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HomeMy WebLinkAbout10-7116JEFFREY D. GORDON I.D. #77895 ARCHER & GREINER, P.C. A Professional Corporation 700 Alexander Park, Suite 102 Princeton, NJ 08540 (609) 580-3713 Appeal of: WEST SHORE COUNTRY CLUB, Appellant, V. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Appellee. PARCEL ADDRESS and NO. 100 Brentwater Road East Pennsboro Township No. 09-19-1596-048. Mailing Address: c/o Jeffrey D. Gordon, Esq. Archer & Greiner, P.C. 700 Alexander Park, Suite 102 Princeton, NJ 08540 Attorney for: Appellant . DOCKET NO. -1 II (Q C) r-? w'as t',..s fLL? C : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW TAX ASSESSMENT APPEAL PETITION FOR ALLOWANCE OF APPEAL FROM THE NOTICE OF THE BOARD OF ASSESSMENT APPEALS OF CUMBERLAND COUNTY 1. Appellant, West Shore Country Club, hereby appeals from the decision issued on October 15, 2010, by the Board of Assessment Appeals of Cumberland County for the property located at 100 Brentwater Road, East Pennsboro Township, Parcel No. 09-19- to A ,66(a. 10 a *$ ? ? 1596-048. ("Tax Parcel"), a copy of this decision being attached hereto and made a part hereof as Exhibit "A" 2. The Tax Parcel is located in East Pennsboro Township, in the East Pennsboro Area School District, and in Cumberland County. 3. The Tax Parcel was initially given an assessment of $10,000,000. 4. The Appellant filed with the Board of Assessment Appeals of Cumberland County (the "Board") an appeal of the assessed valuation of the Tax Parcel for year 2011. 5. On October 15, 2010, the Board gave notice of its decision setting the assessment at $10,000,000 on the Tax Parcel. See Exhibit "A". 6. The Appellant is aggrieved and dissatisfied with the aforementioned action of the Board. 7. The Appellant avers that the assessment placed upon the Tax Parcel by the Board is unlawfully excessive, erroneous, discriminatory, improperly determined, based on mistakes of fact and law, does not reflect the fair market value of the parcel, and lacks uniformity with respect to other assessed real estate in the County, all (or severally) of which are contrary to the laws and Constitution of the Commonwealth of Pennsylvania. 8. The Appellant avers that the assessment of the Tax Parcel, pursuant to the applicable State Tax Equalization Board or common level ratio, is excessive. 2 9. The Appellant avers that the applicable State Tax Equalization Board or common level ratio must be applied to the current market value to arrive at the assessment of the Tax Parcel in conformity with the Uniformity Clause of the Pennsylvania Constitution, taxing statutes enacted by the General Assembly 52 P.S. § 5452.10, and Daugherty v. County of Allegheny, 920 A.2d 936 (Pa.Cmwlth. 2007), citing Downingtown Area School District v. Chester County Board of Assessment Appeals, 590 Pa. 459, 913 A.2d 194 (2006); Clifton v. Allegheny County, 969 A.2d 1197 (2009). 10. The Appellant avers that the Board's action unfairly singled out Appellant for non-uniform treatment in violation of the Pennsylvania Constitution, Article VIII, Section 1; 72 P.S. §§ 5348.1 and 5020-402; and, the Equal Protection and non- discrimination guarantees of the Federal and State Constitutions. 11. This Appeal is filed in accordance with the provisions of the laws of the Commonwealth of Pennsylvania pertaining to the filing of appeals to the Court of Common Pleas from a decision of a Board of Assessment Appeals and, in particular, the provisions of 72 P.S. §§ 5350, 5453.704, 5020-518.2 and 5020-518.1, as applicable, in order that Your Honorable Court may hold a hearing thereon and fix a just and proper assessment in accordance with the provisions of law. 12. Appellant is aggrieved by the Board's Decision and seeks hearing de novo in the Court of Common Pleas, as provided by the laws of the Commonwealth of Pennsylvania. 