LO UNIFLOW_Billing_0164_001

SCARINCI | HOLLENBECK eS MTT EAUE nT ATTORNEYS AT LAW 201.896.4100 + sh-law.com WILLIAM C. SULLIVAN, JR. | Partner wsullivan@sh-law.com Phone: 201-896-7215 January 15, 2025 BY EMAIL Phillip Neuer, Esq. Chair, Zoning Board of Adjustment Township of West Orange 66 Main Street West Orange, New Jersey 07052 Re: Zinnia Health, LLC 33 Mount Pleasant Ave. Block 88, Lot 26 Our File No.: 16018.1000 Dear Chairman Neuer: On behalf of applicant, Zinnia Health, LLC, I am writing to object to the request for adjournment made by letter of January 14, 2025 from Matthew P. Dolan, Esq., counsel for the Committee of Managers of Llewellyn Park (“COM”). Zinnia Health, LLC’s application was filed by letter of September 6, 2024. The first hearing of the application was held on November 21, 2024. Due to the Board’s busy schedule, the hearing is to be continued on January 16, 2025. COM was provided with notice of the November 21, 2024 hearing by certified mail dated November 6, 2024. COM had every opportunity to retain a professional planner. Based on Mr. Dolan’s correspondence, they did not identify a planner until early December and the “potential conflict” of that planner was not revealed until “right before the holidays.” In any event, COM apparently has now retained Michael Pessolano, yet it remains unclear why Mr. Dolan advises us two days before the hearing that Mr. Pessolano is not available. We submit that COM had plenty of time to retain a planner and prepare for testimony at the hearing this week, Their failure to do so and resulting request for an adjournment imposes an unfair burden on the Applicant and appears to be delay for delay’s sake. Page 1 of 2 4932-1327-0800, v. 1

There is no basis for the adjournment of our hearing altogether. If the Board is inclined to provide COM with the opportunity to present Mr. Pessolmano’s testimony at a later date, we submit that we should be permitted to continue our testimony and we are hopeful that we can complete our case on the 16, Furthermore, while we recognize that the Board has a very busy schedule, we respectfully request that a special meeting he held to conclude the hearing on this application so that we are not delayed until the February 20, 2025 meeting due to this last minute request by COM. Thank you for your consideration. Very truly yours, BAS: Chat f WILLIAM C. SULLIVAN, JR. For the Firm cc: Diana Chandler Alexander Fisher, Esq. Matthew Dolan, Esq. Scott Burman Harrison Katzen John McDonough Page 2 of 2 4932-1327-0800, v. 1