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HomeMy WebLinkAbout01-06797 .' ~. NQV 3 0 2001 J> '. YVETTE KANE, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CUMBERLAND COUNTY BOARD OF ASSESMENT APPEALS, CIVIL ACTION - LAW Appellee No. 01_ &791 0;;J I~ ORDER AND NOW, thiS~ay of Dc.c.~ ,2001, upon consideration of the foregoing Petition it is hereby ordered that a stattl3 etll.fcr6.ce on the appeal shall be held on the ;;(f{:Ii of '/lJ~ ,200a at 9'.: 1() o'clock .-&m. in Courtroom No, I , Within twenty (20) days after the date of entry by the C01ll1 of the order fixing the hearing date on the appeal, the Appellant shall mail by certified mail a copy of the Petition and Order to the following: the Board of Assessment Appeals of Cumberland County, the Commissioners of Cumberland County, Hampden Township, and the Cumberland Valley School District. Any person or government agency upon whom a copy of the Petition and Order required to be served under the paragraph set forth above may intervene in the appeal proceedings as a matter of right by filing with the Prothonotary within twenty (20) days after receipt of the copy of the Petition and Order a praecipe directing intervention either as an Appellant or Appellee. If such praecipe has not been filed by said person or government agency within the said twenty (20) day period, intelvention thereafter shall be governed by the Pennsylvania Rules of Civil Procedure 2326 through 2350, inclusive. BY THE COURT: i' J~ f\.. ~ \ ~ ~i'- u}\b.*O ~/j~ (''''I!;'l'''-'''WJ>.~",I, , ~ ""!~" ~., , ~, n' ", "", ,.."T^ - 1~J;rrr ';~~~1N8@,~"67.:!!d-Ifu~f~';"i:Y-';'~:"_;,j,'I'J~;'~.,~i!f'Uii-'\i,~';"' {U..j":%1G~""~iUi"';f(;'~-~5!!;:i-ti\lj~:Th...;!EHH~~,~W--';~~' "~',1{,i~_~mMWll]i~'"~ ~ ' ;0"'" .~' '''-''-' - ~.> '.-" , s~ , c 'I",",' . [I'. ~ . ..; ", " VUI\'>~~::'":,,,:> ,;~, Cr.~i~ ,I\[t\l Pl-J'i!V"":'V["',/\! '1.-1 I, ,- ;~I J ~ '. /-\i\Ji\ " ,~,~;:<~.!kl~J~!Mt_~.IL^,c ",~,"" 'J"'--',",,~ .1',;,",",,<,' ',",,\';1C'"',," '"__', """,,c ',,,__,,,,, ~,'" ""","","'f-.~"', ,~ ,,~,~~O ,~ ''''%'T'9l, ,1 . YVETTE KANE, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CUMBERLAND COUNTY BOARD OF ASSESMENT APPEALS, CIVIL ACTION - LAW No. 0/- 1;7 W1 ~ -- I.JV- Appellee PETITION FOR APPEAL FROM THE DECISION OF THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS Appellant, Yvette Kane, by her attorneys; Joseph A. Klein, Esquire and Mark S. Silver, Esquire, Joseph A. Klein, P,C., files this Petition for Appeal from the Decision of the Cumberland County Board of Assessment Appeals based upon the following statement of facts: 1. Appellant is Yvette Kane whose property is the subject of this Appeal and is located at 230 East Lauer Lane, Hampden Township, Cumberland County, Pennsylvania. 2. Appellees are the Board of Assessment Appeals of Cumberland County, The Board of Commissioners ofCumberlimd County, Hampden Township and the Cumberland Valley School District. 3, The Appellant, Yvette Kane. is the owner of a single t1unily residential property located at 230 East Lauer Lane, Hampden Township, Cumberland County, Pennsylvania known as Cumberland County Tax Parcel Number: 10-19-1598-249. 4. The Appellant timely appealed from the assessments on her property located at 230 East Lauer Lane, Hampden Township, Cumberland County, Pennsylvania, appealing the assessment in the amount of $279,390 on Cumberland County Tax Parcel Number: 10-19- 1598-249 for the tax year 2002. 