7 2 2024 Submission

DELL’ITALIA & SANTOLA ATTORNEYS-AT-LAW 18 TONY GALENTO PLAZA. ORANGE, NEW JERSEY 07050 STACY A. SANTOLA, ESQ. Telephone (973) 672-8000 301 SOUTH LIVINGSTON AVENUE, SUITE 100 Telecopier (973) 672-8215 JOHN P. DELLITALIA, ESQ.** * Of Counsel DASBARRISTERS@GMAIL.COM JOHNPDELL@AOL.COM July 2, 2024 Via Hand Delivery Via Email dchandler@westorangeorg Township of West Orange 66 Main Street West Orange, New Jersey 07052 Attn: Diana Chandler Planning and Development RE: VARIANCE 31 BRADFORD AVENUE, WEST ORANGE, NJ HEARING DATE JULY 18, 2024 Dear Ms. Chandler: Enclosed please find the following: Executed Continuance Form Revised Application Form Copy of the Letter sent to all residents within 200 feet List of Residents within 200 feet Certified mail receipts Panelist List NAM PWNS Very truly yours, DELI?IVALIA & SANTOLA BY: JPD/ap Enclosures JOHN P. DELL’ITALIA, ESQ. LIVINGSTON, NEW JERSEY 07039 ‘Telephone (973) 535-8811 Telecopier (973) 672-8215, REPLY TO ORANGE, NJ Copy of Notice submitted to the West Orange Chronicle for ad to be published on 6/3/24

TOWNSHIP OF WEST ORANGE FORM PH-iZ CONSENT TO CONTINUANCE/EXTENSION OF HEARING Cross out inapplicable items in () The undersigned applicant, in the appeal pending before the West Orange Zoning Board of Adjustment, identified as application number 2B-23-11 hereby consents to the continuance/postponement of the hearing/decision on said matter, involving property identified -01 & 2.01 as: Block(s): 55.06 ; Lot(s): ; Address: 31 & 29 Bradford Avenue, West Orange, NJ 07052 It appears after initial review that, due to the (agenda back log) and/or (complex nature of the applicant’s application for development), the Zoning Board will not be able to properly review and make a decision on the application within the statutory time set by the New Jersey Municipal Land Use Law. Itisonthis_24 day of 2024 agreed by and between the applicant(s) Jose De Olveira & Joel Newman _, and the Zoning Board of Adjustment of the Township of West Orange, New Jersey that the statutory time for hearing/decision shall be extended to duly 18, 2024 or the first succeeding agenda date available. It is further understood that if at said time and place a quorum of the Board is not present, this matter will be further continued to the next succeeding regularly scheduled meeting of the ane , Date Wicant or Attorney

TOWNSHIP OF WEST ORANGE - APPLICATION FORM FOR THE PLANNING BOARD OR ZONING BOARD OF ADJUSTMENT ICANT INFORMATION Full Legal Name; _De Oliveira, Jose & Newman, Joe! (Last) First) Mailing Address: __31 & 29 Bradford Avenue West Orange NJ 07052 (Street) (City) (State) (Zip) ’ Telephone Number: (973) 223-0690 Email:_jmotiveira@hotmail.com Is the Applicant an: & Individual, (1 Corporation, Partnership, Other Ifthe Applicant is a corporation or partnership, a list of the names and addresses of persons having a 10% . {nterest or more in the corporation or partnership must be attached, Relationship of the applicant to the property: &@ Owner, J Tenant or Lessee, O) Purchaser under contract (with consent of owner, C] Other (please specify) If the applicant is not the owner of the property in question, the applicant must submit an affidavit with the owner(s) authorization to proceed with this process, |. B. PROPERTY OWNER INFORMATION « Check here ifsame as applicant, If the owner is not the applicant, please complete the following: Owner's Name: Address: Telephone Number: (____) Email: OPERTY INFORMATION: 37 Street Address; 31 & 29 Bradford Avenue, West Orange, NJ 07052 Block Number(s): __ 55.06 ; Lot Number(s): _ 1.01 & 2.01 3 Tax Plate: ; Zone of Property: R-5 The location of the property is approximately 1 feet from the intersection of. Northfield Avenue and 31 Bradford Avenue (closest intersection.) Has there been any previous Zoning Board of Adjustment or Planning Board hearings involving this property? 0 Yes, Date(s): ;& No If yes, please attach copies of the written decisions adopted by the Board to each application. Please attach a list of all contiguous or adjacent property owned by the applicant or owner, 1 None is this property listed in “The Historic Sites Survey” prepared by Robert Guter 7/9/1992 [1] Yes R No TAPLANMINGMRNDuciment LibrarsPLRZBA Applicutton 420-1 S.doe

