CHERNIN AND FREEMAN A PROFESSIONAL CORPORATION

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1 6c CL

2 CHERNIN AND FREEMAN A PROFESSIONAL CORPORATION JRECEIVED KAY 1 S1977 SANFORD E. CHERNIN HOWARD FREEMAN VILLAGE PLAZA SHOPPING CENTER IO75 EASTON AVENUE SOMERSET. NEW JERSEY O8873 (ZOl) 82S-74OO MAY 17, 1977 DAVID H. BEN-ASHER, ESQ. \lh EVERGREEN PLACE EAST ORANGE, NEW JERSEY RE: URBAN LEAGUE OF GREATER NEW BRUNSWICK, ET ALS V. MAYOR AND COUNCIL OF THE BOROUGH OF CARTERET, ET ALS DOCKET NO. A SOUTH PLAINFIELD DOCKET NO. A-^ DEAR MR. BEN_ASHER: ENCLOSED HEREWITH PLEASE FIND COPY OF BRIEF AND APPENDIX ON BEHALF OF THE DEFENDANT-APPELLANT, MAYOR AND COUNCIL OF THE BOROUGH OF SOUTH PLAINFIELD, WITH REFERENCE TO THE ABOVE MATTER. WOULD YOU KINDLY ACKNOWLEDGE RECEIPT OF SAME ON THE COPY OF THIS LETTER AND RETURN. RS VERY TRULY, NFORD E. CHERNIN DELIVERED CA002151N{OM}

3 c. CHERNIN S FREEMAN, A PROFESSIONAL CORPORATION VILLAGE PLAZA SHOPPING CENTER 1075 EASTON AVENUE SOMERSET, NEW JERSEY (201) ATTORNEY FOR SOROUSH OP SOUTH PLAINFIELD Plaintiff URBAN LEAGUE OF GREATER NSW BRUNSWICK, ET AL, Defendant vs. THE MAYOR AND COUNCIL OF THE SOROUSH OF CARTE8HT, ET AL, SUPERIOR COURT OF HEW JERSEY APPELLATE DIVISION Docket No. A- CIVIL ACTION NOTICE OF MOTION PLEASE TAKE NOTICE THAT SANFQRD E. CHERNIN, ATTORNEY FOR THE DEFENDANT, SOROUSH OF SOUTH PLAINFIELO, MAKIN THIS APPLICA- TION ON BEHALF OF SAID BOROUGH OF SOUTH PLAINFlELD AND JOINTLY ON BEHALF OF THE DEFENDANTS, TOWNSHIP OF CRANBURY, TOWNSHIP OF HAST BRUNSWICK, TOWNSHIP OF MONROE, TOWNSHIP OF PXSCATAWAY, TOWNSHIP OF PLAINSSORO, BOROUGH OF SAYREVILLE AND TOWNSHIP OF SOUTH BRUNSWICK, HEREBY APPLIES TO THE SUPERIOR COURT OF NEW JERSE APPELLATE DIVISION, FOR AN ORDER OF SAID COURT GRANTING A STAY

4 OF THE PROVISIONS OK THE FINAL JUDGMENT OF JULY 9, 1976 PENDING THE OUTCOME OF APPEALS HERETOFORE FILED* THE MOVANT SHALL RELY UPON THE CERTIFICATION ANNEXED HERETO. DATED: SEPTEMBER 27, 197S CHEftNXN S FREEMAN ATTORNEYS FOR DEFENDANT, SOROUSH OF SOUTH PLAIHFIELD /S/ SANFORD, CHERNfN SANFORD CHERNIW

