CKY High School Complaint

OCN-L-002164-21 08/20/2021 6:01:21 PM Pg 1 of 16 Trans ID: LCV20211937309

Ronald D. Cucchiaro, Esq.

Attorney ID # 041191998
WEINER LAW GROUP LLP
331 Newman Springs Road
Bldg. 1, Suite 136
Red Bank, NJ 07701
Phone: (732) 978-1210
Fax: (732) 978-1201
E-mail: rcucchiaro@weiner.law
Attorney for Plaintiff, Township of Brick
Our File No.: BRICKLSP-002L
2099204_1.DOC
TOWNSHIP OF BRICK, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: OCEAN COUNTY
DOCKET NO.: OCN-L-
vs.
CONGREGATION KEHILOS YISROEL, Civil Action

INC.
ORDER TO SHOW CAUSE
Defendant. WITH TEMPORARY RESTRAINTS
THIS MATTER, having been opened to the Court on
application for an Order to Show Cause filed by the Weiner
Law Group LLP, Attorneys for the Plaintiff, Township of
Brick, (Ronald D. Cucchiaro, Esq., appearing), on notice to
Adam Pfeffer. Esq., Attorney for Defendant, Congregation
Kehilos Yisroel, Inc., and the Court having reviewed the
Brief and Certification in Support of Application for Order
to Show Cause with Temporary Restraints, and for good cause
shown;
IT IS on this ________ day of August, 2021;

ORDERED that the Defendant, Congregation Kehilos
Yisroel, Inc., shall SHOW CAUSE before this Court on August
______, 2021 at 9:00 in the forenoon, or as soon thereafter
as counsel may be heard, why a preliminary injunction should
not issue 1) enjoining Defendant from using property
identified as Block 1095, Lot 1 on the official tax map of
the Township of Brick and more commonly known as 200 Van Zile
Road as a school; and it is
ORDERED that pending the hearing scheduled in this
Order to Show Cause, the Defendant be, and hereby is
temporarily enjoined and restrained from using property
identified as Block 1095, Lot 1 on the official tax map of
the Township of Brick and more commonly known as 200 Van Zile
Road as a school.
ORDERED that service of this Order to Show Cause, and
all papers upon which it was based, shall be made by
delivering by e-filing of this Order to Show Cause and the
papers on which it was based; and it is further
ORDERED that any opposition papers to the application
shall be filed and served so as to be received on or before
August______, 2021, and that reply papers thereto may be
filed and served so as to be received on or before
________________ _____, 2021; and it is further
-2-
ORDERED that argument of the application for a
preliminary injunction shall be by a videoconference to be
scheduled by the Court; and it is further
ORDERED that Defendant shall have leave to move for the
dissolution or modification of the restraint granted herein
on two (2) days’ notice to the Plaintiffs.
_________________________________
Honorable
2099204_1 BRICKLSP-002L Order to Show Cause (Twp. of Brick v. Congregation Kehilos Yisroel) 8.20.21
-3-
Ronald D. Cucchiaro, Esq.

Attorney ID # 041191998
WEINER LAW GROUP LLP
331 Newman Springs Road
Bldg. 1, Suite 136
Red Bank, NJ 07701
Phone: (732) 978-1210
Fax: (732) 978-1201
E-mail: rcucchiaro@weiner.law
Attorney for Plaintiff, Township of Brick
Our File No.: BRICKLSP-002L
2099537_1.DOC
TOWNSHIP OF BRICK, SUPERIOR COURT OF NEW JERSEY

Plaintiff, LAW DIVISION: OCEAN COUNTY
DOCKET NO.: OCN-L-
vs.
CONGREGATION KEHILOS YISROEL,INC. Civil Action
Defendant. FINAL ORDER
THIS MATTER, having been opened to the Court on
application for an Order to Show Cause filed by the Weiner
Law Group LLP, Attorneys for the Plaintiff, Township of
Brick, (Ronald D. Cucchiaro, Esq., appearing), seeking relief
by way of a summary action pursuant to R. 4:67-1(a), and the
Court having considered the papers submitted in support of
and in opposition to the relief sought, as well as the
arguments of counsel; and good cause having been shown for
the entry of this Order;
IT IS on this ________ day of August, 2021;
Yisroel, Inc. has violated the terms and conditions contained

in the Resolutions memorialized by the Township of Brick
Planning Board which never approved a school use on the
subject Property; and it is further
Yisroel, Inc. has violated the Township of Brick Code by
failing to obtain site plan approval from the appropriate
Township land use board; and it is further
Yisroel, Inc., violated the Uniform Construction Code at
N.J.A.C. 5:23-2.14(a) by failing to stop the performance of
interior alterations to the subject Property without a permit
and is required to pay Plaintiff the penalty amount of
$500.00 pursuant to Violation # V-21-00165; and it is further
N.J.A.C. 5:23-2.4(a) by performing interior alterations to
the subject Property without a permit and is required to pay
Plaintiff the penalty amount of $2,000.00 pursuant to
Violation # V-21-00166; and it is further
N.J.A.C. 5:23-2.14(a) by failing to obtain the required
permit to change the use of the Property from a synagogue to
-2-
a school, and is required to pay Plaintiff the penalty amount
of $2,000.00 pursuant to Violation # V-21-00167; and it is
further
ORDERED that Defendant, Congregation Kehilos Yisroel,
Inc. is prohibited from using the subject Property as a
school or any other use not previously approved by the
Planning Board; and it is further
ORDERED that the Plaintiff are found to be the
prevailing parties and awarded counsel fees and costs in the
amount of $________________.
_______________________________
Honorable
2099537_1 BRICKLSP-002L Final Order (Twp. of Brick v. Congregation Kehilos Yisroel) 8.20.21
-3-
Civil Case Information Statement

