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HomeMy WebLinkAbout10-6534 BERT M. GOODMAN, ESQUIRE Attorney I.D. No. 21559 60 Soldiers Square Wayne, Pa. 19087 610-240-0345 IN RE: APPEAL OF MACY'S RETAIL HOLDINGS, INC. APPEAL FROM THE CUMBERLAND COUN'PY BOARD OF ASSESSMENT APPEALS MUNICIPALITY: LOWER ALLEN TOWNSHIP ASSESSMENT FOR THE TAX YEAR 2011 OCT 15 2010 Attorney for Appellant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA. CIVIL ACTION - LAW NO . J 0 ~ ~ 5 3 y C ,V~.' ORDER AND NOW, this 1~ day of dLC. ,2010 upon consideration of the foregoing Petition it is hereby ordered that a on the appeal shall be held on the a/fit of ~.,~rt,c,12041 at 31j o'clock P M. in Courtroom No. ~ 4 Within twenty days after the date of entry by the Court of this order, the Appellant shall by regular mail send a copy of the Petition and Order to the following: the Board of Assessment Appeals of Cumberland County, the Commissioners of Cumberland County, Lower Allen Township, and the West Shore School District. Any person or governmental agency upon whom a copy of the Petition and Order is required to be served under paragraph mentioned 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 governmental agency within the said twenty (20) day period intervention thereafter shall be governed by the Pennsylvania Rules of Civil Procedure 2326 through 2350 inclusive. >- ~ to BY THE COURT: ~ ~• ~ _, I QS ryt~.t~,, tic; ~ =--~' -,`~- !D~! ~L ~l0 Q ~} ~~ __ ~ CFA) . ~ ~ ~,~ r ~ ~~! x .. `~ ti._: "~ ._ ;~;; EASTBURN AND GRAY, P.C. Mark S. Cappuccio, Esquire Attorney I.D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215) 345-7000 IN RE: APPEAL OF MACY' S RETAIL HOLDINGS, INC. APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS MUNICIPALITY: LOWER ALLEN TOWNSHIP Attorney for West Shore School District cr% IN THE COURT OF COMMON PLC = PA gym., OF CUMBERLAND COUNTY , : CIVIL ACTION - LAW : NO. 10-6534 CIVIL TERM ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of West Shore School District in the above- captioned matter. EASTBURN AND GRAY, P.C. By: Mark S. Ca iccio, Esquire Attorney I. D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215) 345-7000 Attorneys for West Shore School District EASTBURN AND GRAY, P.C. Mark S. Cappuccio, Esquire Attorney I.D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215) 345-7000 IN RE: APPEAL OF MACY' S RETAIL HOLDINGS, INC. APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS MUNICIPALITY: LOWER ALLEN TOWNSHIP Attorneys for Appellee, West Shore School District : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW NO. 10-6534 CIVIL TERM ANSWER OF WEST SHORE SCHOOL DISTRICT TO PETITION FOR APPEAL OF MACY'S RETAIL HOLDINGS, INC. West Shore School District, by and through its attorneys, Eastburn and Gray, P.C., files this Answer to Appellant's Petition for Appeal and avers as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. (a) - (m). Denied. The averments set forth in paragraph 6(a)-(m) are denied as conclusions of law to which no responsive pleading is required. To the extent the averments contain factual averments, they are denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Appellee, West Shore School District, respectfully requests that this Honorable Court deny the appeal of Appellant and enter such further relief as the Court may deem just and proper. EASTBURN AND GRAY, P.C. By: /f?' Mark S. Capp cio, Esquire Attorney I. D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215)345-7000 Attorneys for West Shore School District Date: November 1,2, 2010 t VERIFICATION I, Joan Anderson, Business Manager for the West Shore School District, verify that the statements made in the attached Petition to Intervene are true and correct based upon my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unworn falsification to