parties or any of them – if any.
 
(m). Violations. All Records reflecting, referencing, or otherwise relating to any violation or claimed violation of any other laws, statutes, ordinances, regulations, rules, requirements, or standards by, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(n). Employment And Labor Matters. All Records reflecting, referencing, or otherwise relating to any other labor or employment matters of, or otherwise concerning, The Smokehouse Parties or any of them, as described hereinabove.
 
(o). E-Mails And Correspondence. All Records of any e-mails, memos, notes, correspondence, documents, or other writings to, from, referencing, or otherwise relating to The Smokehouse Parties or any of them.
 
(p). License Transfers. All Records reflecting, referencing, or otherwise relating to any transfer of any retail license or other transfers of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(q). Premises Expansions. All Records reflecting, referencing, or otherwise relating to any premises expansions of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(r). Objections. All Records reflecting, referencing, or otherwise relating to any objections to expansions, transfers, or other proposed or completed actions by, of, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(s). Stock. All Records reflecting, referencing, or otherwise relating to any “stockholding” or stockholder information or changes thereto, of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(t). Property Documentation. All Records reflecting, referencing, or otherwise relating to any property record, property title, or other property documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(u). Insurance or Bonding Documentation. All Records reflecting, referencing, or otherwise relating to any insurance or bonding documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(v). Tax Documentation. All Records reflecting, referencing, or otherwise relating to any tax, tax payment, tax history, tax credit, tax arrearage, tax warrant, or other tax-related documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(w). Fee Documentation. All Records reflecting, referencing, or otherwise relating to any fee, fee payment, fee history, fee credit, fee arrearage, or other fee-related documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(x). Land Use. All Records of planning, certified plans, engineering, zoning, applications, approvals, permits, permissions, variances, inspections, code enforcement, compliance vel non, stop-work orders, land use, intended land use, soil conservation, erosion, sediment control, sedimentation, stormwater management, land disturbance, environmental concerns, building, construction, insurance, bonding, escrows, taxation, financing, complaints, or neighborhood opposition, including inter alia e-mails, minutes, resolutions, and deliberative materials, relating to The Smokehouse Parties or any of them.
 
(y). All Other Records. All other Records of any other kind or nature relating to The Smokehouse Parties or any of them.
 
13. Violations Of Laws – IF Any. Specifically and without limitation to the foregoing, I am hereby seeking, to the extent if at all existing, each and every Record reflecting any “violation”, “reporting violation”, or other past, present, future, or anticipated violation, breach, or other transgression of federal, state, county, town, local, or other ordinance, rule, regulation, requirement, or other law or standard - including without limitation any violation of rules, regulations or other laws enforced by or otherwise relating to or concerning any of the following:
 
Environmental Protection Agency (EPA).
Centers For Disease Control (CDC).
Agency for Toxic Substances and Disease Registry (ATSDR).
Health Resources and Services Administration (HRSA).
National Institutes of Health (NIH).
United States Department Of Justice (USDOJ).
U.S. Attorney’s Office (USATTY).
Federal Bureau Of Investigation (FBI).
U.S. Department of Health & Human Services (USHHS).
Office of the Inspector General, Department of Health and Human Services (OIG).
U.S. Department of Homeland Security (USDHS).
Federal Emergency Management Agency (FEMA).
Office of the New Jersey Governor (NJ GOV).
New Jersey Office of Homeland Security and Preparedness (NJOHSP).
New Jersey Office of Emergency Management (NJOEM).
New Jersey Department Of Environmental Protection (NJDEP).
New Jersey Department of Health (NJDOH).
Your New Jersey Board of Examiners of Electrical Contractors.
Union County Department of Public Safety (UCDPS).
Union County Department of Health Management (UCDOH).
City of Elizabeth New Jersey, Health Department (Elizabeth Health).
United States Department of Agriculture (USDA).
USDA Food Safety and Inspection Service (FSIS).
U.S. Food and Drug Administration (FDA).
Union County Utilities Authority (UCUA).
Union County Clerk (UC Clerk).
Union County Utilities Authority
New Jersey Department of Law & Public Safety, Division of Alcoholic Beverage Control (NJABC).
Municipal Board of Alcoholic Beverage Control, City of Elizabeth, New Jersey (Elizabeth A.B.C. Board).
Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).
U.S. Equal Employment Opportunity Commission (EEOC).
U.S. Department of Justice (USDOJ), Civil Rights Division (CRD).
Occupational Safety and Health Administration (OSHA).
United States Department of Labor (USDOL).
U.S. Immigration & Customs Enforcement (ICE).
New Jersey Department of Labor and Workforce Development (NJDOL).
New Jersey Office of the Attorney General (NJAG).
New Jersey AG Division of Consumer Protection/Regulated Business Section (DCA/OCP).
New Jersey Department Of Banking And Insurance (NJDBI).
New Jersey Board of Examiners of Electrical Contractors (NJBEEC).
All other New Jersey state and local agencies.
Any other potentially-relevant government agency or authority.
 
14. Definition Of “Records”. “Records” should be construed in the broadest sense and manner possible and should include any information kept, held, filed, produced or reproduced by, with or for your agency or office in any physical form whatsoever, including without limitation all audio recordings, blog posts, correspondence, data maintained electronically, data, e-mails, executive summaries, extracts, faxes, instant messages, Internet posts, letters, log-book entries, memos, paper records, personal messages, social media communications, spreadsheets, summaries, synopses, telephone records, test-reports, visual recordings, and any other materials.
 
