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HILL WALLACK up AiTORNEYS aT La? des Caan Cura 20 Box, Pano sist Tension 65) 9240808, Pa (60) 452-858 ‘rani Esooare, Bs, Pasa, La Uae Lauro aa Aucanons ager Da: (609) 734-6957 Siooerenahnmcinex cou July 21, 2012 HAND DELIVERY Deputy Clerk ‘Superior Court of New Jeracy Union County Courthouse Ist Floor, Room 107 2 Broad Street Elizabeth, New Jersey 07207 Re: LEHIGH ACQUISITION CORP. v. TOWNSHIP OF CRANFORD et al, DKT NO. UNN-L-0140-08 CRANEORD DEVELOPMENT ASSOCIATES, LLC et aly. ‘TOWNSHIP OF CRANFORD 4: aj DKT NO. UNN-L-003759-08 (consolidated) Dear Madam or Sir: Enclosed for filing in the above entitled matter by plaintiff Cran‘ord Development Associates ct al is an original and a copy of the notice of motion in aid of litigant’s rights, together with supporting brief, appendix and form of order. Please conform and return the extra copy to our waiting courier A check for the filing fee is also enclosed. As indicated by the certification of service attached to the notice of ‘motion, these papers have been served on all parties, Ihave also hand-delivered a courtesy copy directly to the Hon, Lisa Chrystal, J.8.C. (FywpoxocsmyervosunaHey 1) Prose Nes | Yeti, Penman Superior Court of New Jersey July 21, 2012 Page 2 Please note that, as per a separate being made to Judge Chrystal, this motion is returnable on short notice on August 3, 2012. J thank you for your time and attention in this matter. Yours truly, HILL WALLACK LLP Attorneys for Cranford Development Associates, LLC, et al ee Hon. Lisa F. Chrystal, J.8.C. Philip Morin, Esq Carl R. Woodward Ill, Esq Douglas Cohen, Esq. Elizabeth MeKenzie, PP, AICP (ewporepocsousrsxounass40y 1b HILL WALLACK LLP ATTORNEYS AT LAW 200 Cameaut Cer, CN 5226, PcevoN NJ 08540-5226 ‘razmona 609) 926 0808 Fac 009] 402-2882 Seman B1sooRr, 0, Part, Lavo Use Lissa A¥D APCATONS Demror a: (09) 734-6957 SDR SHTLIATLACR CO July 21, 2012 Hon. Lisa F. Chrystal Superior Court of New Jersey Union County Court House Lith Floor 2 Broad St. Elizabeth, New Jersey 07207 Re: LEHIGH ACQUISITION CORP. v. TOWNSHIP OF CRANFORD et al, DKT NO. UNN-1-0140-08 CRANFORD DEVELOPMENT ASSOCIATES, LLC et al v. TOWNSHIP OF CRANFORD et al, DKT NO. UNN-1-003759-08 Dear Judge Chrystal: Enclosed for the Court’s consideration is a notice of motion in aid of litigant’s rights together with a supporting appendix and proposed form of order. To enable construction of the low and moderate income housing development provided for in the Court’s order of December 9, 2011, CDA seeks relie! from the failure by Cranford Township to consent to CDA’s regrading a portion of Birchwood Avenue in the immediate vicinity of 215-235 Birchwood ‘Avenue as part of its construction of the development. CDA requests that the Court hear this motion on short notice because the proposed road improvement is integral to the application for site plan approval currently scheduled to be heard by Court-appointed Special Hearing Officer Douglas Wolfson, Esq. on August 8, 2012. CDA originally requested that Cranford Township consent to the proposed road improvement on May 24, 2012, At that time, it provided the Township with fully engineered plans and Supporting data intended to show that the proposed improvement would have rno detrimental effect on other residents of Cranford. Regrettably, although (eswooxpocsonds monanss8e7,3)