5 CERTIFICATION 1. I AM ATTORNEY FOR THE DEFENDANT, SOROUSH OF SOUTH PLAINFIELD, A?IO HAKE THIS CERTIFICATION IN SUPPORT OF MY NOTICE OF MOTION FOR A STAY PENDING THE OUTCOME OF THE APPEALS FILED. 2. ON AUGUST 23, 1976 THE BOROUGH OF SOUTH PLAINFIELD FILED ITS NOTICE OF APPEAL FROM. THE ENTIRETY OF A DECISION RENDERED BY THE HONORABLE DAVID D, FURMAN, d.s.c. DATED JULY S, LIKEWISE, THE DEFENDANTS, TOWNSHIP OF CRANSUSY, TOWNSHIP OF EAST BRUNSWICK, TOWNSHIP Of MONROE, TOWNSHIP OF PI5CATAWAY, TOWNSHIP OF PLAINS8ORO, BOROUGH Of SAYREVILLS AND TOWNSHIP Or SOUTH BRUNSWICK, HAVE ALSO FILED NOTICES OF APPEAL FROM THE:SAME'JUDG- MENT. IN ADDITION, TWZ PLAINTIFF HAS FILED A NOTICE OF CROSS APPEAL AND ADDITIONALLY, HAS FILED SEPARATE NOTICES Of DIRECT APPEAL FROM VARIOUS PORTIONS OF THE SAME JUDGMENT. EFFECTIVELY, ALL OF TH PARTIES HAVE APPEALS MOW PENDING IN THE APPELLATE DIVISION. 3. THE MATTERS CONTAINED IN THIS LSTISATION ARE OP VAST AND FAR REACHING IMPORTANCE HOT ONLY TO THE RESIDSNTS AND CITIZENS OF THE BOROUGH OF SOUTH PLAINFIELD, TOWNSHIP OF CRAN8URY, TOWNSHIP OF EAST BRUNSWICK, TOWNSHIP OF MONROE, TOWNSHIP OF PISCATAWAY, TOWNSHIP OF PLAIN58ORO, BOROUGH OF SAYREVILLE, TOWNSHIP OF SOUTH BRUNSWICK, BUT TO ALL RESIDENTS AND CITIZENS THROUGHOUT THE STATE OF NEW UESScY AMD ELSEWHERE. THE MATTERS INVOLVED ARE OF GREAT

6 SUBSTANCE AND INVOLVE LEGAL AND CONSTITUTIONAL ISSUES WHICH OUGHT! BEST BE RESOLVED BY AN APPELLATE TRIBUNAL. *». FURTHER, THE COURT IS AWAR2 THAT THE LEGISLATURE HAS RECENTLY ENACTED A NEW LAND USE LAW EFFECTIVE AUGUST 1, 197S AND REQUIRED A PULL AND COMPREHENSIVE REVIEW OF ALL EXISTING MASTER PLANS AND ZONINS ORDINANCES TO THE END THAT THEY BE REDRAFTED AND ADOPTED IN ACCORDANCE WITH THE NEW LAND USS LAW OH OR BEFORE FEBRUARY 1, 1977, 5. THE UUDGMENT OF THIS COURT DATED UULY % *?& REQUIRES FULL COMPLIANCE BY THE MUNICIPALITIES WITHIN NINETY C90> DAYS FROcM ITS DATE. EFFECTIVELY, THIS HOULD MEAN THAT EACH MUNICIPALIT MUST REVIEW ITS ORDINANCES AND COMPLY WITH THE COURT'S JUDGMENT AMD TH2N REDO THE ENTIRE THING ONCE MORE IN ORDER TO ACCOMPLISH THE PURPOSES AND INTENT OF THE NEW LAND USE LAW. 6. IN ANY EVENT, IN ORDER TO EFFECTIVELY COMPLY WITH EITHER THE COURTS JUDGMENT OF JULY 9, 1976 OR THE NEW LAND USE LAW, IT WILL BE NECESSARY FOR THE RESPECTIVE MUNICIPALITIES TO SEEK THE AID AND ADVICE OF PROFESSIONAL PLANNERS* THE BOROUGH OF SOUTH PLAINFIELD DO S NOT HAVE A FULL TIME PLANNER ON ITS STAFF. THIS MEANS THAT SOLICITATION THROUGHOUT THE PROFESSIONAL PLANNING FIELD &1LL HAVE TO BE MADE, PLANNERS INTERVZg&ED, BIDS RECEIVED AND APPROVED. IT WOULD BE WHOLLY IMPOSSIBLE TO ACCOMPLISH THE COMPLIANCE DICTATED BY THE COURT WITHIN THE NINETY DAY PERIOD.