15. Headings. The headings and sub-headings for numbered Items #1 through #18 herein are for purposes of your convenience of reference only, and should not be construed to be words of limitation or otherwise of any substantive significance relative to this OPRA request.
 
16. Costs. If there are any copying or other fees for this, please let me know what they are and how they are calculated, before fulfilling the request and forwarding the Records to me. As this OPRA request should be considered a matter of public importance, and as its results will be shared with the general public, I am asking that any otherwise-applicable fees be waived for this production of Records. I am also asking that all Records be provided to me electronically to the full extent possible, so as to obviate the need for any photocopying expense.
 
17. Appeals. In the event that any portion of my request is denied, please inform me of each of the specific reasons for any such denial in writing - and provide me with the name, address, and other contact information of the person or entity to whom an appeal should be directed.
 
18. Additional OPRA Requests. This OPRA request is not intended to be exhaustive, and I may need to make additional or follow-up requests.
 
I will appreciate a response from you and your office as soon as possible. I look forward to hearing from you shortly.
 
Respectfully, and with thanks,

John J. Tormey III, Esq.
 
cc:
VIA U.S. MAIL and E-MAIL:
grc@dca.state.nj.us
Government Records Council (GRC)
PO Box 819
Trenton, New Jersey  08625  USA

The EPA Hail Mary.

Law Office of John J. Tormey III, Esq.
John J. Tormey III, PLLC
1636 Third Avenue, PMB 188
New York, New York  10128  USA
(212) 410-4142 (phone)
(212) 410-2380 (fax)
jtormey@optonline.net
https://www.tormey.org
 
REQUEST UNDER THE FREEDOM OF INFORMATION ACT (“FOIA”)

Tuesday, January 7, 2025
 
VIA FAX: 1-212-637-5046, U.S. MAIL, and E-MAIL:
r2foia@epa.gov
calderon.wanda@epamail.epa.gov
Wanda Calderon - Government Information Specialist
EPA - Region 2 - Main Regional Office
U.S. Environmental Protection Agency (EPA)
290 Broadway, 26^th Floor
New York, New York  10007-1866  USA
 
VIA FAX: 1-212-637-5046, U.S. MAIL, and E-MAIL:
ruvo.richard@epa.gov
Richard Ruvo - Director, Air & Radiation Division
EPA - Region 2 - Main Regional Office
U.S. Environmental Protection Agency (EPA)
290 Broadway, 26^th Floor
New York, New York  10007-1866  USA
 
VIA U.S. MAIL
EPA – Region 2 - Edison, NJ Environmental Center
U.S. Environmental Protection Agency (EPA)
2890 Woodbridge Ave.
Edison, New Jersey  08837-3679  USA
 
VIA U.S. MAIL
National Freedom of Information Act (FOIA) Office
U.S. Environmental Protection Agency (EPA)
1200 Pennsylvania Avenue NW (2310A)
Washington, DC  20460  USA
 
Re: City of Elizabeth, NJ (Plenary) Liquor Retail License No.: 2004-33-227-001
Business: “Front Street Smokehouse & Saloon, Inc.” – (908) 354-1818 – www.frontstreetsmokehouse.com
Location: One South Front Street, Elizabeth, New Jersey 07206 USA (Elizabeth Avenue and Front Street).
Possible Aliases: a/k/a “Lava Lounge”, f/k/a “South Seas Bar”.
Principal: Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA.
Principal: Philip Costanza, 523 3^rd Avenue, Elizabeth, New Jersey 07202 USA.
Principal: Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.
 
Dear Ms. Calderon, Mr. Ruvo, and Colleagues:
 
As you may recall from prior correspondence on other matters, I am an attorney in New York, and a citizen and resident of the Hamlet of Pearl River, the Town of Orangetown, and the County of Rockland. Under Title 5 of the United States Code, Section 552 (5 U.S.C. §552) (“FOIA”):
http://www.law.cornell.edu/uscode/text/5/552
request is hereby made that you and your offices timely provide to this, my law office, full, complete, unredacted, and otherwise unexpurgated copies of each and every document and other item of material (collectively, “Records”) which may be at all responsive to the following:
 
1. Time-Frame. I am seeking all Records reflecting, referencing, or otherwise relating to the above-referenced bar, restaurant, businesses, location, and/or individuals from January 1, 2000 forward to the present day.
 
2. The Restaurant And Bar. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “Front Street Smokehouse & Saloon, Inc.” of Elizabeth, New Jersey, including without limitation the following more specific types of matters:
 
Public health, environmental health, toxicity, air quality, water quality, solid waste, garbage, recycling, refuse, sewers, utilities, public works, stormwater, run-off, New Jersey Sanitary Code (NJSC), whistleblower protections, workplace health, workplace safety, working conditions, any other environmental matters, police calls or visits, fire calls or visits, EMS calls or visits, other emergency calls or visits, business licensing, economic development, film permits, engineering, tax accounting, tax control, tax assessments, tax collections, construction, licensing, planning, zoning, city ordinances, Americans With Disabilities Act (ADA) compliance, apprenticeships, child labor, collective bargaining, Consumer Credit Protection Act (CCPA), discrimination, employee benefits, Employee Retirement Income Security Act (ERISA), Fair Labor Standards Act (FLSA), Family And Medical Leave Act (FMLA), firing, hiring, Immigration And Nationality Act (INA), independent contractor arrangements, internships, layoffs, maternity leave, paternity leave, minimum wage standards, nonimmigrant workers, overtime, pay equivalency, pensions, personal service agreements, postering, recordkeeping, right to work matters, tips, underpayments, unemployment insurance, unfair labor practices, unionization, visas, wages, wage garnishment, and workers’ compensation.
 
