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HomeMy WebLinkAbout98-00676 "'-. ,.. " .' ... ~ ,"l. . ~' ~ ~ ~ ~ ~ ~. ...c 4- .'S V) .:~ ~ -L ~ " ~ .J ~ ! , !' i / ) / , L' 'it'- "" II ",.; ~ ~"~ :~-' J(j):!') ) , ,\,:'(.: ( ,,,;;4 eV~' If.'l!. \~?\ -f}:f1 j,~;1 ljJ l(~. ' .1( rn, , ,.' \,; ~i """';', -!'Ioo." ::s: ", ~ ."j 1:'--. ~ ~, r"':'-~, c, D G \ , . D.o: ~. I '_'.l~ ;;:itr'. 1\'_ :;/ . ,.~ " '~", ;;:. " IN RE: SOUTH MIDDLETON TOWNSHIP ZONING HEARING BQAlID 520 PARK DRIVE BOILING SPRINGS, PENNSYLVANIA 3.7007-9536 DECISION OF ZONING HEARING BQAlID WILLIAM R. RONAN AND GERALDINE L. RONAN 97 - 32 DOCKET NO.: DATE OF APPLICATION: LOCATION OF PROPERTY: REQUESTED RELIEF: AUGUST 11, 1997 729 PETERSBURG ROAD, CARLISLE, PA APPEAL FROM DETERMINATION OF ZONING OFFICER NOVEMBER 3, 1997 AND DECEMBER 9, 1997 JANUARY 5, 1998 DATE OF HEARINGS: DATE OF DECISION: BOARD MEMBERS IN ATTENDANCE: PAUL HEISHMAN, LARRY BREAM, IVO V. OTTO, JR. ) PROPER NOTICE OF THE ABOVE HEARINGS WAS GIVEN BY ADVERTISING IN THE SENTINEL, CARLISLE, PENNSYLVANIA ONCE A WEEK FOR TWO WEEKS PRIOR TO THE HEARINGS AS APPEARS FROM PROOF OF PUBLICATION. ADDITIONALLY, NOTICE OF THE HEARINGS AND THE APPLICATION WAS SENT TO ALL ADJOINING PROPERTY OWNERS, POSTED ON THE PROPERTY IN QUESTION AND POSTED IN THE SOUTH MIDDLETON TOWNSHIP OFFICE. " \ . I ; i I. PROCEDURAL HISTORY r , j II ) , ~ \ . \~ , .1 ; 1 [ .' !; I, (, ,. I I This case comes before the South Middleton Township Zoning Hearing Board ("Board") on an appeal from a determination of the Zoning Officer of South Middleton Township ("Township") dated July 21, 1997. The Zoning Officer of the Township issued an enforcement notice to Mr. William Ronan dated July 21, 1997 (Township Exhibit-1) which pertained to property at 729 Petersburg Road(Subject Property). In sununary, the enforcement notice suggested that there were three (3) apartments being rented at the subject property, none of which were occupied by the owner of the property, and that such use was in violation of the Township Zoning Ordinance. The owners of 729 Petersburg Road, William R. Ronan and Geraldine L. Ronan, filed on August 11, 1997 a timely appeal of the Zoning Officer's 1 determination to the Board. Hearings were conducted before the Board on November 3, 1997 and December 9, 1997. At thsse hearings, the Ronans were represented by legal counsel and had an opportunity to present both verbal and written evidence. The Township appeared before the Board in the person of the Zoning/Code Enforcement Officer, Mr. Timothy D. Duerr. Mr. Terry Rickert and Mr. and Mrs. Kenneth Wetzel, neighbors to the subject property, appeared at the hearings with the benefit of counsel and objected to the appeal and advanced the affirmation of the enforcement notice. Counsel for the Ronans and counsel for the objectors have filed briefs which have been reviewed by the Board. The Board conducted an Executive Session on December 29, 1997 for purposes of deliberations in connection with this case.l II. DISCUSSION The property at 729 Petersburg Road ("Subject property") is located within an Agricultural Zoning District pursuant to the Township Zoning Ordinance. The enforcement notice issued by the Township/Zoning Officer (Township Exhibit-I) suggested that the subject property had been owner occupied and occasionally had also a one-apartment rental unit. The notice suggested that the rental use had been discontinued for a period of a year or more and, thereby, lost its non-conforming status and that any further apartment renting at the subject property would be illegal under the South Middleton Township Zoning Ordinance. At issue is whether the subject property constituted a non- conforming use under the Zoning Ordinance. If such non-conforming use is established, the second issue would be the nature of the non-conforming use as to whether the subject property was a three- unit apartment building or a two-unit building. A further issue would be whether the non-conforming status was an apartment building status or an owner-occupied dwelling that had an accessory apartment. The final issue is whether any non-conforming status had been abandoned. Mrs. Geraldine Ronan testified on behalf of the applicants, She indicated the subject property was originally owned by Mr. and Mrs. Arnold Hagen, who had owned the property since the early 1950's. Mr. Hagen died in 1962 and Mrs. Hagen died in September of 1994. Mrs. Ronan and her husband were executors of the Hagen estate. She testified that she was quite familiar with the Hagens' paperwork and the Hagens themsel ves. She would take Mrs. Hagen to the hospital two times a week and she was in periodic contact with Mrs. Hagen at other times. The Ronans had lived in the vicinity of the subject property since 1944. 1 An executive session is authorized for quasi-judicial deliberations pursuant to 65 P.S. 5278(a)(5). 2 Mrs. Ronan suggested that the subject property consisted of a first floor dwelling unit which was previously occupied by Mrs. Hagen, a second floor apartment and a basement efficiency apartment. Documentary evidence presented included rental receipt books from Mrs. Hagen's records showing rent receipts as far as back as 1958 (See Exhibits A-I and A-2). The Ronans also produced advertising bills relating to the subject property (Exhibit A-3). These bills refer to a "furnished efficiency", an "efficiency one-adult" and a "second floor apartment" as the type of apartments being rented. These bills are of miscellaneous dates starting in 1978 and going through 1989. Mrs. Ronan suggested that the efficiency apartment was the apartment on the basement level and that the other apartment was a second floor apartment that Mrs. Hagen maintained. Mrs. Ronan indicated that she and her husband were appointed executors of the Hagen estate in October of 1994, a public sale was held in September of 1995, that she and her husband were the beneficiaries of the estate and received title to the property in October of 1995 during the administration of the estate. Mrs. Ronan also presented evidence from the electric company (Exhibit A-4) which she offered to verify that there were separate electric meters for each dwelling unit. The documentation verifies that the second floor apartment had a separate electric meter connected in 1960 and that Mrs. Ronan had a meter connected for the basement unit in 1996. Prior to 1996, Mrs. Hagen had the basement and first floor area on the same electrical unit. Mrs. Ronan testified that previously the basement area had a separate electric meter but she did not produce any documentation in support of that claim. The outside of the subject property has an appearance of a single- family dwelling. Mrs. Ronan suggested that there were at least three (3) mailboxes at the property and multiple electric meters. She indicated that there are three (3) separate physical entrances to the three units in the interior of the premises with separate keys and locks. In addition to a two-car garage, there is a large driveway that would accommodate four (4) cars and another separate driveway area. Each unit has its own separate bathroom and kitchen area. It was established during Mrs. Ronan's testimony that the basement unit was quite often used only by a homeless woman with her children and that no rent was paid for that use. It was also established by other testimony that the basement area of the structure was used by the Hagens for picnics and other uses in conjunction with the Hagen's use of the dwelling unit on the first floor level. Maxine Wetzel of 740 Petersburg Road testified and indicated that she has resided near the subject property for approximately thirty- four (34) years. She testified that in 1971 there was no apartment 3 unit in the basement of the subject property. However, she did acknowledge that there was an apartment used on the second floor and even acknowledged that after 1971 there was a periodic renting of the basement area as a separate unit. She had a falling out with Mrs. Hagen in 1983 and had limited contact with her since that time. Mr. Terry Rickert testified that he has lived across from the subject property since 1981. Mr. Rickert suggested that Mrs. Hagen would rent the upstairs apartment at certain times and the downstairs apartment at other times but that the traditional use was to only have one rental unit at a time. He suggested that he only recalls two (2) mailboxes at the subject property. Testimony established that the first Zoning Ordinance within the Township was enacted in 1969 and became effective in January 1970 (Exhibit A-7). III. LEGAL ANALYSIS Pennsylvania law imposes the burden upon the landowner to establish a non-conforming use by presenting objective evidence demonstrating that the property was devoted to the alleged use at the time of the enactment of the Zoning Ordinance. Appeal of Lester M. Pranqe. Inc., 166 Pa. Cornrow. 626, 647 A.2d 279 (1994). On the issue of abandonment, the burden of proving abandonment of a non-conforming use is upon the party asserting the abandonment and such proof must be by overt acts, or failure to act, demonstrating actual abandonment. Appeal of Lester M. Pranqe. Inc., supra. The Township in its enforcement notice cites S1901.1.C of the Zoning Ordinance which provides that a non-conforming use cannot be re-established if it discontinued for any reason for a period of twelve (12) months or more. Such a timeframe in a Zoning Ordinance is not absolute and creates only a presumption of intent to abandon. Appeal of Lester M. Pranqe. Inc., supra. IV. APPLICATION OF LAW TO THE FACTS It is clear that there has been apartment use at the subject property prior to the enactment of the original Zoning Ordinance in 1970. The Ronans have met their burden in connection with that issue. What remains unclear is whether the basement unit was being rented as a separate unit in 1970 at the time of the adoption of the Ordinance. The documentary evidence presented by the Ronans (Exhibits A-I and A-2), does not verify two (2) different apartment units but, rather, appears to represent rental receipts for only one (1) apartment use. It is clear from the testimony of all witnesses and from documentary evidence (Exhibit A-3) that the basement unit was rented as a separate unit after 1970. However, 4 ". there is conflicting testimony betweetn the witnesses as to the existence of a separate basement unit apartment prior to the enactment of the 1970 Zoning Ordinance. Tho lack of any reference indicating two (2) separate apartment units in the rental receipts pre-1970 (Exhibits A-l and A-2)along with the lack of any documentation from the utility company (Exhibit A-4) suggesting a pre-1970 separate electrical meter for the basement property weighs against the landowners in their assertion that there was a separate basement dwelling unit at the subject property pre-1970.' On the abandonment issue, the Ronans adequately addressed the inconsistency between correspondence from their attorney (Exhibit T-2) suggesting that the subject property was vacant for over two years and the actual use of the subject property. Mrs. Hagen's illness along with her subsequent death clearly caused a break in the continuity of acquiring a tenant at the property. The record is void of any evidence suggesting that there were overt acts or failures to act by Mrs. Hagen or by the Ronans that would demonstrate an abandonment of any apartment use at the subject property. Even assuming the subject property may have laid vacant for more than twelve (12) months, the lack of any settled purpose by the landowners to abandon the multiple family use at the subject property is clear from the record. The objectors in their brief attempt to suggest that any apartment use at the subject property must be conducted in conjunction with "owner occupied use". The current Zoning Ordinance within the Township authorizes "accessory apartments" within the agricultural district by conditional use with an accessory apartment defined as a secondary dwelling unit contained within an owner occupied single-family detached dwelling (Township Zoning Ordinance 5602.2) . However, at issue is what was the use of the property prior to enactment of the Zoning Ordinance. It is clear that Mr. and Mrs. Hagen occupied the subject property prior to the enactment of the January 1970 Zoning Ordinance and it is also clear that they had an apartment on the second floor of the subject property at the same time. In essence, there were two (2) separate dwelling units within the one (1) structure. The fact that one (1) of the dwelling units was owner occupied does not suggest a different type of use than a non-owner occupied two-dwelling unit structure. Furthermore, the 1970 Zoning Ordinance allowed, by special exception in agricultural districts, a use termed "converted apartments" (See 5402 of 1970 Zoning Ordinance). Converted apartments were defined under the 1970 Zoning Ordinance as "a multi-family dwelling constructed by converting an existing building into apartments for more than one 2 The Ronans suggested in testimony that there previously was an electrical meter for the basement unit but that such unit was removed, Even if it was proven that the basement unit did have a separate meter, the logic behind the removal of that electrical meter would suggest an abandonment of any separate apartment use of the basement unit. 5 family, without substantially altering the exterior of the building." (See definitional section of 1970 Zoning Ordinance at No. 10). The "converted apartment" use, which was allowed in 1970, did not include any limitation or restriction that would merit the "owner occupied" tag to be applied to the use. Accordingly, there is no legal or rational basis to impose an "owner occupied" restriction upon a two-dwelling unit use at the subject property which pre-dated the 1970 Zoning Ordinance. V. FINDINGS OF FACTS THE BOARD HEREBY HAKES THE FOLLOWING FINDINGS OF FACTS: 1 Prior to the adopting of a Zoning Ordinance in South Middleton Township, there existed a use at the property at 729 Petersburg Road of a multi-family dwelling consisting of two (2) separate dwelling units. 2 The use of a multi-family two (2) separate dwelling units at the subject property has continued from prior to enactment of zoning in South Middleton Township until the present time. v.r. CONCLUSIONS OF LAW THE BOARD HEREBY HAKES THE FOLLOWING CONCLUSIONS OF LAW: 1 The applicants, William R. Ronan and Geraldine L. Ronan, have met their burden of proof and have demonstrated that a non-conforming use existed at property 729 Petersburg Road, Carlisle, PA, prior to enactment of the January 1970 South Middleton Township Zoning Ordinance, which use was a multi-family two-dwelling structure. 2 The applicants have failed to meet their burden by way of objective evidence that, as of the enactment of zoning in South Middleton Township in January 1970, there existed a third apartment unit on the basement floor of the subject property. . t :. 3 '.~~~' The Township and the objectors have failed to meet their burden of proof in showing any overt acts or failure to act that would demonstrate an abandonment of the multi-family use at the subject 6 property since January 1970. VII. DECISION It is the decision of the South Middleton Township Zoning Hearing Board that the appeal of William R. Ronan and Geraldine L. Ronan from the July 21, 1997 enforcement notice issued by South Middleton Township is sustained in part and denied in part. The appeal is sustained in the sense that it is determined that there was no abandonment of a non-conforming use at property at 729 Petersburg Road, Carlisle, PA, which use consisted of a multi- family dwelling unit at the subject property encompassing two (2) separate dwelling units. The appeal is denied in the sense that it advanced a suggestion that there existed three (3) separate dwelling units at the subject property which had all obtained non-conforming use status. It is determined that two (2) dwelling units at the subject property may continue as a legal non-conforming use, with these units being the first floor dwelling unit and the second floor dwelling unit. The basement area of the subject property has no legal status to be used as a separate dwelling unit.J DATE MAILED A. LARRY BREAM, SECRETARY SOUTH MIDDLETON TOWNSHIP ZONING HEARING BOARD ANY PERSON AGGRIEVED BY THE DECISION OF THE ZONING HEARING BOARD MAY APPEAL TO THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. THE APPEAL MUST BE FILED WITHIN 30 DAYS FROM THE DATE OF THIS DECISION. 3 The Ronans advanced in their brief a request that the Board consider addressing a third apartment unit as an expansion of the existing two (2) dwelling unit non-conforming Use pursuant to 51904 Township zoning ordinance. such an issue is not properly before the Board on a procedural basie. Furthermore, the criteria for the granting of a special exception for expansion of a non-conforming use under 51904 include a number of factors which were not addressed in the testimony at the hearing of this case. Accordingly, the Board does not address in this decision the merit, if any, of Ronan's request to expand a non-conforming Use pursuant to 51904. 7 . ~ TERRY T. RICKERT, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V ZONING HEARING BOARD OF SOUTH MIDDLETON TOWNSHIP, Appellee NO 98-676 (") .0 '11 c: OJ -..' ""l~: J;2o :;1 c: (11 [! : ::..., i,l:D 2..01 -.,m zr- I ~~) .~-: UJ -i,,? ~:C: '-.Je, :=-:: .,.J~ ~;:l-) ...-+1 ~r' -,- ,)(') 1:.- .! W 13m .c ~ -f c- > \0 ~ William R. Ronan and Geraldine Ronan, Intervienors FILING OF RECORD The Zoning Hearing Board of South Middleton Township, pursuant to the Writ of Certiorari issued in the above captioned matter, hereby files and certifies the record of the above proceedings that took place before the South Middleton Township Zoning Hearing Board. The contents of the record are as follows: 1 Application of William R. Ronan and Geraldine L Ronan for an appeal from the Zoning Officer's determination, 2 Transcript of proceedings from November 3, 1997. 3 Transcript of proceedings from December 9, 1997. 4 Exhibit A-I (receipt book) JUL-31-97 THU 10:36 A~ SOUTH ~IDDLETON TSHP@ r. "\i r ., FAX NO, 717 258 3577 P. 02 ~outb ;ffiibbleton ~obJtt5bip 520 Parle Drive, Boiling SpriUK3, P A 17007 PHONE: (717) 258-5324 FAX: (717) 2S8.3577 .' .' APPLrCAUON FOR APPE..l.r.. SPECIAL EXCF.PTION OR V.4.RJANl"'E , \' . I, 1 To the Zoning He:lring Board of'South Middleton TOWlUhip, Cumberland CoUl1ty, Pemuyl";3: 1. The name address of ( appeU:urr. applieant r William R. Ronan and Geraldine L. Ronan, 759 Petersburg Road, CarliSle, PA I I I' I' I l , 2. Address of property Involved: 729 Petersburq Road. Carlisle. PA 3, (Applicant,~) (is, acluat) the owner of propetty, Ifllot, the name and ~ of owner is 4. Name and 3ddress of( ~\IJom'~, Applicant's) 3ttomey, ihny, who will be r=preSentlng (1qsJI'lo1l'~, Applicant) at he3ring: F.dwarn r.. Schomo, Roo.. 36 S, Hanover St.. Carlisle, PA . . S, The prcpexty is presently used as follows: mUlti-family dwellinq (three aoartmentsl J 6. The appe:ll', special elCception or variance sought by (Applicant, .?~U~) citlni ]lrCSCIIt zonini c1assification of property and the section of the Zoning Ordinance UIIder which the appeal, speci3! c.'tceptioll or valiance is rcques~d: we appeal the detennination of the zoninq officer dated July 21. 1997, a coov of which is attached. (Section lQOI) 7, The llrDlIIl.ds for appesJ, or r=:1Sons for special exception or valiance, ate: Applicants have a vested right to nonconfonninq use status for 3 aoartrrents. which nonconfonning use has never been abandoned, 8. For an appeal from ndecisiOl1 or order of the gOverning body or orany officer OT agency attach a true copy of,the order. (d".;?J' (V~ ' . I~ ^ ""'tJA. ~.., S~gnature f Applic t I ,1/. '.. ~. _ / ,..A.-<-<t,u/-v:c..<. . d-" '/-( A--" _ . Signature of (Appellant, Applicant) Date accepted and filed ~ 0 /9/" Received by: j --;-r:.-.ol- S-Iov7- / .-- Fee: S .;2.SD SEE BACK OF APPlICA nON FOR ADDmONAL INFORMATION REQUIRED NAME ADDRESS SMITH, CALVIN J. WOOD, BErry C. HEYMAN, EUGENE F, WESTBROOK, GALEN 722 PETERSBURG ROAD 541 E, OLD YORK ROAD 619 LEREW ROAD 562 E. OLD YORK ROAD WETZEL, KENNETH RICKERT, TERRY T. BRYMESSER, STEPHEN JOHNSON, JERRY A. 740 PETERSBURG ROAD 726 PETERSBURG ROAD 751 PETERSBURG ROAD 748 PETERSBURG ROAD LESKO, B.R. 724 PETERSBURG ROAD SNYDER 744 PETERSBURG ROAD ~ER da;l} /-I, IScl~Jal'lltl~ 752 PETERSBURG ROAD ~outb :flllibbltton m;obJnsbip f'IV(Q) fi5)~ 520 Park Drive, Boiling Springs, PA 17007 ~ IJ' U PHONE: (717) 258-5324 FAX: (717) 258-3577 July 21,1997 Certified # P 180 163 357 Mr. William Ronan 759 Petersburg Road Carlisle, Pa 17013 Re: 729 Petersburg Road Dear Mr, Ronan: As the Zoning Officer of South Middleton Township, I have determined that you are In violation of the following provisions of the Zoning Ordinance of 1989, as amended, for the reasons which I have specified. The previous owner had occasionally rented one apartment while liVing there herself. However, since that time, the dwelling located at 729 Petersburg Road was vacated for a period in excess of a year. According to Section 1901d, if a non-conforming use is discontinued for a period of a year or more, the use loses its non-conforming status as thus cannol be reinstated. At present, conditions suggest that three apartmenls are being rented, none of which is occupied by the owner of the dwelling. Before an accessory apartment use can take place, it must receive conditional use approval from the Board of Supervisors and subject to the following criteria found in Section 602.2: 1, The livable floor area of the accessory apartment shall not exceed seven-hundred twenty (720) square feet. 2. Only one accessory apartment may be permitted within a single-family delached dwelling. 3. An accessory apartment may only be permitted and may only continue in use as long as the principal dwelling is occupied by the owner of said dwelling. 4. The lot area for the principal dwelling shall meet the minimum lot area requirement for the applicable district where located. 5. The exterior architeclural character of the principal dwelling shall not be altered in a manner which departs from the primary feature of the building as a single-family detached dwelling unit. "'I '> .~ " '~'I+ ., . DUE .- 0"' . ~ ~ ". .' It .s . 'J.' ., ',(0",. .- .,.. " ... ,. " " ., .. .. " ~.. , 'fHl: Ii v"tM~FlfetD~~W~NY l~t"fE \lJ. ;) . uo'" I J 0 GAIIL1~l.i I'A \ ..__.._._.._ ""'_00 . ClAM' 0100 CLASSIFIED "OVERTISINO INVOICE ITHE EVENINO SENTINl:L 1/ OIJ P.O. BOX 130 CARLISLE PA 17013 ".,''', .~.u..n_n""'"ll..' t , I', \; (;i ) ( , ., . ,tj INVOICE NO. ~, ARM EXH18IT A> 16 PAV THta ~'" N'L 4.Y/ ~.~2 ~:):.., ,0:,.... .. I' "'1' ',{"'. .. " ..:j~' .~ ~i'~.i " , PAY THIS ^MOU~~ i " .." --. """.u-;:;, ~ ~, CLASSIFIED ADVERTISINO INVOICE t:.V l::N1 NG ~l:N1'1 Nl::L ....,...~. ..~:4:.,.; i I IllIl:: II>. O. UOX 130 CAfiL1~LC I I I I 1 I I , I l'M""~~'f,.iJ .~ Gf;OSS AMf UJ c , I ,. " I.' VCLASSIFIED "OVERTISINO INVOICE L L:1H,lu ,JI...'i!!fl..:.L '''', ~'.- I.),) :.~., !, . 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IIIIIJllN IHIS POIlIIllN WIIH YllllH HIMIITANCI ~i ., \, 'i 350 8513!:l ',;.... ." THIS SPACE FOR ADDRESS ONLY .. , r HAUEN, MON1(;A 12Y I>t.Tcir/",BUk'G WU (;A..Ll:.; t..t: f'A ~ 3.d9 17lJI3 I . L. .J ..' , \ ...., '.) " 3.50 I' ClASSIFIF.D. ADVERTlSIND INVOICE r tl;.;..1 i'~.l I tl ~ L . LL~Sj.IIiV AOV:"rI.IN~ I" () "IH 1~" ~A~Ll~Lt ~A CLASSIFIFD ADVERTISING INVOIC[ THE SENTINEL CLASSFIiED ADVeRTISING P 0 dO X 13 0 l/WCARLISLE PI\ "..11" .'''1.."111'1"_""11'" ..... INVOice NO. 1~, 1(1 S INDEXlNG TERM dJICE'1 8TART DATE TELEPHONE NO. aAD 1/)~/~1 ?S -~ I lid: ~ 1MI8 RATE . AMOUNT. GROS AM UHf , 5 4. '" ') o. /. S PAYTHISAMaUNT . 0 4 0; ,,' - &~VS~ AMT DUe AFT'R 01/19: ........~_.. ~. ~ "', -_._.,-.---_..~- , CLASSIFIED ADYERTISINQ INVOICE I THE SENTINEL CLASSIFIED ADVERTISING P 0 1:10 X 130 CARLISLE PA 1701 ~ (: I'., I Ii I~ I U ,'fj ".11111:.""1...... In."..1I.. '..... IHVOICf! 140. 144445 BILLING DATI J9/19/88 INDUING TERM 1 ADULT EFF STAnr DATE TELEPHONE NO. ORDER N ~/13/88 258-676 .",WOI", TIMES RAlI!' 7 3 ET AMOUNT G S AMOUNT 4.45 6.45 .;;\,f:. 'It-- I.' .~! ";. .. ; " PAV THISAMauNT. 4. 4 5 " , I .~~~ " 'f'Y)' . " , 6.45 ----~ - -_...,--...- I; "., i.- CLASSIFIED ADVERTISING INVOice TH.E )CNTIN~L CLAS,IfIEO ADVEnTISING ? IJ .;OX 130 170 CARLISLE PA 1701: , I, I "..."...............-.....,.. ..... I I I I (. 