authorities. ,.r C' G?c•?.oG? Date: November !e? , 2010 Joan C. Anderson Director of Business Affairs West Shore School District EASTBURN AND GRAY, P.C. Mark S. Cappuccio, Esquire Attorney I.D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215) 345-7000 x? Attorneys for West Shore y --- ,- School District =W= IN RE: APPEAL OF MACY' S RETAIL HOLDINGS, INC. APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS MUNICIPALITY: LOWER ALLEN TOWNSHIP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW : NO. 10-6534 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on November 2010, I served true and correct copies of the Answer to Petition for Appeal by United States first class mail, postage prepaid, upon the following: Bert M. Goodman, Esquire 60 Soldiers Square Wayne, PA 19087 Attorney for Appellant Steven P. Miner, Esquire Daley, Zucker, Meilton, Miner & Gingrich, LLC 1035 Mumma Road, Suite 101 Wormsleyburg, PA 17043 Attorneys for Lower Allen Township Stephen D. Tiley, Esquire Frey & Tiley 5 South Hanover Street Carlisle, PA 17013 Attorneys for Cumberland County Board of Assessment Appeals it Edward L. Schorpp, Esquire Cumberland County Solicitor Cumberland County Court House One Court House Square, Room 208 Carlisle, PA 17013 Attorney for Cumberland County EASTBURN AND GRAY, P.C. d By: MA S. Capp io, Esquire Attorney I. D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215) 345-7000 Attorneys for West Shore School District Date: November /z , 2010 EASTBURN AND GRAY, P.C. Mark S. Cappuccio, Esquire Attorney I.D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215) 345-7000 Attorney for West Shore School District 4? c ?- IN RE: APPEAL OF MACY' S RETAIL HOLDINGS, INC. APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS MUNICIPALITY: LOWER ALLEN TOWNSHIP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA : CIVIL ACTION - LAW : NO. 10-6534 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that on November 1.2__, 2010, I served a true and correct copy of the foregoing Entry of Appearance via United States first class mail, postage prepaid, upon the following: Bert M. Goodman, Esquire 60 Soldiers Square Wayne, PA 19087 Attorneys for Appellant Steven P. Miner, Esquire Daley, Zucker, Meilton, Miner & Gingrich, LLC 1035 Mumma Road, Suite 101 Wormsleyburg, PA 17043 Attorneys for Lower Allen Township Stephen D. Tiley, Esquire Frey & Tiley 5 South Hanover Street Carlisle, PA 17013 Attorneys for Cumberland County Board of Assessment Appeals Edward L. Schorpp, Esquire Cumberland County Solicitor Cumberland County Court House One Court House Square, Room 208 Carlisle, PA 17013 Attorney for Cumberland County EASTBURN AND GRAY, P.C. By: ii? --r-" ark S. Cap cio, Esquire Attorney I. D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215)345-7000 Attorneys for West Shore School District Date: November 4, 2010 THE PR J7 N TqR 2010 MOv 23 PH r2: 4 6 IN RE: CUMBERLAND COUNT THE COURT OF COMMON APPEAL OF MACY'S RETAIL HO?'>?1 ttV?tN1A : F CUMBERLAND COUNTY, PA APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS : CIVIL ACTION - LAW MUNICIPALITY: LOWER ALLEN TOWNSHIP : NO. 10-06534 CIVIL TERM ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Lower Allen Township in the above- captioned matter. Respectfully Submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC Ile By: Steven Miner, Esquire Attorney I.D. No. 38901 1035 Mumma Road, Suite 101 Wormleysburg, PA 17043 Phone: (717) 724-9821 Email: sminerna.dzmmstlaw.com IN RE: APPEAL OF MACY'S RETAIL HOLDINGS, INC APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS MUNICIPALITY: LOWER ALLEN TOWNSHIP IN THE COURT OF COMMON OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW : NO. 10-06534 CIVIL TERM CERTIFICATION OF SERVICE A ?jam ? J I, Steven P. Miner, Esquire, certify that on I served via United States