PEQRAPPLICATION oe wet OE Indicate the type of application being submitted, check all boxes that apply, Note that more than one variance } may be necessary, please indicate the number of each type needed: 1) O Interpretation of ordinance or map. 2) O Appeal of action of Zoning Officer. 3) & Variance “CI” Reason: C1 shape of property; a physical features; &I exceptional situation. 4) Cl Variance “C2”, 5) O Variance *D”, 6) © Subdivision without variances: O major; O minor; 0 preliminary; © final; Qpretiminary and final. 7) Q Subdivision with variances: & major; (] minor; O pretiminary; 0 final; Copreliminary and final. 8) O Site Plan: O pretiminary; 1 final; Oopreliminary and final; (2 with variances; ( without variances, 9) (1 Amended Site Plan. 10) C1 Conditional Use. 1}) € Conceptual, 12) Cl Home Professional Office. 13) Cl Home Occupation, 14) 0 Soil Remoyai Permit, Please list the specific Sections of the Ordinance for which a variance is sought, If additional space is required, please attach a list. Section: 25-8.4-B _; Proposed: ; Description: Section: 3 Proposed: ; Description: . Section: ; Proposed: 3 Description: H Section: __; Proposed: ; Description: : E, DESCRIPTION OF PROPERTY Existing Use of the Property Briefly describe the major elements of your proposal: (a more detailed description is required in Section G) x The property is_10,995.93 (square feet); 25 (acres) Impervious Surface Coverage: Present: ; Proposed: Building Coverage: Present: ; Proposed: Is the property located; Within 200 feet of another municipality? C1 Yes No Adjacent to an existing or proposed county road? &l Yes ONo Adjacent to other county lend? O Yes RINo Adjacent to a state highway? 0] Yes No TAPLANNING.BED|Oncument LibraqhPUAZUA Application 1-20-15ulae

The following information is respectfully requested to enable the Board to facilitate the processing of this application: APPLICANT’S ATTORNEY: _John P. Dell'talia, Esq, Telephone Number: (973) 672-8000 Email: _johnpdell@aol.com Address: 18 Tony Galento Plaza, Orange, NJ 07050 APPLICANT'S ENGINEER: Mizra Baig, PE Telephone Number: (201 )736-7546 Email:_ ksiengineering@gmail.com Address: 80 Broadman Parkway, Jersey City, NJ 07305 APPLICANT'S ARCHITECT: ___ Rui Amaral Telephone Number: ( 973) 477-5369 Email: ramaralra@aol.com Address: APPLICANT'S PLANNER: Telephone Number: ( ) Email: Address: OTHER EXPERT(S): Telephone Number: ( ) Email: Address; [f necessary, please list any additional experts below, including address, telephone number and email address, TAPLANNING ARD\Ovcument Library WPB-ZBA Applicutton 4-201 Salve