6/22/89 MEII -RATE 26 3 FLAT CHR .00 7.83 NET AMOUNT G N .00 9.83, I I PAvrHtUMaUNT .. GROSS AMT DUE AFTER CLAS!oIHUJ Auvt;Hll!oIf\jf.j If\jVOIl,;f THE EVENING SENTINEL ~57 EAST NORTH STREET CARLISLE PA 17013 I INVOICE NO CLASS f!ILLI'-lQ DAlE I 01~99 601 02/27/78 I INDE>tI"-lQ lfll\l EFFICIENCY I STAHT DAlE lELEP'lONE NO OIlDEH ,.,,0 I 02-27-78 258-6768 01499 I I NET .U.lOU,.,.T c;OIJHAI.lU'-"" i 3.00 r;rr PAY THIS AI"lOUNT .... 3.00 3.33 GROSS AMT DUE AFTER 03-09 >~, " . , '1 ".III".....~'..I"_n...... ..... , ..l j ) -J I , I ....", INVOICE HO. ii " .' , 81lUNO DATI" 01/27/89 155087 "INDEXING TERM EFFICIENC 'I,' ., START DATE TELEPHONE NO, OADEA ,'-' ., 1/25/81 258-6768 IIl1WOM)J TIMES - RATE NET.AMOUNT GROSS A'-'OUNT 5,) .00.0 fLAT CHR 4.90 b.9 ,:.4,,~"__J:" ~"'1;"~;"';'.l.'~'';''', ..~ I j , \ r I i II I I ~ \ \,; , . I r "'t" . .~. , . PAVTHIUMaUNT. 4. Y () 6. Q C GROSS AMT DuE AFTE~ 02/11 '~:: ,", . " > .........--.~l~~t'.. " " ,oj .. 1-- , 1 '~: ) ~~ ... I,' . ,- " 9 .,':t . . .'}. ,; .. I, 'j .' oj T~ir~'"s~r:L "'c\f ._.~~r.u...'-"}I.l'oSO.H' IHAGEN ARNOLD R 0 6 BOX 240 PA 17013 'lC,~~. .. , ...11. '. I ,;. t ft , , ." ''"'.; CARll SLE L "\.."" .-J CLASSIFIED ADVER riSING INVOICE ,THE SENTINEL iCLASSIFIED ADVERTISING !P 0 80X 130 [CARLISLE PA I ! Forwarding & Addross corroctlon roquoSled INVOICE NO, 219437 INDEXING TERM FURNISHED DILLING DATE: 09/01/90 START DATE TELEPHONE NO. 8/30/90 258-6768 ll"lSIWO~01 TIMES RATE NET AMOUNT GROSS AMOUA 5.10 7.10 9 3 PAYTHISAMOUNT ~ 5.10 7.10 GROSS A~T DUE AFTER 09/16 .". I Cl^S~tJlt II ^IIVl HIISII'.II; INVOice rilE EVEr: UW SENTI NEL 1J~"7 EAs'r NCmTrl STll EET CARL SLE PA 170 1'/013 1~"'OtCE ~o CLASS l'llllf.u IlAIf 1000827 601 04/24/18 <;tA I AtE ~ NO 04/~1/78 2~76 ER .....0 J,900d27 .. -....- L'''''.'i I'oflRO , , HAtC: ~ .35 .2u 3 .- r , I I , 4.20 : ! PAY t.or,; A'.lOUfIIT ~ 3.78 I ;"""'".....-~ --....~.-._-~.-. .Qll.Q_~2_".~!il..BYElILnOLo~/04 .' I I ) I ! :::11~~~. i 1-~-91:-~ . ~+~~.t- !! D Dauphin <DePosit Bank I ~L~~"'~~ I I I I I """."'..-,-,.- MONIKA HAGEN 12-82 .'MQ '1:03 B008 ,U,I: "0'" 2"8Q.. ~II' t, "',"1"'''''' """'-"~'" - ___:.!:......AN.,r"~..,~ d:tJ~.~-L!19~ NUMDER 388 ~:11 . ..~ '-""1 $1 If,to : ^<- -.. ....--....-. -,-., .~. DOLLARS ~ Q Q 0388 ."0000000" QO.,' ....u._. r ":."0> i.... ...,~ '. .. , .' .' !i4, .." ..... ,,: ,. ,-- I\"r-" -5 , '1 ~.,1\.:, '~ , L ; ,'~.r .1,'; ,\' ( ': L , ' \ I 1/ I~ ) i : .~ I , i j j ... ...~ , \ '~>'.. '~4i ' , , 'I} \ , . \q~ f i I b -~ r~ 1 I I I ! 1 ! ifJ i , \ r , j t I , ~ \ ) f I ~: 'jc}'.,,'" " " " ... .. ,. .... '. .". .. I I I MONIKA HAGEN 12.82 I. /1 : . , jWfj'-.J:.>_19_gf, ~~11 I lPAYWTIII-:../' 1.,L,; d/'i?- _ .~, '.'11 ,,- :,;.., '~vJ $':H;,n.. ".'J \ IORDIROF_V..:z.~~,... . .~?~..<a:'*"R"L~~ 1.1't~.:S'._. __0. !- ~~/~:;."J?-/;J~;;1~. ~4 DO L L A R S I! . D DaUphin:-of'~;~~'- ~, ~~~ I ald Trust Company I ~ALlSl[,PE'*'SYlVA"""l'OU /1M I ,,__ J,_ .' I ",.... , .:j(p...~.4V~?k14'- I -11:0:1 BOOB :11,1: 1,011I 21,B!:j I, ~II' Cj Cj 0 3? 5 .,'ooff'oooo?B :I.,' ........... NUMIlER 375 ......--... ~ .' '" ~~W~~'\';~:';R~.",'I,,,,'.~)'~'~~,'I'~r~'''''~~~'''-''------''-~~,.."..A",.,....-.....~.' ,-,~._~.. :.,.,";.....':',..~' ~.'T'I'': t';lc';'>:""-:-,>,'~"'-n.......__ NUMBER 429 j I 1\ I 0 O' 6 L MON~KA ~GENI 12'~ 0 _ PAYTOTHI U,.O ~ I ~~ _..,J./;./. \ iORDIROF_~.~"";---. .L I i ~ 9.e&,A"').JM1~-~ \ r / -0 ~ DauphlncoePostt Bank , a1d Trust companv CAAUSlt. ptNHSYLVANlA 11013 ej-/Z 191.0_ ~11 313 $ [f,'-io' .... _ \ ,..__ '~''''d._ DOLLARS f. I. MtMO' . +~o:l~:looB:lI,I: 1,01ll21,BCjI,~1I ~i1ILri4;j{/.,~ Cj Cj 0 I, 2 Cj ,"0<000000 5 ~~:,~'_. I' -.''10, .., .. , .' .' , '''''', " ....... '.- ';i "r I. , -'.,.' I. ~.\,""',<.. . ... , . ,J. ~ I.};';-. ,\1 { ': ~, 'I' I'. ";: 1,.., I, J( .'Ef I I , ! ,t. .... - \ ~':~. .?:-",' .; " , , . :''l~ (, 6 .~ ,., ~...~--~...,....:.. ! \ I j ( ) I ~ \ h f~ .1 ~ !.' ~ oj ~ I ., " " ,,;....,.. ... , ) .' , , , )' .". RETRIEVE 10/03/97 12:~6:~U OPTIO~.' L~ TRX: 680 KEY: ~T.~U ~~~ bl~!U~ ......... ......... .....""........ ~ ACCT STAT 20 ID _ TYPE RATE/REV 140 11 . POL SUB OPR DIST CONT DMD NON-CURT SPEC MIN t TJ\X EXEMPT M MC S M METERII 10 1 G 32234977 .PEND ORD" 194 43 o o .00 100.00 729 PETERSBURG RD 2FL CARLISLE PA 17013 SERVICE LOCATION .,.. DWELLING UNITS SPEC COST ID GEO LOC SERV TYPE WH CAPACITY INSTALL PRES PRES DATE INDEX DATE 08/17/60 6088.000 10/01 / / .000 / / .000 / / .000 / / .000 / / ,000 / / .000 / / .000 1 SIC CODE 8830 ENGINEERING CODE 16546-29804 MS TOD C T M LOC RI D ID o 03 00 4 o o o o o o o CONSTANT 1.000 .000 .000 ,000 .000 ,000 .000 .000 o 52 R E C X 1 .,.. /'-/- tOR DAlfS at DI^,II MllR 12/3"91 CIlICK IIIRI Ih~~.9 INHERITANCE TAX RETURN ~O~~:~TugtDI1I$ ClAIMIll 0 'l::\l1Ws:1' RESIDENT DECEDENT riiiNiiMiiiR COMMOHWIAl1ll0,rrHlmlv^,,,^ (TO BE fiLED IN DUPLICATE 21 - 9' O',^OlMIHI or "VI"U' ILL ) " - 0859 orru,o..t .. WITII REGISTER OF W S COUNTY CODE lIAUI$I\Uno. fA 171:11.0601 Y[^n li[Ctli1Rr-nr.h\r~1i~ r.flOl I~Rif1,\lij[n[1illll^\1 6[C[6(Rr~1:GlAmln6lii( II Hagen, Monika A. 729 Petersburg Road IOmntCOifTV1lUh\!l! Iliiilrorliii.,rr-\O;.uUrliil" Carlisle, PA 17013 579-48-9836 9/21/94 12/19/04 c..., Cumberland :g: I. O,lolnol Relurn 0 2. Supplomontal Ralurn 03. Romnlndar Rtllur" (ror dolo. of doolh prior 10 12.IJ.02) 05. rod.ral E.tal. lax RDlurn Roqulrod -lO. Tolol Numbor or Sare Oopolil Doxo' 19. Ulillo 10 Is 9roolor Ilton lioo 17, (Illlnr 1110 dilloronco on Iino 19. Tills h lho OVERPAYMENT. ao Jilmn~rr:II:all1lf,IIj(:II;Hla:lllalllil; iI:llmnnT!nall:ITIR:I1NJilil'liil:J:l" 20, IIlin. 17 h oroolor Ihon lino 10. .ntor Iho dilloronc. an Ilno 20, Thh h Ih.TAX DUE. A. Enlor Iho Inlol0l' on 1110 balanco duo on Iino 20A. 0, Enlor Iho tolol 01 B". 20 and 20A 0" Bno 200. Thl. II tho DALANCE DUE. Ma~o Cllock raValllo 10: Roohlor or WIlIt, Agonl : .". .', "~i":;'I,', ';'. ".::.' .....1It-:; DE SUnETO,ANSWER ALl.QUEStlOHS;bHlnE..I.~R$E..SID~iANb.iT.OiIlE.QHECK;MArH.i:+t."/iII;?i:;:}::\',~V~ll;;:~' ;')';;:! ij;J~ilio' 01 J1n,jury. I dodnrn Ihol rhoyo ~~;';-J~iurn. inductinn nccomponr1ng .cho'dulo. 0 ..----;;; my ~nowlodg. and L;ilof. iI Is hua, co"nel ond conlploln. I dodoro Ihol 011 rool oltolo hns boon rOJ1orrod otlrul markel voluo. Doclo 0 pOflonal roprolonloliYO 11 balad on olllnlormolion 01 wl.ich prClporor hOl (lny ~nowlodoo. l1OR1ill,1ir:ormW~~i~'lllIROii!lURH ^liliil1 @~^t[~r&if.~IVC ^uGiB ~_/A?.....I,?'~' z o ;:: :3 ::> .... ii: <( u "' '" z o ;:: <( .... ::> .. :!: o u X <( .... , . D~, 10l 6. lImilod E.lat. Docadonl Diad TOllnlo Esq, . 243-3727 1. Roal E.lalo (Schodulo AI I II 2. Stack. and Oand. (SeI'odulo 01 ( 21 3. Clo.oly Hold Slock/Pa,lno"Mp 1"'0'0.1 (Schodulo q (31 ~. MorlgooOl and Nolo. Rocoi,oblo (SeI,odulo DI ( d) 5. COlh, Bonk Doposits & Miscollanoous Porsonol rroporly( 5) (Schodul. EI 6. Joinlly Ownod Prapo'ly (Schadul. II 7. Tran.fo" (Schodulo G) (Schodulo L) O. Tolol Gran Assoh (lolollinol 1.71 9. Funorol Exponlos, Admlnhlroliyo COlh, Miscollanooul ( 9) Exp.n,ol (Sch.dulo HI 10. Dobl., Morlgaoo lIabllitio.. UOnllSeI,odulo II 11. Tolal Doduclla"'(lalol Bnol 9 & 101 12. No! Voluo of Eltalo (Ii no 0 minuslino 11) 1:J. Charilablo and Goyornmonlollloquoih 15cliodulo J) IA. Nol Voluo Suhjoc1lo Tax llino 12 minu,lino IJ) 15. Amounl of Iino 1d laKablo 01 6% raiD (Inelud. valuo. Irom Schodulo K or Schodulo M.) 16. Amount or Iino 1A laxoblo 01 15% rulo (Includo voluo. from Schodulo K or SeI,odulo Mol 17. Principal lox duo (Add 10K. from lino 15 and rrom Iino 16.) 18. Crodils Spoulol rovolly Crodil rrior roymonh + fl... 000.00 + .f)3 r- /...3 . J.lu/.\nEn 190',000,00 ,~ -- ., . ,.. 207,921.77 TI,.... <t;TI-/ .----.. -'-'.. -,. DE C' . -'rl~1. V/ . . , .: <;'( ---:!I-C~~U'~~tn/~ CL.."'i';,, I ( 61 ( 7) 397 , 921. 77 ( 01 (10) 23,482.83 11,086.97 (II) 34,569.80 (12) 363,351. 97 (l3) (Id) 363,351. 97 X .06 = 363,351.97 X ,15 = 54 , 502 . 80 (171 (151 (16) Dilcount 2,473.61 Inloroll 49,473.61 110) (19) (20) (2M) (200) 5,029.19 5,029,19 ,llXHIBIT A-v UAlt , ~.:1-<: J9f}.!.- I .2-.;l~-?'s 140718120897 ROW621 File No 1994-00859 Decedent HAGEN MONIKA " . .. r" , , " Date Filed 10/06/1994 10/06/1994 10/06/1994 10/07/1994 10/11/1994 10/24/1994 12/13/1994 12/21/1994 Cumberland County - Register Of Wills Page 1 PA File No 2194-00859 Docket Entries 1 PETITION FOR PROBATE AND GRANT OF LETTERS TESTAMENTARY 2 OATH OF PERSONAL REPRESENTATIVE 3 DEATH CERTIFICATE 4 DECREE OF PROBATE AND GRANT OF LETTERS TESTAMENTARY 5 CERTIFICATION OF NOTICE UNDER RULE 5.6(A) 6 CERTIFICATION OF NOTICE UNDER RULE 5,6(A) 7 INHERITANCE TAX PYMT PAID - 38 000,00 ACN - 101 RECEIPT - M9132BO SCHORPP .E6wARD L B INHERITANCE' TAX PYMT PAID - 9tOOO.00 ACN- 101 RECEIPT - A22619 SCHORPP DWARD L 2/23/1995 9 INHERITANCE TAX RETURN TAX DOCKET 14 239 13 2/27/1995 10 ROLL 4 BATCH 235 PAGES 1 THRU 19 2/23/1995 11 INHERITANCE TAX PYMT PAID - 5L029,19 ACN - 101 SCHORPP ~DWARD L RECEIPT - AA22861 3/20/1995 12 ROLL 5 BATCH 427 PAGE 1 4/2711995 8/30/1995 13 REV 1547 NOTICE INH TAX APPRAISEMENT ROLL 6 BATCH 599 PAGES 4 Docket: 14 Book: Page: 239.00 14 FIRST AND FINAL ACCOUNT AND DISTRIBUTION 10/10/1995 15 ACCOUNT CONFIRMED ABSOLUTELY 10/17/1995 16 DECREE AWARDING REAL ESTATE ROLL 6 BATCH 599 PAGES 4 .- 140718120897 '. ROW621 File No 1994-00859 Decedent HAGEN MONIKA Cumberland County - Register Of Wills Page 2 PA File No 2194-00859 9/23/1996 17 STATUS REPORT 6.12 COMPLETE "'--':~"'.:. ,.,. ARTICLE IV R-A RESIDEHTIAL-AGRICULTURE DISTRICT SECTION 400. Purpose. The purpose of the R-A Residential-Agriculture District Is to encourage the continued use of the land for agrlcu.ltural purposes and permit those uses which are compatible and allied with agricultural operations; to preserve open space and to permit low density residential development which wi II not require extensive public services or facilities and to otherwise create conditions conducive to carrying out these and other broad purposes and objectives of thIs Ordi- nance as set forth In Section 2 and 3 - Enactment, SECTION 401. Use Regulations. A buildIng may be erected or used, and a lot may be used or occupIed, for any of the following purposes: I, Agriculture, horticulture nursery, orchards and greenhouses, riding academies, livery and boarding stables, dog kennels, animal hospitals, animal husbandry, 2. Country estates and farmsteads Including the main dwel ling, stables, barns and accessory buildings and structures, 3, Churches, or similar places of worship and parish houses, convents. 4. PublIc schools, libraries, museums, and munIcipal buIldings, 5. Single-family detached dwellings, 6. Home occupation when In compliance with Article X, Section 1010 and when authorized by a permit Issued by the Zoning Officer or recommendation by the Board, 7. Signs when erected and maintained In accordance with the provisions of Article XIII, Signs. 8. Accessory use on the same lot with and customarily IncIdental to any of the above permitted uses. SECTION 402, Special Exceptions, The Board may authorize as a SpecIal Exception the following uses subject to the procedures outlined In Article XI, Planned Developments: I. Apartments, town houses, garden apartments, converted apartments, group dwellings, (sIngle and two-famIly, multiple famIly) In' . accordance with Article X, General Regulations, Section 1002, 1003, and 1004, Area, Building Coverage and Yard Regulations, 2, Col leges, hospitals, nursIng homes and convalescent homes and retirement homes or villages. 3. Mortuaries, 4, Municipal parks, playgrounds, and recreation areas including swimming pools. -20- ~outb jOOibbldon ~own5bip ,0){O) /5)~ 520 Park Drive, Boiling Springs, PA 17007 ~ lJ' U PHONE: (717) 258-5324 FAX: (717) 258.3577 Certified # P 180163357 Mr. William Ronan 759 Petersburg Road Carlisle, Pa 17013 Re: 729 Petersburg Road Dear Mr. Ronan: As the Zoning Officer of South Middleton Township, I have delermlned that you are in violation of the following provisions of the Zoning Ordinance of 1989, as amended, for the reasons which I have specified. The previous owner had occasionally rented one apartmenl while living there herself. However, since that time, the dwelling located at 729 Petersburg Road was vacated for a period in excess of a year. According to Section 1901 d, If a non-conforming use is discontinued for a period of a year or more, the use loses Its non-conforming stalus as thus cannot be reinstated, At present, conditions suggest that lhree apartments are being renled. none of which is occupied by the owner of the dwelling. 'I , I Before an accessory apartment use can take place, It must receive conditional use approval from the Board of Supervisors and subject to the following criteria found in Section 602.2: j , 1. The livable floor area of the accessory apartment shall nol exceed seven-hundred twenty (720) square feet. I' 2. Only one accessory apartment may be permitted wllhin a single-family detached dwelling. 3. An accessory apartment may only be permitted and may only continue in use as long as the principal dwelling is occupied by the owner of said dwelling. 4. The lot area for the principal dwelling shall meet the minimum lot area requirement for lhe applicable district where located. 5. The exterior architectural characler of the principal dwelling shall not be altered in a manner which departs from the primary feature of the bUilding as a single-family detached dwelling unit. -r~/ EXHIBIT ~1 AfZ..M 6, One additional off-street parking space shall be provided. 7. The applicant shall submit a plan and supporting documenlatlon to establish compliance with the slandards herein In accordance with Article XX, Therefore, this current use of the property is a violation of Sections 602,2 (specifically 602b and 602c) and 1901 d of the Zoning Ordinance 1989 as amended. THIS LETTER SHALL CONSTITUTE OFFICIAL NOTICE OF MY DETERMINATION. YOU WILL RECEIVE NO FURTHER NOTICES. Upon receipt of this Notice, you have two (2) options: 1, You can correcl the aforesaid violalions by ceasing the use of all the apartments until a conditional use approval Is obtained and subject to the criteria required by Section 602.2. 2. You may appeal this determination to the Zoning Hearing Board. If no action is laken wilhin thirty (30) days of lhis Notice, be advised that South Middleton Township will take the necessary legal aclion at that time, Such action can result in an order against you to correct the violations, imposition of monetary penalties (fines, costs, expenses, etc.), and other acllon deemed appropriate by the Township or the District Justice. There will be no further notices, Sincerely, ~ Timolhy . uerr Zoning/Codes Enforcement Officer ,1~:jJ ~ j- ,"^W OffiCES LANDIS BLACK ta SCHORPP 36 lOUTl1 HANOVER STREET C^RLlSlE, PENNSYlV^NJ^ 17011 ROBERT R, BVoCK EDWARD L, lCHORPP TELEPHONE 1717120\3-3717 ). OOYD VoNDll IIU14'191l4, JOlEPH ), MclNTOlH ,llJ4o'l9n: February 24, 1997 Browning Ferris, Inc, Central Pennsylvania District P.O. Box 8895 Boston, MA 02266-8895 Mr. Tim Stoudt South Middleton Township Municipal Bldg, 520 Park Drive Boiling Springs, P A 17007 RE: Mr. and Mrs. William Ronan 729 Petersburg Road, Carlisle, Pennsylvania Account No.: 6706543 Dear Sirs: This office represents Mr. and Mrs, William Ronan concerning referenced account. I am enclosing with the Browning counterpart of this letter, my client's check remitting the balance due under statement date of December 17, 1996, This amount is being paid under protest and is subject to a credit offsel for the following reasons, The December 17, 1996, stalement ilemizes billings for the period December 3, 1995, through February 28, 1997. You were previously advised, and we are confinnin~ "herein, that this property was vacant from ADriJ. 1994, throulZh ADril, 1996. Therefore, the Ronans are entitled to an adjustment credit for the period from December 3, 1995, through April 1, 1996. L, addition, the Ronans utilized your tag syslem for trash pick-up for the period from April 1, 1996, through December 31, 1996. During that period, 15 tags at $2.87/1ag were used for trash service, Therefore, the account should be credited in the amount of $43.05 for the actual services paid by my clienls. Mr. Sloudt informed my clienls thai they were not permitted to use the lag system for this premises. In response to his communication, my clients initialed use of the cart syslem commencing January, 1997. No dispute is made as 10 the billing from that time through the February billing date, -F-:l EXHIBIT ~1 ftef1\ \ " l\FFIOl\VIT COMMONWEALTH OF PENNSYLVANIA ) . . COUNTY OF CUMBERLAND ) SS, I, ;1 We, Edward L, Schorpp and ~P....~ I?? , ~......r~./.d:Tv€< the witnesses whose names are signed to the attached or foregoing instrument, being duly qualified according to law, do depose and say that we were present and saw Testatrix sign and execute the instrument as her Last Will; that Monika Hagen signed willingly and that she executed it as her free and voluntary act for the purpose therein expressed; that each of us in the hearing and sight of the Testatrix signed the will as witnesses; and that to the best of our knowledge the Testatrix was at that time eighteen or more years of age, of sound mind, and under no constraint or undue influence. " I L, Schor .day of affi~med an ~ubscribed to before me by Edwa~ ~ m, /:. T v~witnesses, this /(0 , 1994. Wi~~~~~~ (SEAL) W{~)~ ~ (SEAL) , 10 (SEAL) No ary t<<)TNlIAI. SfAL SUSAN It GUYBl. Notary Public CaM Cumbellancl County My Comm\sSlOll ElcplIlS SellI, 4, 1995 , ,;.,.. CERTIFICATION OF NOTICE UNDER RULE 5.6 (AI Name of Decedent: Monika Haqen Date of Death: Seotember 21. 1994 Will No. 2194-0859 Admin. No. To the Register: I certify that notice of beneficial interest required by Rule 5.6(a) of the Orphans' Court Rules was served on or mailed to the following beneficiaries of the above-captioned estate on Name Address william R. Ronan. 759 petersburq Rd.. Carlisle. PA 17013 Geraldine L. Ronan. 759 Petersburq Rd,. Carlisle. PA 17013 Notice has now been given to all persons entitled thereto under Rule 5.6(a) except None Date: /O-//-9~ ~~~~ Sl.gnature Name Edward L. Schorco. Esouire Address 36 South Hanover Street Carlisle, PA 17013 Telephone (7171 243-3727 Capacity: Personal Representative x Counsel for Personal Representative EXHIBIT IC-'J. CERTIFICATION OF NOTICE UNDER RULE 5.6 (AI Name of Decedent: Monika lIaaan Date of Death: Seotember ;p. 1994 Will No. 2194-0859 Admin. No. To the Register: I certify that notice of beneficial interest required by Rule 5.6(a) of the Orphans' Court Rules was served on or mailed to the following beneficiaries of the above-captioned estate on liIDllg Address Joan Marv,Adrian Dominican Sisters.622 Tavlor Ave. . Elmhurst. IL 60126 Paul Marv, 164 Five Fields Road. Madison. CT 06443 Jim Marv. 26 Hansom Hill Road. Windsor. CT 06095 Mrs. Frances Nunder. 321 Willowridae Drive. Amherst. NY 14150 Anna Montesano. 45 Emerson Drive. Eaaertsville. NY 14226 Mrs. and Mrs. Lorenz Schlaaintweit. 8376 Kaikenfied Post Teisnach. Niederbaver Waldo Germanv Mrs. Elsbeth G. Eddv. 13000 Piscatawav Drive. Fort Washinaton. MD 20744-6220 Notice has now been given to all persons entitled thereto under Rule 5.6(a) except None c. ~~#/ Signature Date: 3A:' .:=..?~-~ ,~ \-.J I- r.' :"1 Name Edward L. Schoroo. Esauire Address 36 South Hanover Street r> 0Ci carlisle. PA 17013 Telephone (7171 243-3727 Capacity: Personal Representative x Counsel for Personal Representative .- .' IN RE: ESTATE OF MONIKA A, HAGEN, Deceased IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSVLVANIA ORPHANS' COURT DIVISION NO. 21 - 94 - 0859 FIRST AND FINAL ACCOUNT OF WILLIAM R. RONAN AND GERALDINE L. RONAN EXECUTORS OF THE ESTATE OF MONIKA A. HAGEN LATE OF SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA Date of Death: Letters Testamentary Granted: Letters Advertised: sentinel - cumberland Law Journal - Account stated as Final september 21, 1994 october 7, 1994 october 15, 22, 29, 1994 October 21, 28, November 4, 1994 SUMMARY & INDEX PRINCIPAL Receipts conversions (Gain) Less Disbursements Balance Before Distributions Advancements to Beneficiaries Principal Balance Remaining' INCOME Receipts Less Disbursements Income Balance Remaining COMBINED BALANCE REMAINING PAGE 2 3 4 8 6 7 EXHIBtT /l-] 398,030.29 1,649.10 -86.638.97 313,040.42 -101.992,43 211,047.99 5,001. 04 - 0.00 5 ,001. 04 216.049.03 1994 9/21 9/21 9/21 9/21 9/21 9/21 9/21 9/21 9/21 9/21 9/21 10/14 10/21 1995 7/7 RECEIPTS OF PRINCIPAL PNC Bank, N.A. -checking account #5140448926 PNC Bank, N.A. - savings account #5130380139 PNC Bank, N.A. - certificate of deposit #1773160094679 PNC Bank, N,A. - certificate of deposit #1773160109513 PNC Bank, N,A. - certificate of deposit #1773160109537 PNC Bank, N,A. - certificate of deposit #1773160120484 PNC Bank, N.A. - certificate of deposit #1773160140554 PNC Bank, N.A. - certificate of deposit #1773160152396 Residence at 729 Petersburg Road, South Middleton Township, appraised value 1963 Pontiac Catalina station wagon, appraised value Personal property, appraised value Cash Pennsylvania National Insurance Company, claim for fence damage state Farm Insurance, car insurance refund Total Receipts of principal 2 27,520,88 74,971.22 10,047.66 10,000.00 10,142.68 40,797.81 10,065.16 20,318.36 190,000.00 300.00 810.00 1,947.00 1,001.00 108.52 398,030.29 "' PRINCIPAL CONVERSIONS TO CASH 1994 Gain Loss 10/27 PNC Bank, N,A, - checking account #5140448926 Proceeds 27,572,63 Account Value 27.520,88 51. 75 1995 6/5 PNC Bank, N.A, - certificate of deposit #1773160094679 Proceeds 10,169.73 Account Value 10.047.66 122,07 6/5 PNC Bank, N.A. - certificate of deposit #1773160109513 Proceeds 10,112,19 Account Value 10.000.00 112.19 6/5 PNC Bank, N.A. - certificate of deposit #1773160109537 Proceeds 10,080.55 Account Value 10.142.68 62.13 6/5 PNC Bank, N.A. - certificate of deposit #1773160120484 Proceeds 41,279.00 Account Value 40.797.81 481.19 6/5 PNC Bank, N.A. - certificate of deposit #1773160140554 Proceeds 10,195.62 Account Value 10.065.16 130.46 6/5 PNC Bank, N.A. - certificate of deposit #1773160152396 Proceeds 20,155.34 , Account Value 20.318,36 163.02 ,). 3 , . 8/18 PNC Bank, N,A. - savings account #5130380139 1994 10/14 10/14 10/14 10/14 10/26 11/9 11/9 11/9 11/9 11/9 11/14 11/22 11/22 11/25 12/6 12/6 12/6 12/16 Proceeds Account Value Net Gain on Conversions 75,947.81 74.971.22 976.59 1,649.10 DISBURSEMENTS OF PRINCIPAL State Farm Insurance, car insurance Metropolitan-Edison Company, electricity to 9/29/94 Westminster Cemetery, Inc., inscribe grave marker United of PA, telephone to 10/31/94 HOffman-Roth Funeral Home, funeral Metropolitan-Edison Company, electricity 9/29 to 10/28/94 Christopher Automotive, invoice William R, and Geraldine Ronan, reimburse for Westminster Cemetery Roy D. Gottshall, appraisal of personal property Orrstown Bank, charge for checks Landis, Black & Schorpp, costs advanced to date Chester Raudabaugh, plumbing repairs United of PA, telephone 10/31 to 11/30/94 Geraldine Ronan, reimburse for Wayne Noss Flowers Register of Wills, on account, Pennsylvania Inheritance Tax Arnold Fuel Oil, invoice United of PA, telephone 11/30 to 12/31/94 Metropolitan-Edison Company, electricity 10/28 to 11/30/94 4 155.03 38.09 150.00 21. 95 5,178.00 35.05 51. 74 650.00 45.00 5.97 333.00 39.25 17.72 45.05 38,000.00 186.13 18.25 50,91 12/21 12/22 1995 1/24 1/24 2/7 2/7 2/7 2/20 3/10 3/10 3/10 3/24 3/24 3/24 4/18 4/18 5/11 5/11 5/11 5/30 6/13 6/13 Register of Wills, on account, Pennsylvania Inheritance Tax Diversified Appraisal, real estate appraisal Metropolitan-Edison Company, electricity 12/1/94 to 1/3/95 United of PA, telephone 1/1 to 1/31/95 Arnold Fuel oil, invoice Metropolitan-Edison Company, electricity 1/3 to 1/31/95 United of PA, telephone 2/1 to 2/28/95 Register of Wills, balance, Pennsylvania Inheritance Tax Robert C, cairns, real estate taxes United of PA, telephone 3/1 to 3/31/95 Metropolitan-Edison Company, electricity 1/31 to 3/1/95 Pennsylvania Department of Revenue, 1994 state income tax state Farm Insurance, car insurance Internal Revenue Service, 1994 federal income tax United of PA, telephone 4/1 to 4/30/95 Metropolitan-Edison Company, electricity 3/1 to 3/31/95 Metropolitan-Edison Company, electricity 4/1 to 5/1/95 United of PA, telephone 5/1 to 5/31/95 Arnold Fuel Oil, invoice Three Springs Practice, opinion letter Metropolitan-Edison Company, electricity 5/1 to 6/1/95 united of PA, telephone 6/1 to 6/30/95 5 9,000.00 300.00 54.99 18,05 323.60 45.45 18,05 5,029.19 225,96 18.32 47.11 37.00 155.03 283.00 18.28 50.75 38.64 18.36 283.37 50.00 44.86 18.20 6/13 7/14 7/14 7/14 8/17 8/17 8/17 RESERVED: 1994 10/14 10/14 10/28 11/18 11/30 12/19 12/20 1995 1/20 Cumberland Crossings, unpaid and unreimbursed account Arnold Fuel Oil, invoice Metropolitan-Edison Company, electricity 6/1 to 6/29/95 United of PA, telephone 7/1 to 7/31/95 Metropolitan-Edison Company, electricity 6/29 to 7/31/95 United of PA, telephone 8/1 to 8/31/95 PA Department of Revenue, 1994 income tax adjustment Landis, Black & Schorpp, costs advanced 11/14/94 to date Landis, Black & SChorpp, attorneys fees Clos~ng and filing releases Total Disbursements of Principal RECEIPTS OF INCOME PNC Bank, N.A., interest, certificate of deposit #1773160109537 PNC Bank, N,A., interest, certificate of deposit #1773160152396 D. Clinton Sauder, farm rent Orrstown Bank, interest, estate checking account #403784 Apartment rent Apartment rent Orrstown Bank, interest, estate checking account #403784 Orrstown Bank, interest, estate checking account #403784 6 9,935,19 73.73 43.44 18.24 56.79 18,28 19,47 86.48 14,938.00 350.00 86,638.97 155,42 350.96 1,800.00 43.11 225.00 225.00 60.54 30.06 : ~ , . , i j I ~, .