[brief] Defendants cannot rely on the invalidly issued zoning permit in 2020.  (Pa 122).  It needs to be stressed that prior to 2020 there was no zoning permit issued for any occupancy of the commercial structure on the PQ for a food use.  Work was done on the property without permits.  Work was done on the property with only construction permits, but no zoning permit.  (Pa 118-121).  The only thing that resembles a "zoning determination" on this property is the 1984 Resolution of the Zoning Board that was issued to [...].  It has already been shown that the Resolution is void because the Zoning Board did not have jurisdiction.  It is also clear that [...] did not rely on anything that was given to it in writing by the municipality regarding the food use when it purchased the property in 2015.  The only written documents relate to the two-family house.  (Pa 88-90).  There is nothing whatsoever in writing dealing with the food use or the commercial structure at the time that [...] purchased the property.  [...] had every opportunity at that time to go to the Board of Adjustment and to obtain a zoning certificate outlining exactly what it could or could not do on the property.  N.J.S.A. 40:55D-68.  It chose not to do that.  In addition, as of January 23, 2020, the zoning officer was on notice that the neighbor was challenging [...]’s right to operate a restaurant out of the commercial building on the PQ. (Pa 95-96).  Under those circumstances, the zoning officer should have refused to issue the permit because there was doubt as to whether the applicant was entitled to it and should have referred the matter to the Board of Adjustment.  See William M. Cox & Stuart R. Koenig, New Jersey Zoning & Land Use Administration § 12–1.4 at 2065 (2021).  Not only was the zoning officer on notice, but the property owner and the applicant were on notice that the neighbor was contesting their rights to operate under a preexisting non-conforming use status.  Either [...] or the property owner could have gone to the Board of Adjustment at that time and established just exactly what their rights were.  (T1 at 53:23-54:13-16).  They chose not to do that and to move ahead.  No equity whatsoever flow to them to rely upon what is clearly an invalid permit.  See Town of Belleville v. Parillo, 83 N.J. 309 (1980); VF Zahodiakin Engineering Corp. v. Zoning Bd. of Adjustment of City of Summit, 8 N.J. 386 (1952); Irvin v. Township of Neptune, 305 N.J. Super. 652 (App. Div. 1997); Auciello v. Stauffer, 58 N.J. Super. 522 (App. Div. 1959); Borough of Rockleigh v. Astral Industries, 29 N.J. Super. 154 (App. Div. 1953); Adler v. Bergen County Department of Parks & Public Property, Town of Irvington, 20 N.J. Super. 240 (App. Div. 1952); Frizen v. Poppy, 17 N.J. Super. 390 (Chancery Div. 1952); *Jantausch v. Verona*, 41 N.J. Super. 89 (Law Div. 1956), aff'd, 24 N.J. 326 (1957);  Clearly, the Defendants cannot rely on an invalid zoning permit nor establish any equities that would support an estoppel argument against the Plaintiffs, who filed suit within thirty days of the Defendants’ opening of this business, having never before been given a copy of the 1984 Resolution nor the supposed March zoning permit.  The Court below erred in failing to conclude that the Defendants could not rely upon that invalidly issued zoning permit.