REQUIREMENTS FOR VARIANCES 4A) 4B) AC-1) 40-2) 4D) 4E) Please attach a written statement labeled “PROPOSAL”, describe the major elements of your proposal, and describe in detail the physicat and use changes proposed, Please attach a written statement labeled “REASONS FOR RELIEF”, which fully answers 4C-1, 4C-2 or 4D (Special Reasons) AND part 4E (Negative Criteria). (For Cl variances only) The strict application of the provisions of the Zoning Ordinance would result in the peculiar and exceptional practical difficulties or exceptional undue hardship under NJLS.A. 40-55D- 70e(1). List in detail wherein this case conforms to this requirement, including, if applicable, reference to the exceptional narrowness, shallowness, or shape of the Property, or the exceptional topographical conditions affecting the property which applicant contends warrants the granting of the variance, (For C2 variances only) State how the purposes of the Municipal Land Use Law would be advanced by a deviation from the zoning ordinance requirements and the besefits of the deviation would substantially outweigh any detriment according to N..S.A ¥0:55D-70c(2), Please list all benefits of the deviation to the Township and any adverse effects, State how the benefits of the deviation would substantially outweigh any detriment to the Township. (For D variances onily) State the special reasons under N.IS.A 40:55D-70d affecting this property, The granting of this variance Will, not be substantially detrimental to the public good and will not substantially impair the intent of the zone plan and zoning ordinance. List in detail the reasons, among others, why the variance can be granted without being materially detrimental to the welfare of the community or injurious to the property or improvements of others in the neighborhood and zone, |. PLAT SUBMISSION 4F) Please list all maps and other exhibits accompanying this application. Attach an additional sheet if necessary. ITEM SIGNED BY DATE/REVISION LNOTICE Applicant ts responsible to publish and serve notice of this application in accordance with Zoning Board of Adjustment/Planning Board requirements; however, notice may not be served until this application is certified as complete and the administrative officer has assigned the applicant a public hearing date. TAPLINNING.BRDIDuctement LihrarytPRAZUA Application 4-20-15,doe

J. VERIFICATION AND AUTHORIZATION SIGNATURE [S REQUIRED FOR ALL OF THE FOLLOWING: APPLICANT'S VERIFICATION Uhereby certify that the above statements made by me and the information contained in the papers submitted in connection with this application are true, [ am aware that if any of the foregoing statements are willfully false, I am subject to punishment. Applicant’s Signature: bP Jost Newer Date: 6,26, eo CONTINUANCE Should the Planning Board/Zoning Board of Adjustment have a full and heavy agenda, or discussion and meeting regarding this application requiring carrying the matter past the statue time limit, the applicant grants permission for such an extension. Applicant's Signature: 4 ia < blt era? Date: ELEL IY oe OWNER’S AUTHORIZATION ~ MUST BE SIGNED Thereby certify that I reside at in the County of and the State of and that [ am the owner of all that certain lot, plece or parcef of land known as Block(s) : Lot(s) on the Tax Map of which property Is the subject of the above application, and that said application is hereby authorized by me. Furthermore, | authorize inspection of the site which is the subject of this application. Owner’s Signature; ZZ LE. heel ¢t Mecsas d Date: ’Ge DAS oO “ THIS APPLICATION DOES NOT RELIEVE THE APPLICANT FROM COMPLYING WITH OTHER TOWNSHIP ORDINANCES SUCH AS THE TREE REMOVAL ORDINANCE AND OBTAINING THE NECESSARY APPROVALS AND PERMITS UNDER SUCH ORDINANCES, TAPLANVING ARDYDocument Lheney\PR-20s| Application 4-2-1 S.dne

PLEASE TAKE NOTICE that the undersigned has filed an appeal or application for Development with the Board of Adjustment for a Cl. Pursuant to Section 25-8.4"solid walls not higher than 6ft are permitted in the rear yard and on side property line up to the rear line of the Applicant's house." The Applicant's solid walls on the rear and east sides have a combined height of 5'-8" + 6'-8" = 12'-4". Magnitude of deviation: An exemption/waiver is requested for a height of 6'-4" (which is the difference between 12'-4" and 6'-0) The applicant also requests any variances, waivers, exceptions deemed necessary at the time of the hearing. On the premises at_31 Bradford Avenue (street address) and designated as Block 5506 Lot(s) __01___and_29 Bradford Avenue (street address) and designated as Block 5506, Lot(s)___02___on the Tax Map of the City of West Orange Township. This notice is sent to you as owner of property in the immediate vicinity. A public hearing has been set for Thursday. July 18,2024, @ 8:00 pm via ZOOM _Please copy and paste into your browser to join the meeting: https://us06web.zoom.us/j/8 1800566092? pwd=5 XavNKuZ0 WbpfD3 YhGD-3ko910 1 g0g. YTY MC-pWI- WIHpIN Webinar ID: 818 0056 6092 Password: 812878 For the West Orange Zoning Board, 66 Main Street, West Orange, NJ. When the case is called, you may appear on video, or by agent or attorney, and present any objection you may have to the granting of the relief sought in the application, The application and appropriate plans are available for review at the office of the Board’s secretary during normal business hours. If you wish to review them or if you have any questions, please call Diana L. Chandler at (973) 325-4108.