~ 1/25 PNC Bank, N.A. , interest, certificate of 178,96 deposit #1773160140554 2/6 PNC Bank, N.A. , interest, certificate of 178,96 deposit #1773160094679 2/20 Orrstown Bank, interest, estate checking 25,23 account #403784 3/20 Orrstown Bank, interest, estate checking 16,75 account #403784 3/27 PNC Bank, N.A. , interest, certificate of 183,48 deposit #1773160109513 3/27 PNC Bank, N.A. , interest, certificate of 748.56 deposit #1773160120484 4/18 PNC Bank, N.A. , interest, certificate of 211.92 deposit #1773160109537 4/18 PNC Bank, N.A. , interest, certificate of 468,71 deposit #1773160152396 4/20 Orrstown Bank, interest, estate checking 16.79 account #403784 5/19 Orrstown Bank, interest, estate checking 17.77 account #403784 6/20 Orrstown Bank, interest, estate checking 20,68 account #403784 7/20 Orrstown Bank, interest, estate checking 21. 25 account #403784 8/18 Orrstown Bank, interest, estate. checking 21. 89 account #403784 Total Receipts of Income 5,001.04 DISBURSEMENTS OF INCOME 1994 None 0.00 , 1995 Total Disbursements of Income 0.00 7 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND William R, Ronan and Geraldine L. Ronan, being duly sworn according to law, deposes and says that the Account as stated is true and correct, and that the Grant of Letters Testamentary and the first complete advertisement thereof occurred more than four (4) months before the filing of the Account. .1-1. //.:.. -1 fAJr;;p-.~1 William R. Ronan ~~~~. ~eraldine L. Ronan Sworn and sUbscrib~o before j{) y/'< day of ift Jl1:1= me this , 1995 No ary Public NOTAAlAl SEAL SUSAN K. GUYER, NolalY Public carlisle, Cumberlarnl Counly Mv Commission Elilllres Sept. 4, 1995 9 'r. 1 2 SOUTH MIDDLETON TOWNSHIP ZONING HEARING BOARD BOILING SPR1NGS, PENNSYLVANIA ~--- 1 3 IN RE: Hearing on application of William R. and Geraldine Ronan, Docket Number 97-32 4 5 6 7 TRANSCRIPT OF PROCEEDINGS 8 Before: PAUL HEISHMAN, Acting Chairman A, LARRY BREAM, Member 9 HUBERT X. GILROY, Solicitor 10 TIMOTHY D. DUERR, zoning Officer 11 Date: November 3, 1997, 5:25 p.m. 12 Place: South Middleton Township Municipal Building 520 Park Drive Boiling Springs, pennsylvania .. 13 14 15 16 ORIGINAL 17 APPEARANCES: 18 19 SCHORPP & BLACK BY: EDWARD L. SCHORPP, ESQUIRE FOR - APPELLANTS 20 21 ECKERT, SEAMANS, CHERIN & MELLOTT, LLC BY: RONALD M. LUCAS, ESQUIRE FOR - PROTESTANTS 22 24 Amy R. Moore, R.P.R Court Reporter-Notary Public ., "..;\ :':,:' ,i, 23 ','E \J 25 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 2 -- 1 INDEX TO 'rES'l'IMONY 2 WITNESSED DIRECT CROSS REDIRECT RECROSS 3 Tim stout 13 17 4 Tim Duerr 19 20/24 26/28 5 Geraldine Ronan 35 6 7 8 9 TOWNSHIP EXHIBITS 10 NO. DESCRIPTION PAGE 11 1 Letter to William Ronan from Timothy Duerr dtd 7/21/97 3 12 2 Letter to Tim stout from Attorney Schorpp dtd 2/24/97 16 1;0. ~... f.'''''1 ..'J. 13 14 15 16 17 APPELLANT EXHIBITS 18 NO. DESCRIPTION PAGE 19 1 Rent receipts book 39 20 2 Rent receipts book 39 21 3 Advertising bills with attached checks 39 22 4 Electric bills 53 23 24 ~ 25 C.P,C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 " 3 ~ 1 PRO C E E DIN G S 2 MR. GILROY: Now we have the Ronan case. 3 For the record, Mr. Heyman will not partake in 4 any discussion, questioning or deliberations involved in 5 this case, and you can go home for dinner or stick around. 6 Our second case is the application of William R. 7 And Geraldine Ronan at Docket Number 97-32. this is an 8 appeal from the determination of the zoning officer. And 9 maybe for the record we'll mark right up front the zoning 10 officer's determination, since that's what's being appealed 11 from, as an exhibit. 12 This is a July 21, 1997 letter to Mr. William ...tot, 1. ) ''''f.'!4' Ronan from Timothy D. Duerr, zoning and codes enforcement 13 14 officer for the township. We'll mark this as Township 15 Exhibit Number 1. 16 (Township Exhibit No.1 was marked.) 17 MR. GILROY: Now, just so we have it right, 18 Mr. Duerr, you're here representing the township, correct? 19 MR. DUERR: Correct. 20 MR. GILROY: And there is no specific attorney 21 here on behalf of the township. Is that right? 22 MR. DUERR: That's right. 23 MR. GILROY: Mr. Schorpp, you're here for the 24 appellant, Do you want, for the record, to enter an ---.) 25 appearance? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 "1 , ., , ;' ~;, I I -.-.:.~:... \ , I 1\ -- 1 MR, SCHORPP: I would enter my appearance, and I 2 would also like to address the makeup of the board at this 3 time, please. 4 MR. GILROY: Okay. Well, why don't you enter an 5 appearance first. Give us your full name and address, 6 MR, SCHORPP: My name is Edward L. SchorpPi 127 7 West High street, Carlisle, Pennsylvania. Please enter my 8 appearance on behalf of the appellants, Mr. and Mrs. 9 William Ronan. 10 MR, GILROY: Let's get everybody in the case 11 before we start discussing procedural stuff. 12 Mr. Lucas, you're here also? ~..". ". '. t~'.~~t. 13 MR. LUCAS: Yes. 14 MR. GILROY: And you want to formally enter an 15 appearance? 16 MR. LUCAS: Yes. Ronald M, Lucas with Eckert, 20 Mr. Rickert resides at 726 petersburg Road; the r I f 'I I ~ \ \~ ., . , ! ! 17 Seamans, Cherin & Mellott. The address is 213 Market 18 Street, Harrisburg. I'm here representing Terry Rickert 19 and Maxine and Kenneth Wetzel, 21 Wetzels, 740 Petersburg Road. They are the property owners 22 across Petersburg Road from the property that's the subject .. t; 24 MR. GILROY: Is there anyone out there that I, 'i I, \ 23 of this appeal. (J 25 we've missed? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 , I r .. I. ..~ 5 -- 1 Now, Mr. Schorpp, you had a procedural issue you 2 wanted to address? 3 MR. SCHORPP: It is my understanding the board 4 is composed of three members with alternates who sit from 5 time to time. Is that correct? 6 MR. GILROY: That's right. 7 MR. SCHORPP: And we must have an alternate 8 sitting this evening? 9 MR. GILROY: Mr. Heishman is an alternate. I'm 10 sorry. Mr. Heyman is the alternate. 11 MR. SCHORPP: In view of the absence of 12 Mr. otto, who, I believe, is the regular member? f~'~J 13 MR. GILROY: Yes. 14 MR. SCHORPP: Since my clients are the 18 appellants, if there would be a tie vote in this matter, it is my understanding in the law that that would not move in favor of their appeal. Therefore, they are asking that the board continue the hearing at this time until such time as there is a fully constituted board to hear the case. 15 16 17 19 20 MR. GILROY: Mr. Lucas, do you have a position, 21 since you've entered an appearance? 22 MR. LUCAS: Yes. Two members present are both 23 regular members of the board. And I agree with 24 Mr. Schorpp, that if there is a tie vote and the status quo I.""J 25 remains, they would not be successful, that the zoning C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 6 ~ 1 officer's determination would apply. 2 However, I don't see any reason to continue the 3 hearing just because there's two members. It's not 4 uncommon not to have a full board at a zoning hearing. I 5 guess it's up to the board to decide what to do. 6 I mean, often boards only have two out of three 7 members present, for whatever reason, or one member has to 8 disqualify themselves. And some boards don't always have 9 alternates. An alternate is only needed to achieve a 10 quorum. So the NPC envisions that if you have a 11 three-member board and one member recuses himself, that you 12 don't bring the alternate in because you have a quorum. So o 13 the board has a quorum. 14 I think we can proceed, if the board desires so. 15 If everybody is here, we can go ahead rather than have 16 everybOdy have to come back again. 17 MR. SCHORPP: The NPC also provides for more 18 than one alternate. In this case, we are still sitting 19 with one empty seat. 20 MR. LUCAS: My understanding of the NPC is the 21 alternates are only to sit if to achieve a quorum. So I 22 think -- even though I don't think that is what everybody 23 envisioned, I think that's been the interpretation. So o 24 even if you had another alternate, the alternate wouldn't 25 necessarily be required for the hearing because there would C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 7 ~ 1 still be two members. So even if we had a second 2 alternate, I don't think it would make any difference. 3 They could sit, but they wouldn't be able to vote. So I 4 think it's up to the board. 5 MR. GILROY: Mr. Schorpp, do you have a position 6 on whether the board can proceed with two members? I mean, 7 whether it's advisable. 8 MR. SCHORPP: I would say that it is probably 9 legally permissible. The only prejudice that can result 10 from a continuance would accrue to my clients and to no 11 other party here this evening. And, therefore, we think in 12 all fairness since they would be the ones prejudiced by a ~',~) 13 continuance because of the time delay of getting to the 14 merits of their case, we think in fairness to them, if 15 they're willing to waive the time limitation in return for 16 having their case heard by a full board, we think that's , , il 17 the fair decision to make. 18 MR. GILROY: The other option is to proceed with 19 the testimony and have the testimony transcribed and ask 20 Mr. otto to review that and participate in deliberations 21 and the decision also. I'm just throwing that out there as 22 a possibility since everybody is here, rather than coming ~ .J , I 23 back on the 9th. I believe that would just involve some 24 cost in preparing the transcript for Mr. otto to review. ~ 25 MR. SCHORPP: We would also expect that there C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 : r, .'...; 9 ~ is being used in violation of your stated directive, or has 2 the directive been complied with? 3 MR. DUERR: To the best of my understanding, 4 it's still being used in violation. 5 THE CHAIRMAN: Is still being used in violation? 6 MR. GILROY: Alleged violation. 7 THE CHAIRMAN: In violation of his 8 determination? 9 MR. GILROY: Right. So the status quo is the 10 existing situation with Mr. Duerr's telling them to stop 11 and they've appealed his request or his directive to stop. 12 MR. SCHORPP: I'd like to add that my clients c) . ":...,. 13 have refrained from renting one of the units pending this 14 determination. The other one was already rented at the 15 time the determination by the zoning officer was issued. 16 MR. LUCAS: And if I could, if it's being 17 continued in violation with the owner not living there and 18 not having attained a conditional use approval for one 19 apartment, then it's in violation and prejUdice is to the 20 township, and they are getting the benefit of continued 21 use. 22 The fact that they rented it in violation, 23 rented it previously in violation of the ordinance, is not r I I I 24 a hardship for them; that's their fault. They didn't come u 25 in and get the approval previously. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 10 -- 1 So in that case, they shouldn't be granted a 2 continuance and we should proceed. Otherwise, they're 3 getting the benefit of continued alleged violation of the 4 ordinance of the zoning officer. If they had come in and 5 said, okay, we'll vacate the premises, we won't use it 6 while this appeal is going on, that would be different. 7 But they're continuing to use it to their benefit. 8 THE CHAIRMAN: That was really the root of my 9 question. I think it's been the practice of this board 10 while I've been a member to try and reach a consensus, and 11 I think that maybe has happened in every case. 12 MR. GILROY: I've never seen a tie vote. I '.'''''~ C"'lf 13 don't know when I've last seen a dissent, to tell you the 14 truth. 15 So based upon prior experience, you're saying 16 the likelihood of a tie vote is remote but that doesn't 17 mean it's impossible? 18 THE CHAIRMAN: Right. If we were to reach a 22 MR. GILROY: Well, I wouldn't suggest that we I , I I \~ n , f I ! I 19 point where we have differing viewpoints, your opinion is 20 that Mr. otto could then review the transcript and cast a 21 tie-breaking vote? 23 have deliberations and make a determination if there is 24 going to be a tie vote because you would have to cast your u 25 vote. I'd suggest that you do one of two; if you're going C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 \ , '~""''''' ~ o 14 15 16 17 18 19 20 21 22 23 24 t) 25 1 1 1 to proceed, then you could proceed and have the record 2 transcribed and give Mr. otto an opportunity to vote upon 3 review of the record, but if he's not available, you could 4 still go ahead and just -- if you would then be prepared to 5 vote, just the two of you, without his input. I' , 6 THE CHAIRMAN: Given that it's at least " I , , , , j , \ I I ~ 7 Mr. Duerr's opinion that there's a violation and any delay 8 would be to allow that violation to continue, I would be 9 inclined that we hold the hearing this evening. 10 MR. BREAM: Okay. 1 1 MR. GILROY: Okay. Mr. Schorpp, your position 12 and objection is noted, but the board is determined that it 13 ..l j will proceed. Mr. Duerr, you are here without counsel for the ') \ , I township, but you, no doubt, have a lot of time to watch lawyers work. So we'll rely upon you to proceed with testimony in fashion, and if you need any help, I'm sure , , i, ' If II I' Ii I! : ~ \ \~ n we'll help you along. First we need to have you sworn in. TIMOTHY D. DUERR, called as a witness, being duly sworn, was examined and testified as follows: MR. GILROY: Mr. Duerr, for the record, can you state your full name and business address and position 'i within the township? I, " C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 i, I , I ~/ \ r , 1"-" 13 4 MR. LUCAS: Yes. MR. GILROY: So you want to turn the matter over to Mr. stout? MR. DUERR: Just for this particular question. MR. GILROY: We're going to have you sworn in, ~ 1 2 3 5 6 sir. 7 8 TIMOTHY STOUT, called as a witness, being duly 9 sworn, was examined and testified as follows: 10 11 MR. GILROY: Mr. stout, can you state your full 12 name, business address and business affiliation with South (~ -,-"'<t"'. 13 Middleton Township? 14 MR. STOUT: John T. stout; 520 Park Drive, 15 Boiling Springs, pennsylvania, assistant code enforcement 16 officer of South Middleton. 17 MR. GILROY: Mr. Duerr? 18 DIRECT EXAMINATION 19 BY MR. DUERR: 20 Q. Mr. stout, the question I'm going to ask you is 21 how did you come about finding out there was more than 22 several apartment uses at the address of 729 petersburg 23 Road? 24 A. I'm not sure of the exact date, but whenever BFI , "-" 25 took over for the trash and recycling in South Middleton C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 -- ,...:t., c~,.~, 15 1 units there; his son was living in one and somebody else 2 was living in another one. He didn't mention a name; it 3 didn't matter. I said if that's the case, you need two 4 separate services for two different bills. You have two 5 different methods, whether it be two tag services or two 6 toter services that South Middleton has. 7 He told me that he was buying tags and selling 8 the tags to those units, that they didn't generate a whole 9 lot of trash. I said that's not the way the system works; 10 they have to have their own service. So I told him with 11 this large bill that he was credited with or had generated, 12 I said I'll try and get BFI to null and void that, void it 13 out; if we start from day one -- I'm not sure of the exact 14 date with one toter, even though it wasn't in full 15 compliance, just to make sure they got service because they 16 didn't generate a whole lot, share one toter with two 17 units. We both agreed to that. 18 And then through that course, I got a letter 19 from his attorney, Mr. Schorpp, which Tim has there. They 20 wanted a refund on the tags. And in a periOd of time in 21 two years, they said it was vacant. In that course, I had 22 turned it over to Tim, as well, knowing that two units are 23 not permissible in the agricultural zoning. 24 u 25 .,';,. "" MR. GILROY: Hold on a second. I'll mark what's been presented as a February 24th, 1997 letter to Mr. stout C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 17 ~ 1 MR. GILROY: Hold on. SInce he's the townshIp's 2 witness, we should -- I assume you're going to have 3 additional testimony? 4 MR. DUERR: Yes. 5 MR. GILROY: Why don't we resolve this witness 6 in case he wants to leave. 14 MR. SCHORPP: I have no questions. 7 Do you gentlemen have any preconceived ideas in 8 how you want to go in order here? 9 MR. SCHORPP: Whatever is the board's 10 preference. 11 MR. GILROY: You're the appellant, why don't you 12 go first, and then Mr. Lucas can go. We'll give you wide ',';;"'\ ( ,.,17 13 latitude in follow-up, however you like. 15 MR. GILROY: Mr. Lucas, any questions for this 16 witness? , , , 17 CROSS-EXAMINATION 18 BY MR. LUCAS: 19 Q. Just to clarify, did Mr. Ronan say he had two; a 20 son and another apartment there? He did noL indicate that 22 A. That's correct. 21 he was living there? 23 MR. LUCAS: No further questions. 24 MR. GILROY: Do you have any questions u 25 additional? I .1 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 22 ~ 1 nppllcnntn, you Indicated previous -- and I quote -- the 2 prov!oun -- Ilocond pnragraph, first page: The previous J ownur l\IId occnlltonlllly rented one apartment while living 4 lhuro hornolf. On what did you base that statement? 5 A. 6 Q. 7 A. u Q. NoLghbors. And who were the neighbors? Mr. Rickert. Now, in your investigation of this matter, did 9 you make a physical inspection of the premises? 10 A. Drive-by, yes. We drove by it. I drive by it 11 every day of the week. 12 Q. three mailboxes in front of the premises? .....;.... (",' 13 14 A. 15 Q. When you drove by, did you happen to notice I can't recall, no. Did you happen to notice whether or not there 16 was more than one electric meter service at the premises? 17 A. 18 Q. 19 20 No. Did you go inside the premises? A. No, I did not. Q. So you don't know whether or not the premises 21 has three separate units within three separate entrances? 22 23 A. No, I do not. Q. And you don't know whether or not the separate 24 units have separate locks with different keys? u 25 A. No. r , I l' I H C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ ~ (~~ u .' 24 1 A. That's correct. 2 MR. SCIIORPP: Thank you. That's all I have. 3 MR. GILROY: Mr. Lucas? 4 CROSS-EXAMINATION 5 BY MR. LUCAS: 6 Q. Mr. Duerr, does the township maintain a file of 7 nonconforming uses? 8 A. Yes, they do. 9 Q. And that's the file you said you review? 10 A. That's correct. 1 1 Q. And was there any nonconforming use certificate 12 for any nonconforming use of this property? 13 A. No, there was not. 14 Q. You said that there was no proof of any 15 additional addresses to this property. If somebody has an 16 apartment or establishes an apartment or apartment 17 bUilding, they come into the township to get a second 18 address assigned for that apartment? 19 A. The township issues all the addresses, yes. 20 Q. And that was not done in this case? 21 A. No. 22 Q. The information from Mr. stout, if there was an 23 apartment there under the township's solid waste plan 24 disposal program, there would be a second charge or 25 different charge for each apartment? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 25 6 A. No. t'; , , t, I' 1'1 'I '~: , , U :Ef ( I .~ 1 A. That's corroct. 2 Q. Did you receIve any communicatIon from Mr. I~onan 3 of any intention to use thIs property after his acquisition r1 of the property? Did he come in and send you any letter 5 saying this is what I intend to do with the property? 7 Q. Did Mr. and Mrs. Ronan -- or did that include i ,. '. 8 Mr. or Mrs. Ronan? 12 A. No. 9 A. Either one. 10 Q. Did Mr. and Mrs. Ronan apply for any particular 11 use of this property once they acquired it? J ,""'\ \.,.~J 13 Q. Did Mr. and Mrs. Ronan, through their attorney, 15 refund because the property had been vacant for over two ') ,\ , I 14 Mr. Schorpp, send any letter except the letter requesting a 16 years? j 17 A. No. 18 Q. When you send out a determination, if someone 21 A. If somebody comes in with information, 19 came in with the information, would that resolve the matter 20 to show a permit or justification? 22 justification, I certainly review it and take it into 23 consideration. And sometimes if they would bring in, like, 24 a permit or a conditional use, I would revoke my '0 25 determination letter. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 26 ~ 1 Q. Is it unusual for any of the township 2 supervisors to ever investigate zoning matters? 3 A. No. 4 Q. Is that pretty common? 5 A. Yes. 6 Q. In fact, is that where citizen complaints more 7 often come, to the supervisors and not to you? 8 A. Very often, yes. 9 MR. LUCAS: No further questions. 10 MR. GILROY: Mr. Schorpp? 11 RECROSS EXAMINATION 12 BY MR. SCHORPP: .~t'.. (., ) Does the township recognize a nonconforming use 13 Q. 14 status of properties that have not been registered by the 15 township by action of the owner? 16 MR. LUCAS: Objection. I don't think I 17 understand that question. I don't know if it's asking for 18 a legal conclusion or -- 19 MR. GILROY: As I understand, the question is, 20 are there other properties out there that are nonconforming 21 but don't have registered nonconformance certificates. 22 MR. LUCAS: I guess the question would be, what 23 is meant by recognized? If somebody comes in and 24 establishes they have a nonconforming use and the township v issues a certificate or that the township knows they're out 25 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 28 ~ 1 Q. And that proof is submitted to you and you make 2 the determination? 3 A. Correct. 4 MR. SCHORPP: Thank you. 5 MR. GILROY: Mr. Lucas, anything else? 6 RECROSS EXAMINATION 7 BY MR. LUCAS: 8 Q. Mr. Duerr, in this case, your enforcement letter 9 talked about the prior owner living there herself, previous 10 owner living there, and occasionally renting out one 11 apartment. The information that was supplied by Mr. Ronan (~) ~-"'" 12 to Mr. Stout was that he's the owner, was not living there, 13 but, in fact, renting out two apartments, correct? 14 A. That's correct. 15 Q. Does that seem to you to be the same thing as 16 the owner living there and renting out an apartment as C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 i . j I I I t t :f It.'.,,;.'., ~;~r .' I' (<if [ 1','/1 .},.- ~ . " ',"l' ll~" ,(".:;. I".,; 'I",'" '<-'" ',~ ~:'),~\ 17 opposed to the owner renting out two apartments? 18 A. No. It's not the same thing. 19 Q. Is a two-apartment or three-apartment building 20 permitted in this agriculture district of the township? 21 A. No, it is not. 22 Q. There is a use for, a conditional use in an 23 agricultural district, for an owner to have one accessory 24 apartment. You talked about that? o 25 A. Yes. 29 -- 1 MR. LUCAS: No further questions. 2 MR. GILROY: Mr. Duerr, to try and make it 3 clear, your enforcement letter suggests that there are 4 three apartments at the subject property. Is that what the 5 township's position is? 6 MR. DUERR: Yes. 7 MR. GILROY: And that three apartments on a 8 particular parcel of land such as this is not an allowed 9 use in that zoning district. What is the zoning district? 10 MR. DUERR: Agricultural. 11 MR. GILROY: And your information is that the 12 three apartments, at least from Mr. Schorpp's letter, were ("';' ',' ) 13 vacant for a period of at least two years? 14 MR. DUERR: That's correct. 15 MR. GILROY: And was your determination letter, 16 Township Exhibit Number 1, issued based upon the vacancy of 17 the apartments for two years? 18 MR. DUERR: That was part of the reason. The 19 other part of the reason was that prior to that vacancy, 20 the owner had lived there; and after that vacancy, there 21 was testimony there were at least two apartments, of which 22 neither of them had the owner living there. 