3 WHEREFORE, Appellant requests that this Court allow the appeal and make such other orders and decrees as shall be just and proper. Dated: 411al '?? J FR D. GORDON, ESQUIRE Attorney for Appellant 4 EXHIBIT "A" Cumberland County Board of Assessment Appeals Old Courthouse, First Floor One Courthouse Square Carlisle, PA 17013 09005821-F3-2 WEST SHORE COUNTRY CLUB CIO BERT X. GOODMAN 60 SOLDIERS SQUARE WAYNE PA 19087 THIS IS N07' TAX BILL Cumberland County Board of Commissioners Gary Eicholberger, Chaimian Richard L. Rov(>gno. Vict-a-Chnirrmn Sarbnrri . Cross. Secretary l f?'l; l NOJ`CM - CUMBERLAND CCU TY BOARD OF ASSESSMENT APPEALS This is your official notice of the decision by the Cumberland County Board of Assessment Appeals regarding your appeal of the assessed value of the real property described below. The Board has determined a change or no change in assessed value, as indicated and explained below. MAILING DATE: 10/15/2010 Muiiic.: 09 - 'FAST PENNSSORO TWP School: 5 - EAST PENNSBORO St) Location: 200 BRENTWATRR ROAD WEST SHORE COU14TRY CLUB APPROX. 193 ACRES Taxable Property Property Type; Cy C ercial .. Golf Course, Parcel Identifier: 09-19 -1596 - 048 . i Effective for Tax Year: 2011 APPEALED BOARD DECISION - i ASSESSED VALUE ASSESSED VALUE Land 5,955,200 8, 955, 200 Buildings 4,044,800 4,044,800 TOTAL CLEAN AND GREEN 10, 000, 000 10, 000, 000 Land NOT NOT Buildings APPLICABLE APPLICABLE j TOTAL Tax Status Taxable Taxable ' I...._Clean and Green Status m_ DECISION: Deni,ed - No As of tlctober- _lt, 2010, the Board ?-f PppealS arteJ11.)r cmle of i. Auxi.l.i.arv Boards has issued r.he ab v":1 ?i....._. .Cgardi ig Yoiir formal appeal. This is your final notice, if you are not satisfied with this decision, you may appeal to the Cumberland County Court of Common Pleas within 30 days from the date of this notice. cc: Secretary of Municipality Secretary of School District Ed Schorp-p, Solicitor WEST SHORE COUTNTRY CI.:U S VERIFICATION Jeffrey D. Gordon, Esquire states that he is the attorney filing the foregoing Petition for Allowance of Appeal from The Notice of the Cumberland County Board of Assessment Appeals; that he makes this Verification as an attorney because the party he represents lacks sufficient knowledge and/or because he has greater personal knowledge, information and belief than that of the party for whom he makes this Verification; and/or because the party for whom he makes this Verification is outside the jurisdiction of the Court and/or Verification of that party cannot be obtained within the time allowed for the filing of the pleading; and that he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: 6148532x1 By: 41?? Y D GORDON 5 ti JEFFREY D. GORDON I.D. #77895 ARCHER & GREINER, P.C. 700 Alexander Park, Suite 102 Princeton, NJ 08540 (609) 580-3700 Attorney for: Appellant Appeal of: IN THE COURT OF COMMON PLEAS WEST SHORE COUNTRY CLUB, Appellant, : CUMBERLAND COUNTY, : PENNSYLVANIA V. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Appellee. PARCEL ADDRESS and NO. 100 Brentwater Road East Pennsboro Township No. 09-19-1596-048. CIVIL ACTION - LAW CERTIFICATE OF SERVICE NO. 10-7116 I, JEFFREY D. GORDON, hereby certify that on November 9, 2010, I caused to be served a true and correct copy of a Real Estate Tax Assessment Appeal, with accompanying papers, by certified mail, return receipt requested, on the following persons: Cumberland County Board of Assessment Appeals Old Courthouse - 1st Floor 1 Courthouse Square Carlisle, PA 17013 ' 0 C ) ? Stephen D. Tiley, Esq. MCC °_ _ Frey & Tiley Z= .4c mar= 5 S. Hanover Street car- ? - :Vp Carlisle, PA 17013-3307 r -Z cn ?o a Cumberland County Commissioners Zc D o _. ? 