PLT letter to PB chair re subpoena 091626

and Environmental Services, LLC, or any Langan affiliate, concerning PB-26-03, the proposed Eagle Rock Avenue/Oval Road traffic signal, relocation or realignment of the Crestmont driveway, associated roadway or parking improvements, or related work. 4. Langan Billing and Payment Records Documents sufficient to identify the person or entity that has paid, reimbursed or is obligated to pay Langan for its work relating to the Crestmont application, proposed traffic signal and associated improvements, including relevant invoices and payment records. 5. WEHI/Garden Homes-Langan Arrangements Relating to Crestmont All agreements, authorizations, proposals, invoices, payment records or other documents reflecting any arrangement under which West Essex Highlands, West Essex LLC, Garden Homes, or an affiliated entity retained, authorized, directed, paid, reimbursed or agreed to pay Langan for work relating in whole or in part to Crestmont, PB-26-03, the proposed traffic signal, the Crestmont driveway relocation, or the Eagle Rock Avenue/Oval Road intersection. 6. Related Communications Communications among Crestmont, WEHI/West Essex LLC/Garden Homes and Langan concerning: (a) the December 2025 agreement; (b) financing of PB-26-03; (c) funding of the Planning Board escrow; (d) financing or design of the proposed traffic signal and associated improvements; and (e) the relationship between those improvements and the proposed West Essex development. Ill. THE REQUEST IS BASED UPON A SPECIFIC, DOCUMENTED CONNECTION BETWEEN PB-26-03 AND PB 24-01 This request is not speculative and is not a fishing expedition. Specific evidence establishes a direct connection between the improvements presently before the Board in PB-26- 03 and the West Essex Highlands development. Most significantly, Langan Engineering and Environmental Services, LLC's January 21, 2026, Traffic Signal Design Report expressly establishes that connection. Langan states that “The proposed traffic signal and associated signal improvements are being implemented in connection with the West Essex LLC development, Planning Board Application No. PB 24-01.” (p.1) Langan further selected 2027 as its design year. In projecting future traffic volumes, it included existing traffic, general background growth and “approved or pending developments in the surrounding area.” (p. 4). Lest there be any doubt that

year. In projecting future traffic volumes, it included existing traffic, general background growth and “approved or pending developments in the surrounding area.” (p. 4). Lest there be any doubt that referenced the proposed and then still pending West Essex Highlands development application, the Langan report states that “traffic generated by the West Essex LLC development (Planning Board Application No. PB 24-01) was incorporated into the analysis.” (p. 4).