23 MR. GILROY: I want to try and pin this down so ~ 24 the board knows what the issue is. Is it the township's 25 position that this is a three-unit apartment building C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 30 ~ 1 that's a nonconformIng use, or is it the township's 2 position that this is an accessory apartment, onc accessory " 3 apartment that would be a nonconforming usc? 4 MR. DUERR: At most, yes, one accessory /~ )1 ) I 5 apartment under the ordinance with the owner living in the 6 other apartment; actually the owner living in the principal 7 house. 8 9 MR. GILROY: So the township has no information that there was actually three separate dwelling units at l 10 the property? 11 MR. DUERR: No. 12 MR. GILROY: And whether it was a three-unit () 13 apartment or two-unit, which would be an accessory 14 apartment with the owner living there, which is different 1 .fi , 1 15 under the ordinance than just two apartment buildings, the 16 township's position is whatever nonconformance it was, it j , 17 was vacated for two years and thus abandoned? 18 MR. DUERR: That's correct. 19 MR. GILROY: Does the board have any questions? i . t r [.' , J.'~ 20 THE CHAIRMAN: I just want to clarify the dates 21 that all this has happerled. When did Mr. Ronan acquire the 22 property? 23 MR. DUERR: I'm not sure of the exact date. 24 THE CHAIRMAN: And I think when Mr. stout began u 25 testifying, he referenced it to when BFI took over the C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ a 19 20 21 22 23 24 .t.> 25 31 1 trash program. Do you have an approximate time frame for 2 that? Did that occur within 1994? 3 MR. DUERR: It didn't happen immediately after 4 that. I believe it happened -- this Occurred within this 5 year, if I'm correct, because a letter was issued in 6 February. So maybe the very end of last year we might have 7 began looking into this matter. 8 THE CHAIRMAN: You're not sure exactly when the 9 Ronan's acquired the property? 10 MR. DUERR: No, I'm not. , 11 THE CHAIRMAN: And just to clarify, again, if 12 the previous owner had occupied the property and had one 13 additional apartment, that would be permissible as a 14 conditional use under the current ordinance and would not ) I , I 15 necessarily be a nonconforming use, but Occupancy by two 16 apartments, neither of which is occupied by the owner, 17 would then be a nonconforming use and that would be a new " ;\ i I " I ( I \ r \ I, iI 18 nonconforming use, as I understand it? MR. GILROY: Let me -- if they don't have a conditional use permit, it's nonconforming. So either way it's nonconforming, whether it's an accessory apartment or-- an accessory apartment without a permit is nonconforming. Two apartments that don't have a family 1'] living there I guess would not be an accessory, and three , \') , 'i would be nonconforming, unless these two gentlemen disagree I: I i l~\ r ,;-;, C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 \ ~ 10 32 1 with that interpretation. 2 MR. SCHORPP: If I may, the issue that we are 3 presenting to the board this evening docs not involve 4 whether or not the applicants have conditional use approval 5 for an owner-occupied property with one accessory 6 apartment. If I may, I'd like to direct one more question 7 to Mr. Duerr. 8 MR. GILROY: Go ahead, Mr. Schorpp. 9 BY MR. SCHORPP: Q. Mr. Duerr, do you know when, for the first time, 11 South Middleton Township allowed the owner occupied 12 residents with an accessory apartment in that geographic .:.... C) ,'- 13 14 location as a conditional use? A. As part of the 1985 zoning ordinance. The exact 15 date of that -- actually it was approved February of 1984. 16 17 MR. SCHORPP: Thank you. MR. GILROY: Mr. Lucas, do you have any 18 questions? 19 20 21 22 23 24 '-.J 25 MR. LUCAS: No. MR. GILROY: Do you have any further testimony? MR. DUERR: No, I do not. MR. GILROY: Any further witnesses? MR. DUERR: No. MR. GILROY: We have Township Exhibit 1 and 2. Is there any objection from Mr. Schorpp to the admission of C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 .R. 33 ~ 1 T-1 and T-2? 2 MR. SCIlORPP: No. 3 MR. LUCAS: No. 4 MR. GILROY: They are admitted into the record. 5 Now, Mr. Schorpp, I tend to disagree with you 6 when you said you thought the neighbors needed to proceed 7 with their burden. 8 MR. SCHORPP: The law, as we understand it, is 9 that those opposing the continuance of a nonconforming use 10 status because it has been abandoned have the burden of 11 proof. 12 MR. LUCAS: I don't think __ :',) 13 MR. GILROY: I don't think it's been proven that 14 there's a nonconforming use status that has -- well, it's 15 been shown that there's a nonconforming use, and there's no 16 testimony saying that it predated the ordinance. And it 17 says even if it did, it's been abandoned. 18 But as I understand the record, what the board 19 has before it right now is the township saying you've got 20 an apartment out there and you don't have a permit, and 21 it's not a -- it's a nonconforming use, but it has not 22 predated the ordinance. 23 MR. SCHORPP: Well, our appeal petition states 24 that it's a nonconforming use which has not been abandoned. u 25 That presupposes that we're going to introduce evidence to C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (000) 863-3657 -". ......". . ~ " '; .., r-.. . ..-- ':...)': . ' I 34 I,. . ~ 1 that effect. 2 MR. GILROY: How can the protestants be expected 3 to disprove that until we've heard what the evidence is? Is there anything in your petition that says it's been an /, " , ) ~ ' 4 8 MR. SCHORPP: That's correct. We don't disagree 5 apartment for a certain period of time that suggests that 6 there's-- as I understand it, it has to predate the 7 ordinance. 9 with that. 10 MR. GILROY: So there's no evidence on the 12 perspective right now, we have a nonconforming use, period. 11 record saying it predates the ordinance. So from my '-') ... . \":"f"! 13 MR. LUCAS: I think from our perspective, the 'I , \ , I 14 use in violation of the ordinance, there's been no -- the 15 township has no record of a nonconforming use. And they're ! 16 saying even if there was such, it was abandoned. But they 17 don't even have record that there is a nonconforming use 18 there. So I think the appellant clearly has the burden of 19 proving there was a nonconforming use in existence. 20 MR. GILROY: Right. And I think we're spending 21 too much time arguing about who goes first. We're all 22 going to hear everything anyhow, I'm sure. So why don't 23 you proceed, Mr. Schorpp. 24 MR. SCHORPP: Fine. We'll call Mrs. Geraldine v 25 Ronan. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 , ... 36 ~ 1 time frame. 2 Q. From your knowledge residing in the vicinity of 3 the property, do you know whether or not while both Mr. and 4 Mrs. Hagen were alive, they rented part or parts of the 5 property to tenants? 6 MR. LUCAS: Objection. I don't think just by 7 living in the area gives a foundation for this question. I 8 think there should be a foundation before there is any 9 question on what was rented. 10 MR. SCHORPP: I'll retract the question for now. 11 BY MR. SCHORPP: 12 Q. Did you know Mr. and Mrs. Hagen? ,'W") '''1 ""~ 13 A. I did. 14 Q. Did you know them very well? 15 A. I knew them very well. 16 Q. How often would you speak with them? 17 A. Daily, weekly. I traveled with Mr. Hagen to 18 work many times. 19 Q. And from your discussions with them and your 20 observations of the property, did you come to know whether 21 or not they rented a portion or portions of the property to 22 other persons? 23 MR. LUCAS: Objection. Either this is following 24 the last question and it involves hearsay -- or, just, once v 25 again, living in the vicinity, I don't think, is a C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 30 ~ 1 MR. GILROY: This is in addition to their living 2 quarters? 3 THE WITNESS: Right. 4 BY MR. SCHORPP: 5 Q. And where did they live? 6 A. They lived in the first floor. 12 A. Yes. 7 Q. Mrs. Ronan, I want to shortly get into your 8 knowledge of Mrs. Hagen during the last years of her life. 9 But before I do that, for now, do you know who was 10 appointed by the Court of Cumberland County to settle 11 Mrs. Hagen's estate? . I::) 13 Q. And who was that? 14 A. My husband and I. '1 . ,\ , ! 15 Q. And were both of you named as executors in her 22 (Attorney Lucas perusing documents supplied by Attorney Schorpp.) , i i i j I I ! \ \~ . f' , , I 16 will ? 17 A. We were. 18 Q. In the settlement of her estate, did you have 19 full access to all of the articles and documents that were 20 in her home? 21 A. Certainly did. 24 (Mr. Duerr perusing documents supplied by Attorney Schorpp.) I' 1'1 :1 i I , ! , 23 u 25 MR. GILROY: Do you want to mark these, Ed? 11 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (000) 863-3657 \ if" 39 ~ 1 MR. SCHORPP: Yes. 2 (Appellants' Exhibits Nos. 1, 2 and 3 were marked.) 3 4 BY MR. SCIIORPP: 5 Q. Mrs. Ronan, I'm going to show you what has been 6 marked as Exhibit A-1, which appears to be a book entitled 7 rent receipts with a series of stubs inside, and ask you if 8 you can identify that, please. 9 A. I can. 10 Q. And what is it? 1 1 A. They are rent receipts from apartments. The ,..-') "..,.... 12 first one is in Mr. Hagen's handwriting dated 1958. 13 MR. LUCAS: Objection. They're her 14 interpretation of what they are. I mean, they're books 15 somebody wrote in. It doesn't say what they're for, if 16 they're for what apartment or what they're for. 17 MR. SCHORPP: Well, if we allow the witness to 18 finish describing the exhibit, maybe you'll know. 19 MR. LUCAS: Well, I think she's already making 20 interpretations, and I'm going to object when she makes 21 them because there's no basis. 22 MR. GILROY: As to whether she has the ability 23 to make them? 24 MR. LUCAS: Yes. I don't know where the , , U 25 foundation is that she has the ability to make what they C.P.C.R.S @ pacourt@kns.net (717) 250-3657 or (800) 063-3657 41 ~ 1 And how are you familiar with their handwriting? Q. 2 A. Because I was around them enough to know how one 3 wrote and how the other one wrote. 4 Q. With your familiarity with their handwriting, 5 can you identify Exhibit A-1 for the board? 6 I can. The first entries are Mr. Hagen's, and I A. 7 have numerous papers in the estate that show his 8 handwriting from where he worked and from where he lived 9 and all other documents. 10 Q. From your search into the estate records that 11 you retrieved after you were appointed, can you testify to 12 the board the approximate earliest dates that you have :'J 13 uncovered what appear to be rent receipts? 14 A. 1953, I believe, are the earliest. 15 Q. And the book that you have in front of you is 1 6 from? 17 A. 1958. Mr. Hagen passed away in 1962. From that 18 point on, they're in Mrs. Hagen's handwriting. 19 Q. And can you identify Exhibit A-2? 20 A. They are definitely Mrs. Hagen's handwriting for 21 receipts. 22 MR. GILROY: Excuse me, ma'am. So there's no 23 problem, identify what it is. 24 THE WITNESS: Dollars for the apartment. v 25 MR. GILROY: Well, it's a receipt book, again? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ... 1 42 THE WITNESS: Right. 2 BY MR. SCHORPP: 3 4 Q. A. 5 Q. And they date from what period of time? This is 1965. And if I show you Exhibit A-3, can you tell us, 6 ma'am, if that exhibit is in the condition that you 7 acquired it? 8 A. 9 Q. Yes, it is. And it appears to be a series of advertising 10 bills with checks attached. Is that correct? 1 1 A. 12 Q. <,.....'" , ) "'1'''' Right. And that's in the same condition that you found 13 it in the estate papers? 14 15 A. Yes. Q. And would you identify for the board what that 16 exhibit contains? 17 A. These are receipts from the Sentinel -- bills, 18 actually, and receipts with checks that she paid for the 19 advertising. 20 21 advertised? 22 Q. And what do the receipts indicate was A. Well, there's a tab over this one, but it says 23 modern apartment, efficiency apartment, efficiency adult. 24 Second floor apartment, adult efficiency. Do I need to go v 25 on? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 .. ~ 1 Q. 43 No. Now, from your discussions with the lIagens 2 and your observation of the property, what do you 3 understand to be the efficiency apartment? 4 A. 5 6 Q. A. 7 Q. The one on the ground level. Which would be the basement? Yes. And you indicated there are also advertising 8 stubs there for a second floor apartment? 9 A. 10 Q. 11 cover? 12 A. Right. And what period of time do those documents '82, '83, '78, '70, '89, '90, '88, '89, '89. () ....,. 13 Looks like from '78 until '89, '90. 14 Q. 15 A. 16 Q. Now, you indicated that Mr. Hagen died when? gune of 1962. c;;r .~r And is it your testimony that prior to his 17 death, the property was being rented in addition to being 18 occupied by both Mr. and Mrs. Hagen? 19 A. 20 Q. 21 two? 22 A. 23 Q. 24 A v 25 Certainly was. And when it was rented, was there one rental or Two. When did Mrs. Hagen die? September the 21st, 1994. Q. Prior to her death from your own personal C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 063-3657 45 ~ 1 basement units rcnted? 2 A. Shc did. The socond floor, the one da y we took 3 her to the hospital, the tenant came down to pay his rent 4 for April. She said, keep your money and go find an 5 apartment somewhere else; I want you to move out. And 6 within a few days, he did. 7 Q. And was that -- that was the second floor 8 apartment? 9 A. Second floor. 10 Q. And that was shortly before when? 11 A. Before she went to the hospital, the last time 12 before she went into the nursing home from the hospital. () -' 13 Q. And at that point in time, was the basement unit 14 also rented? 15 A. There was a young girl living there who lived 16 there from time to time. 17 Q. When Mrs. Hagen was admitted to the nursing 18 home, did you have a discussion with her about finding a 19 tenant for the one who vacated the second floor? 20 A. We did. And she wanted to handle it herself, 23 and said just put it on hold until I get home. MR. LUCAS: Objection. MR. SCHORPP: It doesn't go to the truth. It's offered as to what was said. MR. LUCAS: As for the truth or as not, it 21 22 24 .....) 2 5 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 '~ 46 ~ 1 doesn't mean anything. 2 MR. SCHORPP: Well, it describes her state of 3 mind. 4 MR. LUCAS: I think it's highly objectionable 5 and should be stricken. 6 MR. GILROY: Hearsay is admitted under the 7 relaxed rules of evidence. And I agree; they're not 8 offering to say what she was doing or what happened, but 9 what she intended, the state of mind of the person. 10 BY MR. SCHORPP: 1 1 Q. From your knowledge of Mrs. Hagen through the 12 years, can you describe her in terms of being a dependent ,~ '..-) 13 person, meaning dependant on others, an independent person? 14 How would you describe her? 15 A. She was extremely independent. 16 Q. And from your discussions with her and your 17 observations after she was admitted to the home, did she 18 feel or express to you that she would never go home again? 19 A. No. She thought up to the last she was going 20 home. 21 Q. And she died -- 22 A. September the 21st, 1994. 23 Q. When were you and Mr. Ronan appointed as 24 executors of her estate? J 25 A. I'm not sure of the exact date; maybe February, C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ 1 March '94. 2 Q. 3 A. 4 Q. 5 A. 47 Appointed executor by the -- Executor, I'm sorry. When she died. Was it in October? October, yes, when you made the claim. 6 I was thinking power of attorney when you said 7 that. 8 Q. And after you wer.e appointed executor -- and by 9 you, I mean you and Mr. Ronan -- were both you and 10 Mr. Ronan employed full time at that point in time? 11 A. 12 Q. Yes, indeed. And did you, in the course of settling the '-j '-...,'" 13 estate, schedule a public sale of her personal furnishings 14 and belongings? 15 A. 16 Q. 17 A. 18 date. 19 We did. And when was the public sale? September of '95. The 16th, I believe, is the Q. And is there a reason why the public sale 20 followed your appointment as executor by that period of 21 time? 22 23 24 u A. Oh, the duration of time? \, ( J Q. Yes. }.".. A Because it took us that long to get ready. My i I. 25 husband and I were both employed, and we had to do it in C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ '-j ",..". 19 20 21 22 49 1 efficiency to accommodate her and her two children, and we 2 did that. And she moved in there sometime before 3 Thanksgiving in 1994, and she was there until after the new 4 year sometime. 5 Q. Was it occupied by any other persons? 6 A. Well, our prodigal son, in a manner of speaking, 7 came home. This is the young lady who from time to time 8 lived in the efficiency, and she came home sometime after 9 the mother of the two children moved out. And she was 10 there until July of '95, and we asked her then to try and 11 find somewhere else to live so that we can move her things 12 for auction down to that level. 13 Q. Now, had that unit been rented in a furnished 14 condi tion? 15 A. It could be termed furnished. Q. Were there items in that unit that you wanted to include in the sale? A. Oh, yes. Q. Were there any other reasons why you did not rent the second floor during the period that you were handling the affairs of the estate? 16 17 18 A. We didn't feel it was in any condition to be 23 rented. 24 v 25 Q. And by that, you mean? A. It was dirty; it needed painted; Mrs. Hagen had C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 50 ~ 1 not been upstairs, by her own admission, for two years 2 before she went to the hospital. She had no idea what 3 condition it was in. I would not have rented anything in 4 that condition. 5 Q. So is it your testimony you wanted to renovate 6 it before you rented it? 7 A. Right. 8 Q. Now, you heard the earlier testimony from 9 Mr. stout and Mr. Duerr concerning a letter which I wrote 10 on your behalf to the township, and that was identified as 11 Township Exhibit Number 2. And in that letter, reference 12 was made to the statement that the property was vacant on ....,.... ( ) 1!" April of 1994 through April of 1996. Is that a correct 13 14 statement? 15 No. A. 16 Can you explain how the mistake was made in the Q. 17 letter? 18 Yes, because I did not consider someone that we A. 19 let live there out of charity constituting a renter or the 20 other prodigal daughter who came home as a renter. 21 Q. But you had it occupied? 22 It was occupied. A. 23 And were these people generating trash that was Q. 24 put out through the township trash system? u 25 A. No. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 I ~ .:\ ~ 1 change. 2 Q. 3 A. 52 And that's per month? Per month, yes. And the succeeding months after (1 ,I 4 August, it was in the 24, $25 range. 5 Q. In addition to the administration of the estate, 6 did either you or Mr. Ronan suffer any setbacks that 7 interfered with your ability to have the property fully 8 occupied? 9 A. Oh, I think big time. November of '95 my ,. I' And did that contribute to a delay in renovating 10 husband had a heart attack. In January, he had bypass 11 surgery. 12 Q. ~=) 13 the second floor? 14 A. 15 Q. I would say so. ,\ , I Now, when did you and Mr. Ronan re-rent the 16 basement unit following the departure of the lady in July ! 17 of 1995? 18 A. The basement we rented to a war college student 19 in August of 1996. 20 Q. And when was the main floor of the property next 21 occupied after Mrs. Hagen's death? 22 A. 23 Q. April of 1996. And when was the second floor next occupied 24 after her death? v 25 A. March of 1996. ::; C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ 10 1 Q. of '95? A. Q. A. Q. A. Q. A. 53 So there was someone in the basement untIl July Right. One of the units was occupied in March of '96? The upstairs. The main floor in April of '96? Yes. And the basement unit, again, in August of '96? Yes. MR. GILROY: Excuse me. Did I miss something? 11 I have the basement unit rented to the war college student, 2 3 4 5 6 7 8 9 12 in-- ,"~) "-0.1" 13 14 THE WITNESS: August of '96. MR. GILROY: And when did you say the second 15 floor was rented? 16 17 THE WITNESS: In March of '96. MR. GILROY: So you went backwards there in your 18 testimony. March of '96, the second floor rented. 19 20 21 22 23 24 o 25 rented. THE WITNESS: Right. It was the first one MR. GILROY: Thank you. (Appellants' Exhibit No.4 was marked.) BY MR. SCHORPP: Q. Mrs. Ronan, I'm going to show you what has been marked Appellants' 4, which is three sheets of paper C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ \~ r (" I, l ;'. " 1'1" Ii , , ! 55 ~ 1 is entered there? 2 A. 3 Q. 4 A. 5 Q. 6 A. 7 Q. 8 A. 9 Q. 1960, August 17th, 1960. And the address of the property designated? 729 Petersburg Road. And is anything else with the address? It says apartment A. At the address, it says second floor? Second floor. So this is when the electric company is telling 10 you that the meter was installed? 1 1 A. 12 Q. .-J........ ( ) -...."-.;of Right, for the second floor. Now, there's a third page, and, again, the 13 install date is? 14 A. 15 16 17 18 19 20 installed? 21 22 name. 23 7/25/96. Q. And what is the address for that? A. 729 petersburg Road, apartment B. Q. Now, does that refer to the basement unit? A. That's the basement. Q. Did you and Mr. Ronan cause this meter to be A. We had it reinstalled and had it put in our Q. During the period, the later part of Mrs. 24 Hagen's years, was the basement unit and the main floor v 25 meter separate? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ '~) """"'" u 1 50 A. The right side closest to the house was her 4 use it. 5 8 9 11 12 13 bathrooms? 2 side. The left side was the tenant for the second floor. 14 A. 3 And, of course, the efficiency was all theirs; she didn't Q. In your knowledge of the years that you have 15 Q. 6 known this property, have any of these units been '16 kitchens? A. Q. A. Q. A. Q. A. 7 physically combined with another unit within the bUilding? No. It wouldn't be feasible. Q. So from your memory, they have always been 10 separate physical units within the building? A. Yes. 17 18 Q. Do each of these units have their own separate They do. Do each of these units have their own separate They do. 19 property, has that been true? Going back for as long as you've known the 20 21 22 23 Yes. And you were in the units and observed that? I was. With respect to the time frame of your ownership 24 of the property and even going back to Mrs. Hagen's death, 25 did the weather have any factor in the period of time it C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ... 60 ~ 1 we not have cross-examination. We'll make a transcript of 2 this hearing and afford it to Mr. otto so that he can 3 appear at the next hearing, if he's available. And Mr. 4 Lucas and Mr. Schorpp, if you want copies of the 5 transcript, you can make arrangements with the 6 stenographer. 7 Does anyone right now know of a problem with 8 December 9th at 5:00? 9 MR. SCHORPP: Let me first say this, that I 10 think it's extremely unfair to allow Mr. Lucas to have a 11 transcript to prepare his cross-examination. 12 MR. RICKERT: We can stay. ::) 13 MR. GILROY: That's one of the advantages and 14 disadvantages of this. We're going to order a transcript 15 for Mr. otto, and I don't want a transcript floating around 16 unless everybody has an opportunity to review it. 17 MR. SCHORPP: We would make an objection on the 18 record to that procedure. 19 MR. GILROY: Okay. 20 MR. LUCAS: The record should note the reason 21 we're continuing this is because of Mr. Schorpp's schedule. 22 And we'll only get a transcript if we pay for one. 23 MR. GILROY: He makes the note that he's 24 objecting, but we don't see a problem with it. I don't ......J 25 think you're going to get an unfair advantage by having an C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 61 , ' I 5 6 (Discussion held off the record.) \. I' I . J,' r I ~, r' ' i j: ') J H' ,.\>j I c: i i i I. i n 1 opportunity to look at the transcript. Mr. Schorpp might 2 be able to realize he missed something by looking at it and 3 add more, so that would be to his advantage, too. 4 The question is, does anybody have a problem with December 9th? 7 MR. GILROY: Just for the record, if the board 8 decides to view the property for any reason, they'll 9 announce that they're going to do that in advance. So the 10 board won't be viewing the property between now and the 11 date of the next hearing, nor will the board have any 12 deliberations between now and then. f) 13 (Whereupon, the hearing recessed at 6:50 p.m.) l~ II I' l , , ,~ I I ~ \ I ~ '\ i I . 