Mail a true and correct copy of the forgoing Entry of Appearance: Edward L. Schorpp, Esquire Cumberland County Solicitor 36 West Allen Street Mechanicsburg, PA 17055 Attorney for Cumberland County Stephen D. Tiley, Esquire Frey & Tiley 5 South Hanover Street Carlisle, PA 17013 Attorneys for Cumberland County Board of Assessment Appeals Mark S. Cappuccio, Esquire Eastburn and Gray, P.C. Bert M. Goodman, Esquire 775 Penllyn Blue Bell Pike 60 Soldiers Square Blue Bell, PA 19422 Wayne, PA 19087 Attorneys for West Shore School District Attorney for Appellant Respectfully Submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC By: Steven P. iner, Esquire Attorney D. No. 38901 1035 Mumma Road, Suite 101 Wormleysburg, PA 17043 Phone: (717) 724-9821 Email: sminer(a,dzmmglaw.com IN RE: APPEAL OF MACY'S RETAIL HOLDINGS, INC. APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS MUNICIPALITY: LOWER ALLEN TOWNSHIP IN THE COURT OF COMMON OF CUMBERLAND COUNTY, PA CIVIL ACTION -LAW NO. 10-06534 CIVIL TERM ANSWER OF LOWER ALL TOWNSHIP TO PETITION FOR APPEAL OF MACY'S RETAIL HOLDINGS, INC. Lower Allen Township, by and through its attorneys, Daley, Zucker, Meilton, Miner & Gingrich, LLC, files this Answer to Appellant's Petition for Appeal and avers as follows: C'j o 'C) ca -4 3C =-n ir*I 1. Admitted. M Q0 2. Admitted. -440 C)i' y.c iz rn 3. Admitted. -'-t u 4. Admitted. 5. Admitted. 6. (a) through (m). Denied. The averments set forth in Paragraph 6(a) - (m) are denied as conclusions of law to which no responsive pleading is required. To the extent that the averments contain factual averments, they are denied and strict proof thereof is demanded at the time of trial. WHEREFORE, Appellee, Lower Allen Township, respectfully requests that this Honorable Court deny the Appellant and enter such further relief that the Court may deem just and proper. Respectfully Submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC Steven Miner, Esquire Attorney I.D. No. 38901 1035 Mumma Road, Suite 101 Wormleysburg, PA 17043 Phone: (717) 724-9821 Email: sminer _,dzmmglaw.com IN RE: : IN THE COURT OF COMMON APPEAL OF MACY''S RETAIL HOLDINGS, INC. : OF CUMBERLAND COUNTY, PA APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS CIVIL ACTION'- LAW MUNICIPALITY: LOWER ALLEN TOWNSHIP : NO. 10-06534 CIVIL TERM VERIFICATION PURSUANT TO 18 PA C.S. 6M9 I, Thomas G. Vernau, hereby certify that I am Township Manager of Lower Allen. Township, and that 'I am authorized to execute this Verification on its behalf, and that the facts set forth in the foregoing ANSWER TO PETITION FOR APPEAL OF MACY'S RETAIL HOLDINGS, INC. is true and correct to the best of my knowledge, information and belief. I understand that false statements made herein:. are made subject to the penalties of 18 Pa. C.S. §4909, relating to unswom falsification to authorities. Daled: // /' ? Z"// L) Thomas G. Vemau, Toggs'hip Manager Lower Allen Township IN RE: APPEAL OF MACY'S RETAIL HOLDINGS, INC. APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS MUNICIPALITY: LOWER ALLEN TOWNSHIP IN THE COURT OF COMMON OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW : NO. 10-06534 CIVIL TERM CERTIFICATION OF SERVICE r? . t V 1 ?"I I, Steven P. Miner, Esquire, certify that on I served via United States Mail a true and correct copy of the forgoing Answer to Petition for Appeal of Macy's Retail Holdings, Inc.: Edward L. Schorpp, Esquire Cumberland County Solicitor 36 West Allen Street Mechanicsburg, PA 17055 Attorney for Cumberland County Stephen D. Tiley, Esquire Frey & Tiley 5 South Hanover Street Carlisle, PA 17013 Attorneys for Cumberland County Board of Assessment Appeals Mark S. Cappuccio, Esquire Eastburn and Gray, P.C. Bert M. Goodman, Esquire 775 Penllyn Blue Bell Pike 60 Soldiers Square Blue Bell, PA 19422 Wayne, PA 19087 Attorneys