5. On November 2,2001, the Cumberland County Board of Assessment Appeals mailed notice of its decision in the form of a Decision Order in which it denied the assessment appeal on Appellant's propelty for the tax year 2002 by reducing the appealed "Old Assessed Value" of $279,390 to its "New Assessed Value" of $242, II O. Attached hereto is a copy of the Decision Order, identified as Exhibit "A", incorporated herein by reference. , h ,~ " - 6. On or about August 20,2001, inconformity with its pre-printed instmctions, Appellant timely mailed her Assessment Appeal Statement together with supporting documentation to the Cumberland County Board of Assessment Appeals, stamped by said Board "Received Aug 2],2001", which Statement set forth some of the reasons for Appellant's having filed her appeal. A copy of Appellant's Assessment Appeal form is attached hereto as Exhibit "B", incorporated herein by reference. 7, The "Revised Assessment Based on Hearing" and the "New Assessed Value" set forth on the attached Decision Order (Exhibit "A") fail to set forth an accurate fair market value ofthe subject property and must be set aside and the fair market value of Appellant's property reduced for the following reasons as thus far known to Appellant: a. By deed dated January 31,200 I, recorded in the Office of the Recorder of Deeds of Cumberland County, PennsylVania in Deed Book 238, Page 876, Appellant Yvette Kane became the legal owner of the subject property. the stated consideration for which as set fOlth on said deed was $2l6,200.00~ and b. Appellant's purchase of the subject property which had been exposed for sale on the market, was an ann's length transaction which occurred nine (9) months prior to the date on which the Decision set forth in the Decision Order (Exhibit "A") appealed from was rendered; and c. The current fair market value of Appellant's property (Cumberland County Tax Parcel Number: 10-19-1598-249) the subject of the within Petition for Appeal is its purchase price, or $216,200.00; and d. The residence situate on Appellant's property was constructed in approximately] 974, some twenty-seven (27) years previous to the date on which the Decision appealed from (10/31/0]- Exhibit "A") was rendered; and e. The Board of Assessment Appeals of Cumberland County in rendering its Decision Order (Exhibit" A") failed to consider the purchase price paid by Appellant for the subject property only nine (9) months previous to the date on which it rendered its "Revised Assessment Based on Hearing - New Assessed Value" (Exhibit "A"); and f. The assessment on Appellant's property is substantially higher than assessments of comparable properties in the neighborhood and the taxing district; and 'o";';''j;)>'\i~I1~, 1 T" lJ~~, <~ __ _ __'- ""~ ""_ _~ " _, -""",-^,- g. The assessment is based upon an erroneous determination oHair market value, particularly as it concerns Appellant's property; and h. The value determination by the Cumberland County Board of Assessment Appeals violates the Equal Protection Clause of the 141h Amendment ofthe United States Constitution; and I. The impact of the assessment bears unequally on the Appellant when compared to assessments of properties of the same class; and J. When related and compared to assessments of similarly situated property owners, the assessment of the property of the Appellant is arbitrary and capricious; and k, The assessment violates the uniformity clause of the Pennsylvania Constitution; and 1. The assessment violates the required equality of tax treatment guaranteed by Pennsylvania Statutory and Constitutional Law; and m, The assessment is based in whole or in part upon appraisals that do not represent the actual fair market value of the Appellant's property; and n, The assessment as determined by the Cumberland County Board of