3. Liquor License. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to City of Elizabeth, New Jersey liquor Retail License No.: 2004-33-227-001. As a point of reference, Records which I have located thusfar from media sources relating to this liquor Retail License and the bar and restaurant can be found at:
https://unhandpiermont.blogspot.com/2024/12/piermont-mayor-bruce-tuckers-foray-into.html
 
4. The Phone Number. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the phone number of Front Street Smokehouse & Saloon, Inc. identified as: “(908) 354-1818”.
 
5. The Website. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the Internet website of Front Street Smokehouse & Saloon, Inc. identified as:

www.frontstreetsmokehouse.com
 
6. The Location. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the location of One South Front Street, Elizabeth, New Jersey 07206 USA – found at the corner of Elizabeth Avenue and Front Street.
 
7. Lava Lounge. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “Lava Lounge”, an apparent alias of the bar and restaurant.
 
8. South Seas Bar. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “South Seas Bar”, the apparent prior name of a bar at the same location.
 
9. Bruce Edward Tucker. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA. You may recognize this individual’s name, as he currently serves as the Mayor of the Village of Piermont, New York, while at one point apparently maintaining an ownership interest in the subject bar and restaurant in Elizabeth, New Jersey.
 
10. Philip Costanza. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Philip Costanza, 523 3rd Avenue, Elizabeth, New Jersey 07202 USA.
 
11. Bruce L. Kain. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.
 
12. The “Smokehouse Parties” – Possible Types Of Records. Next, for your ease of reference, I will now refer to these following people, places, and businesses, collectively, as, simply, the “The Smokehouse Parties”:
 
- Retail Licensee No.: 2004-33-227-001.
- Front Street Smokehouse & Saloon, Inc.
- One South Front Street, Elizabeth, New Jersey 07206 USA (Elizabeth Avenue and Front Street)
- “Lava Lounge”.
- “South Seas Bar”.
- Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA.
- Philip Costanza, 523 3rd Avenue, Elizabeth, New Jersey 07202 USA.
- Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.
(collectively, “The Smokehouse Parties”).
 
I am seeking, in each case to the extent as may be existing:
 
(a). Incidents. All Records - if any - reflecting, referencing, or otherwise relating to any accidents, incidents, citations, tickets, deficiencies, non-compliance, unsafe conditions, hazardous conditions, other conditions, injuries, “Dram Shop Act” events, recalls, health matters, environmental matters, New Jersey Sanitary Code violations, or other untoward occurrences - including without limitation in connection with any contamination, infection, disease, hygiene problem, food poisoning, other poisoning, other unsanitary condition, transportation, labelling, mis-labelling, air pollution, noise pollution, water pollution, other water quality concerns, ambulance call, EMS call, hospitalization, medical attention, contagion, “spreader” event, epidemic, pandemic, hazardous material, hazardous waste, solid waste, sewage, storage tanks, insecticides, rodenticides, pesticides, garbage, sanitation, pollution, food waste, other waste, or other refuse - at the subject location of “One South Front Street, Elizabeth, New Jersey  07206  USA”, or otherwise relating to The Smokehouse Parties or any of them, whether relating to food processing, preparation, storage, handling, dressing, sale, quality-control, quality-assurance, disposal, personal injuries, or otherwise.
 
(b). Complaints. All Records reflecting, referencing, or otherwise relating to any employee, worker, independent contractor, intern, apprentice, vendor, customer, patron, consumer, resident, citizen, or other complaints about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(c). Inspections. All Records reflecting, referencing, or otherwise relating to any inspections of, or otherwise concerning, the subject location of One South Front Street, Elizabeth, New Jersey 07206 USA, or otherwise relating to The Smokehouse Parties or any of them.
 
(d). Food-Related Or Solid Waste Licenses, Permits, And Renewals. All Records reflecting, referencing, or otherwise relating to any food-related, solid waste, or other licensure, licenses, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(e). Alcohol Licenses, Permits, And Renewals. All Records reflecting, referencing, or otherwise relating to any alcohol-related or other licensure, licenses, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(f). Applications And Renewals. All Records reflecting, referencing, or otherwise relating to any applications or renewals for licenses, permits, or other permissions, of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the applications themselves.
 
(g). “Retail Licenses”, Permits, And Renewals. Specifically, all Records reflecting, referencing, or otherwise relating to any “retail licenses”, licensure, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(h). Adverse Actions Against Licenses Or Permits. All Records reflecting, referencing, or otherwise relating to any license, permit, or other suspensions, cancellations, revocations, or terminations, of or otherwise concerning The Smokehouse Parties or any of them – if any.
 
(i). Proceedings. All Records reflecting, referencing, or otherwise relating to any administrative, legal, or other proceedings about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(j). Claims And Litigations. All Records reflecting, referencing, or otherwise relating to any claims, mediations, arbitrations, or litigations about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(k). Enforcement Actions. All Records reflecting, referencing, or otherwise relating to any enforcement or comparable actions against, about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(l). Fines Or Other Penalties. All Records reflecting, referencing, or otherwise relating to any fines or other penalties assessed against or otherwise imposed upon The Smokehouse Parties or any of them – if any.
 
(m). Violations. All Records reflecting, referencing, or otherwise relating to any violation or claimed violation of any other laws, statutes, ordinances, regulations, rules, requirements, or standards by, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(n). Employment And Labor Matters. All Records reflecting, referencing, or otherwise relating to any other labor or employment matters of, or otherwise concerning, The Smokehouse Parties or any of them, as described hereinabove.
 
