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Home My WebLink About10-7139Wayne C. Kruzek, Esq. Stavitsky & Associates LLC 341 Broad Street Clifton, New Jersey 07013 (973) 594-9292 ATTORNEY FOR PETITIONER r -PE 12 AM 10 - 5 NF LEASING CORPORATION DBA NEIL FUNERAL SERVICES c/o SCI FUNERAL SERVICES, V. Petitioner, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, BOROUGH OF CAMP HILL AND THE CAMP HILL SCHOOL DISTRICT, Respondents. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW -113-1 NO. of 2010 PETITION FOR APPEAL FROM THE DECISION OF THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS AND NOW COMES, NF Leasing Corporation DBA Neil Funeral Services c/o SCI Funeral Services, by and through its counsel, Stavitsky & Associates LLC, and files this Petition for Appeal from the Cumberland County Board of Assessment Appeals, and in support thereof avers as follows: 1. NF Leasing Corporation DBA Neil Funeral Services c/o SCI Funeral Services, ("Petitioner") is a business with an address of 1929 Allen Parkway, Houston, Texas 77219. 2. Petitioner is the owner of a certain tax assessment parcels, together with all improvements, identified by Parcel Number 01-21-0273-378 ("Premises"). 3. Respondent, Cumberland County Board of Assessment Appeals ("Board"), is a board for assessment and revision of taxes within the general assessment law of the Commonwealth of Pennsylvania. 4. The Premises are located within the boundaries of Cumberland County, Camp Hill Borough and Camp Hill School District. A true and correct copy of this Petition shall be served forthwith upon the municipality and school district. a?„ 1 U uo Cwt Q? 5. For the purposed of the 2011 tax year, the Board assessed the Premises, which is designated with Parcel Number 01-21-0273-378 as follows: LAND $ 370,900 IMPROVEMENTS $ 1,820,900 TOTAL $ 2,191,800 6. On or about July 27, 2010 Petitioner filed a Commercial Assessment Appeal Form with the Cumberland County Board of Assessment Appeals. 7. On October 22, 2010 a hearing was held before the Board. 8. On October 27, 2010 the Board issued two decisions denying a reduction in the tax assessment for Parcel Number 01-21-0273-378. A true and correct copy denying a reduction in the tax assessment is attached hereto as "Exhibit A" and incorporated herein by reference. 9. Petitioner alleges that the decision denying a reductions is improper, unsatisfactory and unlawful for one or more of the following reasons: a. The assessment on Petitioner's property is substantially higher than assessments of comparable properties in the taxing district. b. The assessment is based upon an erroneous determination of the fair market value, particularly as it concerns Petitioner's property. C. The value determination by the Cumberland County Board of Assessment Ipeals violates the Equal Protection Clause of the 14` Amendment of the United States Constitution. d. The impact of the assessment bears unequally on the Petitioner when compared to the assessment of the properties of the same class. e. When related to assessments of similarly situated property owners, the assessment of the Premises of the Petitioner is arbitrary and capricious. f. The assessment violates the Uniformity Clause of the Pennsylvania Constitution. g. The assessment violates the required equality of tax treatment guaranteed by the Pennsylvania Statutory and Constitutional Law. h. The assessment is based in whole or in part upon appraisals that do not represent the actual value of the said Premises. i. The ratio of assessed value to actual value applied in making the assessments is in excess of the ratio applied throughout the taxing district. j. The assessment as determined by the Cumberland County Board of Assessment Appeals does not reflect the current market value of the Premises as multiplied by the state mandated ratio and determined by the State Tax Equalization Board. k. The assessment lacks uniformity. 