Assessment Appeals does not reflect the current fair market value of the property; and o. The assessment lacks uniformity; and p. The assessment is discriminatory; and q. The assessment is otherwise unjust and inequitable. '~""w,,~::;li ~ f "" "' , 'C _ _ ' ,,<,," __, "._ '"' - ~ ~,< ~ ,~< WHEREFORE, the Petitioner requests this Honorable Court to reverse the decision of the Cumberland County Board of Assessment Appeals, reduce the assessment and thereafter make all necessalY orders and decrees to etTectuate said decision. Respectfully submitted: ~ ~ Mark S. Silver, Esquire Attorney 1.0. No,: 09825 Joseph A. Klein, P,C. 500 North Third Street, 71h floor P.O. Box 1152 Harrisburg, Pa 1710 I (717) 233-0132 Attorneys for Appellant, Yvette Kane Date: l\~.~ ~ "c,~,' Cumberland County Board of Assessment Appeals Old Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6350 (717) 240-6354 (fax) Board of Assessment Appeals Lloyd W. Bucher R. Fred Hefelfinger Sarah Hughes BONNIE M. MAHONEY Chief Assessor STEVEN D. TILEY Assistant Solicitor DECISION ORDER MAILING DATE: November 2, 2001 PARCEL N,UMBER: 10-19-1598-249. KANE, YVETTE 230 EAST LAUER LANE CAMP HILL PA 17011 Dear Property Owner: This letter is to officially notify you of the decision of the Cumberland County Board of Assessment Appeals regarding the above-referenced parcel. DATE OF APPEAL HEARING: 10/12/2001 DATE DECISION RENDERED: 10/31/2001 EFFECTIVE FOR TAX YEAR: 2002 DECISION RENDERED: (] Withdrawn By Applicant [ ] Abandoned For Failure To Appear [ 1 Denied - No Change [ 1 Approved Review Appraiser's Changes (Xl Revised Assessment Based on Hearing [ 1 Other: TOTAL VALUE FAIR MARKET CLEAN AND GREEN CLEAN AND GREEN STATUS Old Assessed Value: New Assessed Vaiue: 279,390 242,110 NOT APPLICABLE J EXHIBIT IT Any person aggrieved by the order of the Board of Assessment may appeal to the Court of Common Pleas by filing a petition in the Prothonotary's office on or before December 2, 2001. -i';~'1'J1IIHT_<", . r 7'- CUMBERLAND COUNTY ASSESSMENT APPEAL - RESIDENTIAL or LAND Under Ihe provisions of law y pe on' aggrieved by any assessment desiring 10 appeal shall file a stalement. in writing, with the Board 01 Assessment Appeals on or fore lember 1st Such slalement shall designate the assessment appealed trom and the address to which the Board shall mail notice o( hen d where 10 appear for a hearing. No appeal shall be heard by the board unless appellant shalllirst have filed the appeal and r' ire documents on or before September 1 st, as set (orlh by law. (') includes laxing districts Record Owner(s) Name: -r 11 L -fl-e... .k A III E'" Mailing Address: 6< 3{) E: L,4 lULl!-. ) A,J .Gt:LJT7D /Ii / J f!A ;7{)// Site Location of Property Subject of APp~a/ ;roO Eo i..L~ l.tJ Number Slrcet Assessors Tax Map Identification H: /().- / '1- /59'1-,31'1-9 Building and/or Land Use: $;Il/y.k 1/L/lIlf rh{)~-!hfj , Number of Stories/A- Total Rooms L Bed ooms ~ Family Room -1- Full Baths L Half Baths ~ Basement ---.L Garage(Cars) 1. Carport .-L Fireplace L Central Air L Lot Size/Acreage I '-I~' aAlA-<- Condominum Common Element ~11Ir Date Purchased --L/1. t, 10 I Purchase Price ~ d /6 I PI 00 Amount of Fire Insurance t ;2/// 000 Assessment APpeale~ I :?71} ~9 () Opinion of Market Value of this Properly j;?Jl,t,'/ () DO If properly is Rented, Stale Annual Rent IV jA State Reasons for Filing This Appeal: ----ri e,.-;"" IS c~ C,roSS el, 's pa ri.-kj b.R -+K)f( /I) L/"':' (t. ':,ses:se cL )It? It.{ / {( Ne/ '7 h~ -4,(1~Ul.; l/tr1((J Df. ./rtij. /70/77<-,.1 j;,(Ji/v_,v'€ 'ilv,f,f/;L.. ..,. ftr;./- ;77(1(-41 LuJu.t ;5 (p fIX,!? /i.., 1!!..e 'J2/6/200.9lks iJ/7r!..1!