(o). E-Mails And Correspondence. All Records of any e-mails, memos, notes, correspondence, documents, or other writings to, from, referencing, or otherwise relating to The Smokehouse Parties or any of them.
 
(p). License Transfers. All Records reflecting, referencing, or otherwise relating to any transfer of any retail license or other transfers of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(q). Premises Expansions. All Records reflecting, referencing, or otherwise relating to any premises expansions of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(r). Objections. All Records reflecting, referencing, or otherwise relating to any objections to expansions, transfers, or other proposed or completed actions by, of, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(s). Stock. All Records reflecting, referencing, or otherwise relating to any “stockholding” or stockholder information or changes thereto, of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(t). Property Documentation. All Records reflecting, referencing, or otherwise relating to any property record, property title, or other property documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(u). Insurance or Bonding Documentation. All Records reflecting, referencing, or otherwise relating to any insurance or bonding documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(v). Tax Documentation. All Records reflecting, referencing, or otherwise relating to any tax, tax payment, tax history, tax credit, tax arrearage, tax warrant, or other tax-related documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(w). Fee Documentation. All Records reflecting, referencing, or otherwise relating to any fee, fee payment, fee history, fee credit, fee arrearage, or other fee-related documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(x). Land Use. All Records of planning, certified plans, engineering, zoning, applications, approvals, permits, permissions, variances, inspections, code enforcement, compliance vel non, stop-work orders, land use, intended land use, soil conservation, erosion, sediment control, sedimentation, stormwater management, land disturbance, environmental concerns, building, construction, insurance, bonding, escrows, taxation, financing, complaints, or neighborhood opposition, including inter alia e-mails, minutes, resolutions, and deliberative materials, relating to The Smokehouse Parties or any of them.
 
(y). All Other Records. All other Records of any other kind or nature relating to The Smokehouse Parties or any of them.
 
13. Violations Of Laws – IF Any. Specifically and without limitation to the foregoing, I am hereby seeking, to the extent if at all existing, each and every Record reflecting any “violation”, “reporting violation”, or other past, present, future, or anticipated violation, breach, or other transgression of federal, state, county, town, local, or other ordinance, rule, regulation, requirement, or other law or standard - including without limitation any violation of rules, regulations or other laws enforced by or otherwise relating to or concerning any of the following:
 
Environmental Protection Agency (EPA).
Centers For Disease Control (CDC).
Agency for Toxic Substances and Disease Registry (ATSDR).
Health Resources and Services Administration (HRSA).
National Institutes of Health (NIH).
United States Department Of Justice (USDOJ).
U.S. Attorney’s Office (USATTY).
Federal Bureau Of Investigation (FBI).
U.S. Department of Health & Human Services (USHHS).
Office of the Inspector General, Department of Health and Human Services (OIG).
U.S. Department of Homeland Security (USDHS).
Federal Emergency Management Agency (FEMA).
Your U.S. Environmental Protection Agency (EPA).
Office of the New Jersey Governor (NJ GOV).
New Jersey Office of Homeland Security and Preparedness (NJOHSP).
New Jersey Office of Emergency Management (NJOEM).
New Jersey Department Of Environmental Protection (NJDEP).
New Jersey Department of Health (NJDOH).
Union County Department of Public Safety (UCDPS).
Union County Department of Health Management (UCDOH).
City of Elizabeth New Jersey, Health Department (Elizabeth Health).
United States Department of Agriculture (USDA).
USDA Food Safety and Inspection Service (FSIS).
U.S. Food and Drug Administration (EPA).
Union County Utilities Authority (UCUA).
Union County Clerk (UC Clerk).
Union County Utilities Authority
New Jersey Department of Law & Public Safety, Division of Alcoholic Beverage Control (NJABC).
Municipal Board of Alcoholic Beverage Control, City of Elizabeth, New Jersey (Elizabeth A.B.C. Board).
Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).
U.S. Equal Employment Opportunity Commission (EEOC).
U.S. Department of Justice (USDOJ), Civil Rights Division (CRD).
Occupational Safety and Health Administration (OSHA).
United States Department of Labor (USDOL).
U.S. Immigration & Customs Enforcement (ICE).
New Jersey Department of Labor and Workforce Development (NJDOL).
New Jersey Office of the Attorney General (NJAG).
New Jersey AG Division of Consumer Protection/Regulated Business Section (DCA/OCP).
New Jersey Department Of Banking And Insurance (NJDBI).
New Jersey Board of Examiners of Electrical Contractors (NJBEEC).
All other New Jersey state and local agencies.
Any other potentially-relevant government agency or authority.
 
14. Definition Of “Records”. “Records” should be construed in the broadest sense and manner possible and should include any information kept, held, filed, produced or reproduced by, with or for your agency or office in any physical form whatsoever, including without limitation all audio recordings, blog posts, correspondence, data maintained electronically, data, e-mails, executive summaries, extracts, faxes, instant messages, Internet posts, letters, log-book entries, memos, paper records, personal messages, social media communications, spreadsheets, summaries, synopses, telephone records, test-reports, visual recordings, and any other materials.
 
15. Headings. The headings and sub-headings for numbered Items #1 through #18 herein are for purposes of your convenience of reference only, and should not be construed to be words of limitation or otherwise of any substantive significance relative to this FOIA request.
 
16. Costs. If there are any copying or other fees for this, please let me know what they are and how they are calculated, before fulfilling the request and forwarding the Records to me. As this FOIA request should be considered a matter of public importance, and as its results will be shared with the general public, I am asking that any otherwise-applicable fees be waived for this production of Records. I am also asking that all Records be provided to me electronically to the full extent possible, so as to obviate the need for any photocopying expense.
 