'I" r,.. t" \~ 'I' '; i ~ : 14 15 16 17 18 19 20 21 22 23 24 (; 25 I,i C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 '~ 64 I"'i 1 INDEX TO TESTIMONY 2 FOR APPELLANTS DIREC'l' CROSS REDIRECT RECROSS 3 Geraldine Ronan 67 77 4 Timothy Duerr 95 5 Geraldine Ronan, 134 138 6 recalled on rebuttal 7 8 FOR PROTESTANTS 9 Maxine Wetzel 98 103 106 10 Terry Reickert 107 114 11 Timothy Duerr 133 12 ""', (,.J 13 14 15 16 17 18 19 20 21 22 23 24 U 25 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (000) 863-3657 65 "'" 1 APPELLAN'I' EXlfIBI'I'S 2 NO. DESCRIPTION MARKED ADMITTED 3 4 1 Rent receipts book 2 Rent receipts book 5 3 Advertising bills with attached checks 6 4 Electric bills 97 7 8 5 6 97 Copy of appraisal 69 PA inheritance tax return 76 9 7 10 Portion of S. Middleton Twp ordinance from 1970 96 97 11 12 (.,..) 13 PROTESTANT EXHIBITS 14 NO. DESCRIPTION MARKED ADMITTED 15 R-1 Last will and testiment of Mrs. Hagen 89 134 16 R-2 17 Cumberland County Register of Wills office record 90 134 18 R-3 First and final account 90 134 19 20 TOWNSHIP EXHIBITS 21 NO. DESCRIPTION MARKED ADMITTED 22 1 23 Letter to William Ronan from Timothy Duerr dtd 7/21/97 140 24 2 u 25 Letter to Tim stout from Attorney Schorpp dtd 2/24/97 140 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 97 97 97 69 ~ 1 definition of multidwelling under the zoning ordinance. 2 MR. SCHORPP: 1~ilt was not my question. My 3 question was assuming that the first ordinance to prohibit 4 a multifamily dwelling at the property was enacted in 5 January of 1970. 6 MR. GILROY: '70, you're saying? 7 MR. SCHORPP: Yes. 8 Can you testify, from your knowledge, as to 9 whether or not the basement unit and the second floor unit 10 were occupied separately prior to that time? 11 THE WITNESS: Yes, they were. 12 BY MR. SCHORPP: -~) ~.. ,.,~ 13 Q. Now, in your administration of the estate of 14 Mrs. Hagen, did you have this property appraised for 15 Pennsylvania inheritance tax purposes? 16 A. We did. 17 Q. And did you have the property appraised as a 18 multifamily dwelling? 19 A. We did. 20 MR. SCHORPP: I believe we're on Appellants' 21 Exhibit 5, if I'm correct. 22 (Appellants' Exhibit No.5 was marked.) 23 BY MR. SCHORPP: 24 Q. Now, Mrs. Ronan, I'm going to show you ....) 25 Appellants' Exhibit 5 and ask you if you can identify that C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 75 ~ the property reported on a Pennsylvania Inheritance Tax 2 return based upon your request that it be appraised as a 3 multifamily dwelling? 4 A. I did. 5 Q. And you reported it and paid Pennsylvania 6 inheritance taxes on that basis? 7 A. We did. 8 MR. SCHORPP: I have a copy, a certified copy of 9 the first page of the Pennsylvania inheritance tax return 10 which shows that the property was reported consistent with 11 the appraisal. 12 I would like to also offer this to show that as ~) 13 far as my client is concerned, the property was reported 14 consistent with the request and taxes were paid. 15 MR. GILROY: Mr. Lucas? 16 MR. LUCAS: The only objection I have is if 17 you're trying to offer this for the fact that an appraiser 18 determined that fact. She can say she paid taxes based on 19 the amount of the appraisal. 20 BY MR. SCHORPP: 21 Q. The appraisal that you received had a number in 22 it for the value of this property. Is that correct? 23 A. Yes. 24 Q. And when you signed the Pennsylvania Inheritance v 25 Tax return, did you use that number? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 n 2 76 A. Yes. Q. I'm going to show you -- I guess this would be 3 Appellants' 6, although 5 is still subject to an objection. 4 Am I correct on that, Mr. Gilroy? 5 MR. GILROY: Yes. 6 (Appellants' Exhibit No.6 was marked.) 7 BY MR. SCHORPP: 8 Q. I show you what has been marked as Appellants' 9 Exhibit Number 6. Can you describe that document for the 10 board, please? 1 1 12 () 13 14 Q. A. That's the inheritance tax return. Q. And that would be the first page of it? A. This is the first page. And is the value reported for real estate on 15 line number 1 consistent with the appraisal? 16 A. 17 Q. It is. 18 husband signed and filed in the estate? And is this the return that both you and your 19 A. 20 Q. It is. From the time that you and your husband learned 21 that you would inherit this property, did either one of you 22 discuss any intention to abandon the three units and 23 combine them in any fashion? 24 A. t.> 25 Q. We did not. :; i , Did you do anything to combine the three units I , :, I . .: . , C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 77 f'.. 1 in any fashion? 2 A. We did not. 3 Q. When Mr. Duerr informed you that your 4 nonconforming use had been abandoned, at that time, did he 5 ask you whether you would like to try and register it as a 6 nonconforming use with the township? 7 A. He did not. 8 MR. SCHORPP: Now I offer Mrs. Ronan for 9 cross-examination. 10 MR. GILROY: Mr. Lucas? 11 CROSS-EXAMINATION 12 BY MR. LUCAS: (-' ,,,<,.l 13 Q. Mrs. Ronan, you owned the property subject to 14 this appeal just solely with your husband. Is that 15 correct? 16 A. That's correct. 17 Q. And neither you nor your husband currently live 18 in the property. Is that correct? 19 A. We do not. 20 Q. The entire time you knew Mrs. Hagen, she resided 21 in the property, correct? 22 A. Yes, she did. 23 Q. One of your exhibits that you presented last 24 time, Exhibit A-3, what you identified as advertising bills u 25 and checks, they were out of order. But the years you C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ( 70 r~ 1 identified was 1970, '02, '83, '80, '89 and '90. Now, 2 there's a four-year gap between '70 and '02; ther0's a 3 five-year gap between '03 and '08; there's nothing after 4 1990, nothing before 1970. You don't have anything filling 5 in those gaps, do you? 6 A. There may be. I have a clothes hamper full of 7 papers. I am not going through all of them. These are 8 what I have pulled out. 10 Q. A. with me. Q. A. Q. 11 12 -l"'~" ( ) '.~. ,'.-. 13 At this present time, yes. This is all I have This is all you have for the hearings, correct? Righ t. 15 obtained from the electric company, and the third page had 16 an installation date of July 25th, 1996. Do you have 17 anything prior to that date? 18 A. 19 Q. Yes. For that which you're claiming is -- I think you 20 claimed that was apartment B. 21 A. 22 No, I don't have anything prior to that. Q. Is there anything on -- there's nothing on this 23 form that says reinstallation, is there? 24 u 25 A. No. Q. It says installation? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ 1 2 79 A. Yes. Q. So if you said reinstallation in your testimony, 3 that's not accurate with what the form states, correct? 4 A. The electric company said that once the meter 5 has been removed, they no longer keep the records. And 6 every three years they have to reexamine the meters and 7 update. So whatever went in between was lost. 8 Q. Well, wait a minute. The first two pages go 9 back to 1960 to 1985. 10 1 1 12 A. ~\ , -...-"' 13 Q. A. Right. 14 into Cumberland Crossings you had neighbors come into the Q. But you don't have any record prior to 1996? Not for the efficiency. Now, you were saying prior to Mrs. Hagen going 15 house. What neighbors came in? 16 A. 17 Q. 18 A. 19 neighbor. Mr. Beltzhoover, Creedon Beltzhoover. Who else? Well, Dr. Davis was there. He's not exactly a 20 Mrs. Janashak. 21 Q. 22 A. 23 Q. Is there anyone else? Not that I can think of at the moment. I...J 24 Township Exhibit Number 2, which is the letter that Now, you testified at the last hearing that the 25 Mr. Schorpp wrote, that that was an inaccurate statement, C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 .." 80 I. I."'! , \ , , \ " I> L I",' , f'1 1 that, in fact, the place had been vacant for almost two 2 years. Is that what you stated at the last hearing? 4 Q. Is that correct? 3 A. It was not an accurate statement. 5 A. It would have been better served by other 6 terminology. But by that point, we had reached a 7 saturation with the township trash business. Just prior to .- 8 that correspondence, I had a letter from the Credit Bureau l 9 in Harrisburg that said my account with BFI was delinquent. 11 account and it was not delinquent, they would contact the 10 In checking with BFI, they said I not only did not have an 12 Credit Bureau and take care of it, in which they did. And (") '\tr~ 13 they had no explanation as to why I received that letter ') \ , I 14 from the Credit Bureau. 15 Just prior to that, I had a certified letter , ! 16 from Mr. stout stating that I was in violation, I, not my 17 husband and I, where we live at 759 Petersburg Road. My 18 husband came out and talked to Mr. stout, and Mr. stout's 19 explanation was that he receives a list of hundreds of 20 names, from where I'm not certain, and that he randomly ; 1 21 goes through those lists and picks out 60 names and I just 22 happened to be one of those names. 23 That, again, was in my name solely. I don't 24 think husband and wife living in the same household are u 25 required to keep separate trash accounts. I r~ C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 r1 1 82 Q. And the woman, the young lady that you said was 2 in there, did she pay rent? 3 4 5 A. Occas ionall y . Q. When did she live there? A. She lived there off and on throughout the years. 6 The last time she lived there was from the winter of '95 Q. Of '96? 7 I don't know if she moved in in March, sometime in '95; 8 moved out in July, early July. 9 10 11 12 A. ''''') (,..,. 13 Q. 14 A. 15 Q. 16 hearing? 17 A. 18 Q. A. Of '95. Q. Okay. How much rent did she pay? She was supposed to pay $100 a month. You were at the entire last hearing, correct? ') I , , I was. Did you hear testimony of Mr. stout at the last i , , I did. And Mr. stout said that your husband had 19 informed him that there was nobody living there. 20 A. 21 into effect. 22 Q. 23 A. That was in 1995 when the trash ordinance went When did this young lady __ () 24 early winter of '95; moved out in July. She did not She moved in, like I said, Febr.uary, March, 25 participate in the trash. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 03 I'i 1 Q. But somebody was living there? 2 A. Yes. She lived there. 3 Q. So your husband is telling the township nobody 4 was there; you're saying people were living there sometimes 5 paying rent, not paying rent? 6 A. Right. My husband said there was no one renting 7 the apartments as such. 8 Q. Mr. stout said your husband said nobody was 9 living there. , 10 A. Well, as I said before, we don't count people 11 who aren't paying rent on a continuous basis as renters. 12 Q. So your feeling was you didn't have to pay trash J ":) C 13 you didn't have to comply with the township ordinance if ') I , I 14 you weren't collecting rent. Is that your position? 15 A. She didn't have any trash to be collected. 16 Q. Did you check with the township of whether if 19 MR. SCHORPP: I'm going to object. I don't ( I i ( I i ~ \ \ . ,,' 17 somebody has to generate trash or whether you have to, as 18 an owner of a property, you have to register it? 20 believe there's any relevance to the township's trash 21 collection system and what her beliefs of how it operated 22 were to this hearing. 23 MR. LUCAS: I think the relevancy is the " " Ij 24 credibility of this witness. Her husband goes to the u 25 township and said nobody is living there -- C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ,I....: 04 /'-\ 1 MR. GILROY: I agree. If somebody is living 2 there, they have to have some trash. Credibility is an 3 issue in this case. 4 THE WITNESS: Well, perhaps they take it to 5 their church dumpster, which I understand is an accepted 6 practice in this township. 7 MR. GILROY: Might I note that it's not a 8 permitted practice. 9 THE WITNESS: Well, I don't know. If the 10 township supervisor says it's an accepted practice ... 11 MR. GILROY: Okay. 12 BY MR. LUCAS: t"'., """,1 13 Q. While Mrs. Hagen lived there, how many cars were 14 ever parked at the house? 15 A. While Mrs. Hagen lived there? '\ , I 17 A. It varied. Some of her tenants each had two P i 16 Q. Yes. 18 cars. She had one car, hnrself. Some of her tenants had 19 two cars, but it could have been three, four. It would 20 have been one for the basement. Most of the people living 21 there were single people, so they would have had only one 23 Q. So are you saying that there were three or four , ~ n I , ;: I " " 22 vehicle. 24 cars there regularly? u 25 A. When she lived there, there could have been, C.P.C.R.S @ pacourt@kns.net (717) 250-3657 or (800) 863-3657 , , II,..... I t) 1 yes. 05 2 Q. Not what could have been; I'm saying what was 3 there. You said you knew that place. 4 5 6 7 8 9 10 A. 11 rented. 12 Q. /j .............' 13 the basement and upstairs apartments were occupied A. I did know that place. I would say four cars. Q. In the last year, how many cars had been there? A. In this past year? Q. Yes. A. Five. Q. Regularly? Well, as regularly as you can keep an apartment Now, you were asked today by Mr. Schorpp whether 14 separately prior to 1970, and you said yes. On what basis 15 do you have that knowledge? 16 A. The basement was occupied in 1962. I'm aware of 17 that because my son was born and I was in and out with 18 Mrs. Hagen taking her to the hospital to visit her husband. 19 The upstairs we have documents that prove, the rent 20 receipts. 21 Q. 22 show that continuation from the '60s to the '90s? Could you point to me the rent receipts that 23 A. There is no rental property that is rented , U 24 continuously from year to year. If there's a landlord that 25 can do that, he's a genius, and I'd like to meet up with C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 86 (l 1 him. But, anyway, this goes from 1950, '64, '65, '66, '67, 2 '70, and I have other ones that go on. These were just 3 offered for an exhibit. 4 Q. So does this say apartment here? Does it say 5 A. Some of them do, some of them don't. They 6 weren't the best record keepers in the world. 7 Q. So there's no question that there's no written 8 evidence of any continuous occupancy of either of those 9 apartments, correct? 10 MR. SCHORPP: I'm going to object to the 11 question. The determination made by the zoning officer in 12 this case referred to a period of time referenced in my (") ~."I'I 13 letter, and there's been no determination that this use was I. I , I 14 abandoned sometime prior to that. 15 MR. GILROY: Mr. Schorpp, you brought up these I' Ii ! 16 records, and I think he can cross-examine on them. 17 MR. SCHORPP: Well, the records were brought up 18 to show the nonconforming use, not whether or not it was 19 abandoned in some previous stage that hasn't been alleged 20 by the township in their determination. 21 MR. LUCAS: I think that's the entire case. I ~.; n I ' I I' 22 They have to prove a valid nonconforming use for a 23 continuous period of time; otherwise they don't have a 24 nonconforming use. u 25 MR. GILROY: We'll give Mr. Lucas leeway. We'll C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ~ ~\ 1 Q. 2 A. 3 Q. 88 And can you tell me what year they were rented? No, I can't. So they could have been one rented one year and 4 another rented another year? 5 A. In my driving by, like Mr. Duerr and Mr. stout, 6 I knew there were cars there through all the periods from 7 1953 when they moved in there and made it into apartments. 8 The drive-by management technique is a new one 9 to me. I've had several courses in management, but that's 10 one I haven't encountered. But if it works for Mr. Duerr 11 and Mr. stout, it works for me. 12 Q. () So that's all how you know whether it was rented 13 is through you driving by? 14 A. No. I had continuous dealings with Mrs. Hagen. 15 She and my mother were on the phone daily, and we lived 16 with my mother, incidentally. That has not been 17 established. 18 Q. Since you and your husband have owned the 19 property, have you not had problems with the septic system 20 since you've been renting out apartments? 21 22 23 24 u 25 A. We had problems with the water. Q. With the septic system? A. Yes. We replaced the septic tank. Q. It was overloaded. Is that not correct? A. Well, it was too small. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 .~ i") 1 2 3 4 89 Q. Too small for what you were using it for? A. Right. Q. For three apartments? A. Right -- no. It was only used for two 5 apartments, that septic tank. There's a separate one for 6 the basement apartment. 7 Q. So the septic tank for what you were using, 8 renting out two apartments, was overloaded once you started 9 renting them out, correct? 10 A. No. We put in an automatic washer; that's what 11 overloaded it. Mrs. Hagen never had automatic washers in 12 the apartments or in her own living quarters. ("') I."." 13 MR. LUCAS: I guess this would be Exhibit 14 Rickert 1 or Objector 1. 15 MR. GILROY: We'll note these as R-1. 1 6 (Exhibi t No. R-1 was marked.) 17 BY MR. LUCAS: 18 Q. Mrs. Ronan, I'm showing you an exhibit marked as 19 Exhibit R-1. Do you recognize what that is a copy of? 20 A. 21 Q. 22 A. 23 Q. Yes. Mrs. Hagen's last will and testament. And what's the date of that will? 16th of March, 1994. And this is basically a one-page will or 24 one-page document and then signature pages and a notary '.....) 25 page after that, correct? C.P.C.R.S @ pacourt@kns.net (717) 250-3657 or (800) 863-3657 90 () 1 A. Right. 2 Q. And the will leaves everything to you and your 3 husband, correct? 4 A. That's correct. 5 Q. And Mrs. Hagen went into the nursing home in 6 April of '94, correct? 7 A. Right. 8 Q. So this is a month before she went into the 9 nu~sing home? 10 A. Correct. 11 Q. And the person who witnessed the will, 12 Mr. Schorpp, your attorney, and this is the person you , -') / __...1 13 referred to, Creedon Beltzhoover? 14 A. Right. 15 Q. Had Mr. Schorpp been your attorney prior to 16 that? 17 A. No. Mr. Schorpp is not my attorney. 18 MR. LUCAS: This will be Exhibit R-2. 19 (Exhibits Nos. R-2 and R-3 were marked.) I I ~ \ , '1 f I 20 BY MR. LUCAS: 21 Q. Exhibit R-2, it's a copy from records from the 22 Cumberland County Register of Wills Office for Mrs. Hagen's 23 estate. " 'j 24 MR. SCHORPP: Are you testifying? o 25 MR. LUCAS: No. I'm-- C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 " I......\ 1 91 2 BY MR. LUCAS: MR. GILROY: I think we can stipulate on that. 3 4 5 Q. Do you recognize theso forms, Mrs. Ronan? A. Yes. Q. And you and your husband are shown as having 6 beneficial interest in this estate on page 1 of the 7 exhibit. On the second page, there are seven individuals 8 listed. Do you know who those individuals are? 9 A. The first one is her niece. The second one and 10 third ones are her nephews. The next two are her sisters. 11 The other one is some of her relatives in Germany __ I 12 don't know ('"") .{ '. 13 left. And the other one is a friend from Maryland. 14 15 A. Cousins, perhaps; I think that's all she had Q. The last one is not a relative? 16 that I would have any knowledge of. No, not to my knowledge; maybe distant, but not 17 Q. And these were all living relatives of 18 Mrs. Hagen but she did not leave any of her estate to them? 19 A. 20 Q. 21 A. 22 Q. She did not. She left it all to you and your husband? That's right. 23 R-3. Do you recognize what R-3 is a copy of? I'll show you what we'll identify as Exhibit 24 A. u 25 Q. Yes. And what is that? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 93 ,"') 1 that I got, I turned over to Mr. Schorpp. 2 Q. 3 A. 4 Q. So this doesn't show any rent in 1995, does it? No. I thought you said that somebody was in there 5 paying rent then? 6 A. I said she paid on occasion. She lived there 7 about four months and left with owing over $400 rent. 8 Q. Did you file a final income tax return for 1994 9 for Mrs. Hagen? 10 A. 11 Q. 12 A. ("'l). ..l.w:. 13 1994? 14 Q. 15 A. 16 Q. 17 A. 18 Q. Mr. Schorpp did. And did that show any rental income? No. I don't have it with me, but I don't -- for Yes. Yes, there would have been up until April. So that did show rental income? That is when her tenant upstairs moved out. In your going through Mrs. Hagen's records, did I' , . 19 she show rental income in prior income tax returns? 20 A. 21 22 23 24 showing it? u 25 Sometimes. Q. Sometimes? , A. Sometimes. .0:' Q. when she received rent, or when she felt like , . ~ I A. When she felt like showing it. :'. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 94 ~ 1 MR. LUCAS: No further questions for this 2 witness. 3 MR. GILROY: Mr. Schorpp, do you have any 4 redirect? 5 MR. SCHORPP: No. 6 MR. GILROY: Anyone on the board have any 7 questions for this witness? 8 THE CHAIRMAN: I have one question I'd like to 9 try and clarify. 10 You've made reference to this young lady who 11 stayed in the basement apartment from time to time. Was 12 she any relation to Mrs. Hagen, or what was the basis of ......~" r) '.'.,","~#" 13 this -- 14 THE WITNESS: She was no relation that I'm aware 15 of. She was a young girl who would have a relationship and 16 when it would go sour, she would move in with Mrs. Hagen in 17 the efficiency. When she got established in another 18 relationship, she'd move out and get booted out again and 19 then she'd call and see if she could come back. 20 What she did was help Mrs. Hagen with the 21 cleaning, would drive her to doctor's appointments, that 22 kind of thing. 23 MR. GILROY: Any other questions? 24 Any other interested party in the audience have u 25 any questions for this witness? ,~\ C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 :~ .I.) ("') "'Jr-',.~ u 95 '\: 1 (Witness excused.) 2 MR. GILROY: okay. Mr. Schorpp, I think you 3 took a couple of exhibits. I just want to make sure we . " 'I " j I ' 4 don't lose track of them here. (Off the record. ) MR. GILROY: Do you have any additional testimony, Mr. Schorpp? MR. SCHORPP: Yes. I call Mr. Tim Duerr. , 5 6 7 8 9 , 10 TIMOTHY D. DUERR, called as a witness, being 11 duly sworn, was examined and testified as follows: 12 13 DIRECT EXAMINATION 14 BY MR. SCHORPP: 1 , I 15 Q. Mr. Duerr, at my request, did you investigate 16 the township zoning ordinances and determine at what point 1 17 zoning would have prohibited, South Middleton Township 18 zoning would have prohibited multifamily dwellings in this 19 location? 20 A. Yes. 21 Q. And as a result of your investigation, what did 22 you determine? 23 The first ordinance on the record is January 5th A. 24 of 1970. 25 Q. That is when it was adopted? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 97 I"'"""j 1 speak to my next witness? 2 MR. GILROY: Okay. 3 (Whereupon, a brief recess was taken.) 4 MR. GILROY: We're back on the record now. 5 Okay. Mr. Schorpp? 6 MR. SCHORPP: I have no further witnesses to 7 present at this time. I do reserve the right, of course, 8 to present other witnesses. 9 MR. GILROY: Do you move the admission of 10 Exhibits A-1 through A-7? Is that right? 11 MR. SCHORPP: That is correct. 12 MR. GILROY: And I understand there is no ...-..., ) .......-' 13 objection to the exhibits except for A-5? 14 MR. LUCAS: Yes, which I don't think I need to 15 repeat it all; I think I've said everything. 16 MR. GILROY: Why don't we just reserve a ruling 17 on that before the end of the hearing. But Exhibits A-1, 18 2, 3, 4, 6 and 7 are admitted. 19 (Appellants' Exhibits Nos. 1 - 4 and 6 and 7 were admitted in evidence.) 20 21 MR. GILROY: And you rest, Mr. Schorpp? 22 MR. SCHORPP: Yes. 23 MR. GILROY: Mr. Lucas, do you have any 24 testimony? '0 25 MR. LUCAS: Yes. Call Maxine Wetzel. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 .. 99 1 A. Just neighborly, talkIng over the back fence to 2 begin with, her comIng down to advise me because I was a 3 24-year old girl who was a city girl, and she needed 4 somebody to mother, so, therefore, she would come down and 5 tell me how to plant my flowers, how to tend to my garden, 6 how to cook this or that, how to preserve this or that, and 7 etcetera. 8 Q. Did your parents know Mrs. Hagen? 9 Yes. They visited whenever we had family A. 10 get-togethers at my house, which was Saturdays and Sundays; 11 she would be part of it. 12 ('.') "~' . 13 14 Q. Did you get to know Mrs. Hagen better in the '60s and '70s? A. We moved out in 1964, and from there until 15 through -- yes. 16 17 18 19 20 Q. Did your father come to move with you in 1971? A. Yes. Q. And was that after your mother passed away? A. Right. Q. At that time, did you get to know Mrs. Hagen 21 even better then after that? 22 23 24 u 25 A. Yes. Q. And how was that? A. Dad and her visited back and forth. He went up and played cards with her Friday nights and sometimes spend C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 100 () 1 sunday afternoons with her. We went out Friday nights. 