WEST ORANGE PLEASE TAKE NOTICE that the undersigned has filed an appeal or apnlication for Development with tha Board af Adjustment for a C1. Pursuant to Section 25-8.4 “salld walls ‘not higher than Git ara permitted in the rear yard and on sido property line up to the rear line of the Applicants’ house.” The Applicants’ solld walls on the reer and gest sides have a ‘combined helght of 648" + 6'B" = 1244", Magnitude of daviation: An examptlon(walver is requested ‘or a height of g'-4" ‘which Is the difference belwean 12-4" and 8-0) The appilcanis also request any variances, walvers, exceptions deemed necessary al the time of the hearing. On andfor between the premises at 21 Bradford Avenua (street address) and dasignsted as Block 5506 Lol(s}___04 und 20 Bradford Avenue (street addrass) and designated as Block 8806 Lol{s) 02 on the Tax Map of tha City of West Oranga Township, THs noice Is sont you as owner of property In the Immediate won A pubile hearing has been set for ZOGH Plesse copy and sate Into your ‘browser to Joln the meeting: Fitpssfus0oWeb zoom uso 800636002? d8XavNKuZOWbpiD3YNGD-BkoSIO1g0g. "1 YMC-pW1-WIHpIN Wobinae 1D: 818 0068 6002 Pasawort: 812878 For the West Orange Zoning Board, 66 Main Streel, Wast Orange, NJ. When tho case.is called, you may appear on video, or by agent o¢ attorney, and present any objection you may have to the granting of the rellaf sought in the application. ‘Tha application and apprapriale plans are avaitable for review at the office of the Board's secretary during normal business hours. If you wish to review thom of if you have any questions, please call Diana L. Chandler at (973) 325-4108, John P, Dali'talia, Esq. Altamey for Appiicants: £13007 WOC July 3, 2024 ($17.84)

DELVITALIA & SANTOLA ATTORNEYS-AT-LAW 18 TONY GALENTO PLAZA ORANGE, NEW JERSEY 07050 JOHN P. DELL'ITALIA, ESQ, ‘Telephone (973) 672-8000 304 SOUTH LIVINGSTON AVENUE, SUITE 100 Telecopier (973) 672-8215 LIVINGSTON, NEW JERSEY 07039 STACY A. SANTOLA, ESQ. ‘Telephone (973) 535-8811 Telecopier (973) 672-8215 JOHNPDELL@AOL,COM REPLY TO ORANGE, NJ July 1, 2024 Via Regular & Certified Mail Jose M. & Jennifer De Oliveira 31 Bradford Avenue West Orange, NJ 07050 Dear Sir/Madam: PLEASE TAKE NOTICE that the undersigned had filed an appeal or application for Development for a C-J Variance from the requirement of the Zoning Ordinance so as to permit the Applicants to replace a retaining wall on and/or between the premises of 3] Bradford Avenue, West Orange and designated as Block $506 Lot(s) 01 on the Tax Map of the City of West Orange and 29 Bradford Avenue, West Orange and designated as Block 5506 Lot(s) 02. This notice is sent to you as owner of the property in the immediate vicinity. The Applicants’ solid walls on the rear and east sides have a combined height of 5'-8" + 6'-8" = 12'-4", Magnitude of deviation: An exemption/waiver is requested for a height of 6'-4" (which is the difference between 12'-4" and 6'-0) The applicants also requests any variances, waivers, exceptions deemed necessary at the time of the hearing. A public hearing has been set for Thursday, July 18, 2024, at 8:00 pm for the West Orange Township Zoning Board via Zoom, i Please copy and paste into your browser to join the meeting: https://us06web.zoom.us/j/8 1 800566092?pwd=5 XavNKuZ0WbpfD3 YhGD- 3ko9101g0g. YIYMC-pWI-WIHpIN Webinar ID: 818 0056 6092 Password: 812878 When the case is called you may appear cither in person, or by agent or attorney, and present and objection you may have to the granting of the relief sought in the application. The application and the appropriate place are available for review at the office of the Board’s secretary during the normal business hours. If you wish to review them or if you have any questions, please call Diana L. Chandler at (973) 325-4108. Ver tuly yours, i DELLAYTALIA & SANTOLA BY: NJOHN P DELLITALIA, ESQ JPD/ap