[brief] The Authority has asked this Court to reverse the reformation of the Redevelopment Agreement and Operating Agreement, as set forth in the March 15, 2024 Order.  Da49.  Such “review of any order entered by the trial court is limited,” and this Court “will not disturb an order unless it is unsupported by the facts of record, *Rova Farms Resort, Inc. v. Investors Insurance Co. of America*, 65 N.J. 474, 483-84 (1974), or the judge misapprehended or misapplied the governing law. ”  *Manalapan Realty, L.P. v.* --- \(^1\)  In this submission, the Authority relies on the same defined terms as used in its initial revised Brief in support of appeal, dated July 3, 2024.  Twp. Comm. of Manalapan, 140 N.J. 366, 378 (1995) (emphasis added).  “A trial court's interpretation of the law and the legal consequences that flow from established facts are not entitled to any special deference. ”  Manalapan Realty, L.P., 140 N.J. at 378, citing State v. Brown, 118 N.J. 595, 604 (1990); Dolson v. Anastasia, 55 N.J. 2, 7 (1969); Pearl Assurance Co. Ltd. v. Watts, 69 N.J. Super. 198, 205 (App. Div. 1961).  As stated in the Authority’s brief in chief, “[t]he traditional grounds justifying reformation of an instrument are either mutual mistake or unilateral mistake by one party and fraud or unconscionable conduct by the other. ”  Dugan Constr. Co. v. N.J. Tpk. Auth., 398 N.J. Super. 229, 242-43 (App. Div.), certif. denied, 196 N.J. 346 (2008) (quoting St. Pius X House of Retreats, Salvatorian Fathers v. Diocese of Camden, 88 N.J. 571, 577 (1982)).  The record before the trial court is clear -- there was no mistake by either party in the drafting of the relevant documents, and the Authority did not engage in any fraud or unconscionable conduct.  [...] argues the trial court “did not need to make a finding of fraud or mistake to reform the Redevelopment Agreement,” and that the trial court acted within its discretionary powers to impose such a remedy.  See, [...] Brief (“Br.”), at 38.  “Mandates of deference do not apply when issues of law are involved, however. ”  Cosme v. Boro. of East Newark Tp. Comm., 304 N.J.Super. 191, 203 (App. Div. 1997), citing In re J.W.D., 149 N.J. 108, 117 (1997).  In this instance, the trial court misapplied the clear legal standard for reformation of contract, and “the questions for determination turn not upon the resolution of disputed facts, but rather upon the legal consequences of the factual complex when applicable rules of law are applied thereto. ”  Pearl Assur. Co. v. Watts, 69 N.J. Super. at 205.  “[W]here the trial judge misapplies the law to the facts, it is the duty of the reviewing court to adjudicate the controversy in the light of applicable principles in order that a manifest denial of justice be avoided. ”  Id., citing Kavanaugh v. Quigley, 63 N.J. Super. 153, 158 (App. Div. 1960).  “The determination whether or not a trial judge has pronounced judgment agreeably with the applicable rule of law is, in this connection, as in all others, one to be made independently by an appellate court, unfettered by principles of decisional deference. ”  Cosme, 304 N.J. Super. 203, citing In re J.W.D., 149 N.J. at 117.  It is for these reasons that (1) the within appeal is properly before this Court, and (2) this Court should reverse the trial court’s reformation of the Redevelopment Agreement and Operating Agreement as set forth in the March 15, 2024 Order.