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Reply to: 25 INDEPENDENCE BOULEVARD WARREN, NEW JERSEY 07059-6747 (908) 647-1022 (908) 647-7721 FAX www.heroldlaw.com HEROLD LAW PROFESSIONAL ASSOCIATION ATTORNEYS AT LAW 70 NE 5th AVE DELRAY BEACH, FLORIDA 33483 (561) 501-6073 FAX: (561) 501-6069 488 Madison Avenue, Suite 1120 NEW YORK, NEW YORK 10022 (646) 227-0180 BY APPOINTMENT ONLY 150 N. RADNOR-CHESTER ROAD, SUITE F-200 RADNOR, PENNSYLVANIA 19087 OFFICE: (610) 977-2023 CELL: (215) 680-1860 Email: rsimon@heroldlaw.com Extension: 113 March 10, 2025 Via E-mail (jvite@westorange.org) Jamilet Baquerizo Vite, Secretary West Orange Township Planning Board 66 Main Street West Orange, NJ 07052 Re: Applicant: The WayMaker, LLC Property: 40 Eagle Ridge Way, Block 106, Lot 20.03 Township of West Orange Scheduled Hearing Date: March 12, 2025 Dear Ms. Vite: As you are aware, this office represents Llewellyn Park (“Client”) with regard to the above- referenced matter (the “Application”), which we understand is scheduled to continue before the West Orange Township Planning Board (the “Board”) on March 12, 2025. At the prior hearing on this Application, the Board Chairman invited our Client to provide in writing a summary of testimony intended to be provided by our engineering expert, Eric Keller, as to the Application. While much of the following is anticipated to be addressed by Mr. Keller in his testimony, we also use this opportunity to bring to the Board’s attention the many procedural and substantive deficiencies with the Application. Our Client continues to participate before the Board as to the Application due to serious stormwater runoff impacts from the Property that continue to adversely impact our Client’s properties and many of its 170 taxpaying residents. The Applicant, prior to submitting its Application, engaged in improper development activities on its Property, such as the improper disturbance of steep slopes, the improper relocation of a New Jersey Department of Environmental Protection (“NJDEP”) regulated drainage ditch, and the improper installation of a drainage pipe (including entering upon our Client’s property without consent), each without first securing the necessary permits from the Township or relief from the Board and/or other regulatory agencies with jurisdiction over such activities, such as the NJDEP, have contributed to cause extensive stormwater damage to our Client’s properties. The

relief from the Board and/or other regulatory agencies with jurisdiction over such activities, such as the NJDEP, have contributed to cause extensive stormwater damage to our Client’s properties. The Application currently before the Board is for Major Site Plan approval under the Township’s Stormwater Management regulations, due to the approximately 1.88 acres of the Property being disturbed to accommodate the construction of a pool building, inground pool,