Filed Complaint with Exhibit

1 PRIME TUVEL & MICELI By: Benjamin T.F. Wine, Esquire N.J. Attorney ID No. 289902018 1 University Plaza, Suite 500 Hackensack, NJ 07601 Attorney for Plaintiff, 410 Main St Holdings LLC 410 MAIN ST HOLDINGS LLC : SUPERIOR COURT OF NEW JERSEY : ESSEX COUNTY Plaintiff, : CIVIL PART - LAW DIVISION : v. : DOCKET NO. : TOWNSHIP OF WEST ORANGE : Civil Action PLANNING BOARD : : COMPLAINT IN LIEU OF : PREROGATIVE WRITS Defendant. : : Plaintiff, 410 Main St Holdings LLC (hereinafter referred to as the “Applicant” and/or “Plaintiff”), by and through its undersigned counsel, Benjamin T.F. Wine, Esquire, of the firm of Prime Tuvel & Miceli, hereby presents this Complaint in Lieu of Prerogative Writs against Defendant, Township of West Orange Planning Board (hereinafter referred to as the “Board” and/or “Defendant”), and, as such, respectfully avers as follows: OPERATIVE FACTS I. The Parties and the Property 1. Plaintiff is the owner of certain real property located at the corner of Main Street and Park Drive North in the Township of West Orange, Essex County, State of New Jersey, and designated as Block 113, Lots 262, 264, and 308 on the Township of West Orange Tax Map (hereinafter collectively referred to as the “Property”). 2. The Board is the duly constituted Planning Board of the Township of West Orange (hereinafter referred to as the “Township”), performing the duties and powers of a planning boardESX-L-001637-25 02/28/2025 2:34:16 PM Pg 1 of 32 Trans ID: LCV2025492774