1 Courthouse Square - Room 200 --4 ca ?. Carlisle, PA 17013 '< °'' < IV Edward L. Schorpp, Esq. 1 Courthouse Square - Room 200 Carlisle, PA 17013 School Board of Directors East Pennsboro Area School District 890 Valley Street Enola, PA 17025 Carl P. Beard, Esq. Andrews & Beard 3366 Lynnwood Drive P.O. Box 1311 Altoona, PA 16603 Board of Commissioners East Pennsboro Township 98 South Enola Drive Enola, PA 17025-2796 Joseph A. Curcillo, III, Esq. Beinhaur & Curcillo 3964 Lexington Street Harrisburg, PA 17109 On November 12, 2010, I caused to be served by certified mail, return receipt requested, on the above parties, a true and correct copy of a Real Estate Tax Assessment Appeal, with accompanying papers, stamped "filed" by the Cumberland County Prothonotary. I understand that false statements are made subject to penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Y Date: ?r ??' ?c1 41 /94 J rey D Gordon, Esq. Archer & Greiner, P.C. 700 Alexander Park, Suite 102 Princeton, NJ 08540 I.D. #77895 (609) 580-3700 6172632v1 WEST SHORE COUNTRY CLUB IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Appellant C-) V. © ° -n CUMBERLAND COUNTY BOARD =m : rrn- OF ASSESSMENT APPEALS, "< -- -0 rn ?' Appellee NO. 10-7116 CIVIL _< rn ° o <o = z° ORDER OF COURT _ c - C"3 c 5> c= Ev o AND NOW, this 16th day of November, 2010, upon consideration of W*t fo rdo Country Club's Appeal from the decision of the Board of Assessment of Appeals of Cumberland County, IT IS HEREBY ORDERED AND DIRECTED that a hearing on this matter will be held on Wednesday, May 11, 2011, at 9:30 a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. The Parties shall file a pre-hearing memorandum with the Court on or before April 29, 2011, in the following format: 1. A concise statement of factual issues to be decided at the hearing. II. A list of witnesses the party intends to call at the hearing along with a concise statement of their anticipated testimony. III. A list of all exhibits each party anticipates presenting at hearing. IV. A statement of any legal issues each party anticipates being raised at hearing along with copies of any cases which may be relevant to resolution of the stated issue. IT IS HEREBY FURTHER ORDERED AND DIRECTED that either party may request a status conference in this matter prior to the hearing in order to discuss any outstanding issues to include the exchange of property value assessments. By the Court, M. L. Ebert , Jr., J. effrey D. Gordon, Esquire Attorney for Appellant ,,,-5e'jphen Tiley, Esquire For Cumberland County bas i a /YLA LCL 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: WEST SHORE COUNTRY : IN THE COURT OF COMMON PLEAS CLUB, : OF CUMBERLAND COUNTY, : PENNSYLVANIA Appellant VS. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, : CIVIL ACTION - LAW NO. 10-7116 CIVIL Appellee Parcel No. 09-19-1596-048 TO THE PROTHONOTARY: : REAL ESTATE TAX : ASSESSMENT APPEAL PRAECIPE tD F-? -'' r- rn ? c? , p c: 3 c=, =C) r ? --a G' '2:: Please enter my appearance on behalf of the Appellee, Cumberland County Board of Assessment Appeals, in the above captioned matter. Dated: /wv Respectfully submitted, Stephen D. Tiley, Esquire Attorney for Cumberland County Board of Assessment Appeals 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.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 : 717-243-6441 IN RE: WEST SHORE COUNTRY : IN THE COURT OF COMMON PLEAS CLUB, : OF CUMBERLAND COUNTY, : PENNSYLVANIA Appellant VS. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Appellee Parcel No. 09-19-1596-048 : CIVIL ACTION - LAW : NO. 10-7116 CIVIL t= REAL ESTATE TAX Mm : ASSESSMENT APPEA?? ?c ? c+ CERTIFICATE OF SERVICE -•c ..g 0 I hereby certify that I served a true and correct copy of the foregoing Praecipe by placing a true and correct copy of the same in the United States mail, postage pre-paid, addressed to: Jeffrey D. Gordon, Esquire ARCHER & GREINER, P.C. Attorney for Appellant 700 Alexander Park, Suite 102 Princeton, NJ 08540 Tel. No. (609)-580-3700 Carl P. Beard, Esquire Joseph A. Curcillo, III, Esquire ANDREWS & BEARD BEINHAUR & CURCILLO Attorney for East Pennsboro School Dist. Attorney for East Pennsboro Township 3366 Lynnwood Drive 3964 Lexington Street Altoona, PA 16603-1311 Harrisburg, PA 17109-2618 Date: Stephen D. Tiley, Esquire Assistant Cumb. Co. Solicitor 5 S. Hanover Street ?s rn Orn c3" r) -r, r, Carlisle, PA 17013 (717) 243-5838 Attorney I.