- Cij.;g 1;J.t..- I , d5J;" lid nJjJr/{l tV Boroffownship List Sales of Comparable Properties a-/f. thaI. OJ/lS€-- ';7./tS.,(./ )( S?e- Property Owner Location I I Total Assm't Date Sold Purchase Price ... rOle;? sfj~~ ----- ...--- ,- and do hereby verify thatlhe >jecllo Ihe penallies of 1 B Pa. IIwe hereby declare my/our intention to appeal from t statemen~s made iqt: is, ap7/?Ceal are tr e and correct. C,S, Section 4904, lallng! un n falsification 10 Signed: _ r-<.. <:- ~L...-- Office Use Only I F~:~dht Ue] Name: ..--- EXHIBIT -:;j9Cjo I 2 . ( , 5"'D') Owner(s) 01 Record Address: ')'i"~'-J!&'l?' ~ ;i(I!:~~~ ,,J, , ,- . f ""- ----- ---- ----- >~"i"'.~"'" ~' > -. . VERIFICATION 1. Yvette Kane, Appellant herein, hereby verify that the statements made in the attached Petition for Appeal from the Decision of the Cumberland County Board of Assessment Appeals are true and correct to the best of my knowledge, information and belief lunderstand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. ~~~~,/~ Yvette Kane Date: 2 ~ JrlO/ "W"""";;~"Wf"" ,." ',' , ~I,'~ " ~ - ~~ , . YVETTE KANE, Appellant IN TUE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CUMBERLAND COUNTY BOARD OF ASSESMENT APPEALS, CIVIL ACTION - LA W Appellee No. CERTIFICA TE OF SERVICE I, Mark S, Silver, Esquire, of Joseph A. Klein, P.C" Attorneys for Appellant, Yvette Kane. do hereby certifY that on this date I served the foregoing PETITION FOR APPEAL FROM THE DECISION OF THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS by placing a true and correct copy of the same in the United States Mail, postage prepaid, sent Certified Mail, Retum Receipt Requested, deposited at Harrisburg, Pennsylvania, addressed as folJows: Cumberland County Board of Assessment Appeals Old Courthouse One Courthouse Square Carlisle, Pa 17013 Steven D. Tiley, Esquire Frey and Tiley 5 South Hanover Street Carlisle, Pa 17013 Solicitor to Cumberland County Board of Assessment Appeals Hampden Township Board of Commissioners Hmnpden Township Municipal Building 230 Sporting Hill Road Mechanicsburg, Pa 17055 Cumberland County Board of Commissioners Office of the Commissioners CumberllUld County Courthouse One Courthouse Square Carlisle, Pa 17013 Board of School Directors Cumberland Valley School District Administrative Office 6746 Carlisle Pike Mechanicsburg, Pa 17050 ~ Mark S. Silver AttorneyI.D, No.: 09825 Joseph A. Klein, P.c. 500 North Third Street, 710 floor P,O. Box 1152 Harrisburg, Pa 17101 (717) 233-0132 Attorneys for Appellant, Yvette Kane Date: \)~ 1.A, -\)\ '.!O~.: 'If;, J_ '~~,~,~ .~ _,~~,_" ,~r " . ~ '",..,.-- ,'-".',"""- i,ri.C~',* 'a.';;;": ^\'d' -"-J{;' '1""''''';:''1",''''(' ~\) T'W;.}i'tti:ar;;''''i)~~''';o~&Trr' ':>,; 0 ',..~' C ~ --Os: ~f~ & Cr ~ t [11("( c5 :'_',1 Z:r,", -. " j ZC' f'~, FS.~E 'J:) -. ~ :<C -:,-'--, --- -. )> "". , ~ -. 7(-"" ~.~f,~,~- '- ~c:5 l-.l .. ::<-~C l:? ~~; i-tl "" .s:: :2: \.,0> -~ ,~,,--) :.> ,V\ -<;' ...J :0 Cr. ~; C, t .~""",,-~,~ :lPmlill~"=~,,~",~~[_,_~,,, ~~!J%l'i~~~1!l~~~?W~F~;j)'\'-~""""'m''',C,;~l'''''''''i;:!~'",,,,,'''',,\",~o''c"''':'i<,:",...,,,,,.l)i~~",!"1>,j-mw'J~;'''11'j'-'<I'\''J-:;',,;::l;:tP'jf,q'!~~:'; ':""~"" ".",~' "u, i;, .,; YVETTE KANE, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, CIVIL ACTION - LAW Appellee No. 2001-6797 CIVIL TERM PRAECIPE TO: THE PROTHONOTARY: Please enter my appearance on behalf of the Cumberland County Board of Assessment Appeals. D,ted/~,.2 ." . 7~ Stephen O. Tiley, Esquire Assistant Cumberland County Solicitor 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 SupremeCourt 10 # 32818 ';""..."8''''~''~__'' "",--;""'_~'''',,," ". " cl_>" I'C ,'. '-, ^~ .