17. Appeals. In the event that any portion of my request is denied, please inform me of each of the specific reasons for any such denial in writing - and provide me with the name, address, and other contact information of the person or entity to whom an appeal should be directed.
 
18. Additional FOIA Requests. This FOIA request is not intended to be exhaustive, and I may need to make additional or follow-up requests.
 
I will appreciate a response from you and your office as soon as possible. I look forward to hearing from you shortly.
 
Respectfully submitted,

John J. Tormey III, Esq.

- - - - -
 
EXHIBIT A – FEE WAIVER REQUEST
 
Freedom Of Information Act – Fee Waiver Request
Tuesday, January 7, 2025
 
Under 5 U.S.C. §552(a)(6), 17 CFR §200.80(f)(1):
 
1. Disclosure Is Not In My Personal Interests. I am not a “Commercial Use” requester, and disclosure in this case is not at all in the interest of me, the requester. 5 U.S.C. Section 552(a)(4)(iii). The disclosure will not further any commercial interest of mine. While I am an attorney in New York, I am not pursuing this matter for any client. Rather, I volunteered to assist the small Village of Piermont, New York out of my own initiative without being asked, pro bono and solely out of my own pocket, as an environmental and community advocate, watchdog, and private citizen - once I realized in April 2024 that Piermont was being threatened by a crooked village government, a corrupted mayor, over-development, and environmental harm. To date I have spent thousands of dollars out of my own hard-earned money for expenses to pursue the matter at hand, and I will not see any of it back. See, e.g., Coalition for Safe Power v. U.S. Dep't of Energy, Civ. No. 87-1380PA, slip op. at 7 (D.Or. July 22, 1988) (citing Better Gov't Ass'n v. Department of State, 780 F.2d 86, 94 (D.C. Cir. 1986)).
 
Therefore, the public interest in disclosure is far greater than my non-existent commercial interest as requester under 17 CFR § 200.80(g)(12). I have no commercial interest whatsoever in this matter.
 
2. Disclosure Is In The Public Interest. Disclosure of the requested information is in the public interest, and disclosure will contribute significantly to operations and activities of the government, both federal and state. Again, I am in the process of exposing a corrupted local village government and local village mayor in the State of New York. The mayor is named Bruce Edward Tucker, and he had an ownership interest in the subject Elizabeth, New Jersey bar and restaurant within your EPA jurisdiction. Whenever I obtain results relating to the Piermont matter, I blog them to my own Google Blogger blog, to between 10 and 300 local Facebook pages, to Twitter/X, to BlueSky, and to Quora, at minimum. I also e-mail the blogs to individual Piermont residents, and they are approximately 2,500 in number. Examples of such blog entries are below, and many thousands of readers have viewed these entries:
https://unhandpiermont.blogspot.com
See, e.g., Friends of the Coast Fork v. U.S. Dept. of Interior, 110 F 3d. 53, 55 (9th Cir. 1997).
 
3. The Requested Records Concern The Operations And Activities Of The Federal Government. The subject matter of the Records that I request of EPA concern the operations and activities of the federal government – namely, the manner in which your EPA interacted with and oversaw, or did not interact with and oversee, “Front Street Smokehouse & Saloon, Inc.” and Bruce Tucker on environmental, health, and safety matters.
 
4. The Requested Records Will Be Informative And Increase Understanding Of Government Activities. The requested Records will be meaningfully informative on those operations or activities so that their disclosure will contribute to increased understanding of specific operations or activities of the government. Right now, there are 2,500 residents of Piermont, New York, many of whom are waiting to see what EPA will reply to today’s January 2, 2025 FOIA request. They read my blog and my other social media posts on a regular basis, as indicated by my Google Blogger statistics. Many of them want to know what oversight the federal government, in the form of your EPA, may or may not have exercised over Piermont Mayor Bruce Tucker’s bar and restaurant in Elizabeth, New Jersey. See, e.g., Better Gov't Ass'n v. Department of State, 780 F.2d 86, 88-89 (D.C. Cir. 1986); McClellan Ecological Seepage Situation v. Carlucci, 835 F.2d 1282, 1284-1286 (9th. Cir. 1987).
 
5. Disclosure Will Contribute To The Understanding Of The Public At Large. Disclosure will contribute to the understanding of the public at large, rather than the understanding of the requester or a narrow segment of interested persons alone. My blog, for example, is worldwide, and not just limited to Piermont, New York residents:
https://unhandpiermont.blogspot.com
How the Piermont matter resolves will be precedential with respect to every other local village government in New York State, and indeed every other local village government within the United States of America. My cause to bring out the truth about Piermont village government and Mayor Bruce Tucker’s malfeasance, has already been picked up by media, and these news outlets also transmit world-wide:
https://rocklandnews.com/unhand-piermont-mayor-bruce-tucker/
https://patch.com/new-york/nyack/discussion-continue-controversial-piermont-apartments-proposal
 
6. Disclosure Will Contribute To Public Understanding Of Government Operations And Activities. Disclosure will contribute significantly to public understanding of government operations and activities - namely, the manner in which your EPA interacted with and oversaw, or did not interact with and oversee, the activities of “Front Street Smokehouse & Saloon, Inc.” and Piermont Mayor Bruce Tucker. The residents of Piermont, and members of the public generally, want to know and have a right to know what oversight the federal government in the form of your EPA may or may not have exercised over “Front Street Smokehouse & Saloon, Inc.” and Mayor Bruce Tucker.
 
