[brief] Perhaps recognizing this clear distinction, [...] drastically overstates [...]’s reliance on the Freedom of Information Act (FOIA), 5 U.S.C. § 552.  (Pb14).  [...]’s passing reference to FOIA was only in the context of noting that this court in MAG looked to both federal and other state’s law in announcing that “agencies are required to disclose only ‘identifiable’ governmental records” and prohibiting “overbroad” requests.  (Db12-13); 375 N.J. Super. at 547-49.  But that decision was issued nearly nineteen years ago.  Since then, a robust line of New Jersey precedents developed the parameters for proper OPRA requests consistent with the law’s purpose, and consistent with the line of cases set forth both in [...]’s opening brief and here.  It is precisely for this reason that use of federal courts to “predict[] the direction of state law” is a “serious problem[].”  Huddell v. Levin, 537 F.2d 726, 738 (3d Cir. 1976).  Federal courts “themselves have recognized, in fact, that the trial and intermediate appellate courts of a state are better able to predict the state’s law than are any of the federal courts. ”  Packard v. Provident Nat’l Bank 994 F.2d 1039, 1046-47 (3d Cir. 1993).  And it is easy to understand why; while related, OPRA and FOIA are different laws with unique requirements and exemptions.  See Commc’ns Workers of Am. v. Rousseau, 417 N.J. Super. 341, 358 (App. Div. 2010) (identifying differences between OPRA and FOIA and finding that, because of these differences, references to FOIA may be “of limited value”).  While [...]’s citations may, for argument’s sake, accurately reflect the status of FOIA case law,\(^3\) that case law is irrelevant where there is direct New \(^3\) [...] does not concede that [...]’s characterization of the status of FOIA case law with respect these issues is accurate, nor that it represents a complete canvassing of what FOIA does and does not permit.  Indeed, while [...] highlights Am. Oversight v. United States EPA, 386 F. Supp. 3d 1 (D.D.C. 2019), in support of his claim that requests under OPRA need not include reference to a subject matter (Pb16-17), he does not mention the D.C. Circuit’s cautionary note in the same case that agencies under FOIA need not honor requests that “‘would require the agency “to locate, review, redact, and arrange for inspection a vast quantity of material,”’ as “‘FOIA was not intended to Jersey precedent on point.  [...], far from attempting to escape responsibility under OPRA as [...] suggests, merely urges this court to apply well-settled precedent that balances a requestor’s right to access with the need to limit the effects on an agency’s daily operations.  Under this line of cases, [...]’s obligation was to identify records with reasonable clarity by way of reference to a discrete and limited subject without seeking all of [...]’s records.  Bent, 381 N.J. Super. at 37; Burke, 429 N.J. Super. at 174; Spectraserv, 416 N.J. Super. at 576; MAG, 375 N.J. Super. at 547.  His request does not satisfy these parameters.  Because the trial court’s decision, and [...]’s arguments in support of it, ask this court to reinterpret OPRA in a manner that would rewrite custodian obligations set firmly in place over the last two decades, this court should reverse the trial court’s decision and deem [...]’s request invalid.