= , .'" , ,,",- ~, ~ '. ~ .." ,. lVl~"", ':"_" U __ t..""!"!'",,< ," ~ ~ 0 , -,' _0,'.- _ '<''''',~'r", '"Y".,,;~;;"'~"di ',-,.''.r}.'',i ""~k-'-""-t~'''' oi<' ,'"..,~ r- ~"'l'trf-r m'~~;--'']f''>0..ft'" (") c -~ -rJ~": rnh< ~'S;: [~C~ ,::.::~~ ro', ~~c5 -- C' :=) -<. a f"'0 C) " C,... -:...n ~ \.0 -.58 ."t W 1,-, :t.} oil r:,_ ~~~~fW")~~"'R!f;,,'j'~'1f[.'$1~\},~_JW~$ffit~~,~ ""':""~'~"'" YVETTE KANE, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS,: Appellee NO. 01-6797 CIVIL TERM ORDER OF COURT AND NOW, this 24th day of January, 2002, upon consideration of the stipulation filed in the above matter on January 24, 2002, the hearing scheduled for March 28,2002, is cancelled. BY THE COURT, J. ;G:ark S. Silver, Esq. P.O. Box 1152 Harrisburg, P A 17108 Attorney for Appellant L ~ -{Y);jJ ') 0 J -}A -OJ.. t}J\5 f) ':of! ~ GY/p ,) ,'. ~ ~/ ~~ ')~,:: 0]("." i"'.;,.~ - ,,<-, r, ",,','.' ,... "'.... ^, ,,' -r---"'::" 'V ')'-',,>---- .:& ...: -t.'- . ',",' ~c.." .Jfl>' ~(:/ 0 <~:/~"-'j' ~ ~' ."::::_--1';',_, ~ ~ .,:,:i,'''',''' ~ '" :-s..:.'r~~ 1.\> S) i;..; '\.) ~::;f r ~ ~tephen D. Tiley, Esq. 5 South Hanover Street Carlisle, PA 17013 Attorney for Appellee :rc ,',"!~, '" '""""!"~;'i{j",.,.,,,",,." ,",', ''''1''0'' ., .. ," ~ L~", h ~ ,..n. ,'_ ,'1'''"''. ,v "" i'~~~'I~=" ,,--," .",,~~~~' ~~~ " ~ "",~" '-2,",,<. ~'1:'';;' "",~"-:; ~,'- ~'~~-';., :"~t-Y-NI'{' ~,'1lr;it( tt'I' ::'"'~ "':'>l~- iir~l!r :r, 'lfillarir-":;"'C;'~~ :"f%l ~ f}/ ,,"" . .'~ ""~ ~~!?~~-"I'~'-IWI'\<!I&''f~~~''<'''';~~~~~~~~mrqm:,]]Ji.,,'~'>~'FW';' ,,''''"0'[--'1 u'_~-~""-'---- ,'~~."~'_. ~ , . - .. , . ,*,- . ,IAN 2 3 ZOGl ~ YVETTE KANE, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, CIVIL ACTION - LAW Appellee No. 2001-6797 CIVIL TERM ORDER AND NOW, thisl'f~ay of J"zn\)2) 1. ,2002, upon consideration of the within Stipulation and Joint Motion for Agreed Order, it is Decreed and Ordered that the total market value of the subject property (tax parcel number 10-19-1598-249) as of the date applicable to this proceeding is $220,000.00. As a result of the year 2000 Countywide reassessment, effective January 1, 2001, the common level ratio is not applicable to said reassessment which shall be fixed at the new predetermined rate of 100% of year 2000 value, The total assessment of the property for tax years beginning on and after January 1, 2002, and thereafter until changed as provided by law, shall be $220,000.00. The Cumberland County Assessment Office shall allocate said total assessment between land and improvements as provided by law, and by the procedures of the Cumberland County Assessment Office, The Cumberland County Assessment Office shall promptly notify the appropriate taxing bodies of the change in assessment. BY THE COURT ~. 3',lver>. ) / 1iL~ ~~ Ol-:;'l/-of[ RKs By: W\I\"1FSNN3d AlNnC' .~' 'r\U38~m 82:2 'Iiy.;:r cO Aa\llQi.... 1 .- 6 ""i-"*~_~, ~--'__'i'. ,_',,"" __'__'~_p__, ~._,,, . ,_ _",. .~_, ,~.___ .. ~J"" -~'1ir "'_"'o_~ ," - , 0 YVETTE KANE, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, CIVIL ACTION - LAW Appellee No. 2001-6797 CIVil TERM STIPULATION AND JOINT MOTION FOR AGREED ORDER AND NOW, this J,s_+- day of January, 2002, it is hereby Agreed and Stipulated between Petitioner, Yvette Kane, by her Attorneys, Joseph A. Klein, P.C., by Mark S, Silver, Esquire, and Respondent/Appellee Board of Assessment Appeals, by its Attorney, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor, as follows: 1, Petitioner filed a Petition for Appeal from the Decision of the Cumberland County Board of Assessment Appeals on November 29, 2001 to which an Order was entered on December 17, 2001 fixing a date and time for a hearing of March 28, 2002 at 9:30 a.m, The parties have now settled this case. 2. This Assessment Appeal relates to the market value applicable as of August 21,2001, the date the appeal was originally filed before the Board of Assessment Appeals, effective for assessments beginning on and after January 1, 2002, 3. The property which is the subject of this appeal is Cumberland County Assessment Parcel No. 10-19-1598-249 and is known as 230 East Lauer Lane, Hampden Township, Cumberland County, Pennsylvania. 