In closing, as set forth hereinabove, I have borne the burden under FOIA of showing that the fee waiver requirements have been met. I have provided you substantive information relating to all of the six (6) factors to be considered under the statute.
 
I am not a “Commercial Use” requester.
 
Respectfully submitted,

John J. Tormey III, Esq.

Safety First.

Law Office of John J. Tormey III, Esq.
John J. Tormey III, PLLC
1636 Third Avenue, PMB 188
New York, New York  10128  USA
(212) 410-4142 (phone)
(212) 410-2380 (fax)
jtormey@optonline.net
https://www.tormey.org
 
REQUEST UNDER THE NEW JERSEY OPEN PUBLIC RECORDS ACT (“OPRA”)
 
Tuesday, January 7, 2025
 
VIA FAX: 1-908-518-7933, and U.S. MAIL:
Dennis Burke, Director
County of Union, New Jersey
Department of Public Safety (UCDPS)
400 North Avenue East
Westfield, New Jersey  07090  USA
 
Re:                 
(Plenary) City of Elizabeth, Liquor Retail License No.: 2004-33-227-001
Business: “Front Street Smokehouse & Saloon, Inc.” – (908) 354-1818 – www.frontstreetsmokehouse.com
Location: One South Front Street, Elizabeth, New Jersey 07206 USA (Elizabeth Avenue and Front Street).
Possible Aliases: a/k/a “Lava Lounge”, f/k/a “South Seas Bar”.
Principal: Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA.
Principal: Philip Costanza, 523 3^rd Avenue, Elizabeth, New Jersey 07202 USA.
Principal: Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.

Dear Mr. Burke, and Colleagues:
 
I am an attorney in New York. I am a citizen and resident of the Town of Orangetown, and the County of Rockland. Under the New Jersey Open Public Records Act (“OPRA”), P.L. 2001, c. 404, N.J.S.A. 47:1A-1 et seq.:
https://nj.gov/opra/
https://www.nfoic.org/new-jersey-sample-OPRA-request
https://en.wikipedia.org/wiki/Open_Public_Records_Act
… request is hereby made that your office provide to this, my law office, full and complete copies of each and every document and other item of material (collectively, “Records”) which may be at all responsive to the following itemized and specific OPRA requests – (while please remaining aware that I have already served a comparable OPRA request upon your colleagues in the Union County Clerk’s office and in the Union County Health Department, so as to avoid any duplication of efforts):
 
1. Time-Frame. I am seeking all Records reflecting, referencing, or otherwise relating to the above-referenced bar, restaurant, businesses, location, and/or individuals from January 1, 2000 forward to the present day.
 
2. The Restaurant And Bar. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “Front Street Smokehouse & Saloon, Inc.” of Elizabeth, New Jersey, including without limitation Records of all matters involving the Union County Police, Union County Emergency Management, the Union County Medical Examiner, Union County Weights and Measures, and Union County Consumer Affairs, any of which may have arisen in connection with this Front Street Smokehouse & Saloon business and One South Front Street, Elizabeth, New Jersey business premises since January 1, 2000, as well as any of the following more specific types of matters:
 
Police calls or visits, fire calls or visits, EMS calls or visits, other emergency calls or visits, business licensing, economic development, film permits, sewers, utilities, public works, engineering, stormwater, tax accounting, tax control, tax assessments, tax collections, construction, licensing, planning, zoning, city ordinances, public health, environmental health, solid waste, garbage, recycling, refuse, and any other environmental matters, Americans With Disabilities Act (ADA) compliance, apprenticeships, child labor, collective bargaining, Consumer Credit Protection Act (CCPA), discrimination, employee benefits, Employee Retirement Income Security Act (ERISA), Fair Labor Standards Act (FLSA), Family And Medical Leave Act (FMLA), firing, hiring, Immigration And Nationality Act (INA), New Jersey Sanitary Code (NJSC), independent contractor arrangements, internships, layoffs, maternity leave, paternity leave, minimum wage standards, nonimmigrant workers, overtime, pay equivalency, pensions, personal service agreements, postering, recordkeeping, right to work matters, tips, underpayments, unemployment insurance, unfair labor practices, unionization, visas, wages, wage garnishment, whistleblower protections, workers’ compensation, working conditions, workplace health, and workplace safety.
 
3. Liquor License. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to City of Elizabeth, New Jersey liquor Retail License No.: 2004-33-227-001. As a point of reference, Records which I have located thusfar from media sources relating to this liquor Retail License and the bar and restaurant can be found at:
https://unhandpiermont.blogspot.com/2024/12/piermont-mayor-bruce-tuckers-foray-into.html
 
4. The Phone Number. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the phone number of Front Street Smokehouse & Saloon, Inc. identified as: “(908) 354-1818”.
 
5. The Website. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the Internet website of Front Street Smokehouse & Saloon, Inc. identified as:

www.frontstreetsmokehouse.com

6. The Location. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to the location of One South Front Street, Elizabeth, New Jersey 07206 USA – found at the corner of Elizabeth Avenue and Front Street.
 
7. Lava Lounge. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “Lava Lounge”, an apparent alias of the bar and restaurant.
 
8. South Seas Bar. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to “South Seas Bar”, the apparent prior name of a bar at the same location.
 
9. Bruce Edward Tucker. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA. You may recognize this individual’s name, as he currently serves as the Mayor of the Village of Piermont, New York, while at one point apparently maintaining an ownership interest in the subject bar and restaurant in Elizabeth, New Jersey.
 