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,: 717-243-6441 IN RE: WEST SHORE COUNTRY : IN THE COURT OF COMMON PLEAS CLUB, : OF CUMBERLAND COUNTY, : PENNSYLVANIA Appellant NS. CIVIL ACTION - LAW c .` a -, CUMBERLAND COUNTY BOARD OF NO. 10-7116 CIVIL -n ASSESSMENT APPEALS, =M Sao 330 -c cn <A , M ? ? Appellee REAL ESTATE TAX r :Z- --a c:) ASSESSMENT APPEAL =C ?'-' Parcel No. 09-19-1596-048 c ?- ORDER ° AND NOW, this 44 day of May, 2011, upon representation by Step hen D. Tiley, Esquire, counsel for the Appellee, that the Appellant has agreed to a general continuance pending settlement negotiations, the hearing scheduled for May 11, 2011 is cancelled and the matter is continued generally at the call of either party. By The Court ?I, ?AA -0 M. L. Ebert, Jr., J. cc: Jeffrey D. Gordon Esquire I r/fi Carl P. Beard, Esquire ? Copes Joseph A. Curcillo, III, Esquire Stephen D. Tiley, Esquire - hand delivered FILED-OF FRI'/V 0F THE PROTr'!D i1? Stephen D. Tiley, Esquire Supreme Court I.D. No.32318 Attorney for Cumberland County 1011 JUN -7 AM 11. 5 3 Board of Assessment Appeals 5 South Hanover Street CUMBERLAND ?3E11d 1 Carlisle Pennsylvania 17013 PENNSYLVANIA Tel: Fax: 717-243-5838 717243 6441 IN RE: WEST SHORE COUNTRY : IN THE COURT OF COMMON PLEAS CLUB, : OF CUMBERLAND COUNTY, : PENNSYLVANIA Appellant VS. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, : CIVIL ACTION - LAW : NO. 10-7116 CIVIL Appellee Parcel No. 09-19-1596-048 TO THE PROTHONOTARY: REAL ESTATE TAX ASSESSMENT APPEAL PRAECIPE Please enter my appearance on behalf of the Appellee, Cumberland County Board of Assessment Appeals, in the above captioned matter. Dated: Respectfully submitted, of Assessment Appeals 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D.#32318 Stephen D. Tiley, Esquire Attorney for Cumberland County Board 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: 717-243-644J IN RE: WEST SHORE COUNTRY : IN THE COURT OF COMMON PLEAS CLUB, : OF CUMBERLAND COUNTY, : PENNSYLVANIA Appellant VS. CIVIL ACTION - LAW CUMBERLAND COUNTY BOARD OF NO. 10-7116 CIVIL ASSESSMENT APPEALS, Appellee REAL ESTATE TAX ASSESSMENT APPEAL Parcel No. 09-19-1596-048 ANSWER AND NOW, comes Appellee Cumberland County Board of Assessment Appeals, by its attorney, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor for Tax Matters, and files this Answer to the "Petition for Allowance of Appeal from the Notice of the Board of Assessment Appeals of Cumberland County," of which the following is statement: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted in part. Denied in part. It is admitted that the Appellant is dissatisfied with its assessment. It is denied that Appellant has a valid reason to be aggrieved and dissatisfied, in that it is denied that the property is over-assessed. Strict proof at trial is demanded. By way of further Answer, the averments of this paragraph set forth conclusions of law to which no responsive pleading is required. 7. Denied. The averments of this paragraph set forth conclusions of law to which no responsive pleading is required. Strict proof at trial is demanded. 8. Denied. The averments of this paragraph set forth conclusions of law to which no responsive pleading is required. Strict proof at trial is demanded. By way of further Answer, the Common Level Ratio published by the State Tax Equalization Board is inapplicable to this appeal as the appeal emanates from the year 2010 Countywide reassessment. The Common Level ration is 100% of year 2010 fair market value. Because of the Countywide reassessment, the State Tax Equalization Board revised the Common Level Ratio to 100%. 9. Denied. The averments of this paragraph set forth conclusions of law to which no responsive pleading is required. Strict proof at trial is demanded. By way of further Answer, the Common Level Ratio published by the State Tax Equalization Board is inapplicable to this appeal as the appeal emanates from the year 2010 Countywide reassessment. The Common Level ration is 100% of year 2010 fair market value. Because of the Countywide reassessment, the State Tax Equalization Board revised the Common Level Ratio to 100%. 