I've had to submit to the North Hunterdon-Voorhees school a FOIA request that in New Jersey is called OPRA. It's my opinion the taxpayers are getting ripped off by the Comegno Law Group that is billing the school/taxpayers for work it really is did/volunteered for Chicago's American Library Association. The OPRA is to determine if this is the case.
Further, an ethics decision may have been biased in an unethical way, indicated to me by the following sentence: "My daughter reads almost every day."
Here is a Table of Contents/Evidence to support the OPRA request and more, and all evidence is included below:
Table of Contents/Evidence:
- NJ SEC Scheduling Letter
- Public Comments at the 8/19/2025 School Ethics Committee Meeting
- OPRA Request 007: Comegno Legal Bills
- Recording of Public Portion of NJ SEC Meeting 8/19/25
- Graphics of NJ SEC Scheduling Letter 8/12/25
- Public Disclosure by Me of the Above Matter on Liberty Launch Group
Below is that OPRA request, but first is some information I reference in the OPRA request, namely, the scheduling letter from the NJ School Ethics Commission.
There is also a transcript of the public comments made at that meeting. I made the recording and the transcript. The entire recording is linked below. To my knowledge, the NJSEC itself makes no such records public, so below is likely the only copy. You will be told by the people who support American Library Association to ignore me and especially the evidence, the recording. Will you not read the transcript for yourselves? Will you not listen?
At the hearing a public statement was read out loud about the imminent public comment portion of the meeting. That statement included the following admonition:
Parties to a matter currently pending before the Commission are reminded not to publicly litigate the merits of their case. The Commission's review in the matter will be limited to the written [unintelligible] and any public comments or statements which address the merits of the matter will not be considered by the Commission today.
In the transcript a Commissioner speaks during a break between public comments that, "My daughter reads almost every day." Cute, right? Not cute. It is an indication, at least to me, that he heard what the Comegno attorney argued, then, despite the unethical nature of her comments and her refusal to follow direct verbal direction from the Commission chairman and again from the Commission attorney, he was swayed by her unethical comments. Why? Because his takeaway was the importance of libraries and how his daughter enjoys reading almost every day. I could hear nothing from him about how the Comegno attorney just blew through ethical requirements without a care in the world. To me, this was the most disheartening part of the hearing and it told me this guy is going to fall for the America / democracy / libraries sob story and decide not to hold the school board responsible for breaking the law.
And should anyone argue the Comegno lawyer's words were simply effective in making a point since the Commissioner was swayed to think of his daughter and her reading thanks to libraries, you don't get or give credit when an attorney achieves a goal in an unethical manner.
I've said this is my opinion, but it's also my opinion anyone looking at the scheduling letter, its red, italicized, and underlined admonition, the public comments and NJSEC's Chairperson's opening statement and NJSEC lawyer's verbal admonition, will come to essentially the same conclusion that Comegno Law Group is draining board/taxpayer money to fund instead volunteer work for the American Library Association that has control over the school board (as my ethics complaint may decide), the legislature that passed the Freedom to Read Act written by ALA (Senator Andrew Zwicker who called me a "meddling minority" told me so directly at a hearing in Trenton), and is now attempting to use taxpayer funds to illegally sway the NJ School Ethics Commission in violation of the New Jersey Rules of Professional Ethics [potentially RPC 3.3(a)(4 & 5); 3.4(c); 3.5(a & c); 8.4(a & c & d)].
Remember, the Comegno Law Group attorney is
- experienced in education law practice,
- got the 8/12/25 letter not to talk about the case,
- heard the opening comments that parties may not talk about the case, discussed the case anyway,
- heard the Commission attorney tell her directly to stop talking about the case, but went right on ahead talking anyway to do what she knows not to do and to three times ignore the School Ethics Commission.
Three strikes you're out, yes? Or no, because librarians are wonderful people who would never hurt anyone, American Library Association is wonderful, its Freedom to Read Act is about liberty and democracy, so the ethics case is moot, nothing to see here, let's move on.
She concluded by directly arguing the merits of the case despite multiple warnings, and even got in the good word for American Library Association's Freedom to Read Act as the reason to defy my ethics complaint by summarizing, "the record shows the members acted in good faith, within policy, and in line with the state law protecting access to books." They did not act in good faith. They violated ethics laws, and their attorney violated professional ethics laws, all to keep children exposed to inappropriate material in schools, in my opinion.