for West Shore School District Attorney for Appellant By: Respectfully Submitted, DALEY,ZkJCKER MEILTON MINEW& IN.QRICH, LLC Ste,,kn P. Miner, Esquire Attorney I.D. No. 38901 1035 Mumma Road, Suite 101 Wormleysburg, PA 17043 Phone: (717) 724-9821 Email: sminerna,dzmmglaw.com Stephen D. Tiley, Esquire Supreme Court I.D. No.32318 Attorney for Cumberland County Board of Assessment Appeals 5 South Hanover Street Tel: 717-243-5838 Carlisle. Pennsylvania 17013 Fax: 717-243-6441 IN RE: : IN THE COURT OF COMMON PLEAS APPEAL OF MACY'S RETAIL : OF CUMBERLAND COUNTY, HOLDINGS, INC. : PENNSYLVANIA Petitioner, VS. CUMBERLAND COUNTY BOARD OF BOARD OF ASSESSMENT APPEALS. Respondent, MUNICIPALITY: LOWER ALLEN TOWNSHIP -? d ? CIVIL ACTION -LAW M me? NO. 10-06534 CIVIL r.< 4- , A ° sa. n- . z -C > C cz? c REAL ESTATE TAX ASSESSMENT APPEAL Parcel No. 13-23-0551-149 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Respondent Cumberland County Board of Assessment Appeals, in the above captioned matter. Dated: Respectfully submitted, By ?Step n D. Ti fey, Esquire Attorney for Cumberland County Board of Assessment Appeals 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.13132318 Stephen D. Tiley, Esquire Supreme Court I.D. No. 32318 Attorney for Cumberland County Board of Assessment Appeals 5 South Hanover Street Tel: 717-243-5838 Carlisle. Pennsylvania 17013 Fax: 717-243-6441 IN RE: : IN THE COURT OF COMMON PLEAS APPEAL OF MACY'S RETAIL : OF CUMBERLAND COUNTY, HOLDINGS, INC. : PENNSYLVANIA Petitioner, VS. CUMBERLAND COUNTY BOARD OF BOARD OF ASSESSMENT APPEALS. Respondent, MUNICIPALITY: LOWER ALLEN TOWNSHIP Parcel No. 13-23-0551-149 : CIVIL ACTION - LAW NO. 10-06534 CIVIL C-) c N C= C:) . MW _ C REAL ESTATE TAX ASSES N-P rn APPEAL . C cars c n :> ANSWER AND NOW, comes Respondent the Cumberland County Board of Assessment, by its attorney, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor for Tax Matters, and files this Answer to Petitioner's "Petition for Appeal from Decision of the Cumberland County Board of Assessment Appeals," of which the following is statement: 1-5. Admitted. 6. Denied. The averments of this paragraph, and each of its sub-lettered paragraphs, set forth conclusions of law to which no responsive pleading is required. Strict proof at trial is demanded. WHEREFORE, Respondent, Cumberland County Board of Assessment Appeals, prays Your Honorable Court for an Order denying Petitioner's appeal or, in the alternative, fixing the assessment of the property at such greater amount than the current assessment as the Court, in its discretion, may deem just and proper. Dated: /? iRespectfully submitted, By40?' ?-? - 7 Step en D. iley, Esquire Assistant Cumb. Cty. Solicitor For Tax Matters 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D.#32318 VERIFICATION I verify that the statements made in the foregoing Answer are true and correct, partially upon personal knowledge and partially upon my belief; to the extent language in the Answer is that of my attorneys, I have relied upon my attorneys in making this Verification. I understand that false statements herein are made and subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Dated: /?/? Bonnie M. Mahoney, Chief Assessor Stephen D. Tiley, Esquire Supreme Court No. 32318 Attorney for Appellant Cumberland County Board of Assessment Appeals 5 South Hanover Street Tel: 717-243-5838 Carlisle. Pennsylvania 17013 Fax.: 717-243-6441 IN RE: : IN THE COURT OF COMMON PLEAS APPEAL OF MACY'S RETAIL : OF CUMBERLAND COUNTY, HOLDINGS, INC. : PENNSYLVANIA Petitioner, VS. CUMBERLAND COUNTY BOARD OF BOARD OF ASSESSMENT APPEALS. : CIVIL ACTION - LAW : NO. 10-06534 CIVIL Respondent, MUNICIPALITY: LOWER ALLEN TOWNSHIP ASSESSMENT : REAL ESTATE TAX Parcel No. 13-23-0551-149 : APPEAL CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing Answer by placing a true and correct copy of the same in the United States mail, postage pre-paid, addressed to: Bert M. Goodman Attorney for Petitioner 60 Soldiers Square Wayne, PA 19087 Steven P. Miner, Esquire DALY ZUCKER MEILTON MINER & GINGRICH, LLC Solicitor for Lower Allen Township 1035 Mumma Rd., Suite 101 Wormleysburg, PA 17043 Atty. ID # 38901 (717) 724-9821 ?y Date: Mark S. Cappuccio, Esquire Eastburn and Gray, P.C. Solicitor for West Shore School District 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 Stephen D. Tiley, Esquire Assistant Cumb. Co. Solicitor 5 S. Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney 1.D.#32318 Stephen D. Tiley, Esquire Supreme Court No. 32318 Attorney for Appellant Cumberland County Board of Assessment Appeals 5 South Hanover Street Tel: 717-243-5838 Carlisle. Pennsylvania 17013 Fax 717 43-Wi IN RE: : IN THE COURT OF COMMON PLEAS APPEAL OF MACY'S RETAIL : OF CUMBERLAND COUNTY, HOLDINGS, INC. : PENNSYLVANIA Petitioner, VS. CUMBERLAND COUNTY BOARD OF BOARD OF ASSESSMENT APPEALS. : CIVIL ACTION - LAW : NO. 10-06534 CIVIL Respondent, MUNICIPALITY: LOWER ALLEN TOWNSHIP : REAL ESTATE TAX ASSESSMENT : APPEAL Parcel No. 13-23-0551-149 RESCHEDULING ORDER AND NOW, this 2 G :[L- day of December, 2010, upon representation by Stephen D. Tiley, Esquire, that the parties have agreed to a continuance of the above captioned matter, the hearing previously scheduled for January 21, 2011 is cancelled and the hearing is rescheduled for Thursday, April 21, 2011 at 1::30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle Pennsylvania. ?ert M. Goodman, Esquire Steven P. Miner, Esquire ark S. Cappuccio, Esquire Stephen D. Tiley, Esquire ?d Ma? cep )01141/10 )a1a1Jprj r'z Q0 r`'7 ' . ?7 ? ci ?2 1 ry n l n ?n N -j ? a ?. o , z c, A Q n4= w orn --? a a - C w ?i IN RE: APPEAL OF MACY' S RETAIL HOLDINGS, INC., Petitioner V. CMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 10-6534 CIVIL TERM IN RE: APPEAL FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS ORDER OF COURT C--) "3 =5 - d Zrn -0 Xx - --a -r' wr co ? Q -v 3 t') CD r-? -?: Cn ^.kh AND NOW, this 7 h day of April, 2011, upon agreement of counsel, the hearing in the above matter previously scheduled for April 21, 2011, is rescheduled for Monday, August 22, 2011, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. ? Bert M. Goodman, Esq. 60 Soldiers Square Wayne, PA 19897 Attorney for Petitioner J Stephen D. Tiley, Esq. 5 South Hanover Street Carlisle, PA 17013 Attorney for Respondent BY THE COURT, /A, J. sley Oler, r., J. Mark S. Cappuccio, Esq. 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 Attorney for West Shore School District .- I-Steven P. Miner, Esq. 1035 Mumma Road Suite 101 Wormleysburg, PA 17043 Attorney for Lower Allen Township :rc J? Attorneys for West Shore School District IN THE COURT OF COMMON PLE.4,S OF CUMBERLAND COUNTY, PA M? rn zrn Z;V CIVIL ACTION - LAW NO. 10-06534 CIVIL TERM CERTIFICATE OF SERVICE N -?v ra CA G? hereby certify that on April -(f-, 2011, I served a true and correct copy of West Shore EASTB RN & GRAY, P.C. BY: M k S. Cappuccio, Esquire Attorne I.D. No. 46763 775 Pe lyn Blue Bell Pike Blue B 1, PA 19422 (215) 31 5-7000 IN RE: PEAL OF MACY'S RETAIL HOLD GS, INC. FROM THE CUMBERLAND BOARD OF ASSESSMENT TAX PARCEL NO. 13-23-0551-149 M ?r C.) -+ca n rr ?rr School pistrict's Interrogatories and Request for Production of Documents and Things, by United States Orst class mail, postage prepaid, on the following: Bert M. Goodman, Esquire 60 Soldiers Square Wayne, PA 19087 Attorney for Appellant Stephen D. Tiley, Esquire Frey & Tiley 5 South Hanover Street Carlisle, PA 17013 Attorney for Cumberland County Board of Assessment Appeals Steven P. Miner, Esquire Daley, Zucker, Meilton, Miner & Gingrich, LLC 1035 Mumma Road, Suite 101 Wormsleyburg, PA 