[brief] Throughout its opposition brief, Plaintiff attempts to improperly shift blame for its own carelessness onto Defendant, claiming that Defendant improperly and, in an effort to gain a windfall, served expert planning and appraisal reports based on an “obvious typographical error” of which the Defendant had “actual knowledge. ”  There is no support for the claim that the Defendant had actual knowledge or even an inkling of the error in the description of the taking.  The error contained within the metes and bounds description affixed to the Plaintiff’s Verified Complaint and Declaration of Taking was not obvious, on paper or on the site, nor is the error properly categorized as a simple “typographical” error.  It was the Plaintiff’s burden to ensure its filing was correct to adequately put the Defendant on notice of the taking.  The Defendant is not a land surveyor and is not able to assess a 60-foot difference simply based upon a map or observation of the construction area without the benefit of a survey or expert review.  The 117.65-foot distance was included in the description of the taking set forth in the recorded Declaration of Taking and in the Plaintiff’s initial Verified Complaint.  (Da001, Da016, Da145).  During the litigation, representatives of the Plaintiff made numerous statements that the project was a “repair and replacement” of the Defendant’s then pre-existing seawall.  (Da145).  Defendant’s existing seawall extended to, at, or near the taking area as shown on the map.  After construction was completed, there was a site inspection that was performed by Defendant’s counsel without the benefit of a survey, which was confusing to Defendant’s counsel, and appeared to be inconsistent with the taking.  (Da145).  Defendant’s planner realized the inconsistency between the metes and bounds description and the taking map after going through the process of preparing his report and reviewing Plaintiff’s documentation, but that determination was one of inconsistency, not that the metes and bounds description was wrong.  (Pa31).  Defendant’s expert was not tasked with determining if the metes and bounds description was correct.  That was the obligation of the Plaintiff.  Defendant sought damages, including damages to Defendant’s home due to construction vibrations and loss of view and privacy, from the project construction, which the Law Division improperly excluded.  Project impacts are relevant in calculating just compensation, and the loss of view and the vibrations damage to the house, reasonably calculable and actually foreseeable, should have been permitted to ensure the Defendant his constitutional right to just compensation.  The Law Division’s exclusion of the engineering report of Defendant’s expert, [...], P.E., as to the increased vulnerability to wave overtopping onto the subject property because [...] did not perform the complex calculations, which Plaintiff would have preferred, was also error.  Such technical scientific data was not required to support Defendant’s expert opinion in this case.  In this matter, the Law Division’s rulings improperly denied [...] from having the jury decide just compensation for the damages to which he was entitled.  As such, this matter should be remanded for further consideration by the Law Division.