7 7. IT IS QUITE APPARENT THAT BUILDERS, OWNERS OF LAND, OR CONTRACT PURCHASERS CAN READILY BE ADVERSELY AFFECTED AND THEIR RIGHTS PREJUDICED IF THERE IS HOT A STAY OF THE JUDGMENT OF JULY 3, SHOULD HEW ORDINANCES 3S ENACTED IN COMPLIANCE WITH THE JUDGMENT, BUILDERS, LAND SPECULATORS, DEVELOPERS AND INDIVIDUALS WHO DESIRE TO PURCHASE LAND FOR THEIR OWN BONES WOULD DE IN POSITION TO COME IN AND OBTAIN BUILDING PSAHITS AND/OR CERTIFICATE OF OCCUPANCY; DEVELOPERS COULD OBTAIN PRELIMINARY APPROVAL FOR A SUBDIVISION, ALL PRIOR TO THE TIME WHEN THIS HATTER WOULD Bt CONSIDERED BY THE APPELLATE DIVISION OF THE SUPERIOR COURT. ANY ALTERATION OF THE TRIAL COURT JUDSI4ENT WOULD VOID THE ISSUANCE OF BUILDING PERMITS OR THE GRANTING OF PRELIMINARY SUBDIVISION APPROVAL. THE SND RESULT WOULD BS WHOLLY DISRUPTIVE AND DAMAGING. I CAN NOT SSLIEVE THAT THE COURT ^OULD CONSIDER PERMITTING THIS TO HAPPEN* THE VERY PERSONS WHO WOULD BE PART OF THE CLASS REPRESENTED 8Y THE PLAINTIFFS WOULD BE THE VERY PERSONS WHO WOULD 3 HOST HARMED IN THE FINAL ANALYSIS. 3. LASTLY, BECAUSE OF THH MAJOR IMPORTANCE OP THE ISSUES ENCOMPASSED WITHIN THE COURT*$ DECISION, IT WOULD APPEAR TO BE AN EFFORT IN WASTED TIME, ENERGY AND EXPENSE TO DIRECT AND COMPEL FULL COMPLIANCE WITH THE COURT*S ORDER PENDING A FULL REVIEW AND FINAL DETERMINATION BY OUR APPELLATE COURTS. 9. IT IS URGENTLY REQUESTED THAT THIS COURT ENTER A STAY OF THE; INJUNCTION SET FORTH IN THE JUDGMENT OF JULY 9, 1976 UNTIL

8 SUCH TIME AS THE APPEAL LODGED JN THIS CASE CAN BE FULLY ARGUED A^D DECIDED. 10. I CERTIFY THAT THE FOREGOING STATEMENTS HADE BY ME ARE TRUE. I AM AWARE THAT IF. ANY OF THE FOREGOINC STATEMENTS MADE &Y HE ARE WILFULLY FALSE/ I A?4 SUBJECT TO PUNISHMENT. DATED: SEPTEMBER 27, 1976 /5/ SAMFOaP E. CHERNiM SANFORD E. CHERNIN

9 ELIZABETH MCLAUGHLIN CLERK LEO H. KIERNAN DEPUTY CLERK CHERNIN & FREBMAN, ESQS. - VILLAGE PLAZA SHOPPING CENTER 1075 EASTON AVENUE SOMERSET, NEW JERSEY Dear Sir: (Emtrt nf APPELLATE DIVISION OCTOBER 15, 1976 OFFICE OF THE CLERK ROOM 316 STATE HOUSE ANNEX TRENTON NEW JERSEY O862S Docket No.A Motion No. Title: URBAN LEAGUE OF GREATER NEW BRUNSWICK, ET AL VS. MAYOR & COUNCIL OP THE BORO. OP CARTERET, ET AL MOTION FOR STAY PENDING APPEAL If deficiencies are noted below or supplemental material is to be submitted please return the copy of this letter with the supplemental material to facilitate handling. Five copies of all supplemental material is required unless noted otherwise. Your motion papers have'been filed under the above docket number. The following has been noted: ( ) Papers apparently satisfy Rule requirements (ST) No supporting brief ( ) Overlength brief ( ) No supporting or verifying affidavits ( ) Insufficient number (Original and four required) ( ) Improper size paper (No larger than 8 1/2" x 11") ( ) No copies of judgment or order referred to and/or appealed from ( ) No copies of written opinion of the lower court, or transcript of oral opinion, or statement of reasons (X) No acknowledgment or proof of service (_) No filing fee ($5.00) (_) No deposit for costs ($200.00); R. 2:5-2 (_) The 15-day service and filing requirement of R. 2:5-6 has not been met ( ) Illegibility (_) No original notice of motion, affidavit, or brief (_) Papers not signed (_) Improperly notarized (X) Other AS ATTORNEY OF RECORD SOLELY FOR SOUTH PLAINFIELD, RELIEF SOUGHT IS LIMITED TO A & TO S. PLAINPISLB, If deficiency noted above, moving papers must be perfected by _ All answering papers must be filed no later than sent to the Court, complete or not, on. All papers will be UT cc: SEE ATTACHED SHEET Very truly yours. Elizabeth McLaughlin Clerk of the Appellate Division For information call Motion Clerk at Form #A-16