Case Details: OCEAN | Civil Part Docket# L-002164-21
Case Caption: TOWNSHIP OF BRICK VS Case Type: OTHER Verified Complaint/OSC with Temporary
CONGREGATION KEHILOS YISR Restraints
Case Initiation Date: 08/20/2021 Document Type: Verified Complaint
Attorney Name: RONALD DAVID CUCCHIARO Jury Demand: NONE
Firm Name: WEINER LAW GROUP LLP Is this a professional malpractice case? NO
Address: 629 PARSIPPANY RD PO BOX 438 Related cases pending: NO
PARSIPPANY NJ 070540438 If yes, list docket numbers:
Phone: 9734031100 Do you anticipate adding any parties (arising out of same
Name of Party: PLAINTIFF : Township of Brick transaction or occurrence)? NO
Name of Defendant’s Primary Insurance Company
(if known): None Are sexual abuse claims alleged by: Township of Brick? NO
THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE

CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION
Do parties have a current, past, or recurrent relationship? NO

If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:
Do you or your client need any disability accommodations? NO

If yes, please identify the requested accommodation:
Will an interpreter be needed? NO

If yes, for what language:
Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO
I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)
08/20/2021 /s/ RONALD DAVID CUCCHIARO

Dated Signed

CKY High School Complaint

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OCN-L-002164-21 08/20/2021 6:01:21 PM Pg 1 of 16 Trans ID: LCV20211937309

OCN-L-002164-21 08/20/2021 6:01:21 PM Pg 2 of 16 Trans ID: LCV20211937309

Ronald D. Cucchiaro, Esq.

TOWNSHIP OF BRICK, SUPERIOR COURT OF NEW JERSEY

CONGREGATION KEHILOS YISROEL, Civil Action

THIS MATTER, having been opened to the Court on

application for an Order to Show Cause filed by the Weiner

Law Group LLP, Attorneys for the Plaintiff, Township of

Brick, (Ronald D. Cucchiaro, Esq., appearing), on notice to

Adam Pfeffer. Esq., Attorney for Defendant, Congregation

Kehilos Yisroel, Inc., and the Court having reviewed the

Brief and Certification in Support of Application for Order

to Show Cause with Temporary Restraints, and for good cause

IT IS on this ________ day of August, 2021;

ORDERED that the Defendant, Congregation Kehilos

Yisroel, Inc., shall SHOW CAUSE before this Court on August

______, 2021 at 9:00 in the forenoon, or as soon thereafter

as counsel may be heard, why a preliminary injunction should

not issue 1) enjoining Defendant from using property

identified as Block 1095, Lot 1 on the official tax map of

Road as a school; and it is

ORDERED that pending the hearing scheduled in this

Order to Show Cause, the Defendant be, and hereby is

temporarily enjoined and restrained from using property

identified as Block 1095, Lot 1 on the official tax map of

ORDERED that service of this Order to Show Cause, and

all papers upon which it was based, shall be made by

delivering by e-filing of this Order to Show Cause and the

papers on which it was based; and it is further

ORDERED that any opposition papers to the application

shall be filed and served so as to be received on or before

August______, 2021, and that reply papers thereto may be

filed and served so as to be received on or before

________________ _____, 2021; and it is further

ORDERED that argument of the application for a

preliminary injunction shall be by a videoconference to be

scheduled by the Court; and it is further

ORDERED that Defendant shall have leave to move for the

dissolution or modification of the restraint granted herein

on two (2) days’ notice to the Plaintiffs.

Ronald D. Cucchiaro, Esq.

TOWNSHIP OF BRICK, SUPERIOR COURT OF NEW JERSEY

CONGREGATION KEHILOS YISROEL,INC. Civil Action

Defendant. FINAL ORDER

THIS MATTER, having been opened to the Court on

application for an Order to Show Cause filed by the Weiner

Law Group LLP, Attorneys for the Plaintiff, Township of

Brick, (Ronald D. Cucchiaro, Esq., appearing), seeking relief

by way of a summary action pursuant to R. 4:67-1(a), and the

Court having considered the papers submitted in support of

and in opposition to the relief sought, as well as the

arguments of counsel; and good cause having been shown for

the entry of this Order;

IT IS on this ________ day of August, 2021;

ORDERED that the Defendant, Congregation Kehilos

Yisroel, Inc. has violated the terms and conditions contained

in the Resolutions memorialized by the Township of Brick

Planning Board which never approved a school use on the

subject Property; and it is further

ORDERED that the Defendant, Congregation Kehilos

Yisroel, Inc. has violated the Township of Brick Code by

failing to obtain site plan approval from the appropriate

Township land use board; and it is further

ORDERED that the Defendant, Congregation Kehilos

____________ _, 2021; and it is further