17043 Attorney for Lower Allen Township 10 Edward L. Schorpp, Esquire Cumberland County Solicitor Cumberland County Court House One Court House Square, Room 208 Carlisle, PA 17013 Attorney for Cumberland County EASTBURN AND GRAY, P.C. ,f By:.iv ark S. C uccio, Esquire Attorney I. D. No. 46763 775 Penllyn Blue Bell Pike Blue Bell, PA 19422 (215) 345-7000 Attorneys for West Shore School District Date: Alpril _d_, 2011 11 Stephen D. Tiley, Esquire Supreme Court No. 32318 Attorney for Appellant Cumberland County Board of Assessment Appeals 5 South Hanover Street Tel: 717-243-5838 Carlislo Pennsylvania 17013 Fax.: 717-243-6441 IN RE: IN THE COURT OF COMMON PLEAS APPEAL OF MACY'S RETAIL : OF CUMBERLAND COUNTY, HOLDINGS, INC. : PENNSYLVANIA Petitioner, VS. CUMBERLAND COUNTY BOARD OF BOARD OF ASSESSMENT APPEALS. Respondent, MUNICIPALITY: LOWER ALLEN TOWNSHIP Parcel No. 13-23-0551-149 CIVIL ACTION - LAW NO. 10-06534 CIVIL C-, L , 4p; rnco m C= r7i , r-a -- C C> ? r > '-- -? C:: CD REAL ESTATE TAX ASSESSMENT APPEAL ORDER AND NOW, this ( t ? L day of August, 2011, upon representation by Stephen D. Tiley, Esquire, counsel for the Respondent, Cumberland County Board of Assessment Appeals that all of the parties have agreed to a general continuance of the above captioned matter, the hearing previously scheduled for August 22, 2011 is cancelled and the case is continued generally at the call of any party. L W, SDT/tl cc: Bert M. Goodman, Esquire Q,Jd B Steven P. Miner, Esquire OOP - I II ? Mark S. Cappuccio, Esquire ®? pj Stephen D. Tiley, Esquire By the Court, John G. French, Esquire Attorney for Cumberland County Board of Assessment Appeals 1 Courthouse Square, Room 107 Carlisle, PA 17013 IN RE: APPEAL OF MACY'S RETAIL HOLDINGS, INC. Petitioner Vs. Attorney I.D. No. 90788 Tel.: 717-759-5297 CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent MUNICIPALITY: LOWER ALLEN TOWNSHIP Parcel No. 13-23-0551-149 C) -p3 IN THE COURT OF COMMOYIrn PLEAS OF CUMBERLAND cin - COUNTY, PENNSYLVANL4 •C CD Y}. CD C.? NO. 10-6534 CIVIL TERM : REAL ESTATE TAX : ASSESSMENT APPEAL • • PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE PURSUANT TO PA. R.CIV.P. 1012(b) con C.r1 Please withdraw my appearance on behalf of the Appellee Cumberland County Board of Assessment Appeals, in the above captioned matter. Dated: ///,?.0,7 /f/ 'ail 817569.1 Respectfully submitted, By Stephen D. Tiley, Esquire 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D.#32318 Please enter my appearance on behalf of the Appellee Cumberland County Board of Assessment Appeals, in the above captioned matter. Dated: Respectfully submitted, Johti G. French, Esquire Solicitor for Cumberland County Board of Assessment Appeals 1 Courthouse Square, Room 107 Carlisle, PA 17013 (717) 759-5297 Supreme Court I.D. # 90788 IN RE: APPEAL OF MACY'S RETAIL • HOLDINGS, INC. Petitioner vs. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent MUNICIPALITY: LOWER ALLEN TOWNSHIP Parcel No. 13-23-0551-149 : IN THE COURT OF COMMON : PLEAS OF CUMBERLAND : COUNTY, PENNSYLVANL4 • : NO. 10-6534 CIVIL TERM : REAL ESTATE TAX : ASSESSMENT APPEAL • CERTIFICATE OF SERVICE I hereby certify that on May 12, 2014, a true and correct copy of the foregoing Praecipe for Withdrawal/entry of Appearance, Pursuant to Pa. R.Civ.P. 1012(b) was served by means of United States mail, first class, postage prepaid, upon the following: Bert M. Goodman, Esquire McNees Wallace & Nurick, LLC Attorney for Petitioner 100 Pine Street PO Box 1166 Harrisburg, PA 17108-1166 Steven P. Miner, Esquire Solicitor for Lower Allen Township Daly, Zucker, Meilton, Miner & Gingrich, LLC 1035 Mumma Road, Suite 101 Wormleysburg, PA 17043 Mark S. Cappuccio, Esquire Eastburn & Gray, P.C. Solicitor for West Shore School District 775 Penllyn Blueball Pike Blue Bell, PA 19422 ohn G. French