10. Philip Costanza. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Philip Costanza, 523 3rd Avenue, Elizabeth, New Jersey 07202 USA.
 
11. Bruce L. Kain. Specifically and without limitation to the foregoing, I am seeking all Records reflecting, referencing, or otherwise relating to one Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.
 
12. The “Smokehouse Parties” – Possible Types Of Records. Next, for your ease of reference, I will now refer to these following people, places, and businesses, collectively, as, simply, the “The Smokehouse Parties”:
 
- Retail Licensee No.: 2004-33-227-001.
- Front Street Smokehouse & Saloon, Inc.
- One South Front Street, Elizabeth, New Jersey 07206 USA (Elizabeth Avenue and Front Street)
- “Lava Lounge”.
- “South Seas Bar”.
- Bruce Edward Tucker, [___] Piermont Place, Piermont, New York 10968 USA.
- Philip Costanza, 523 3rd Avenue, Elizabeth, New Jersey 07202 USA.
- Bruce L. Kain, 1147 Debra Drive, Linden, New Jersey 07036 USA.
(collectively, “The Smokehouse Parties”).
 
I am seeking, in each case to the extent as may be existing:
 
(a). Incidents. All Records - if any - reflecting, referencing, or otherwise relating to any accidents, incidents, citations, tickets, deficiencies, non-compliance, unsafe conditions, hazardous conditions, other conditions, injuries, “Dram Shop Act” events, recalls, health matters, environmental matters, New Jersey Sanitary Code violations, or other untoward occurrences - including without limitation in connection with any contamination, infection, disease, hygiene problem, food poisoning, other poisoning, other unsanitary condition, transportation, labelling, mis-labelling, air pollution, noise pollution, water pollution, other water quality concerns, ambulance call, EMS call, hospitalization, medical attention, contagion, “spreader” event, epidemic, pandemic, hazardous material, hazardous waste, solid waste, sewage, storage tanks, insecticides, rodenticides, pesticides, garbage, sanitation, pollution, food waste, other waste, or other refuse - at the subject location of “One South Front Street, Elizabeth, New Jersey  07206  USA”, or otherwise relating to The Smokehouse Parties or any of them, whether relating to food processing, preparation, storage, handling, dressing, sale, quality-control, quality-assurance, disposal, personal injuries, or otherwise.
 
(b). Complaints. All Records reflecting, referencing, or otherwise relating to any employee, worker, independent contractor, intern, apprentice, vendor, customer, patron, consumer, resident, citizen, or other complaints about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(c). Inspections. All Records reflecting, referencing, or otherwise relating to any inspections of, or otherwise concerning, the subject location of One South Front Street, Elizabeth, New Jersey 07206 USA, or otherwise relating to The Smokehouse Parties or any of them.
 
(d). Food-Related Or Solid Waste Licenses, Permits, And Renewals. All Records reflecting, referencing, or otherwise relating to any food-related, solid waste, or other licensure, licenses, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(e). Alcohol Licenses, Permits, And Renewals. All Records reflecting, referencing, or otherwise relating to any alcohol-related or other licensure, licenses, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(f). Applications And Renewals. All Records reflecting, referencing, or otherwise relating to any applications or renewals for licenses, permits, or other permissions, of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the applications themselves.
 
(g). “Retail Licenses”, Permits, And Renewals. Specifically, all Records reflecting, referencing, or otherwise relating to any “retail licenses”, licensure, permits, or renewals of, by, for, or otherwise concerning The Smokehouse Parties or any of them – including without limitation the licenses themselves.
 
(h). Adverse Actions Against Licenses Or Permits. All Records reflecting, referencing, or otherwise relating to any license, permit, or other suspensions, cancellations, revocations, or terminations, of or otherwise concerning The Smokehouse Parties or any of them – if any.
 
(i). Proceedings. All Records reflecting, referencing, or otherwise relating to any administrative, legal, or other proceedings about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(j). Claims And Litigations. All Records reflecting, referencing, or otherwise relating to any claims, mediations, arbitrations, or litigations about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(k). Enforcement Actions. All Records reflecting, referencing, or otherwise relating to any enforcement or comparable actions against, about, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(l). Fines Or Other Penalties. All Records reflecting, referencing, or otherwise relating to any fines or other penalties assessed against or otherwise imposed upon The Smokehouse Parties or any of them – if any.
 
(m). Violations. All Records reflecting, referencing, or otherwise relating to any violation or claimed violation of any other laws, statutes, ordinances, regulations, rules, requirements, or standards by, concerning, or otherwise relating to The Smokehouse Parties or any of them – if any.
 
(n). Employment And Labor Matters. All Records reflecting, referencing, or otherwise relating to any other labor or employment matters of, or otherwise concerning, The Smokehouse Parties or any of them, as described hereinabove.
 
(o). E-Mails And Correspondence. All Records of any e-mails, memos, notes, correspondence, documents, or other writings to, from, referencing, or otherwise relating to The Smokehouse Parties or any of them.
 
(p). License Transfers. All Records reflecting, referencing, or otherwise relating to any transfer of any retail license or other transfers of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(q). Premises Expansions. All Records reflecting, referencing, or otherwise relating to any premises expansions of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(r). Objections. All Records reflecting, referencing, or otherwise relating to any objections to expansions, transfers, or other proposed or completed actions by, of, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(s). Stock. All Records reflecting, referencing, or otherwise relating to any “stockholding” or stockholder information or changes thereto, of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(t). Property Documentation. All Records reflecting, referencing, or otherwise relating to any property record, property title, or other property documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(u). Insurance or Bonding Documentation. All Records reflecting, referencing, or otherwise relating to any insurance or bonding documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(v). Tax Documentation. All Records reflecting, referencing, or otherwise relating to any tax, tax payment, tax history, tax credit, tax arrearage, tax warrant, or other tax-related documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(w). Fee Documentation. All Records reflecting, referencing, or otherwise relating to any fee, fee payment, fee history, fee credit, fee arrearage, or other fee-related documentation of, by, for, or otherwise concerning The Smokehouse Parties or any of them.
 