Besides, that Freedom to Read Act was signed into law on December 9, 2024. The alleged unethical actions taken by the board predated that and the ethics complaint itself was filed on November 4, 2024. Even the respondents themselves complained in their response, "this matter was initially and incorrectly filed on October 23, 2024." Gosh forbid a pro se complainant should misfile a complaint without the petty attorney trying to score points because screw justice. Always the effort to belittle, to attack the messenger, but still, Comegno Law Group knows my ethics complaint predated the passage of the Freedom to Read Act, so summarizing by saying, "the record shows the members acted ... in line with the state law protecting access to books," is not only arguing the merits of the case, but it is deceptively dishonest to argue something that postdated the complaint. It is factually false. It might even right there represent an additional violation of yet another professional rule of attorney ethics. "RPC 8.4. Misconduct; It is professional misconduct for a lawyer to:... (c) engage in conduct involving dishonesty, fraud, deceit or misrepresentation." And all after having been warned three times not to discuss the merits of the case, in a matter that may represent another violation of the ethics code. Had she not violated at least one rule, another rule would not have been violated. My opinion, of course.
I am publishing all this so the taxpayers and especially the parents at the school can see for themselves exactly what happened at the 8/19/25 NJSEC meeting and how they are being used/sponged off of to promote a Chicago ALA agenda—all to keep school kids subject to ALA's 60 year effort to indoctrinate school children (shown
here). They can also see that local control needs to be restored from ALA's overarching control, such control being so complete that a law firm willingly defied rules of professional conduct, starting with their own school board. The ALA policy embedded in school policy needs to be removed and books that are pervasively vulgar or educationally unsuitable per
Pico standards need to be summarily removed, Freedom to Read Act notwithstanding. The US Supreme Court trumps the Chicago American Library Association.
That initial ethics decision will be out in a few weeks. Let's hope soon afterwards some school board members become ex school board members.
And get rid of that unethical law firm. What's the problem? Plenty of ethical lawyers can take their place, do far better, and not rip you off. My opinion!
NJ SEC Scheduling Letter (red, italic, underlined lettering in original):
12 AUGUST 2025
SCHOOL ETHICS COMMISSION
August 12, 2025
For Complainant
Dan Kleinman
641 Shunpike Rd #123
Chatham, NJ 07928
For Respondents
John B. Comegno II, Esquire
Giulia Lima, Esq.
Comegno Law Group
521 Pleasant Valley Avenue
Moorestown, NJ 08057
SUBJECT: DAN KLEINMAN v. JESSICA VIOTTO, BETH KOTRAN, TARA
MARIE HINTZ, BRYAN CHAPMAN, DANIEL SPANTON, GLEN
FARBANISH, JOHN MELICK, BRENDAN MCISAAC, NORTH
HUNTERDON-VORHEES BOARD OF EDUCATION, HUNTERDON
COUNTY, SCHOOL ETHICS COMMISSION DOCKET #C89-24
Dear Parties:
Please be advised that the above-captioned matter will be discussed by the School Ethics
Commission (Commission) at its meeting on August 19, 2025. At this meeting, the Commission
will discuss whether probable cause exists for the allegations in the Complaint. Probable cause
shall be found when the facts and circumstances presented in the Complaint and Written
Statement would lead a reasonable person to believe that the School Ethics Act has been violated.
In addition, because Respondents alleged that the complaint is frivolous, the Commission
will also discuss this allegation, and any response thereto. If the Commission determines that the
Complaint is frivolous, such a finding may constitute sole grounds for dismissal, and such
dismissal shall constitute final agency action. N.J.A.C. 6A:28-9.4. In addition, pursuant to N.J.S.A.
18A:12-29(e), the Commission may impose a fine not to exceed five hundred dollars ($500.00).
The Commission’s meeting will take place at the New Jersey Department of Education,
100 Riverview Plaza, Trenton, New Jersey 08625. Although you are permitted to attend public
session, please note that this is not an opportunity to discuss or to otherwise publicly litigate the
merits of the case. Further, the Commission’s review and discussion of this matter will take place
in Executive Session.
Page 2
Following its meeting on August 19, 2025, it is anticipated that the Commission will adopt
a decision at its next regularly scheduled monthly meeting thereafter. Once adopted by the
Commission, the parties shall be duly notified of the Commission’s decision (in writing) and will
be advised as to how the above-captioned matter will be processed.
