2325 COM Cover Letter re Zinnia Health Objection w Exs

February 3, 2025 VIA HAND DELIVERY AND EMAIL Ms. Diana Chandler Zoning Board of Adjustment Secretary Township of West Orange 66 Main Street West Orange, New Jersey 07052 Re: Zinnia Health LLC –Board of Adjustment Application for 33 Mount Pleasant Avenue, Block 88, Lot 26, Township of West Orange, NJ Dear Ms. Chandler: We represent the Committee of Managers of Llewellyn Park (the “COM”). We are writing you to provide a number of documents the COM would like you to include as part of the record on the above-referenced application which the COM referred to previously and/or intends to further address at the continued hearing on February 13, 2025. Initially, as agreed at the prior January 16, 2025 hearing, we have enclosed herein at “Exhibit 1” a summary report of planning testimony that the COM intends to have its planner, Michael J. Pessolano, P.P. testify to at the continued hearing. We have also enclosed herein at “Exhibit 2” certain legal Complaints that were referred to at the prior hearing involving Zinnia Health LLC (the “Applicant”). We believe these legal Complaints provide context to the type of operation the Applicant runs and contradicts the Applicant’s testimony regarding the benefits of this proposed center operating in the West Orange community. The first Complaint entitled Linda Rodgers-Cromer, LCADC v. Zinnia Health LLC, Daniel Cincotta, Deena Scher, docket number ESX-L-004622-23 (the “Whistleblower Complaint”), was a Complaint filed by Ms. Linda Rodgers-Cromer that contains a number of deeply troubling allegations related the Applicant’s treatment facility located at 206 Bergen Avenue, Kearny, New reply to: Matthew P. Dolan Direct Dial: 973-602-3478 MDolan@meyner.com Meyner and Landis LLP Attorneys At Law One Gateway Center Suite 2500 Newark, New Jersey 07102 www.meyner.com 973-624-2800 Fax: 973-624-0356 New York: 100 Park Avenue 16th Floor New York, New York 10017 (516) 683-0171