4. The parties stipulate that the total market value of the subject property as of the date of the original Petition to the Cumberland County Board of Assessment Appeals and as of January 1, 2002 is $220,000.00. Stipulation and Joint Motion For Agreed Order Yvette Kane vs, Cumbo Co, Board of Assessment Appeals page I of 3 -?"!-l%h':~._J\I '---" _P' ~_"=,_~,~... , " - - ~ .." __,. "0 , ~ , ;"'-; if"- _"~f-' "''';jic'1<lil'Y~ . ~- -- .,' ., 5, As a result of the year 2000 Cumberland County Countywide reassessment, the predetermined ratio is now 100% of the year 2000 value. The common level ratio of 100 is inapplicable as it does not vary by more than 15% of the predetermined ratio. Therefore, the assessment shall be fixed as of January 1, 2002 at $220,000.00, 6. The Cumberland County Assessor's Office shall allocate the total assessment between land and improvements as provided by law and the procedures of the Cumberland County Assessment Office. 7, The $220,000,00 assessment shall be effective for tax years beginning on and after January 1, 2002 and shall remain unchanged unless and until changed as otherwise provided by law, and shall be implemented beginning with the 2002 county and municipal taxes and beginning with the 2002-03 school real estate taxes. 8, The Cumberland County Assessment Office shall promptly notify that appropriate taxing bodies of the change in assessment, and instruct the taxing bodies to make any appropriate refunds, 9, Each party to this appeal shall bear its own costs. 10. The Court is requested to enter the proposed Order attached hereto, 11, The undersigned Attorneys each hereby warrant to the other and to the parties and to the Court that he has reviewed this Settlement Stipulation with his client or clients and that he has specifically been authorized to enter into this Settlement Stipulation by his client or clients. Stipulation and Joint Motion For Agreed Order Yvette Kane VS, Cumb, Co, Board of Assessment Appeals page 2 of 3 -n 7., _ ,,"",,,, - ~,~" J __ _ __~ , ~, --> . ~- :"";0.'-'-"--" ~_' r:: -'-~_-~'-'-~-"" , -~--~ ,~"-- < : .... ~ " , Respectfully Submitted, PETITIONER, YVETTE KANE JOSEPH A KLEIN. P.C, By (lA~ Mark S. Silver, Esquire P,O. Box 1152 Harrisburg, PA 17108 Attorneys for Petitioner RESPONDENT, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS DA TED:/fHtl 02 ~ t/.8 (I:A BY ~, Ste en D, Tiley, Esquire Assistant Cumberland County Solicitor Attorney for Respondent 5 South Hanover Street Carlisle, PA 17013 (717) 443-5838 Supreme Court ID# 32318 Stipulation and Joint Motion For Agreed Order Yvette Kane vs, Cumb, Co, Board of Assessment Appeals page 3 of 3 "!'P-~'",., _, .._=~.. _ _. ~- --,- ? i~ il!'P!i!'~" ,,,-~WL. ~, __" __'_' ,1,T ~.~ ,"", ,'-. ~~~ "" ---''."',,,- ,'-"-C- ,',-,,';, 'T___.-"_ ~.JIij'j'~:'"' "T~~T 'I '!rrnrr~ffrfr"{i'I,1r -i'~-"(.',; o c S;: ""OeD !:pm ~__T' ZC' ~2~~ r-:-r-' <--.....- 3E~' ;:;:;0 c z =< E >5 f3 o N Q, , I;: ;-,z: T, f'~:::: ~~~; ..,.-,'-. :~..'~~ ::ri - ~" -'~--" ?~~t-,: ~ ~ N r'V ::t:-f> -'.. S? :n .j:"" "' 0_"'__' UJ!!f1!~~"Rf,~l1!f."""-'''l'lHW~~~~~j~M~~!!fLt~~li;;t~'