Subject to the exceptions set forth at N.J.A.C. 6A:28-6.6(g), the Commission shall hold all
information confidential regarding any pending matter until the Commission finds that a school
official has violated the Act, or until such time that the above-captioned matter is settled,
withdrawn or dismissed.
If you have any questions, please contact our office at school.ethics@doe.nj.gov.
Sincerely,
/s/
Dana Jones
School Ethics Commission
Public Comments at the 8/19/2025 School Ethics Committee Meeting:
Giulia Lima, Esq., Comengo Law Group for Respondents:
Good morning members of the Commission. I am Giulia Lima, Counsel for Respondents, the North Hunterdon-Voorhees Board of Education members named in the matter C89-24. This matter involves a May 7, 2024, vote by the North Hunterdon-Voorhees Board of Education on a library book challenge. This challenge was handled under established district policy. A review committee of educators, administrators, and a parent, considered the book and issued a divided recommendation.
At the public meeting, more than twenty residents spoke with most supporting the book remaining. The board then voted not to remove it. That decision was made through the proper process and within the board's authority.
The process was consistent not only with the district policy, but also with the principles later codified in the New Jersey Freedom to Read Act, which affirms students' right to access information and prohibits book bans based on disagreement with ideas.
Dana Jones, School Ethics Commission Staff Member and Attorney:
Wait, Miss Lima, I just want to remind you, you can't talk about the merits of the case.
Giulia Lima:
Okay.
Dana Jones:
So we talk and then the Commission decides whatever they decide. They're only going to consider what was in the complaint and the writ.
Giulia Lima:
Yes.
Dana Jones:
So not, nothing of what you're talking about today. We do want to make sure that you don't talk about anything that we consider merits, defenses to the case.
Giulia Lima:
Okay.
School libraries have centers for voluntary inquiry, play a unique role in promoting intellectual freedom, providing equitable access to learning, resources, and promoting democracy by providing services to all, regardless of race, ethnicity, creed, age, ability, gender, or social economic status.
In sum, the record shows the members acted in good faith, within policy, and in line with the state law protecting access to books.
Thank you for your time and your commitment to our schools, our teachers, and our students.
...
Male Commissioner:
My daughter reads almost every day.
...
Jeannine Pizzigoni, School Ethics Commission Staff Member:
Can you state your name, please, and what case you are here for?
Dan Kleinman, Complainant:
Yes, my name is Dan Kleinman. I'm here for the case of the young lady over here that ...
[Discussion ensues within the SEC about Commissioner Richard Tomko having to go offline again like he did for Giulia Lima for conflict related to North Hunterdon-Voorhees BOE as he was applying for a contract with the BOE. He has recused himself from the C89-24 process. He will have the same access to the final decision after it is posted on the Commission’s website when the public will have access to that decision.]
I came here because I'm interested in the administration of justice. I'm fascinated by this School Ethics Commission. I wanted to just observe for myself what was going on in this case. I wasn't planning to say anything.
Jeannine Pizzigoni:
Okay.
Dan Kleinman:
And then the attorney spoke up. [Laughter ensues.] She's a very nice lady.
But she did speak up on the, on the, uh, related to the case and and how you should basically be voting because she pointed out to how important libraries are and it's essential to our democracy that we have libraries.
Then she was told, "We're sorry, you can't talk about things related to this case." And then she proceeded to proceed with more things related to this case. It's an attempt to spin the Ethics Commission.
I'm not impressed with that. I just came to observe today. And what I observed was the continuing effort to claim that librarians are wonderful people and all books are wonderful, as the reason why this case should be, in your mind, just set aside.
It's not the issue whether all libraries are wonderful, and I'm not gonna argue the merits of the case. I'm not impressed that she would, came up here and talked about this in violation of your rules, was warned about it, and then proceeded to continue to talk about this case in violation of the rules.
It's not impressive. I hope when you make your decision that your decision is based on everything it's supposed to be based on, and the justice of the matter, and whether the law was violated, and that's it.
And this is a very fascinating process. And I thank you guys for the efforts that you all put into doing this every month, it's a very important issue.
Thank you.
Robert Bender, School Ethics Commission Chairperson:
I can tell you that, uh, as a commissioner, uh we've read, this material, it's not just a statement here or there, but we look into the depth of each case. And uh, uh, are we swayed? Uh, no, uh, we listen, uh, just as, as, you know, free speech, but at the same time, what we're dealing with is very serious. And, right now, we, we have read this, uh, we are certainly in detail in this, uh, and, uh, we'll give that great consideration. So, we don't take these things lightly.