2 With Father living in the house, that's the only time you 3 got to be alone and talk was when you went out. So he 4 would be by himself; he'd walk up to Mrs. Hagen's. 5 Q. And were you in her house, then, as of that time 6 when your father was there back and forth? Did you get in 7 her house? Were you ever in her house? 8 A. I left her take the place of my mother. After 9 she died, I was in and out, and she was in and out of our 10 house. I saw her visually every day. 11 Q. Did you do things for Mrs. Hagen in her house? 12 A. I cleaned for her; I painted for her; I sewed ("') ,.,..,- 13 for her; whatever she needed done, I did. 14 Q. There was a question about the condition or what 15 was in that house as far as the upstairs, the basement, 16 downstairs. Where did Mrs. Hagen live? 17 A. She lived in the middle floor. 18 Q. And what was on the second floor? 19 A. An apartment. 20 Q. What was in the basement? 21 A. When we first moved out there, there was, like, 22 a guest compartment that she used whenever her family came 23 to visit. 24 Q. When your father moved in with you in '71, at '---.J 25 that time, was there anything else in the basement? Was C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 104 ~ 1 that correct? 2 A. Yes. She used it also. When they had cookouts 3 outside, she'd have the hot pad that was in the enclosure 4 downstairs as extra use when she had cookouts on the 5 fireplace out in the yard. 6 Q. So she had a kitchen in the apartment in the 7 basement? 9 A. She had a refrigerator, a sink and a two-burner hot pad, table and chairs. Q. And there was also a bathroom in the basement? A. Yes. They kept that for convenience. Q. And was there a separate doorway that entered 8 10 1 1 12 (I,) '-'I 13 into the apartment that was separate from the rest of the 1 4 house? 15 A. It went into her laundry. 16 Q. And was that doorway locked, have a separate 17 lock? 18 A. Yes. She had a key to all of the apartments, 19 though, visited them frequently when nobody was there. 20 Q. And as I understand your testimony, you 21 indicated that, according to you, Mrs. Ronan never rented 22 both the second floor and the basement at the same time. 23 Is that correct? 24 A. Mrs. Ronan has, yes. u 25 Q. I'm sorry. Mrs. Hagen. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 105 ".-..., 1 A. Not that I recall. She subsidized one or the 2 other. 3 Q. But she did rent both on occasion? 4 A. On occasion. She kept the people out of the 5 upstairs because it took heat to go upstairs, and the heat 6 downstairs was supplied because the furnace was in the 7 downstairs, and that would help pay for her fuel oil during 8 the winter. 9 Q. Now, you testified that you were in frequent 10 contact with Mrs. Hagen up to 1983? 11 A. Right. 12 Q. What happened in 1983? () 13 A. Somebody put in her head that we had stolen some 17 money from her. Q. And how much money? A. I have no idea. Q. Was it a lot of money, a substantial sum? A. I imagine so, because she sent the State Police 14 15 16 18 19 around, and they questioned me for two or three hours. 20 They wanted me to take a lie detector test; my daughter 21 did, and I refused to on the grounds that this woman I 22 treated like my mother, I said I would not give her the ,':I : i 23 satisfaction of taking a lie detector test. We did not 24 speak after that but once. u 25 MR. SCHORPP: That's all the questions I have. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 i f t. ;~ lOCi t) 1 MR. GILROY: Mr. Lucas? 2 mmumc'I' I':XAM I NM' I ON 3 BY MR. LUCAS: 4 Q. Were all the neighbors questioned at that time 5 in 1983? 6 A. Terry was a neighbor at that time. I don't know 7 how many people were asked. 8 Q. Did you find out tllat Mrs. Ilagen had eventually 9 believed somebody elso was rosponsible? 10 A. She told me -- this was in '83 when she had us 11 investigated for that. She told me at Thanksgiving of 1981 12 when she had broken both elbows and fallen -- I was taking ('""") " " 13 her back and forth for therapy, and that was on a daily 14 basis. 15 She said she knew who took her money and she 16 would tell me some day whenever she felt easy enough to 17 tell who. And she assumed -- later on she threw hints to 18 me; she didn't say it diroctly, but she said it was a 19 relative of the friond, the bottom name on that list of the 20 recipients in the will thoro from Maryland, Pete -- 21 Q. You don't havo to givo the name. 22 A. Ho came up and visited in a travel trailer, and 23 she said he was the ono that took the money. 24 Q. Mr. Schorpp asked you about that downstairs. u 25 You said sho -- and this was something that was created C.P.C.Il.S @ pacourt@kns.net (717) 250-3Ci57 or (800) 863-3657 107 r1 1 after your father had moved in in '71? 2 A. No. She had the laundry down there beforehand, 3 which had an automatic front loader washer. So she did use 4 an automatic washing machine, and a dryer was there. 5 Q. But the actual putting a kitchen or bathroom 6 there wasn't done until after 171? 7 A. After my father moved in because my husband did 8 the conversion. He closed the furnace off so it was 9 separate and not part of the room. 10 Q. And initially she used that for cookouts or for 11 family? 12 A. Right. o 13 MR. LUCAS: No further questions. 14 MR. SCHORPP: No questions. 15 MR. GILROY: Anything from the board? 16 Thank you, ma'am. 17 (Witness excused.) 18 MR. LUCAS: Call Terry Rickert. 19 20 TERRY RICKERT, called as a witness, being duly 21 sworn, was examined and testified as follows: 22 23 DIRECT EXAMINATION 24 BY MR. LUCAS: u 25 Q. Your full name and address? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ..., ...-.... , 1 A. 2 Q. 108 'I'orry IlJclwrt; 7U, l'oLomhurq Iland. Mr. III cllClrL, WhOI'll do you 1\ vo in relation to 3 the proporty and to tho Wotznlll? 4 A. 5 Q. 6 property? 7 A. 8 Q. 9 property? 10 A. Ilight acrOIlH tho Htroot. So right acrmlU tho stroot from the Hagen 'I'hat's correct. And you're further up the hill from the Wetzel That's corroct. Kenny and Maxine are down the 11 hill from me. I'm diroctly across from the Hagen property, 12 the houso, itself. The entire property, IId say, is across () 13 from both of us. 14 Q. 15 A. How big is the Hagen property? Slightly less than 30 acres; a barn, a house, an 16 apartment upstairs, and I believe there's a shed out back. 17 Q. 18 A. 19 Q. 20 A. How long have you lived there? 1981. And did you know Mrs. Hagen? I knew Mrs. Hagen well the first few years. My 21 ex-wife knew her extremely well, and my children, while 22 they were still there. 23 Q. 24 u 25 You said your ex-wife knew her extremely well. A. Yos. Q. Did she go over to Mrs. Hagen's residence? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 109 .~''', 1 Mrs. Hagen called a lot, and early on she was A. 2 extremely friendly to everyone, and she would ask us to go 3 to the store and so forth. And, frankly, she was getting 4 up in years; we volunteered to get her groceries from time 5 to time and so forth. Several people were doing that. We 6 weren't the only ones, but we did try to help whenever we 7 could. 8 Q. Now, you referred to an upstairs apartment. 9 Since you've lived there and before Mrs. Hagen's death, did 10 she ever rent out that upstairs apartment? 1 1 A. She did from time to time; it was very sporadic. 12 Times went on when she lived there herself for a long, long ~ C,) . ......, ~ 13 time and no one was around at all. Generally if she rented 14 anything, it was the upstairs. Although at one time, I 15 think there was someone downstairs for a month or two that 16 was helping her with the house or something. Maybe it was 17 a relative; I don't know. 18 But generally it was just the upstairs, and 19 times went by when nothing was rented for quite some time. 20 But she was consistently keeping it to one rental unit and 21 herself living there, and that was the important thing. 22 She kept a very tight control on the renter that was there 23 at the time. 24 Q. Were you familiar or know of any problems with u 25 the sanitary sewer on-site septic system there? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 110 f) 1 A. Well, I knew there were problems. She was very 2 disciplined, and whenever someone rented from her -- I 3 heard her before when I was sitting there, she actually 4 rented one time, where she had problems with the septic 5 system and so forth, just limitations. It was very old, I 6 guess. And basically she had to -- I mean, she only rented 7 to one tenant at one time because of that. But, moreover, 8 the situation existed that she also asked them to limit 9 their use very much. 10 Now, frankly, on one occasion while she was 11 renting the upstairs, I tried to rent the downstairs from 12 her for an individual that was working for me. And I was " 13 unsuccessful just because plain and clear she would not 14 rent the downstairs while the upstairs was being rented ) i , I 15 because of the problems with the sanitary unit. 16 Now, how it's set up over there I do not know, ! 17 and I just know that that was the reason she gave me. 18 Q. Since the Ronans have been renting apartments 19 there, has there been a problem with the septic system? \' 20 A. Just from across-the-street-observation, not 21 having seen any documents or actually spoken to them about 22 it, they have replaced, I believe, the septic tank one 23 time, the upper tank, if there is two; I believe there's at 24 least that. And Mr. Ronan, himself, mentioned to me that u 25 they had applied or at least had research done to consider C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 112 t"""'\ 1 eight cars have been over there at one time. It's an 2 extreme safety problem to the hill. The way the driveway 3 is set up, the individuals have to back out on Petersburg 4 Road; they cannot pullout. 5 Q. This is a short path to the garage where the 6 cars pull right in and back right out? 7 A. 8 Q. That1s correct. And this would be just down from the hill that1s 9 just above on Petersburg Road? 10 A. 11 Q. That1s correct. From 1981 until Mrs. Hagen died, did she live 12 there continuously the entire time that she rented out one ('""') ...I..<~ 13 apartment? 14 A. She was always there, yes. I think there was a 15 trip to Germany one time where she was gone for a month or 16 two. Exactly when, I don't know. 17 Q. Did she ever leave and rent out her main floor 18 to somebody else? 19 A. 20 Q. 21 at the most? 22 23 No. She managed that with an iron fist. So she was always living there, plus one tenant, A. Yes. Q. Since the Ronans have owned the property, have 24 they lived in the house, Mr. and Mrs. Ronan? \...) 25 A. No. Not to my knowledge, they have not. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 113 n 1 Q. So it would have been separate two to three 2 tenants there? 3 4 A. That's correct. The upstairs, the main floor and the basement, guest room as everyone called, has been 5 occupied off and on. There's been a sidewalk put in that 6 was not there before, a walkway from the lower area up to 7 the doorway. It wasn1t needed before because generally 8 they parked upstairs in the driveway and walked down 9 through the area to get in, if anyone stayed as a guest or 10 something like that. 11 As far as the upstairs unit, there is a separate 12 staircase going up there. It1s definitely got an upstairs C'i:.1) eo,d apartment, no doubt about it. 13 14 Q. Mr. Rickert, you are currently a South Middleton 15 Township supervisor, correct? 16 A. That's correct, until January 3rd. 17 Q. You are appearing here in your individual 18 capacity? 19 A. That's correct. 20 Q. Not as a township supervisor? 21 A. No, I am not here as a township supervisor. 22 Q. As a property owner of the property across on 23 Petersburg Road? 24 That's correct. A. u MR. LUCAS: No further questions. 25 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 " 116 ~ 1 afraid that I was trying to steal her property or 2 something. I really don't know. 3 Q. And it would be your testimony that you didn't 4 do anything to antagonize her against you? 5 A. Not to my knowledge, no; just trying to improve 6 a farm that was extremely run down. 7 Q. Did you ever complain to Mrs. Hagen about one of 8 the persons living at the property? 9 A. No. She was very clear that she was renting out 10 the upstairs. She disciplined them extremely well. She 11 went through tenants on that upstairs on a routine basis. 12 If anyone got loud or out of hand, they were out of there. ("P'") -'1.,.... 13 She was an excellent landlord with that 14 upstairs, and I believe that's exactly why the intent is to 15 have someone that owns the property there in the building 16 so you can discipline the tenants and keep them under 17 control. 18 Q. If I were to tell you that I personally served 19 eviction notices on persons living in the basement, would 20 you say that that couldn't have happened? 21 A. Never saw them. 22 Q. Never saw them? 23 A. Never saw them, no. 24 Q. And for a long time you weren't allowed in the o 25 property? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 (\ 1 A. 117 I had no reason to go in the property. I was 2 never notified by her that I shouldn't be in the property. 3 I only went over to say hi to her, and, perhaps, she called 4 me to give me some strudel or something like that. She did 5 that on a regular basis. 6 You have no knowledge of the property prior to 7 Q. 1981? A. Q. A. Q. A. 8 9 10 11 12 1981 I moved in, that1s correct. To your knowledge, did she have a job? Mrs. Hagen? Yes. She had a job there at the house and so forth C~ 13 keeping track of the farm. As far as working outside, no. Did she have 14 Q. Did she receive farm rent? . \ , I 15 somebody renting, farming it for her? 16 A. That1s correct. I believe it's $1,800 a year , , , 17 for the rent of the acreage around the house. 18 Q. And she would have received whatever rents from 19 the people that lived there? 20 A. I was not in her business, Counselor. I can i ~, ...; Ii .~ If 21 only assume that she was charging them rent for those 22 apartments upstairs. I believe she was because she threw 23 people out when they did not pay rent, but I never actually 24 saw rent or saw her receive rent. () 25 Q. Now, you know that she received $1,800 farm C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ..-.... o &> 19 20 21 22 23 24 25 118 1 rent, but you were not in her businoss? 2 A. I believe I read that off the documentation that 3 you provided for my counselor just a few minutes ago. 4 Q. Are you indicating that you just learned that as 5 a part of the process 6 A. The $1,800 amount, that's correct. I knew she 7 was renting the farmland out, but the $1,800 figure is on 8 the document you just gave us. 9 Q. Now, when did you learn that the Ronans had 10 acquired the property? 11 A. When did I learn? 12 Q. Yes. 13 A. I was up painting my dormers. Bill Ronan, I had 14 approached Bill a couple weeks before then on what was 15 going on. I was concerned that -- I was concerned about 16 developers moving in the property; I'll be frank with you. 17 And I asked Bill how things were going. He said, don't 18 worry about it. He came back up to me in two weeks and yelled across the street, we got the property. I said, that1s great. Q. Have you complained directly to either Mr. or Mrs. Ronan about their use of the property since they acquired it? A. The only complaint I made about the property was regarding renting out three units. C,P,C',R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ! I' .1 I- '\ I. , r ! I i ( I ~ \ , ,':( , i . I :: PI \, " I ~ : ., \ , ! r' , /."."..j (:J 16 17 18 19 20 21 22 23 119 2 Q. And when did you make that complaint? A. As far as renting out the three units? Q. Yes. A. I asked Mr. Ronan to join me one day up at my property. We sat together for three and a half hours or 3 4 5 6 so, and we talked about things in general on a neighborly 7 basis. I mentioned the unit to him. I went over the 8 zoning ordinance. I went over the situation as it existed 9 and asked him if there was any way we could work something 10 out, that the unit would not be used in a contrast with 11 what it was used over the past 10 or 15 years. 12 Q. Do you recall when that conversation occurred? 13 A. When the meeting was? Mrs. Ronan dropped him 1 ,\ , I 14 right off in the driveway, and he walked in the driveway. 15 Do you recall what Saturday that was? , , , MRS. RONAN: 7th of June. \ i , I ,I I , .~ \ ,~ Ii Ii ~, , BY MR. SCHORPP: Q. I'm asking you, sir. A. I'd have to look and see. Q. You donlt recall? A. No. Q. Is it true, sir, that the Ronans -- MR. GILROY: Excuse me one minute. Can you move \, " , u 24 your chair back a little bit? 11m just a little more 25 comfortable with questioning not in each other's face. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 i; ~ 125 () 1 MR. SCHORPP: It goes to his credibility in 2 terms of what he's saying about Mrs. lIagen; vis-a-vis, what 3 his relationship was with her across the street. It's a 4 credibility question. 5 MR. GILROY: If she came and opposed his land 6 use or complained about him and we have some record of 7 that, I think it may be relevant, and if you have that 8 offer. But, otherwise, cross-examining this witness in 9 whether he was in compliance with the zoning ordinance or 10 not, what relevancy does that have? 1 1 MR. SCHORPP: It goes to the bone of this 12 gentleman and why he's here today. f"<l) t'I.~ 13 MR. GILROY: His compliance or lack thereof 14 three or four years ago goes to his motive today? 15 MR. SCHORPP: Correct. 16 MR. LUCAS: I don't see any relevancy or any -- 17 this is off the wall. 18 (Board members conferring with Solicitor Gilroy. ) 19 20 MR. GILROY: Mr. Schorpp, welre going to suggest 21 that that's not relevant testimony, so why don't you go on 22 to another issue. And if you want to make an offer, we can 23 put that on the record. 24 BY MR. SCHORPP: . U Q. When did the zoning hearing board proceedings 25 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 126 ~ 1 involved in your property occur, just so 11m clear? 2 A. You got me. I'd have to pull the records. I 3 don't know exactly when the date was. Itls been several 4 years. 5 Q. Has Mrs. Ronan had a neighborly relationship 6 with you since then? 7 A. 8 Q. 9 A. Mrs. Ronan? 11m sorry; Mrs. Hagen. I really didnlt talk to Mrs. Hagen since my wife 10 left seven and a half years ago. She, frankly, was very 11 upset with me when Vanessa left. 12 Q. Now, in your observations of this property, ,. 13 would you agree with me that there are two electric meters 14 on the property? 15 A. I believe there are. 11m trying to recall here 16 on the side. I believe there are two electric meters, yes. 17 Q. 18 A. And you were inside the property? I had been inside the property several times, 19 generally in the kitchen. A. Only when she asked me for help to go down and I I ~ \ \"; , , II 20 Q. Are you aware of the makeup of the basement of 21 the property? 22 23 maybe move something and so forth or to check something. 24 w 25 \, " Q. So the answer is yes? A. Yes. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 \-'..... .r.) 1 A. 128 No. If she asked me, I went over to the 2 kitchen, she said help me with this, and I went down the 3 steps. I mean, it's her basement. You go down the steps, 4 and itls her basement. 5 Q. 6 A. 7 Q. 8 A. 9 Q. 10 A. 11 Q. 12 A. ("", .,) 13 Q. 14 A. 15 Q. 16 Were you ever on the second floor? Yes. It has a bathroom? Yes, it does. Kitchen? Yeah. And other rooms? I believe therels one or two rooms. Separate entranceway? Stairway going up. Door with a lock on it? A. Therels a door. I assume there's a lock on it. 17 I never opened it. 18 And then the entranceway to her living quarters, Q. 19 separate doorway? 20 21 A. In the back way, yes. Q. Isnlt it true that some of Mrs. Hagen's tenants 22 park in the other garage bay from time to time? 23 24 u 25 A. I donlt know that. Q. You don't know that? A. I donlt know that. Let me be clear. There's C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 1\ '. 129 ~ 1 one door upstairs, okay, and then there's -- it's a house. 2 There's a door downstairs, a basement door; you go into the 3 door upstairs, and you go into the one room, and thatls 4 where she lived. There's stairs on the other room that 5 goes up into the second floor, and that's it. And as far 6 as -- then you go into the doors and a little garage, and 7 she pulled into the one, and usually there was a lot of 8 stuff in there. 9 Now, as far as anyone ever using it, I canlt sit 10 here and testify that no one ever used that or that she 11 didnlt because I really don't know. 12 Q. All right. But you lived across the street (", '......' 13 since 1981 and you really don't know. Is that what your 14 testimony is? 15 A. I'm saying I lived across from 1981; I don't 16 know if a car was ever in her garage other than her own. I 17 canlt testify to that accurately. 18 Q. So I guess that's possible, but you donlt know? 19 A. Yup. Anything is possible, Counselor. 20 Q. And you've already testified that youlve seen 21 cars parked in other areas on the property other than the 22 driveway. Is that correct? 23 A. At what period of time? 24 Q. Any period of time. u 25 A. Just over the last 30 days, 60 days, yes, sure. C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 O... ....' . l :0;1'4.' () 18 19 130 1 Q. And over the period of time since you've lived 2 there, you've seen that? 3 A. Generally the cars were always in the upper 4 driveway. 5 6 Q. But you've seen cars in the lower area? A. Yes. Fellows used to come over and help do her 7 grass and things like that. Kenny Wetzel used to come up 8 and take care of her lawn and so forth. He would drive 9 across, or he would just drive the mower across. 10 Q. SO you know everybody who ever parked a car down 11 there. Is that what you're testifying? 12 A. Absolutely not. How would I possibly know 13 everyone that ever parked a car there? Why would you ask 14 me that? 15 Q. Because -_ Mr. GILROY: asking the questions. lawyer can voice that. THE WITNESS: I apologize, but I really don't 16 Well, Mr. Rickert, Mr. Schorpp is 17 And if there's an objection, your 20 know everyone that ever parked there. If thatls a 21 legitimate question, I apologize. I do not know everyone 22 that ever parked a car there, no. 23 24 25 BY MR. SCHORPP: Q. ;1 I, " And you don't know everyone that ever rented from her either, do you? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 t) ('"'' ,~"J u 1 2 3 133 heat her unit. 4 me that. 5 6 7 8 9 10 11 Q. And she told you this? A. She told me that, yes, she did absolutely tell MR. SCHORPP: Tha t's all I have. MR. GILROY: Mr. Lucas, any questions? MR. LUCAS: No questions. MR. GILROY: Any questions from the board? Okay. Next witness. MR. LUCAS: Call Tim Duerr for one question. MR. GILROY: Okay. Mr. Duerr, you're still 12 under oath. Go ahead. 13 DIRECT EXAMINATION 14 BY MR. LUCAS: 15 Q. Mr. Duerr, do you know when the township 16 required the mandatory recycling or trash pickup, 17 approximately what year? 18 19 20 21 22 A. 1993, April. MR. LUCAS: Thatls all. MR. GILROY: Mr. Schorpp? MR. SCHORPP: I have no questions of Mr. Duerr. MR. LUCAS: We have nothing further except we 23 would offer the exhibits R-1, 2 and 3. 24 25 MR. GILROY: Any objections, Mr. Schorpp? MR. SCHORPP: I need to refresh my memory of C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 .~ 135 1 Mrs. Hagenls on a daily basis, I was usually there before 2 she was out of bed, Mrs. Wetzel. I frequently stopped on 3 my way to work to make sure that she was up and about. 4 Q. Any other particulars that you -- 5 A. Well, when I told Mrs. Wetzel that I had gone no 6 further than the kitchen, we were talking about what the 7 contents of the house were. And I did not go through her 8 house before her death to decide what was in it. When I 9 went in to take her groceries, take her prescriptions, 10 whatever, I went into the kitchen. 11 12 c'j~') 13 '1:0.'" 14 15 16 17 18 u Q. Now, it's your testimony that Mrs. Hagen did, in fact, rent to more than one tenant at the same time? A. Right. Q. On a continuous basis? A. On a continuous basis. Q. And you were physically in the premises when that occurred? A. I was. Not only that, every evening for dinner 19 we had a discussion of Mrs. Hagen's tenants and her aches 20 and pains because she commiserated with my mother on a 21 daily basis. 22 And when she did that, she was discussing more Q. 23 than one tenant at the same time? 24 Yes, and what they did and didnlt do. A. 25 Q. When she had other tenants there, did they have C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 138 ,...., 1 through her husband. MR. GILROY: Well, it's also not relevant, 'I, 2 3 Mr. Schorpp. I mean, even assuming for purposes of 4 argument that Mr. Rickert has a motive that he didnlt like . " .