PLT letter to PB chair re subpoena 091626

The chairman of each Board, or such person as he or she r 1ay designate, shall have the power to administer oaths and issue subpoenas to compel ‘he attendance of witnesses and production of documents. In addition, West Orange Code §25-46.7, governing the powers and duties of the Planning Board, expressly provides that the County and Municipal! Investigations Law applies to “the issuance of subpoenas, the administration of oaths and the taking of testimony.” Finally, West Orange Code §25-48.4(a) provides that intervsted parties shall be afforded the right to cross-examine witnesses, either through counsel or dir2ctly if unrepresented, subject to the presiding officer's discretion and reasonable limitations consistent with due process. Thus, both State law and the Township's own Land Use Regulations expressly authorize the Chair to compel production of relevant documents. The documents requested below bear directly upon issues raised by the application and upon the meaningful examination and cross- examination of witnesses concerning those issues. II. DOCUMENTS REQUESTED I respectfully request issuance of a subpoena duces tecum requiring production of the following: 1. December 2025 WEHI-Crestmont Agreement As testified to by Crestmont’s attorney and club manager et the July 1, 2026, West Orange Planning Board hearing regarding PB 26-03, the complete executed agreement entered into in or about December 2025 between Crestmont Country Club, Inc. and West Essex Highlands, West Essex LLC, Garden Homes, and/or any affiliated entity concerning the proposed traffic signal, Crestmont improvements, the West Essex Highlands development, or PB-26-03, including all exhibits, schedules, amendments, supplements, side agreements and attachments. 2. W-9 and Escrow-Funding Documents As identified in the April 14, 2026, Completeness Review memorandum from the Township Consulting Planner Malvika Apte and Langley Oudemns, Associate Planner, of Heyer, Gruel & Associates to Richard Schkolnick, Esq., counsel for Crestmont, the W-9(s?) submitted in connection with the Planning Board escrow account for PB-26-03, together with documents sufficient to identify the person or entity that supplied. deposited, reimbursed or agreed to provide funds for that escrow account, including checks, wire-transfer records, transmittal correspondence, reimbursement agreements and related

ntity that supplied. deposited, reimbursed or agreed to provide funds for that escrow account, including checks, wire-transfer records, transmittal correspondence, reimbursement agreements and related payment records. 3. Crestmont—Langan Agreements All engagement letters, retainer agreements, contracts, proposals, scopes of work, amendments and other agreements between Crestmont Country Club and Langan Engineering 2