Dan Kleinman:
Okay. This, her argument that the Freedom to Read Act passed in New Jersey, you know, that was written by Chicago's American Library Association. It's almost proof of what I've been saying. But thank you very much.
OPRA Request 007: Comegno Legal Bills:
Please provide all legal bills and accompanying documentation of what was done and when from any law firm including the Comegno Law Group, P.C., wherein the bills relate to preparation for and appearance at the August 19, 2025 New Jersey School Ethics Commission. Consider this an open request until I am provided with documentation, just in case any bill has not yet been received. Requesting this OPRA request to remain open will obviate the need for additional OPRA/FOIA requests, thereby saving time and money for all. Once all such documents are provided to me, this request may be considered closed. I am aware some law firms write legal bills in a manner that essentially circumvents OPRA laws. Let's hope such games will not be played here or that will result in additional OPRA requests and associated costs that you will have brought upon yourselves.
My interest in the subject matter contained concerns saving the school district legal fees for work Comegno Law Group may have performed gratis for Chicago's American Library Association. Essentially, Comegno Law Group, while ostensibly representing the school district, in reality performed work that may have violated New Jersey Rules of Professional Conduct so as to benefit a special interest group, namely, American Library Association, the very same special interest group that is at the basis of the ethics complaint about the potential for the school board having broken ethics laws by favoring special interest groups in a manner against the law, among other things. Comegno Law Group may have unethically promoted the interests of the special interest group while completely ignoring the interests of its client school board; any interests of the school board that were not also interests of the special interest group were not discussed at all before the NJ School Ethics Committee. For example, the issue of board members having promised to vote a certain way on a certain issue in exchange for votes was not discussed. Comegno Law Group was told repeatedly, including in person at the 8/19/25 meeting by the attorney for the Commission who had to interrupt the Comegno Law Group member, not to speak on topics relating to the case, but that didn't stop Comegno Law Group from charging ahead anyway with its open advocacy for special interest group American Library Association and for New Jersey's Freedom to Read Act that was written by American Library Association and passed as law in New Jersey. The argument was essentially that since that law passed, the ethics matter under review was irrelevant, so no ethics were violated. Ethics violated but not discuss by the attorney were essentially ignored. Comegno Law Group may have violated rules of professional conduct to support American Library Association, but it never supported its school board client in the other ethics issues in the ethics complaint, and it certainly does not benefit the client to act unprofessionally to support the very outside interest group the school board may have also unethically supported, namely, American Library Association, the very basis of the ethics complaint. So basically, Comegno Law Group volunteered work for American Library Association but charged the school board for that work. This OPRA/FOIA request is to determine the existence and extent of the damage, if any, so it may be returned to the taxpayers. I was at the hearing to see all this. I have produced a transcript and the notice of hearing from the Commission to prove all this. No member of the school board was in attendance, so only I saw this. The meetings are not officially recorded. I recorded the meeting on my iPhone and I produced an accurate transcript as a result. So there's zero change Comegno Law Group can say it didn't happen or can keep people from hearing it for themselves. All work billed to the school board related to the above should not have been billed to you. The school board should refuse to pay any portion of any bill related to this matter. Further, it should send a demand for payment of legal fees to American Library Association that directly benefitted from Comegno Law Group's unethical actions. Finally, to avoid these litigious people supporting American Library Association's ability to harm school children with inappropriate material suing me, the above is all my opinion.
Recording of Public Portion of NJ SEC Meeting 8/19/25:
Graphics of NJ SEC Scheduling Letter 8/12/25:
Public Disclosure by Me of the Above Matter on Liberty Launch Group:
Spotify:
X:
NOTE ADDED 15 SEPTEMBER 2025:
The OPRA request was effectively denied and closed on 12 September 2025. From experience, 100% of the time a FOIA request is denied, the government is hiding something.
In my case, they are hiding legal bills. In the past I received legal bills. Not this time. They are definitely hiding something. I suspect it's that the law firm is serving American Library Association, not the school district itself.
They say they don't have the legal bills because they are "sent directly to the District's insurance carrier." If that is true, then they have not reviewed the bills and they are possibly violating even more ethics laws. They might even be hiding that they know tax money is being used to support Chicago ALA goals.
I'll have to dig in more now, and they will eventually blame me for wasting the public's money. It's like they blame book challengers for wasting public money when it's ALA diktat that creates the book challenges in the first place.
Here is the actual rejection letter, and click to enlarge:
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