PLT letter to PB chair re subpoena 091626

The report further explains that, as part of the signalization project, Crestmont's existing exit-only driveway along Eagle Rock Avenue would be relocated and aligned directly opposite Oval Road, thereby becoming the southern leg of the proposed sivnalized intersection. Most importantly, Langan's conclusion is that the propose: traffic signal is “warranted and operationally justified under the 2027 Build condition.” (p. 9). Its conclusion further states that the applicable traffic-signal warrants reflect existing and anticipated traffic demands associated with both general background growth and “the West Essex LLC development (Planning Board Application No. PB 24-01).” (p. 9). Thus, the connection between the Crestmont improvemenis and the now-denied West Essex Highlands development application is not an inference advanced by objectors. It is expressly stated in the professional engineering report supporting the proposed signal and associated improvements. IV. THE JUNE 10, 2026, DENIAL OF P B 24-01 HEIGHTENS THE RELEVANCE OF THESE DOCUMENTS The relationship between the two projects has assumed adiitional significance because the Planning Board denied PB 24-01 on June 10, 2026, and that denial is presently the subject of judicial proceedings. Accordingly, traffic from the proposed West Essex development that Langan incorporated into its 2027 Build analysis cannot simply be assumed to material ze in 2027. Indeed, even if the Planning Board had approved PB 24-01 in June 2026, there was no possibility that the Oval Road traffic would have been increased beyond possible construciion vehicle traffic. This presents an important factual question for the Board in considering PB-26-03: Would the proposed signal satisfy the applicable traffic-signal warrants, and would the proposed improvements otherwise be justified, if traffic atiributable to the presently unapproved West Essex development were removed from Langan's analysis? It also raises a separate but related question concerning how and why the improvements presently before the Board were conceived, commissioned, financed and designed. V. THE CONTRACTUAL AND FINANCIAL DOCUMENTS ARE DIRECTLY RELEVANT TO THOSE QUESTIONS Against this factual background, the December 2025, agreement between Crestmont and WEHI/Garden Homes, the W-9 and records concerning funding 0 the PB-26-03 escrow, and the agreements and

E QUESTIONS Against this factual background, the December 2025, agreement between Crestmont and WEHI/Garden Homes, the W-9 and records concerning funding 0 the PB-26-03 escrow, and the agreements and payment arrangements involving Crestmont, WE! II/Garden Homes and Langan are directly relevant. They may establish that Crestmont independently conceived, commissioned and financed the improvements presently before the Board.