10 Peter J. Selesky, Esq. 22 Kirkpatrick Street New Brunswick, N.J Huff & Moran, Esqs. Cranbury-South River Rd. Cranbury, N.J Dennis Cummins, Jr., Esq St. Anne Street Fair Lawn, N.J Bertram E. Busch, Esq. 99 Bayard Street New Brunswick, N.J Roland A. Winter, Esq. 940 Amboy Avenue r Edison, N.J Richard F. Plechner, Esq. 351 Main Street Metuchen, N.J Louis J. Alfonso, Esq. 325 Highway 516 Old Bridge, N.J Martin A. Spritzer, Esq. 4l4 Main Street Metuchsn, N.J Edward J. Johnson, Jr., Esq. 1 Greenbrook Road Middlesex, N.J Thomas R. Farino, Jr., Esq. l8l Gatzmer Avenue James Burg, New Jersey Joseph H. Burns, Esq. 103 Bayard Street New Brunswick, N.J. O89OI. Daniel Bernstein, Esq. P.O. Box 1148 Plainfield, N.J Joseph L. Stonaker, Esq. 245 Nassau Street Princeton, N.J John J. Vail Esq. 121 North Broadway South Amboy, N.J Barry C. Brechman, Esq State Highway 27, Suite 207 Kendall Park, N.J Arthur W. Burgess, Esq. One Main Street Woodbridge, New Jersey Gary M. Schwartz, Esq. 65 Millton Road East Brunswick, N.J Guido J. Brigiani, Esq. 1 Oakland Road Jamesburg, N.J Frank J. Jess, Esq. 270 Hobart Street Perth Amboy, N.J Gilbert L. Nelson, Esq. 203 Livingston Avenue New Brunswick, N.J William J. 0'Shaughnessy, Esq. 744 Broad Street Newark, N.J Daniel A. Searing, Esq H Ftreet, N.W., Suite 410 Washington, D.C David H. Ben Asher, Esq. 134 Evergreen Place East Orange, N.J Rubin & Lerner, Esqs. 101 Bayard St. P.O. Box 827 New Brunswick N.J Charles V. Booream, Esq. 199 North Main Street Milltown, N.J. O885O Alan J. Karcher, Esq. 61 Main Street Sayrcville, N.J

11 o CHERNIN AND FREEMAN A PROFESSIONAL CORPORATION SANFORO E. CHERNIN HOWARD FREEMAN * r<fc l~ S\ <-F * ; P<" E"\ AU ,,,,,. _ V LLAGE PLAZA SHOPPING CENTER 1075 EASTON AVENUE SOMERSET. NEW JERSEY (201) AUGUST 2 0, 1976 MRS. ELIZABETH MC LAUGHLIN, CLERK SUPERIOR COURT OF NEW JERSEY, APPELLATE DIVISION STATE HOUSE ANNEX. TRENTON, NEW JERSEY RE: URBAN LEAGUE OF GREATER NEW BRUNSWICK, ET AL V. THE MAYOR AND COUNCIL OF THE BOROUGH OF CARTERET, ET AL DOCKET NO. C-^ DEAR MRS. MC LAUGHLIN: ENCLOSED HEREWITH PLEASE FIND ORIGINAL AND COPY OF NOTICE OF APPEAL IN CONNECTION WITH THE ABOVE, WHICH WE REQUEST YOU FILE. OUR CHECK IN THE AMOUNT OF $25.00 COVERING FIL- ING COSTS IS ATTACHED. YOURS VERY TRULY, SANFORD E. CHERNIN SEC:WMK ENC. CC: CLERK, MIDDLESEX COUNTY SUPERIOR COURT HON. DAVID D. FURMAN, J.S.C. ALL ATTORNEYS OF RECORD

