Supporting Documentation · Mar 12, 2025
Filed Complaint with Exhibit
78b097184f918ae04432dd39495b5caf856b621333f190f53fe0a4409822faddIndexed text · page 45
Show all pages29 A. Declaring that the Board’s denial of the Application was arbitrary, capricious, unreasonable and contrary to the MLUL, the Zoning Ordinance, and the lawful rights of the Plaintiff; B. Declaring that the Resolution memorialized by the Board was arbitrary, capricious, unreasonable and contrary to the MLUL, the Zoning Ordinance, and the lawful rights of the Plaintiff; C. Granting Plaintiff preliminary and final major site plan and conditional use approval and bulk variance relief, which approval shall expressly include the right of Plaintiff to develop the Property with a three (3) story, mixed-use building with 12 residential units and approximately 900 sq.ft. of commercial space; and D. Awarding such other and further relief as this Honorable Court may deem equitable and just, including attorney’s fees and costs of suit. Respectfully submitted: PRIME TUVEL & MICELI Dated: February 28, 2025 By: /s/ Benjamin T.F. Wine BENJAMIN T.F. WINE, ESQUIRE Attorney for Plaintiff, 410 Main St Holdings, LLCESX-L-001637-25 02/28/2025 2:34:16 PM Pg 29 of 32 Trans ID: LCV2025492774
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- Sep 29, 2026
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