NEW JERSEY SCHOOLS INSURANCE GROUP

6000 Midlantic Drive

Mt. Laurel, NJ 08054
(609) 386-6060 FAX (609) 386-8877

March 8, 2016

Marc A. Cappizzi
Business Administrator
9 Hunter Street
P.O. Box 815
Lodi, NJ 07644

Re:

Insured:
Claimant:
Docket No.:
Complainant:
Claim No.:
Date of Loss:

Lodi Board of Education

Board member: Joseph Licata
CO1-16
Ryan Curioni
15GL03908D
using 2/29/16

Dear Mr. Cappizzi:

Thank you for speaking with me about this matter.
The New Jersey Schools Insurance Group formally acknowledges receipt of the School Ethics
Commission Complaint titled Ryan Curioni v. Joseph Licata, Docket number C01-16. As you
know, Mr. Curioni is alleging that Joseph Licata has been using Lodi BOE administrator, Jamie
Ciofalo during work days to work for the benefit of The Lodi Boys and Girls Club.
The New Jersey Schools Insurance Group (NJSIG) provides the District with a General
Liability Policy, effective July 1, 2015 to July 1, 2016. This policy has a $16,000,000 policy
limit regarding bodily injury and property damage. It also contains an Extension of Coverage for
Statutory Compliance Litigation. This has a $5,000 deductible which applies to defense and
indemnification. There is also a $100,000 annual aggregate.
As you know, N.J.S.A. 18A:12-20 imposes a duty upon the District to reimburse Board
Members for reasonable costs to defend themselves against an administrative action brought
against them for the performance of their duties.
However, N.J.S.A. 18A:12-20 does not impose a duty upon the District to reimburse them for the
legal costs they incur for any cross-claims or counter-claims they may decide to bring against the
Complainant in this matter. Therefore, any cross-claims or counter claims or other actions which
these respondents wish to file against Mr. Curioni will be at their own expense.

NJSIG has assigned Howard Nirenberg of the law firm of Nirenberg Varano, LLP (telephone:
201-996-9114) who will provide a defense for Mr. Licata in this matter. The defense is
conditional and subject to a complete reservation of rights on the issues of both defense and
indemnity under all of the terms, conditions, limitations and exclusions of our policy.
Since the District has a $5,000 deductible, we have asked Mr. Nirenberg to send his bills directly
to you with a second copy to us, until the deductible is met.
Please feel free to contact me with any questions or concerns with regard to this matter.

Very truly yours,

Ronald Huntley, CCLA

Liability Claim Examiner
New Jersey Schools Ins. Group
609-386-6060 ext. 3091
RHuntley@njsig.org

C:

Board member: Joseph Licata

c\o Marc A. Cappizzi
Business Administrator
9 Hunter Street
P.O. Box 815
Lodi, NJ 07644
Robert Lane
Nathan Lane Agency, Inc.
545 Goffle Road
Wyckoff, NJ 07481

bc:

Tony Ruggeri, Claims Supervisor, NJSIG