12 CHERNIN FREEMAN, A PROFESSIONAL CORPORATION VILLAGE PLAZA SHOPPING CENTER 1075 EASTON AVENUE SOMERSET, NEW JERSEY (201) ATTORNEY FOR DEFENDANT, MAYOR AND COUNCIL Plaintiff URBAN LEAGUE OF GREATER NEW BRUNSWICK, ET AL, Defendant THE MAYOR AND COUNCIL' OF THE BOROUGH OF CARTERET, ET AL, vs. OF THE BOROUGH OF SOUTH PLAINFIFLD SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION MIDDLESEX COUNTY Docket No CIVIL ACTION NOTICE OF APPEAL NOTICE IS HEREBY GIVEN THAT THE DEFENDANT, MAYOR AND COUNCIL OF THE BOROUGH OF SOUTH PLAINFIELD, APPEALS TO THE SUPERIOR COURT OF NEW JERSEY, APPELLATE DIVISION, FROM THE ENTIRETY OF A JUDGMENT DATED JULY 9, 1976 AND ENTERED BY THE HONORABLE DAVID D. FURMAN, J.S.C. CHERNIN S FREEMAN "ATTORNEYS; FOR DEFENDANT, MAYOR AN&.. CpUNCJL OF THE BOROUG^/OF/'SO]/T/H P LA I NF I ELD DATED: AUGUST 20, 1976 BY. C / / SANFORD E. CHERNIN

13 CERTIFICATION THE UNDERSIGNED DOES HEREBY CERTIFY THAT HE SHALL COMPLY WITH R.2:5-3(A) (REQUEST FOR TRANSCRIPT), SAID TRANSCRIPT TO BE ORDERED BY LETTER ADDRESSED TO LOUIS FINKEL, SUPERVISOR, MIDDLE- SEX COUNTY COURT HOUSE CERT IFI ED SHORTHAND REPORTERS, DATED AUGUST 20, 1976, AND NO DEPOSIT FOR SAID TRANSCRIPT BEING REQUIRED UNDER R.2:5-3(D). THE ABOVE MENTIONED REQUEST IS A JOINT REQUEST FOR THE TRANSCRIPT SIGNED BY ALL ATTORNEYS FOR DEFENDANT-APPELLANT MUNICIPALITIES FILING NOTICES OF APPEAL; A COPY OF SAID REQUEST IS TO BE FILED BY BERTRAM E. BUSCH, ESQ., ATTORNEY FOR DEFENDANT- APPELLANT, EAST BRUNSWICK TOWNSHIP. THE UNDERSIGNED HEREBY CERTIFIED THAT NO DEPOSIT IS REQUII^ ED TO BE MADE WITH THE CLERK OF THE APPELLATE DIVISION BY DEFENDANT-APPELLANT, BOROUGH OF SOUTH PLAINFIELD, FOR COSTS OF THE WITHIN APPEAL. IN ACCORDANCE WITH R.2:5-2. THE UNDERSIGNED DOES HEREBY CERTIFY THAT THE ORIGINAL OF THE FOREGOING NOTICE OF APPEAL HAS BEEN FILED WITH THE CLERK OF THE SUPERIOR COURT OF NEW JERSEY, APPELLATE DIVISION; THAT A COPY OF THE SAME HAS BEEN FILED WITH THE CLERK OF THE MIDDLESEX COUNTY COURT; THAT A COPY OF THE SAME HAS BEEN MAILED TO THE HONORABLE DAVID D. FURMAN, J.S.C.; AND THAT COPIES OF THE SAME HAVE BEEN FORWARDED TO THE FOLLOWING ATTORNEYS BY ORDINARY MAIL ON AUGUST 2 0,1976. BAUMGART BEN-ASHER, ESQS. DANIEL A. SEAR ING,ESQ. (OF COUNSElp ATTORNEYS FOR PLAINTIFFS NATIONAL COMMITTEE AGAINST 134 EVERGREEN PLACE DISCRIMINATION IN HOUSING, INC. EAST ORANGE, N.J ^+25 H ST., N. W., WASHINGTON, D. C. 2(^005 PETER J. SELESKY, ESQ. ATTORNEY FOR DEFENDANT, CARTERET 22 KIRKPATRICK ST., NEW BRUNSWICK, N.J