~ I 5 to see any further development, the issue before the board 6 this evening is not that matter. 7 MR. SCHORPP: I agree; however, it does go to 8 his credibility. 9 MR. GILROY: I don't know if it would go to his 12 thatls a multiple housing development or apartment building 10 credibility, but this is not an issue of them putting a 11 development in there; this is an issue of whether or not () 13 or not. 14 BY MR. SCHORPP: 15 Q. Prior to the time that he was made aware of this \ , , 16 potential second house, had he complained to you or your J 17 husband about using the place with the septic in it? 18 A. He did not. 19 Q. Do you have any other disagreements with his 20 testimony? 21 MR. GILROY: I think we can stipulate she W i 22 probably disagrees with a lot. 23 THE WITNESS: Thatls not entirely true. 24 MR. SCHORPP: That's all I have. .. ! I u 25 MR. GILROY: Okay. Mr. Lucas? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 139 ('. 1 CROSS-EXAMINATION 2 BY MR. LUCAS: 3 Q. Did I understand you just to say in response to 4 your counsel's question that you did not go through her 5 house; you only went through the kitchen? 6 A. This was when she was ill, I went in through the 12 MR. GILROY: Mr. Schorpp, any further testimony? 7 kitchen to take her groceries or whatever we could pick up 8 for her. I did not go through the house to inventory what 9 was there. That does not mean that I was not in the house 10 at other times. 11 MR. LUCAS: No further questions. (.~ 13 MR. SCHORPP: No. 14 MR. GILROY: Do you have any additional 15 testimony? 16 MR. LUCAS: No. l , 17 MR. GILROY: You may step down, ma'am. 18 (Witness excused.) 19 MR. LUCAS: Nothing further. 20 MR. GILROY: Okay. Anybody else have anything 22 okay. We have the exhibits. We kept out that ! ,:,; U 21 else they want to put on the record in this case? 23 one exhibit. Is that right? I don't think we formally 24 admitted Township's Exhibits 1 and 2. Anybody have any I i I u 25 objection on those? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 ,'~ o 140 ,~ MR. SCHORPP: No. 2 MR. LUCAS: No. 3 MR. GILROY: Those two exhibits are admitted. 4 (Township's Exhibits Nos. 1 and 2 were admitted in evidence.) 5 6 MR. SCHORPP: I do have a hearing memorandum I 7 would like to submit to the board. 8 MR. GILROY: You might want to hold it. This 9 board is going to meet again on January 6th. That's a 10 Tuesday. It will not be for purposes of taking any 11 additional testimony, but hopefully be perfect for purposes (""") ";", 12 of rendering a decision in this particular case. And I'm 13 sure the board would like to get a memorandum, but I'd 14 prefer they both be filed at once, unless, Mr. Schorpp, you 15 want to submit yours. 16 MR. LUCAS: On January 6th the board is just 17 going to vote? 18 MR. GILROY: Just going to vote. TheY'll take 19 official action. There will be no further testimony. 20 MR. LUCAS: No need for argument at that time? 21 MR. GILROY: We're going to ask you to argue in 22 your memorandum. I'd suggest for purposes of the 23 memorandum that some of the issues that I see right off the 24 bat are who has the burden of proof in this particular case 25 to prove a nonconforming based upon the procedural C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 141 r'1 1 situation of an enforcement notice being sent by the 2 township. 3 The second issue is from a zoning standpoint, is 4 this a different use if itls an owner-occupied property 5 with a rental unit as compared to nonowner occupied. 6 MR. SCHORPP: We will agree that we have no 7 rights under the conditional use for an owner-occupied with 8 an accessory apartment. 9 MR. LUCAS: I don't think that's the issue. I 10 think the issue is the difference between an owner 11 occupying a single family house and having one apartment 12 and a three-unit apartment building. I think that's a big o '-.," 13 difference here, and I think that is a key issue in this 14 case. 15 I don't think the issue is conditional use. I 16 think the issue is the differences in the -- 17 MR. GILROY: Well, can we all agree that this is 18 either a single family residence or this is a two-unit 19 residential building or this is a three-unit residential 20 building? Those are the three options. 21 MR. LUCAS: The second may be a -- yeah. The 22 second may be under the single family detached dwelling 23 with an accessory apartment. 24 MR. GILROY: They're making an issue out of it, u 25 and you're saying itls not? C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 143 ~ 1 So there's four options; there's a single family residence, 2 there's an owner-occupied residential dwelling with an 3 accessory apartment, there's a two-residential unit 4 bUilding or therels a three-unit residential unit bUilding. 5 MR. LUCAS: I think it's a key issue. 6 MR. GILROY: I've raised it just so 7 Mr. ,Schorpp is saying he's not advancing as an issue, but 8 you see that Mr. Lucas is suggesting that they will argue 9 that thatls a determination the board should make as at 10 least one of their options. So we need to address that. 11 And certainly the issue of abandonment, if there c'"'] 12 is a determination that a nonconforming use is in existence 13 and whether use of that is abandonment, and then I'll look 14 forward to your eloquence on this issue, and that is if you 15 have an apartment upstairs and one downstairs and you use 16 one at one time and one at the other, are you continuing 17 use on that. 18 Because there's been testimony on this issue, 19 and I don't know what it's going to result in. But in case 20 the board finds that as a fact, that they did not use two 21 at once but they kept separate units but they just weren't 22 in use, does that mean it was a two-unit place or a 23 three-unit place but only two used at once, and any other u 24 issues that counsel would like to advance. 25 MR. LUCAS: Do we have to argue over Exhibit C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 (; 144 t'i 1 A-5? I think there's no basis that that exhibit should 2 come in. 3 MR. GILROY: I think we ruled to keep it out. 4 MR. LUCAS: You held the ruling. 5 MR. GILROY: Okay. I'm going to suggest we keep 6 it out. What's the boardls ruling on it? 7 Okay. Exhibit 5 is out. Mr. Schorpp, we'll 8 hand that back to you. 9 MR. GILROY: Gentlemen, welre asking you to 10 present these memorandums simultaneously. 1 1 MR. LUCAS: Is there a question about, will all <:;. 12 three members be on the board in January? We have a term 13 expiring. I just thought of that. 14 MR. Rickert: My question was -- I overheard you 15 talking about a vacation schedule up here __ will all three 16 members be here at the i , ' I' , I I I I I , ~ '\ ,':( i I :1 tl " '. 'I I: , 17 MR. GILROY: They'll be here on the 6th. 18 MR. Rickert: Fine. That's all I needed to 19 know. 20 MR. GILROY: Gentlemen, can you have a 21 memorandum to me by the 19th? 22 MR. SCHORPP: The 19th of December? 23 MR. GILROY: Yes. 24 MR. SCHORPP: That would be a little difficult 25 for me. I have a memorandum on most of those issues. I do C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 1... 145 1 not have one on all of them. I came prepared to give it 2 this evening. I told you at the first hearing that I had 3 one. Mr. Lucas has had plenty of time to prepare one. 4 MR. GILROY: I assume your memorandum doesn't 5 address all of these issues. 6 MR. SCHORPP: No, it does not. 7 MR. GILROY: Well, the problem is, we need to 8 have the benefit of your memorandums and then the zoning 9 hearing board needs to meet in executive session and 10 deliberate all before the 6th. So when can you have it to 11 me, Mr. Schorpp? 12 And, Mr. Lucas, when do you think you can have a ("") >-;,~t 13 14 15 u memorandum? 16 MR. LUCAS: I can have it to you on the 19th, if you want it. MR. GILROY: How about the 23rd? MR. SCHORPP: That is a 'lIednesday? MR. GILROY: That's the Tuesday before. Will that be satisfactory? 17 18 19 20 Okay. Memorandums can be filed with my office 21 on the 23rd and sufficient copies to send to the zoning 22 hearing board members. I will circulate those to the 23 zoning hearing board members, and we'll try to meet the 24 following week in an executive session. And then we're 25 going to advertise a meeting for January 6th. And for C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 146 (\ 1 those folks who are here interested in this particular 2 case, there will be no additional testimony; the board will 3 merely hopefully act at that particular meeting. 4 Mr. Schorpp and Mr. Lucas, thank you for your 5 courtesies and courtesies of your clients during this 6 hearing. 7 MR. SCHORPP: I'd like to thank the board for 8 their cooperation at the last hearing. 9 MR. GILROY: Folks, we still have items 2 and 3. 10 We're going to take a short recess to pick up the exhibits 11 and then move along. 12 (Whereupon, the preceding portion of the hearing was concluded at 7:10 p.m.) (~ 13 14 15 1 . \ , I 16 22 l ( I l' ~ i~ , \ ; ,':( , , 17 18 19 20 21 ~ 25 it ,,( ", \1". 'i i \ , 23 24 C.P.C.R.S @ pacourt@kns.net (717) 258-3657 or (800) 863-3657 TERRY T. RICKERT, Appellant IN THE COURT OF COMMON PLEAS CUMllERLAND COUNTY, PENNSYLVANIA No. -1998- to7~) t!q,k/~':t!.('1" v, SOUTH MIDDLETON TOWNSHIP ZONING HEARING BOARD, Appellee LAND USE APPEAL NOTICE OF LAN!) USE APPEAL AND NOW, comes Appellant, Terry T. Rickert, by and through his allorneys, Eckert Seamans Cherin & Melloll, LLC, appeals the Decision of the South Middleton Township Zoning Hearing Board dated January 5. 1998, pursuant to Article X-A of the Pennsylvania Municipalities Planning Code, 53 P.S. ~11001-A, ~., and in support thereof, states as follows: 1. Appellant is Terry T, Rickert ("Rickert"), an adult individual residing at 726 Petersburg Road, South Middletan Township, Cumberland County, Pennsylvania, 2. The South Middleton Township Zoning Hearing Board ("Zoning Hearing Board") is a duly organized and constituted zoning hearing board created by the South Middleton Township Board of Supervisors, 520 Park Drive, Boiling Springs, Pennsylvania. 3. On or about July 21, 1997. the Zoning Officer for South Middleton Township (the "Township") issued an enforcement notice to William Ronan ("Ronan") relating to property located at 729 Petersburg Road, South Middleton Township. Cumberland County, Pennsylvania (the "Subject Property"), A copy of the enforcement notice is attached hereto as Exhibit" A" and incorporated herein by reference, 4. The enforcement notice notified Ronan that there were three apartments being rented at the Subject Property and that such use was in violation of the South Middleton Township Zoning Ordinance. '~ 5. The Subject Property is locuted in the Agricultural ("A") Zoning District. 6. The South Middlcton Township Zoning Ordinance ("Zoning Ordinance") permits 'I single-family detached dweilings in the A District. However, only one apartment is permitted as an .' accessory use to a single-family detached dwclling and that one accessory apartment use is only permitted so long as the principal dwelling is also occupied by the owner of the dweiling, 7. , I I I Ronan acquired the Subject Property in 1994 and the Subject Property is not owner- occupied as required by the Zoning Ordinance. 8. On or about August II. 1997, William R. Ronan and Geraldine L. Ronan, owners of the Subject Property, filed an appeal from the Zoning Officer's determination to the Zoning Hearing Board (the "Ronan Appeal"). 9. Hearings were conducted by the Zoning Hearing Board on November 3, 1997 and December 9, 1997. 10. Rickert, who lives directly across the street from the Subject Property and is an affected party, appeared at the hearings with counsel, objected to the Ronan Appeal, and presented 'I . I , I evidence and legal argument in support of the Zoning Officer's enforcement notice. 11. I , , The Ronan Appeal to the Zoning Hearing Board contended that the Subject Property is presently used as a multi-family dwelling with three apartments and that Ronan had a vested right to rent three apartments on the Subject Property as a non-conforming use. 12, On January 5, 1998, the South Middleton Township Zoning Hearing Board rendered its decision sustaining in part and denying in part the appeal of William R. Ronan and Gerald L. Ronan (the "Decision"). A copy of the Decision is attached hereto as Exhibit "B" and incorporated herein by reference. 2 13. The Decision sustained the Ronan Appeal, In part, by finding that Ronan could rent two apartments on the Subjectl'roperty even though the dwelling Is not owner-occupied because the use was non-conforming and that the non-conforming use had nOl been lIbandoned, 14, The Decision denied the Ronan Appelll. In pllrt, by finding that Ronan had only established non-conforming use status for two lIpartments rather than three aplIrtments as contended by Ronan. IS. To the extent the Decision sustained Ronan's Appeal, in part, the Decision of the Zoning Hearing Board was erroneous, arbitrary. capricious, constituted an abuse of discretion, and was otherwise contrary to law, in that: (a) Ronan failed to establish the existence of a non-conforming apartment use prior to the adoption of the South Middleton Township Zoning Ordinance in 1970; (h) Any apartment use for the Subject Property prior to the adoption of the Zoning Ordinance in 1970 was only sporadic or intermittent which Is insufficient, as a matter of law and fact, to support a finding of non-conforming use StlltUS; (c) In the alternative, even if the evidence conclusively supported the establishment of a non-conforming use for one accessory apartment at the Subject Property, the accessory apartment use was abandoned and could not be reestablished; (d) In the alternative, even if the evidence conclusively supported the establishment of a non-conforming use for one accessory apartment at the Subject Property, such use was terminated In 1994. The zoning regulations only permit an accesso"'J apartment where the owner of the properly occupies the principal dwelling and the principal dwelling on the Subject Property hlls not been owner-occupied since 1994;ÿ 3 '. . ~outfJ ~ibbldon ~otnQbip 520 Park Drive, Boiling Springs, PA 17007 PHONE: (717) 258-5324 FAX: (717) 258-3577 Certified # P 180 163357 Mr. William Ronan 759 Petersburg Road Carlisle, Pa 17013 Re: 729 Petersburg Road Dear Mr. Ronan: As the Zoning Officer of South Middleton Township, I have determined that you are in violation of the following provisions of the Zoning Ordinance of 1989, as amended, for the reasons which I have specified, The previous owner had occasionally rented one apartment while living there herself. However, since that time, the dwelling located at 729 Petersburg Road was vacated for a period in excess of a year. According to Section 1901d, if a non-conforming use is discontinued for a period of a year or more, the use loses its non-conforming status as thus cannot be reinstated, At present, conditions suggest that three apartments are being rented, none of which is occupied by the owner of the dwelling. Before an accessory apartment use can take place, it must receive conditional use approval from the Board of SupelVisors and subject to the following criteria found in Section 602.2: 1. The livable floor area of the accessory apartment shall not exceed seven-hundred twenty (720) square feet. 2. Only one accessory apartment may be permitted within a single-family detached dwelling. 3. An accessory apartment may only be permitted and may only continue in use as long as the principal dwelling is occupied by the owner of said dwelling. 4. The lot area for the principal dwelling shall meet the minimum lot area requirement for the applicable district where located, 5. The exterior architectural character of the principal dwelling shall not be altered in a manner which departs from the primary feature of the building as a single-family detached dwelling unit. "''''. .. ""'.""',1'." "'", 0'" o '''---.--. IN RBI SOUTH MIDDLETON '1X>>INSIlIP ZONING HEARING BOARD 520 PARK DRIVl!l BOILING SPRINGS, PENNS~LVANIA 3.7007-9536 DECISION OF ZONING HEARING BOARD WILLI/lH R. RONAN AND GERllLDINE L. RONAN 97 - 32 DOCKE'l' NO.: DA'l'B OF APPLICA'l'IONt LOCATION OF PROPERTY: AUGUST ll, 1997 729 PETERSBURG ROAD, CARLISLE, P~, APPSAL FROM DETERMINATION OF, ZONING OFFICBR NOVBMBER 3, 1. 997 AND DECEMBER 9, 1997 JANUARY 5, 1998 REQUESTED RELIEF: DATE OF HEARINGS: DATB OF DBCISION: SOARD MEMBBRS IN A'l''l'BNDANCE: PAUL HEISHMAN, LARRY BRE/lH, IVO V. OTTO, JR. PROPER NOnCE OF THE ABOVE HEARINGS WAS GIVEN B~ ADVER'l'ISING IN THE SENTINEL, CARLISLE, PENNSYLVANIA ONCE A WEEK FOR TWO WEEKS PRIOR TO THE HEARINGS AS APPEARS FROM PROOF OF PUBLICATION. ADDITIONALLY, NonCE OF THE HEARINGS AND THE APPLICATION WAS SENT TO ALL ADJOINING PROPERTY OWNERS, POS'l'ED ON THE PROPBRTr IN QUESTION AND POS'l'ED IN THE SOUTH MIDDLETON TOWNSHIP OFFICE. I , ! ! I. PROCElDVRAL HISTORY This case Comes before the South Middleton Township Zoning Hearing Board ("Board") on an appeal from a detennination of the zoning Officer of South Middleton Township ("Township") dated July 21., 1.997. The Zonin!1 Officer of the Township issued an enforcement notice to Mr. William Ronan dated July 21, 1997 (TownShip Exhibit-l) which pertained to property at 729 Petersburg Road(Subject Property). In sununary, the enforcement notice suggested that there were three (3) apartments being rented at the subject property, none of which were occupied by the owner of the property, and that such use was in violation of the Township [Joning Ordinance. The owner:r of 729 Petersburg Road, William R. Ronan and Geraldine L. Ronan, filed On August 11, 1997 a timely appeal of the Zoning Officer's , 1. determlnation to the Doard. I1oaringl1 woro conductod baloru tllO Baard on November 3, 1997 and December 9, 1997. At theBe hearingD, the RonanG were represented by legal counsol alld had an opportunity to prellent botll verbal and written evldence. The Townsl1ip appeared before tho Board in the person of tile Zoning/Code Enforcemont Officer, Mr. Time thy D. Duerr. Mr. Terry nickert and Mr. and Mrs. Kenneth Wetzel, neighbers te the Dubject property, appearod at the hearings with the benefit ef counsel ~nd objected to the appeal and advanced the affirmation of the enforcement notice. Counsel tor the Renans and ceunsel for the objectors have filed briefs which have been reviewed by the Beard. The Board conducted an Bxecutive Session on December 29, 1997 for purposes ef deliberatians in oennectian with this case.! II. DISCUSSION The praperty at 729 Petersburg Read ("Subject property") is located within an Agricultural Zoning District pursuant to the Township Zaning Ordinance. The enforcement netice issued by the Tawnship/Zening Officer (Tawnship Exhibit-I) suggested that the subject property had been awner occupied and occasionally had alsa a ane-apartment rental unit. The notice suggested that the rental use had been discontinued for a period ef a year or more and, thereby, lost its non-conforming status and that any further apartment renting at the subject property would be illegal under the South Middleton Tawnship Zaning Ordinance. At issue is whether the subject preperty constituted a nan- conforming use under the Zoning Ordinance. If such non-cenforming use is establiShed, the second issue would be the nature of the nan-confarming use as to whether the subject preperty was a three- unit apartment building or a two-unit building. A further issue would be whether the non-conforming status was an apartment building status or an owner-occupied dwelling that had an accessary apartment. The final issue is whether any non-conforming status had been abandoned. Mrs. Geraldine Ronan testified on behalf of the applicants. She indicated the subject property was originally ewned by Mr,. and Mrs. Arneld Hagen, who had owned the preperty since the early 1950's. Mr. Hagen died in 1962 and Mrs. Hagen died in September of 1994. Mrs. Ronan and her husband were executors of the Hagen estate. She testified that she was quite familiar with the Hagens' paperwork and the Hagens themselves. She would take Mrs. Hagen to the haspital two times a week and she was in periodic contact with Mrs. Hagen at other times. The Ronans had lived in the vicinity of the subject praperty since 1944. I All Dl<ccutlve oeoolon is authorized for quani-judicial deliberations purnuant to 65 P.B. 5278(a)(5). 2 ,I Mrs. Ronan l1uggostfld tllat tho subjoot proporty consistod of a first floor dwelling unit which was praviously occuplad by Hrs. lIagon, II aacond floor apartment and a hasomont oiiicionoy apartmont. Documentary evidonae presented included relltal receipt books from Mrs. Hagen's records sllowing rent recelpts as far as back IJS 1958 (SOD Exhibits A-I and n-2). The Ronans also produced advartising bills relating to the Bubject property (Bxhibit n-3). ThOBe bills refer to a "furnished effioienoy", an "effioiency one-adult" and a "second floor apartment" as the type of apartments being rented. These bills are of misoellaneous dates starting in 1978 and going through 1989. Mrs. Ronan suggested that the effioienoy apartment was the apartment on the basement level and that the other apartment was a second floor apartment that Mrs. Hagen maintained. Mrs. Ronan indicated that she and her husband were appointed executors of the Hagen estate in Ootober of 1994, a publio sale was held in September of 1995, that she and her husband were the benefioiaries of the estate and reoeived title to the property in Ootober of 1995 during the administration of the estate. Mrs. Ronan also presented evidence from the electrio oompany (Exhibit A-4) which she offered to verify that there were separate electric meters for each dwelling unit. The dooumentation verifies that the seoond floor apartment had a separate electric meter oonneoted in 1960 and that Mrs. Ronan had a meter conneoted for the blJsement unit in 1996. Prior to 1996, Mrs. Hagen had the basement and first floor area on the same eleotrical unit. Mrs. Ronan testified that previously the basement area had a separate eleotric meter but she did not produce any documentation in support of that claim. 1\ , ; , , , t , The outside of the subject property has an appearance of a single- family dwelling. Mrs. Ronan suggested that there were at least three (3) mailboxes at the property and multiple eleotric meters. She indicated that there are three (3) separate physioal entrances to the three units in the interior of the premises with separate keys and looks. In addition to a two-oar garage, there is a large driveway that would acoommodate four (4) cars and another separate driveway area. Eaoh unit has its own separate bathroom and kitchen area. It was established during Mrs. Ronan's testimony that the basement unit was quite often used only by a homeless woman with her children and that no rent was paid for that use. It was also established by other testimony that the ba6ement area of the struoture was used by the Hagens for picnios and other uses in oonjunotion with the Hagen's use ot the dwelling unit on the first floor level. Maxine Wetzel of 740 Petersburg Road testified and indicated that she has resided near the subjeot property for approximately thirty- four (34) years. She testified that in 1971 there was no apartment 3 unit in the basement of the subjoot property. However, she did aoknowledge that thoro was an apartmont used on the seoond floor and oven acknowledged that after 1971 there was a periodio renting of tho basement area aD a soparate unit. Sho had a fISHing out with Hrs. llafJen in 1983 and had limited contaot w.lth IIf1r s:l.noe that time. Hr. 'ferry R:l.okert testified that he has lived aoross from the subjeot property since 1981. Hr. Riokert suggested that Hrs. Hagen would rent tIle upstairs apartment at certain tJmes ISnd the downstairs apartment at other times but that the traditional use was to only have one rental unit at a time. He sugfJested that he only reoalls two (2) mailboxes at tho subjeot property. Testimony established that the first Zoning Ordinanoe within the 'fownship was enaoted in 1969 and beoame effective in January 1970 (Exhibit A-7). III, LEGAL ANALYSIS Pennsylvania law imposes the burden upon the landowner to establish a non-oonforming use by presenting objeotive evidenoe demonstrating that the property was devoted to the alleged use at the time of the enaotment of the Zoning Ordinanoe. Appeal of Lester M. PranCle. Inc., 166 Pa. Commw. 