Letter to Board 104 Winding Way

SPRINGFIELD │ NEWARK │ VOORHEES │ ELIZABETH | UNION | ELMWOOD PARK │MORRISTOWN | SUMMIT | CHERRY HILL | VINELAND │ | NEW YORK │ATLANTA | Stephen F. Hehl Anita Lynn James Steven H. Merman Natasha Montalvo Trevor J. Endler Maria Kelly Certified Trial Attorneys 370 CHESTNUT STREET UNION, NJ 07083 TEL: (908) 687-7000 FAX: (908) 687-7028 www.lawjw.com January 5, 2026 Via FedEx & Electronic Mail: ZoningBoard@westorange.org Mr. Philip D. Neuer Esq., Zoning Board Chairperson Zoning Board of Adjustment TOWNSHIP OF WEST ORANGE Town Hall 66 Main Street West Orange, NJ 07052 Re: Application for Bulk “c” Variance Approval Applicant: Pardo Development Group, Inc. Property: 104 Winding Way Block: 46.01 Lot: 33 Application No.: ZB-24-17 Dear Chairperson Neuer and Members of the Board: As you are aware, this office represents the Applicant, Pardo Development Group, Inc., with regard to the above referenced application. Kindly allow this letter to clarify the issues identified by the Board at the last hearing on this matter. First, as discussed during the last board meeting, the property is surrounded on two of three sides by the Rock Spring Golf Course. As this Board is aware, the Golf Course was purchased by West Orange and is operated by a private entity. Additionally, this property has subsequently been placed in the town’s Green Acres inventory. Due to this designation, it is unavailable to be purchased by an individual or entity without subsequently replacing the land in the Township’s inventory with another parcel of land. The Board additionally requested that we provide more information on the parcel of land and its history. We were provided with a full title report on the property which demonstrated that the property has existed as a separate parcel since at least 1955. This strengthens our position that the size of the lot is not a self-created hardship and is instead a condition that pre-exists the changes in zoning requirements.