14 WILLIAM C. MORAN, JR., ESQ. ATTORNEY FOR DEFENDANT, CRANBURY CRANBURY-SQUTH RIVER ROAD CRANBURY, N.J. 0*8512 DENNIS J. CUMMINS, JR., ATTORNEY FOR DEFENDANT, ST. ANNE ST. FAIR LAWN, N.J ESQ. DUNELLEN BERTRAM E. BUSCH, ESQ. ATTORNEY FOR DEFENDANT, EAST BRUNSWICK 99 BAYARD STREET NEW BRUNSWICK, N.J ROLAND A. WINTER, ESQ. ATTORNEY FOR DEFENDANT, EDISON 940 AMBOY AVENUE EDISON, N.J RICHARD F.~ PLECHNER, ESQ. ATTORNEY FOR DEFENDANT, HELMETTA 351 MAIN STREET METUCHEN, N.J. 0 88^+0 LAWRENCE LERNER, ESQ. ATTORNEY FOR DEFENDANT, HIGHLAND PARK 101 BAYARD STREET NEW BRUNSWICK,N.J GUIDO J. BRIGIANI, ESQ. ATTORNEY FOR DEFENDANTS, 1 OAKLAND ROAD JAMESBURG, N.J JAMESBURG SPOTSWOOD LOUIS J. ALFONSO, ESQ. ATTORNEY FOR DEFENDANT, 3 25 HIGHWAY 516 OLD BRIDGE, N.J MADISON (OLD BRIDGE) MARTIN A. SPRITZER, ESQ. ATTORNEY FOR DEFENDANT, METUCHEN 414 MAIN STREET METUCHEN,N.J EDWARD J. JOHNSON, JR., ATTORNEY FOR DEFENDANT, 1 GREENBROOK ROAD MIDDLESEX, N.J ESQ. MIDDLESEX

15 CHARLES V. BOOREAM, ESQ. ATTORNEY FOR DEFENDANT, MILLTOWN 199 N. MAIN STREET MILLTOWN, NJ THOMAS R. FARINO, JR., ESQ. ATTORNEY FOR DEFENDANT, MONROE 181 GATZMER AVENUE JAMESBURG, N. J.. ' JOSEPH H. BURNS, ESQ. ATTORNEY FOR DEFENDANT, NORTH BRUNSWICK 103 BAYARD STREET NEW BRUNSWICK, N.J DANIEL S. BERNSTEIN, ESQ. ATTORNEY FOR DEFENDANT, PISCATAWAY 700 PARK AVENUE PLAINFIELD, N.J JOSEPH L. STONAKER, ESQ. ATTORNEY FOR DEFENDANT, PLAINSBORO 245 NASSAU STREET PRINCETON, N. J ALAN J. KARCHER, ESQ. ATTORNEY FOR DEFENDANT, SAYREVILLE 61 MAIN STREET SAYREVILLE, N.J JOHN J. VAIL, ESQ. ATTORNEY FOR DEFENDANT, SOUTH AMBOY 121 N. BROADWAY SOUTH AMBOY, N.J ANDRE W. GRUBER, ESQ. ATTORNEY FOR DEFENDANT, SOUTH BRUNSWICK 1215 LIVINGSTON AVENUE NORTH BRUNSWICK, N.J ROBERT C. RAFANO, ESQ. ATTORNEY FOR DEFENDANT, SOUTH RIVER 129 MAIN STREET SOUTH RIVER, N.J & GARY M. SCHWARTZ, ESQ. 6 5 MILLTOWN ROAD EAST BRUNSWICK, N.J

16 A.RTHUR W. BURGESS, ESQ. BARRY H. SHAPIRO, ESQ. ATTORNEY FOR DEFENDANT-WOQDBRIDGE 167 MAIN STREET" WOODBRIDGE, N.J GILBERT L. NELSON, ESQ. ATTORNEY FOR THIRD PARTY DEFENDANT, 203 LIVINGSTON AVENUE NEW BRUNSWICK, N.J FRANK J. JESS, ESQ. ATTORNEY FOR THIRD PARTY 270 HOBART STREET PERTH AMBOY,N.J NEW BRUNSWICK DEFENDANT, PERTH AMBOY WILLIAM J. 0'SHAUGHNESSY, ESQ. ATTORNEY FOR INTERVENORS, N.J. WOMEN VOTERS, ET AL 7^*+ BROAD STREET NEWARK, *N. J LEAGUE OF CHERNIN g FREEMAN ATTORNEYS F,,OR DEFENDANT, SOUTH P-WUNFIELD,./ BY r. HOWARD FREBMAN