626, 647 A.2d 279 (1994). On the issue of abandonment, the burden of proving abandonment of a non-conforming use is upon the party asserting the abandonment and such proof must be by overt acts, or failure to act, demonstratlnfJ actual abandonment. Appeal oE Lester M. Pranqe, ~, supra. The Township in its enforcement notice cites S1901.1.C of the Zoning Ordinance which provides that a non-conforming Use cannot be re-established if it discontinued for any reason for a period of twelve (12) months or more. Such a timeframe in a Zoning Ordinance is not absolute and creates only a presumption of intent to abandon. ADPeal oE Lester M. PranCle, ~, supra. IV. APPLICATION OF LAW TO 'fEE FACTS It is clear that there has been apartment use at the subject property prior to the enactment of the original Zoning Ordinance in 1970. :Phe Ronans have met their burden in connection with that issue. What remains unclear is whether the basement unit was being rented as a separate unit in 1970 at the time of the adoption of the Ordinance. The documentary evidence presented by the Ronans (Exhibits A-I and A-2), does not verify two (2) different apartment units but, rather, appears to represent rental receipts for only o~e (1) apartment use. It ia clear from the testimony of all w~tnesses and from documentary evidence (Exhibit A-3) that the basement unit was rented as a separate unit after 1970. However, 4 thoro in conflioting tostimony botwoon tho wi tnouGos liB to the oxiutonco of a separate basemont unit apartmont prior to tho onaotment of the 1970 Zoning Ordinanco. The lack of any reforonco indicating two (2) separate apartnront units in the rontal recoiptn pro-1970 (Exhibits A-I and A-2)along with tho laok at any documentation from tho utility company (Exhibit A-4) suggesting a pro-1970 neparate olectrical meter for the basement property weighs a!1ainst the landowners in their assortion that there Was a separate basement dwelling unit at the Gubjoct property pre-1970.' On the abandonment issue, the Ronans adequately addressed the inconsiutency between correspondence from their attorney (Exhibit T-2) suggesting that the subject property was vacant for ovor two years and the actual Use of the subject property. Mrs. Hagon's illness along with her subsequent death clearly caused a break in the continuity of acqui.ring a tenant at the property. The record is void of any evidence suggesting that there were overt 'acts or failureI!' to act by Mrs. Ha!1en or by the ~onans that would demonstrate an abandonment of any apartment use at the subject property. Even assuming the Bubject property may have laid vacant for more than twelve (12) months, the lack of any I!'ettled purpose by the landowners to abandon the multiple family use at the subject property is clear from the record. The objectors in thei.r brief attempt to suggest that any apartment Use at the subject property must be conduoted in conjunction with "owner oocupied use". The current Zoning Ordinance within the Township authori~es "accessory apartments" within the agri.oultural district by conditional use with an aocessory apartment defined as a secondary dwelling unit contained within an owner ocoupied single-family detached dwelling (Township Zoning Ordinance 5602.2) . However, at issue is what was the use of the property prior to enactment of the Zoning Ordi.nance. It is clear that Mr. and Mrs. Hagen occupied the subject property prior to the enactment of the January 1970 Zoning Ordinance and it is also clear that they had an apartment on the I!'econd floor of the subject property at the same time. In essence, there were two (2) separate dwelling units within the one (1) struoture. The fact that one (1) of the dwelling units was owner occupied does not suggest a different type of use than a non-owner ocoupied two-dwelling unit structure. Furthermore, the 1970 Zoning Ordinance allowed, by special exception in agricultural districts, a use termed "converted apartments" (See 5402 of 1970 Zoning Ordinance). Converted apartments were defined under the 1970 Zoning Ordinance as "a mUlti-family dwelling constructed by converting an existing building into apartments for more than one 2 The Ronan" suggested in testimony that there previously was an electrical meter for the basement unit but that such unit was removed. Even if it waD proven that 1:he basement unit did have a oeparate metor, tho logic behind the removal of that olectrical meter would Duggest an abandonment of any separate apartment U"e of the baDement unit. 5 fllmily, without Dubstllntially altering tllo extorior of tIle bUilding." (Soe defjnitional aoction of 1970 Zoning Ordinance at No. 10). Tho "convertad apartmont" IIS6, which wau allowod in 1970, did not include any limitlltion or routriction tllat would morit tho "owner ocoupied" tag to be applied to tho use. Accordingly, thoro is no legal or rational bRsiu to imponD an "ownor oooup.:Lod" restriction upon a two-dwalling uni t U:J11 lit tllo Gubjeot proparty which pro-dated the 1970 zoning Ordinanco. I- " /i " , J. V. FINDINGS OF FACTS 'l'HB BOARD HEREBY MAKES 'I'HE FOLLOWING FINDINGS OF FACTS: 1 , prior to the adopting of a zoning Ordinance in South Middleton Township, there existed a use at the property at 729 Petersburg ROlld of II mUlti-family dwelllng consisting of two (2) separate dwelling units. , 2 The use of a mUlt.:L-family two (2) separate dwelling units at the subject property has continued from prior to enactment of zoning in South M~ddleton Township until the present time. J VI. CONCLUSIONS OF LAW THE :SOARD HEREBY MAKES THE FOLLOWING CONCLUSIONS OF LAW: '1 . ,\ , , 1 The applicants, William R. Ronan and Geraldine L. Ronan, have met their burden of proof and have demonstrated that a non-conforming use existed at property 729 Petersburg Road, Carlisle, PA, prior to enactment of the January 1970 South Middleton Township Zoning Ordinance, which use was a multi-family two-dwelling structure. , , , 2 The applicants have failed to meet their burden by way of objective evidence that, as oi the enaotment of zoning in South Middleton Township in January 1970, there existed a third apartment unit on the basement floor of the subject property. ' 3 ':( 1 The Township and the objectors have failed to meet their burden of proof in sho.....ing any overt acts or failure to act that would demonstl:ate an abandonment of the multi-f;,u/lily Use at the subject 6 f"~ . , property sinco January 1970. VII. DECISION It is the deoision of tho South Middleton Township Honin9 Roaring Board that the appeal of William R. Ronan and Geraldine L. Ronan from the July 21, 1997 enforoement notioe issued by South Middleton Township is sustained in part and denied in part. The appeal is Dustained in tho sonso that it is deter.mined that there was no abandonment of a non-oonforming use at property at 729 Peterllburg Road, Carlisle, PA, which use consisted of a multi- family dwelling unit at the subjeot property encompassing two (2) separate dwelling units. The appeal is denied in the sense that it advanced a suggestion that there existed three (3) separate dwelling units at the subject property whioh had all obtained non-oonforming use status. It is determined that two (2) dwelling Units at the subjeot property may continue as a legal non-oonformin'J use, with these units bein'J the first floor dwelling unit and the second floor dwelling unit. The basement area of the subjeot pro~erey has no le'Jal status to be used as a separate dwelling unit. ~/J(r;g-- _ DATE ~D ~~~ . "'B, SECRE:AnY SOUTH MIDDLETON TOWNSHIP ZONING HEARING BOARD ANY PERSON AGGRIEVED BY THE DECISION OF THE ZONING HEARING BOARD HAY APPEAL TO THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. THE APPEAL MUST BE FILED WITHIN 30 DAYS FROM THE DATE OF THIS DECISION. · The Ronans a~vance~ 1n their brief a request that the Board consi~er addressing a thi~d llputrnent unit as an expansion of the existing two (2) dWQ11ing unit non-conforming use purauant to 51904 Townahip Zoning ordinance, such an iasue ia not properly before the aoar~ on a procedural haais. Furthermore. the critB~ia for the granting of a special exception for expansion of a non-conforming Uue under 51904 include a number of factorD which wore not "ddreDDed in the toatilnony at the hearing of thlc cace. Accordingly, the BO(lrd docs not addrosG in thin c.!ccision the Ji,crit, if \lnj', af ROlHm'c roquoot to o>:puuci n non-Conforming uOe p~rt~~nt to S190f., 7 " CEltTIFICATE OF MAILING "I. I hereby certify thnt on this If - day of February, 1998, and In accordance with Section 1003-ACc) of the Pennsylvania Municipalities Planning Code, 53 P,S. ~IIOO3-A(c), a true and correct copy of the foregoing Notice of Land Use Appeal was mailed by first class mall to the following persons: WIlliam R. Ronan Geraldine L. Ronan 729 Petersburg Road, Carlisle, PA 17013 Edward L. Schoorp, Esq, 127 W. High Street Carlisle, PA 17013 a~ John R. achur, Esq, Ally. 1.0. 58141 149896,1 CEUTIFlCATE OF MAILING ..t I hereby certify that on this If - day of February, 1998, and In accordance with Section 10OJ-A(c) of the Pennsylvania Municipalities Planning Code, 53 P.S. ~ 11003-A(c), a true and correct copy of the foregoing Notice of Land Use Appeal was mailed by first class mall to the following persons: William R. Ronan Geraldine L, Ronan 729 Petersburg Road, Carllsle,PA 17013 Edward L. Schoorp, Esq, 127 W. High Street Carlisle, PA 17013 a~ John R. achur, Esq, Ally. J.D, 58141 149896.1 Ii 1 I : & , . -gompIttlll;mt 111KVot 2 rot Idcfillonlll HMe... .~It.It.". 3, "I, and 4b. 'Prtnt your nwne and add,.., on th, "....m or IhI, form 10 IhIt w. Cln retum tN, can! 10 you. -MIlCh IhII toRn 10 thl front of the mallp1eoe, or on the bade If Iplct dot, not: .=!RItlIm R_pt Roq_'on lho maJlploco boIow tho .rtldo nLrOOo" -The Rltwn Receipt wlllhow to MMmllhIlltk:la WlI delivered Ind the dal. doI_. Consull poarm.sl., fo, ,... 3. A1ticI. AddrasB8d 10: 48. ArtIcI. NUmb., P 433 108 627 4b. S.lVfce Typ. Cl R.glsI.'ad 10c CerUftlld Cl Exprass Mall lJ IllIUnod lJ Rslum Rece/plfor Merc:hand.. Cl COO 7. 0.,. ot 0 v.1l! ~ 9. I" 8. Add,. .' Add,.ss (Only If requ.SIsd and 'Ba Is paJd) I also wish 10 ,acelv. 111. following s.lVfces (fo, an .lIt.. f..': 1. [J Add'.....'. Add.... 2. [J R.slrtcted O.tlvery South Middleton Township Zoning Hearing Board 520 Park Drive Boiling Springs, PA l7007 98-676 5. Racelved By: (Pllnt Name) I .!I Domestic Return ReceIpt .lill~~:~~~I'i~~;1;;"lii~~,h~:~).:i';~;';:~.,;r:":;';O'~-Vi"""'''''-,,,. 'c~_.",..._____._.~_ '_"_u,___._ -' .;.>.;'\.:.. ~ i~' I ' ; '.,~ ,\i I' , , L , ' I' Ie , ' 1/: ,~ , I , .fI" P 1133 108 b2? Stroot &. Number 520 Park Posl OIfiCo. Slale. a. ZIP Code Boil' . Postage $ CertifiedFeo Spocia! Delivery Fee Restricted Delivery Fee OIl m Aelum Receipt Showing 10 ..... Whom a. Oale Oetivered '[-Recel>lSlloomgIoVollom, q: Dale. & hlrtes.see's Mi'ess g TOTAL Postage & Fee. $ CO C") P05tma~ or Dalll e ~ ~ ..:...-....._...._~-_.-. - ,~~;- ;<.J--- : ~ .,.' , '. .',..:.,~,.'......, ~ , .'.. . .', , ~/: ~~. ; ~ '. .., " 'J,'", ..... ~ . ~. 'l. '. . ~ ....... \. " '. . .. . , ~ \', '~'1. ~ .J 1 .~.~ 1'. t. " i .' . t < :;'1> " . .. " " ", . . , .. - .I; ". J ~. ,J- ~.:- \""j, ;.... ' .r., ' "'.. l1' ";~ ,. I Terry T. Rickert Appellant VS. South Middleton Township Zoning Hearing Board IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1998-676 CIVIL Ternl9 WRIT OF CERTIORARI COMMONWEALTH OF PENNSYLVANIA) SS. COUNTY OF CUMBERLAND) TO: South Middleton Township Zoning Hearing Board We, being willing for certain reasons, to have certified a certain action between Board Terrv T. Rickert. AppellAnt- V" !';nl1t-h Mit1t11",t-ron '1'ro"~~hip 7oniR3 Hearing pending before you, do command you that the record of the action aforesaid with all things concerning said action, shall be certified and sent to our judges of our Court of Common Pleas at Carlisle, within days of the date hereof, ?n together with this writ: so that we may further cause to be done that which ought to be done according to the laws and Constitution of this Commonwealth. WITNESS, the Honorable George E. Hoffer, P.J. our said Court, at Carlisle, Pa., the 4th day of , 19 .2.!L. Februarv ?!u.~~~ Prothonota '~ \ .' (') '-0 (') c u:J ..,z :'* -., '1J -.. ~.., j-q ......', n1fn C1}L" co /- -~~ N ';)nl :" I. "6 C'I .-.J 0 -':',., r-;.;:.:.. ;-:,~ ::;J-Ij :"'_u, d:r ~~~~-; "'(') :;:: (]'11 --, --:; 'r_ ~:j :.) ~1J -, en -< PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court ---------------------------------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) TERRY T, RICKERT, (Appellant) vs, SOUTH MIDDLETON TOWNSHIP ZONING HEARING BOARD, (Appellee) WILLIAM R. RONAN and GERALDINE L. RONAN, (Intervenors) Ne. 98-676 Civil Term 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): Land use appeal on the merits 2, Identify counsel who will argue case: Ronald M. Lucas, Esq. (c) John R. Kachur, Esq. Eckert Seamans Cherin & Mellott, LLC 213 Market Street Harrisburg, PA 17101 Telephone: (717) 237-6000 for Appellant (b) Hubert X. Gilroy, Esq. Broujos & Gilroy Four North Hanover Street Carlisle, Pa 17013 Telephone: (717) 243-4574 for Appellee Edward L. Schorpp, Esq. 127 West High Street Carlisle, PA 17013 (717) 243-9258 for Intervenors (a) 3. I will notify all parties in writing within two days that this case has been listed for argument, 4. Argument Court Date: December 9, 1998 DATED: November 4, 1998 ~ (J ,0 0 \~~ c:> .1 :-r:. 'c;J --:0; ,;:> .l.~ r1'lt'f', ,::: n1r=:: Z::'1 , ,--,1'" :;~C~. t.r. ::ocr r... ~",. <' I~~<...) ~;.:- )=1\ r2\..) ~1 ~1- [; -" (;:;.1,.-, :;: tlfi' _"l ~ ~:- .- ,,., ~ TERRY T, RICKERT, APPELLANT V. SOUTH MIDDLETON TOWNSHIP ZONING HEARING BOARD, APPELLEE V, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WILLIAM R. RONAN and GERALDINE R. RONAN, INTERVENORS 98-0676 CIVIL TERM IN RE: APPEAL FROM A DECISION OF THE ZONING HEARING BOARD OF SOUTH MIDDLETON TOWNSHIP BEFORE BAYLEY. J. AND HESS. J. ORDER OF COURT AND NOW, this Q.'8'day of January, 1999, the decision of the Zoning Hearing Board of South Middleton Township, IS AFFIRMED. By the Court, ' / / \J/' /'/ "( " , / Lv.v" Edgar B, Bayley, J, Ronald M. Lucas, EsqUire For Appellant ... ~.,) In.~J2<,l I {,;,,9 f9f. .0 X. ,0. Edward L. SChorpp, Esquire For Intervenors :saa FII r.rJ-o"\':I~ICc .1: ....' f JI... 0- .,.,.~ ""'~"1 "., 'aT'A!"\Y :. I'''. ';'.:..' -j-;. JIJ1 O::j Jr,!' 2q ;" n,:>(, -='.. . ;..(... d.,1 U' .... 11 CL"....." '. . I/'t"'!" '1\"d~,:t~L.~"',\,j 'v,.J ",I~ I PEI\! ;'~S'('L\lj\:' ;Ii\ r , " TERRY T, RICKERT, APPELLANT V, SOUTH MIDDLETON TOWNSHIP ZONING HEARING BOARD, APPELLEE V, WILLIAM R. RONAN and GERALDINE R, RONANI INTERVENORS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 98-0676 CIVIL TERM IN RE: APPEAL FROM A DECISION OF THE ZONING HEARING BOARD OF SOUTH MIDDLETON TOWNSHIP BEFORE BAYLEY. J. AND HESS. J. OPINION AND ORDER OF COURT BAYLEY, J., January, 1999:.. William R. Ronan and Geraldine R. Ronan, intervenors, own 729 Petersburg Road, South Middleton Township, The property is located in an Agricultural Zoning District under a South Middleton Township Zoning Ordinance enacted in 1970. A use permitted in that district as of right is a single-family detached dwelling, The ordinance allows one accessory apartment within an owner occupied single-family dwelling subject to conditional use approval by the Township Board of Supervisors. In 1996, the Ronans, who are the current owners, rented apartments on the first floor, second floor and in the basement of 729 Petersburg Road, They do not live in the dwelling. The South Middleton Township Zoning Officer issued a notice to the Ronans on July 21, 1997, that the three rental units in 729 Petersburg Road violate the South 98-0676 CIVIL TERM Middleton Township Zoning Ordinance. The Ronans appealedl and a hearing was conducted before the South Middleton Township Zoning Hearing Board. The Board Issued the following decision: It is the decision of the South Middleton Township Zoning Hearing Board that the appeal of William R. Ronan and Geraldine L. Ronan from the July 21, 1997 enforcement notice Issued by South Middleton Township is sustained in part and denied in part, The appeal Is sustained In the sense that It Is determined that there was no abandonment of a non-conforming use at property at 729 Petersburg Road, Carlisle, PA, which use consisted of a multi-family dwelling unit at the subject property encompassing two (2) separate dwelling units. The appeal is denied in the sense that it advanced a suggestion that there existed three (3) separate dwelling units at the subject property which had all obtained non-conforming use status. It is determined that two (2) dwelling units at the subject property may continue as a legal non-conforming use, with these units being the first floor dwelling unit and the second floor dwelling unit. The basement area of the subject property has no legal status to be used as a separate dwelling unit. (Footnote omitted.) (Emphasis added.) Terry T. Rickert, who lives across the street from 729 Petersburg Road, appealed from the decision of the Zoning Hearing Board. The issues were briefed and argued on December 12, 1998, without taking additional testimony.' Our scope of review is limited to determining if the South Middleton Township Zoning Hearing Board committed an error of law, and whether its findings of fact are supported by substantial evidence. Nascone v. Ross Township Zoning Hearing Board, 81 Pa. Commw. 482 (1984). The Board is the Judge of the credibility of the witnesses and the weight to be given to their testimony. Roseberry Life Insurance Company v. 1. The Zoning Hearing Board did not enter an appearance. -2- 98-0676 CIVIL TERM ZonIng HearIng Board of City of McKeesport, 664 A,2d 688 (Pa, Commw. 1995). The Zoning Hearing Board found that Arnold Hagen and his wife purchased 729 Petersburg Road and started living In the dwelling on the property In the early 1950's, The Hagens created a second floor apartment in the dwelling which they began renting in 1958. They continued to live In the first floor. After Mr. Hagen died In 1962, Mrs. Hagen continued to reside in the first floor, She died in September, 1994. William and Geraldine Ronan are the executors and beneficiaries of her estate and they received title to the property in October, 1995, The Zoning Hearing Board found that the Hagens established a second floor apartment in their dwelling prior to the enactment of the 1970 zoning ordinance. That finding Is supported by substantial evidence upon which tile Board was the judge of the credibility of the witnesses. The Board concluded that the use of the dwelling as a two family multi-family unit is a nonconforming use. Appellant does not maintain that the Board erred in finding that the second floor apartment is a nonconforming use; rather, he maintains that because Mr. & Mrs. Hagen, and later Mrs. Hagen, continued to live in the property after that use was established, the nonconforming use is limited to an accessory apartment in an owner occupied dwelling. Appellant argues that the Board erred because in enacting the 1970 zoning ordinance it "has already determined legislatively that an owner-occupied dwelling with one accessory apartment is different than a non-owner occupied, two apartment dwelling." Therefore, appellant concludes that the non-owner occupied -3- 98-0676 CIVIL TERM dwelling cannot now be used as an apartment.2 To qualify as a continuation of an existing nonconforming use, a proposed use must be sufficiently similar to the nonconforming use as not to constitute a new or different use. Hanna v. Board of Adjustment, 408 Pa. 306 (1962). The proposed use need not, however, be identical to the existing use; rather, similarity in use Is all that is required. Pappas v. Zoning Board of Adjustment, 527 Pa. 149 (1991). In L1mley v. Zoning Hearing Board of Port Vue Borough, 533 Pa, 340 (1993), the Supreme Court of Pennsylvania stated: Clearly, the nature of a non conforming use must be determined from the actual use from which the property Is being put rather than from the Identity of the users. (Emphasis added.) In the case sub judice, there were no restrictions on the use of a dwelling in South Middleton Township for multi-family living prior to the enactment of the zoning ordinance in 1970. The Zoning Hearing Board found that before the zoning ordinance was enacted, 729 Petersburg Road was being used by two families. The fact that the Hagens, who were one of those families, were the owners of the property is of no legal import because it Is the actual use to which the property was being put prior to the enactment of the zoning ordinance rather than the identity of the users that determines the nature of the nonconforming use. L1mley v. Zoning Hearing 2. The Ronans did not appeal from the decision of the Board that the use of the basement as a separate apartment was not established before the enactment of the 1970 zoning ordinance and, therefore, does not constitute a valid nonconforming use. -4- 98-0676 CIVIL TERM Board, supra. The fact that the 1970 zoning ordinance only allows an apartment as an accessory use with conditional use approval In a dwelling In an agricultural zone Is also of no legal Import because the property was being used as a two-family dwelling prior to the enactment of the zoning ordinance. Even If, contrary to the law set forth In L1mley, a two family use of the dwelling Is not the same use as existed prior to the enactment of the zoning ordinance because at that time one of the families was the owner, the use for two non-owner families Is a natural expansion of the nonconforming use, In L1mley, appellant opened a public restaurant and bar In a building that had previously housed a non- profit private club. The previous use as a private club was nonconforming In a residentially zoned district. A zoning hearing board held that the use of the premises as a public restaurant and bar was a new use and not a continuation of the existing nonconforming use. A Court of Common Pleas and the Commonwealth Court affirmed the zoning hearing board, but the Supreme Court of Pennsylvania reversed, finding that the current use was "[s]imllar to, and a natural expansion of, the food and beverage facility that constituted the existing nonconforming use." The Court stated that "[L]abellng the users as members and quests of a private club or as members of the general public is not determinative of the actual use of the premises." The same reasoning applies to a two-family use of 729 Petersburg Road, and Is consistent with the direction of the Supreme Court of Pennsylvania In Township of Chartlers v. W.H. Martin, Inc., 518 Pa. 181 (1988), that "[o]nce It has been determined that a -5- 98.0676 CIVIL TERM nonconforming use Is In existence, and overly technical assessment of that use cannot be utilized to stunt Its natural development and growth." Appellant maintains, alternatively, that Intervenors' nonconforming use as established by the South Middleton Zoning Hearing Board has been abandoned, For a lawful nonconforming use to be abandoned there must be an Intent to abandon and actual abandonment reflected by overt acts or the failure to act indicating abandonment. Action Audio Service Inc. v. Upper Darby Township Zoning Hearing Board, 699 A.2d 1375 (Pa. Commw. 1997), In Action Audio, the Commonwealth Court stated that even where a zoning ordinance sets a time limit on abandonment '1he expiration of that period creates a presumption of intent to abandon the nonconforming use; however, the party asserting abandonment must still demonstrate concurrent overt acts or failure to act which show abandonment." In the case sub ludlce, the South Middleton Township Zoning Hearing Board concluded: The record is void of any evidence suggesting that there were overt acts or failures to act by Mrs. Hagen or by the Ronans that would demonstrate an abandonment of any apartment use at the subject property. Even assuming the subject property may have laid vacant for more than twelve (12) months, the lack of any settled purpose by the landowners to abandon the multiple family use at the subject property Is clear from the record, This conclusion is supported by substantial evidence upon which the Board was the judge of the credibility of the witnesses, For the foregoing reasons, the following order is entered, -6- . ,\ , I .f\ -, -, -..'-"- .... ~ . . 98-0676 CIVIL TERM AND NOW, this ORDER OF COURT /.r.?1J.. Cod day of January, 1999, the decision of the Zoning Hearing Board of South Middleton Township, IS AFFIRMED. / By the Court, // / \ ~{w/ Edgar B. Bayley, J. Ronald M. Lucas, Esquire For Appellant Edward L. Schorpp, Esquire For Intervenors :saa -7- i,.' . f I -, ~\l ,