On May 30, 2018 a Letter,Correspondence was filed involving a dispute between Pennrose Llc, and Andre Oliveriera, Annette L Smith, Aparecida S Coutinho, Apc Associates Llc, Carl Muller, Carol L Radomski, Carol Muller, Chakrya K Molinoff, Charles Furlong, Christine E Herb, Christine Greatrex, Daniel Hanks, Daryl F Tonia, David Hercock, Diane Speer, Diego Castellanos, Doris G Blyler, Edward Mulka, Elizabeth Falco, Erika Gore, Eugene M Flacche, Eva Hanks, George C Greatrex Jr, George Freudenberg, Giovanna Ferriera, Hoover Quintero Garcia, Hui Y Shih, James E Weist, Jeffrey B Canfield, Jeffrey D Herb, Jeffrey L Molinoff, Joanne K Welch, John M Pfrommer, John S Radomski, Jose A Coutinho, Joseph Cavalieri, Karen Woznica, Katherine O Schimmel, Keenan Builders Llc, Lee H Schimmel, Margo Furlong, Marie E Kern, Ming T Shih, Muir A Mcmath, Paulette Smith, Rebecca Castellanos, Recon Investment Group Llc, Richard J Smith, Robert Gore, Robert Woznica, Ronnie M Tarchichi, Roseanne M Canfield, Russell Smith, Scott G Kern, Sigmund Tonia, Susan M Stevens, Syeda F Ahmed, Syed M Ahmed, Theodore J Speer Jr, Thomas B Mitchell, Umur Selek, Vito Brasile, Warren G Blyler, Wongsduan Mulka, for Mt. Laurel in the District Court of Burlington County.
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BUR-L-001147-18 08/28/2019 6:33:52 PM Pg 1 of 4 Trans ID: LCV20191543408 Law Offices Taenzer, Ettenson & Aberant A Professional Corporation Uri Hugo Taenzer 123 North Church Street P.O. Box 237 Alan H. Ettenson Moorestown, New Jersey 08057 (856) 235-1234 Kevin E. Aberant Fax (856) 235-1911 (Member of N.J. and PA. Bar) Email Aberant@tesalaw.com August 28, 2019 Hon. Paula T. Dow, J.S.C. Burlington County Courts Facility 49 Rancocas Road Mt. Holly, NJ 08060 Re: Pennrose, LLC vs. APC Associates, et. als. Docket L-1147-18 Dear Judge Dow: Please accept this letter as a supplement to the letter brief I submitted in opposition to Russ Smith’s Notice of Motion returnable on August 30, 2019 which seeks an Order “to strike testimony of Moorestown Township.” While I am mindful that the Court Rules do not contemplate any further submissions for this pending motion, I have just received correspondence that directly addresses the issues Mr. Smith is raising in the present application, and therefore I believe the interests of justice are best served by this communication. Iam attaching as “Exhibit A” to this letter an enclosure letter from Clarke Caton Hintz (the Township’s Affordable Housing Planner) to the Township of Moorestown which forwarded “a revised Draft Housing Element and Fair Share Plan and Land Use Plan Amendment for consideration by the Planning Board.” I have not enclosed the draft plan, which is in a binder three inches thick. I was handed this letter (with the draft amended plan) yesterday, which was after the deadline for submission of opposition to the motion. The letter further notes: “The Land Use Plan is being modified to reflect the change in affordable housing sites and to return the Pennrose site to a professional office land use category.” This confirms what I represented at oral argument for the prior motion, and that anticipated action by the Planning Board to change the master plan is not mere speculation. I appreciate your indulgence in your kind consideration of the attached. Most respectfully, TAENZER, ETTENSON & ABERANT A Professional C: oration KEVIN BERANT KEA/Img cc: Mr Russ Smith Township of Moorestown BUR-L-001147-18 08/28/2019 6:33:52 PM Pg 2 of4 Trans ID: LCV20191543408 EXHIBIT “A” BUR-L-001147-18 08/28/2019 6:33:52 PM Pg 3 of 4 Trans ID: LCV20191543408 @® @ H Clarke Caton Hintz Judith F. Murphy, PP, AICP Architecture Planning Board Secretary Planning Township of Moorestown. Landscape Architecture ur W. Second Street Moorestown, NJ 08057 August 22, 2019 100 Barrack Street Re: Draft Housing Element and Fair Share Plan Trenton NJ 08608 Land Use Plan Amendment clarkecatonhintz.com Tel: 609 883 8383 Dear Ms. Murphy, Fax: 609 883 4o44 Please find enclosed with this letter a revised Draft Housing Element and Fair Share Plan and Land Use Plan amendment for consideration by the Planning Board. The present schedule for a public hearing on this document is October 3, 2019 but may need to be adjusted because of unfolding events. This document is intended to replace the April 4, 2019 Housing Element and Fair Share Plan. The Land Use Plan is being modified to reflect the change in affordable housing sites and to return the Pennrose site to a professional office land use category. Copies are included for the following persons: ° Planning Board — 11 copies ° Planning Board Attorney — 1 copy ° Planning Board Planner — 1 copy Community Development — 3 copies for the Department's internal use and for viewing by the public Philip Caton, FAICP Township Council not on Planning Board — 4 copies Township Manager — 1 copy John Hatch, FAIA Township Attorney — 1 copy George Hibbs, AIA Township Clerk —1 copy Brian Slaugh, AICP Michael Sullivan, AICP Additionally, I will send copies to Special Counsel Michael Edwards and Court Master John Maczuga directly. Emeniti Sincerely, John Clarke, FAIA Carl Hintz, AICP, ASLA Btian Slaugh, PP, AICP Affordable Housing Consultant Page 1 of2 BUR-L-001147-18 08/28/2019 6:33:52 PM Pg 4 of 4 Trans ID: LCV20191543408 @@H Clarke Caton Hintz Cc. Thomas Neff, Township Manager Anthony Zappasodi, Dir. of Community Development Kevin Aberant, Esq., Township Attorney Michael Edwards, Esq., Special Counsel John Maczuga, PP, AICP, Special Court Master W:\s000's \Moorestown|s180.19 37d Round Plan\Memos and Correspondence\Trans, of 10.19 HEFSP.docx Page 2 of 2