(x). Land Use. All Records of planning, certified plans, engineering, zoning, applications, approvals, permits, permissions, variances, inspections, code enforcement, compliance vel non, stop-work orders, land use, intended land use, soil conservation, erosion, sediment control, sedimentation, stormwater management, land disturbance, environmental concerns, building, construction, insurance, bonding, escrows, taxation, financing, complaints, or neighborhood opposition, including inter alia e-mails, minutes, resolutions, and deliberative materials, relating to The Smokehouse Parties or any of them.
 
(y). All Other Records. All other Records of any other kind or nature relating to The Smokehouse Parties or any of them.
 
13. Violations Of Laws – IF Any. Specifically and without limitation to the foregoing, I am hereby seeking, to the extent if at all existing, each and every Record reflecting any “violation”, “reporting violation”, or other past, present, future, or anticipated violation, breach, or other transgression of federal, state, county, town, local, or other ordinance, rule, regulation, requirement, or other law or standard - including without limitation any violation of rules, regulations or other laws enforced by or otherwise relating to or concerning any of the following:
 
Environmental Protection Agency (EPA).
Centers For Disease Control (CDC).
Agency for Toxic Substances and Disease Registry (ATSDR).
Health Resources and Services Administration (HRSA).
National Institutes of Health (NIH).
United States Department Of Justice (USDOJ).
U.S. Attorney’s Office (USATTY).
Federal Bureau Of Investigation (FBI).
U.S. Department of Health & Human Services (USHHS).
Office of the Inspector General, Department of Health and Human Services (OIG).
U.S. Department of Homeland Security (USDHS).
Federal Emergency Management Agency (FEMA).
Office of the New Jersey Governor (NJ GOV).
New Jersey Office of Homeland Security and Preparedness (NJOHSP).
New Jersey Office of Emergency Management (NJOEM).
New Jersey Department Of Environmental Protection (NJDEP).
New Jersey Department of Health (NJDOH).
Your Union County Department of Public Safety (UCDPS).
Union County Department of Health Management (UCDOH).
City of Elizabeth New Jersey, Health Department (Elizabeth Health).
United States Department of Agriculture (USDA).
USDA Food Safety and Inspection Service (FSIS).
U.S. Food and Drug Administration (FDA).
Union County Utilities Authority (UCUA).
Union County Clerk (UC Clerk).
Union County Utilities Authority
New Jersey Department of Law & Public Safety, Division of Alcoholic Beverage Control (NJABC).
Municipal Board of Alcoholic Beverage Control, City of Elizabeth, New Jersey (Elizabeth A.B.C. Board).
Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).
U.S. Equal Employment Opportunity Commission (EEOC).
U.S. Department of Justice (USDOJ), Civil Rights Division (CRD).
Occupational Safety and Health Administration (OSHA).
United States Department of Labor (USDOL).
U.S. Immigration & Customs Enforcement (ICE).
New Jersey Department of Labor and Workforce Development (NJDOL).
New Jersey Office of the Attorney General (NJAG).
New Jersey AG Division of Consumer Protection/Regulated Business Section (DCA/OCP).
New Jersey Department Of Banking And Insurance (NJDBI).
New Jersey Board of Examiners of Electrical Contractors (NJBEEC).
All other New Jersey state and local agencies.
Any other potentially-relevant government agency or authority.
 
14. Definition Of “Records”. “Records” should be construed in the broadest sense and manner possible and should include any information kept, held, filed, produced or reproduced by, with or for your agency or office in any physical form whatsoever, including without limitation all audio recordings, blog posts, correspondence, data maintained electronically, data, e-mails, executive summaries, extracts, faxes, instant messages, Internet posts, letters, log-book entries, memos, paper records, personal messages, social media communications, spreadsheets, summaries, synopses, telephone records, test-reports, visual recordings, and any other materials.
 
15. Headings. The headings and sub-headings for numbered Items #1 through #18 herein are for purposes of your convenience of reference only, and should not be construed to be words of limitation or otherwise of any substantive significance relative to this OPRA request.
 
16. Costs. If there are any copying or other fees for this, please let me know what they are and how they are calculated, before fulfilling the request and forwarding the Records to me. As this OPRA request should be considered a matter of public importance, and as its results will be shared with the general public, I am asking that any otherwise-applicable fees be waived for this production of Records. I am also asking that all Records be provided to me electronically to the full extent possible, so as to obviate the need for any photocopying expense.
 
17. Appeals. In the event that any portion of my request is denied, please inform me of each of the specific reasons for any such denial in writing - and provide me with the name, address, and other contact information of the person or entity to whom an appeal should be directed.
 
18. Additional OPRA Requests. This OPRA request is not intended to be exhaustive, and I may need to make additional or follow-up requests.
 
I will appreciate a response from you and your office as soon as possible. I look forward to hearing from you shortly.
 
Respectfully, and with thanks,

John J. Tormey III, Esq.
 
cc:
VIA U.S. MAIL and E-MAIL:
grc@dca.state.nj.us
Government Records Council (GRC)
PO Box 819
Trenton, New Jersey  08625  USA