10. Denied. The averments of this paragraph set forth conclusions of law to which no responsive pleading is required. Strict proof at trial is demanded. 11. Admitted in part. Denied in part. It is admitted that Appellant has the right to appeal the decision of the Board of Assessment Appeals to the Court of Common Pleas of Cumberland County pursuant to 72 P.S. §5453.704. The reference to Section 5350 is to the Third Class County Assessment law which is inapplicable at this time. References to Section 5020-518.1 and 5020-518.2 are to the General County Assessment Law but those provisions are superceded by Section 5453.704. It is noted that the said assessment laws were consolidated effective January 1, 2011 by the Consolidated County Assessment Law with the applicable appeal to Court provision being at 53 Pa. C. S. A. §8854. 12. Admitted in part. Denied in part. The averments of paragraph 6 of this Answer are incorporated herein. It is admitted that Appellant is entitled to a de novo hearing by the Court of Common Pleas. WHEREFORE, Appellee, Cumberland County Board of Assessment Appeals, prays Your Honorable Court for an Order denying the appeal, or, fixing the fair market value, and assessment, of the property in such amount as the Court may deem just and proper. Dated: `?'?''' Respectfully submitted, By- Stephen D. Tiley, 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: WEST SHORE COUNTRY : IN THE COURT OF COMMON PLEAS CLUB, : OF CUMBERLAND COUNTY, : PENNSYLVANIA Appellant VS. : CIVIL ACTION - LAW CUMBERLAND COUNTY BOARD OF NO. 10-7116 CIVIL ASSESSMENT APPEALS, Appellee REAL ESTATE TAX ASSESSMENT APPEAL Parcel No. 09-19-1596-048 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing Answer and Praecipe by placing a true and correct copy of the same in the United States mail, postage pre-paid, addressed to: David A. Schneider, Esquire ARCHER & GREINER, P.C. Attorney for Appellant 700 Alexander Park, Suite 102 Princeton, NJ 08540 Tel. No. (609)-580-3700 Carl P. Beard, Esquire ANDREWS & BEARD Attorney for East Pennsboro School Dist 3366 Lynnwood Drive Altoona, PA 16603-1311 Joseph A. Curcillo, III, Esquire BEINHAUR & CURCILLO Attorney for East Pennsboro Township 3964 Lexington Street Harrisburg, PA 17109-2618 Date: '?W, . l Stephen D. Tiley, Esquire Assistant Cumb. Co. Solicitor 5 S. Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney I.D.#32318 G IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WEST SHORE COUNTRY CLUB, No. 10-7116 CIVIL m' Appellant _ ' vs. -71 ENTRY OF APPEARANCE CUMBERLAND COUNTY BOARD Filed on Behalf of: a, OF ASSESSMENT APPEALS, EAST PENNSBORO AREA SCHOOL DISTRICT Parcel No. 09-19-1596-048 Counsel of Record for this Party: Appellee EAST PENNSBORO AREA SCHOOL Interested Party PATRICK J. FANELLI, ESQUIRE PA. ID. No. 85640 ANDREWS & BEARD 3366 Lynnwood Drive PO Box 1311 Altoona, PA 16603-1311 (814) 943-3304 pfanelli _andrewsbeard.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WEST SHORE COUNTRY CLUB, No. 10-7116 CIVIL Appellant vs. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Parcel No. 09-19-1596-048 Appellee EAST PENNSBORO AREA SCHOOL Interested Party PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the undersigned on behalf of the East Pennsboro Area School District, in the above-captioned matter. Pdfri k J. nelli, Esquire P.A. I \D. N . 85640 3366 L ood Drive P.O. Box 1311 Altoona, PA 16603-1311 Attorney for School District Dated: June 15, 2011 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WEST SHORE COUNTRY CLUB, Appellant vs. