[brief] This matter was initiated by Plaintiff/Respondent [...] in accordance with the Open Public Records Act, N.J.S.A. 47:1a-1 et seq. by way of Complaint and Motion for Order to Show Cause Hearing on January 10, 2022.  [...].  The basis for this motion was that Plaintiff/Respondent filed an OPRA request with the [...] on January 4, 2022 (hereinafter referred to as the “Request”).  Da210-213.  The Order to Show Cause was originally granted, and a hearing date was set by [...].  Da061-064.  Ultimately, Plaintiff/Respondent’s Complaint was amended to add [...] as a party.  Da042-049.  On March 23, 2022, this matter was transferred to Camden County and consolidated with two (2) other matters, involving similar issues.  Da066-070.  The Plaintiff/Respondent in the other matters is the “[...]”, and the Defendants are [...] and the [...]. \(^1\)  Id.  Oral argument was held on April 21, 2022 as to all these matters. \(^2\) --- \(^1\)  The [...] was the only municipal defendant to argue the privacy issue and whether the requested information was a public record under the OPRA statute.  For the purposes of this brief, the City is not planning to include pleadings or other procedural documents for the other matters in the Appendix, as they are not relevant to the City’s arguments contained herein.  However, the City will gladly provide any additional items or pleadings at the Court’s request, if deemed necessary for further consideration.  \(^2\)  See “1T” Transcript of Proceedings from April 21, 2022.  On May 26, 2022, the City received the trial court’s decision in this matter, which found that the e-mail addresses are a public record; that the privacy exception to OPRA did not apply to e-mail addresses; and that OPRA extends to personal information provided by individuals to a private entity when signing up for a third-party service that provides governmental alerts.  Da072-124.  The trial court gave the parties the opportunity to brief the issue of counsel fees due to the unique situation, and further oral argument was scheduled on that issue specifically.  Id.  The City filed a Motion for Reconsideration on June 13, 2022.  Da126-128.  The City argued in the Motion for Reconsideration that the Court misinterpreted the definition of a government record as set forth in the OPRA statute; that the Court failed to appropriately consider the evidence and persuasive authority, including newly presented evidence, as to the privacy issue; and that the trial court erred in determining that the requested information was required to be disclosed under the common law right of access.  Id.  This motion was denied after being considered “on the papers”, on July 1, 2022.  Da130-148.  On July 21, 2023, the Court entered a Consent Order prepared by the parties which confirmed that the May 25, 2022 Order was not a final judgment or order for purposes of appeal, since the issue of counsel fees was not yet resolved.  Da150-154.  The Consent Order also stayed production of the documents/records and the payment of counsel fees, pending this appeal.  *Id.*  On August 30, 2022, [...] filed a Motion for Reconsideration, which was denied on November 3, 2023.  Da156-180.  Oral argument was then held on the issue of counsel fees on March 13, 2023.  On March 28, 2023, the Court issued an order which approved a reduced fee award, finding the municipal parties responsible for a portion of fees associated with their specific matter.  Da182-208.  Hoboken’s portion totaled $16,526.80.  *Id.*  Voorhees had a separate action for indemnification against [...], which was granted.  *Id.*  **STATEMENT OF FACTS**