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Parcel No. 09-19-1596-048 Appellee EAST PENNSBORO AREA SCHOOL Interested Party No. 10-7116 CIVIL CERTIFICATE OF SERVICE I, Patrick J. Fanelli, Esquire, hereby certify that the foregoing PRAECIPE FOR ENTRY OF APPEARANCE was served this 15th day of June, 2011, via US First Class Mail, on the following: Stephen D. Tiley, Esquire 5 S. Hanover Street Carlisle, PA 17103 Joseph A. Curcillo, III, Esquire 3964 Lexington Street Harrisburg, PA 17109-2618 David A. Schneider, Esquire 700 Alexander Park Ste 102 Princeton, NJ 08540 AND,RF-W,S & B P&ic J. Aelli, Inquire P.A. I. "N .85640 3366 Lynnwood Drive P.O. Box 1311 Altoona, PA 16603-1311 Attorney for School District John G. French, Esquire Attorney for Cumberland County Board of Assessment Appeals 1 Courthouse Square, Room 107 Carlisle, PA 17013 IN RE: WEST SHORE COUNTRY CLUB, Attorney I.D. No. 90788 Tel.: 717-759-5297 IN THE COURT OF COMMON • PLEAS OF CUMBERLAND C) Appellant mc�7 rn vs. uyr CUMBERLAND COUNTY BOARD OF : NO. 10-7116 CIVIL TERM r - ASSESSMENT APPEALS, z a Appellant : REAL ESTATE TAX --s : ASSESSMENT APPEAL Parcel No. 09-19-1596-048 PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE PURSUANT TO PA. R.CIV.P. 1012(b) f`.3 tit cr; Please withdraw my appearance on behalf of the Appellee Cumberland County Board of Assessment Appeals, in the above captioned matter, Dated: ..)-,-J.9/ / 6,20 /7 817569.1 Respectfully submitted, Byj'�=�� / , Stephen 1 . 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: / Z Respectfully submitted, By z Jo 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: WEST SHORE COUNTRY : IN THE COURT OF COMMON CLUB, vs. Appellant : PLEAS OF CUMBERLAND • • CUMBERLAND COUNTY BOARD OF : NO. 10-7116 CIVIL TERM ASSESSMENT APPEALS, Appellant Parcel No. 09-19-1596-048 • : 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: David A. Schneider, Esquire Attorney for Appellant Archer & Greiner, PC 700 Alexander Park, Suite 102 Princeton, NJ 08540 Carl P. Beard, Esquire Solicitor for East Pennsboro School District 3366 Lynnwood Drive Altoona, PA 16603-1311 Joseph A. Curcillo, Esquire Solicitor for East Pennsboro Township 3964 Lexington Street Harrisburg, PA 17109-2618 John G. French IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WEST SHORE COUNTRY CLUB, No. 10-7116 CIVIL Appellant vs. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Parcel No. 09-19-1596-048 Appellee EAST PENNSBORO AREA SCHOOL Interested Party ENTRY OF APPEARANCE CT rri CD Counsel for: EAST PENNSBORO AREA SCHOOL DISTRICT Carl P. Beard, Esquire Pa. Id. No. 33479 Ronald N. Repak, Esquire Pa. Id. No. 309138 ANDREWS & BEARD 3366 Lynnwood Drive P.O. Box 1311 Altoona, PA 16602 (814) 943-3304 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WEST SHORE COUNTRY CLUB, No. 10-7116 CIVIL Appellant vs. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Parcel No. 09-19-1596-048 Appellee EAST PENNSBORO AREA SCHOOL Interested Party PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Patrick J. Fanelli, Esquire, and enter the appearance of Carl P. Beard, Esquire and Ronald N. Repak, Esquire of Andrews & Beard, on behalf of East Pennsboro Area School District. ANDREWS & BEARD Carl P. Beard, Esquire Pa. Id. No. 33479 Ronald N. Repak, Esquire Pa. Id. No. 309138 3366 Lynnwood Drive P.O. Box 1311 Altoona, PA 16602 (814) 943-3304 FAX (814)-943-3430 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WEST SHORE COUNTRY CLUB, No. 10-7116 CIVIL Appellant vs. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Parcel No. 09-19-1596-048 Appellee EAST PENNSBORO AREA SCHOOL Interested Party CERTIFICATE OF SERVICE I, Carl P. Beard, Esquire, hereby certify that a true and correct copy of the foregoing Entry of Appearance has been served on the following parties of record by U.S. First Class Mail, postage pre -paid on this 28th day of May, 2014: John G. French, Esquire Solicitor for Cumberland County 1 Courthouse Square, Room 107 Carlisle, PA 17013 Joseph A. Curcillo, Ill, Esquire Solicitor for East Pennsboro Township 3964 Lexington Street Harrisburg, PA 17109 David A. Schneider, Esquire Archer & Greiner, PC 700 Alexander Park Ste 102 Princeton, NJ 08540 ANDREWS & BEARD Carl P. Beard, Esq Pa. Id. No. 33479 Ronald N. Repak, Esquire Pa. Id. No. 309138 3366 Lynnwood Drive P.O. Box 1311 Altoona, PA 16602 (814) 943-3304