1. The assessment is discriminatory. M. The assessment is otherwise unjust and inequitable. WHEREFORE, Petitioner requests this Honorable Court reverse the Decision of the Cumberland County Board of Assessment Appeals, reduce the assessment and thereafter make all necessary orders and decrees to effectuate said Decision. Respectfully submitted, STAVITSKY & ASSOCIATES LLC By: ?, --"" ' ? /(t/ AYNE . R EK, ESQ. 341 Br d Street Clifton, New Jersey 07013 (973) 594-9292 Pennsylvania Bar #209150 EXHIBIT A ii i??j Cumberland County Board of Assessment Appeals Oltl Courthouse, First Floor One Courthouse Square Carlisle, PA 17013 01002126-F3-2 NFH LEASING CORPORATION C/O BRUCE J. STAVITSKY, ESQ. STAVITSKY & ASSOCIATES 341 BROAD STREET CLIFTON NJ 07013 RECEIVED NOV 0 1 2010 Cumberland County Board of Commissioners Gary Eichelberger, Chairman Richard L. Rovegno, Vice-Chairman Barbara B. Cross, Secretary UMBER, AN 'CJI 7 F AA SES:;MENT 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: 10/27/2010 Munic.: 01 - CAMP HILL BORO School: 2 - CAMP HILL SD Location: 3401 MARKET STREET LOT 1 & 2 TRACT 1 PB 45&57 PO Taxable Property Property Type: C5 Commercial - General (Grp 5) DECISION: Denied As of October 22, Auxiliary Boards appeal. Parcel Identifier: 01-21-0273-378. Effective for Tax Year: 2 011 APPEALED BOARD DECISION ASSESSED VALUE ASSESSED VALUE Land 370,900 370,900 Buildings 1,820,900 1,820,900 TOTAL 2,191,800 2,191,800 7 a NOT NOT dings B uil APPLICABLE APPLICABLE T L Tax Status Taxable Taxable Clean and Green Status - No Change. 2010, the Board of Assessment Appeals and/or one of its has issued the above decision regarding your formal assessment 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 Schorpp, Solicitor NFH LEASING CORPORATION Wayne C. Kruzek, Esq. F g° =- g Stavitsky & Associates LLC + Nov 341 Broad Street ( Clifton, New Jersey 07013 594 9292 973 s :a a; t - ( ) ATTORNEY FOR PETITIONEWEE l N SY NF LEASING CORPORATION DBA NEIL FUNERAL SERVICES c/o SCI FUNERAL SERVICES, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Petitioner, CIVIL ACTION-LAW NO. of 2010 CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, BOROUGH OF CAMP HILL AND THE CAMP HILL SCHOOL DISTRICT, Respondents. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY/CLERK OF SAID COURT: Enter my appearance on behalf of NF Leasing Corporation dba Neil Funeral Services c/o SCI Funeral Services, Papers may be served at the address set forth below: Wayne C. Kruzek, Esa. Attorney for Parry Named Above Supreme Court ID No.:209150 Firm: Stavitsky & Associates LLC Address: 341 Broad Street, Clifton-New Jersey 07013 Telephone No.: 973-594-9292 Facsimile: 973-594-9977 Date: Signature: Lf)A. . /1", W ne ruzek, Esq. Wayne C. Kruzek, Esq. Stavitsky & Associates LLC 341 Broad Street Clifton, New Jersey 07013 (973) 594-9292 ATTORNEY FOR PETITIONER NF LEASING CORPORATION DBA NEIL FUNERAL SERVICES c/o SCI FUNERAL SERVICES, V. Petitioner, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, BOROUGH OF CAMP HILL AND THE CAMP HILL SCHOOL DISTRICT, Respondents. p!ir?S',??,e?. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW NO 13of 2010 CERTIFICATE OF SERVICE I, Wa ne C. Kruzek, Esq., hereby certify that on the day of (N U 6v-, 2010, I served a copy of the Petition directed to the Respondents by First Class United States Mail, postage prepaid addressed to: Cumberland County Board of Assessment Solicitor, Cumberland County Appeals I Courthouse Square Old Courthouse, First Floor Carlisle, Pennsylvania 17013 One Courthouse Square Carlisle, Pennsylvania 17013 Camp Hill Borough Solicitor Solicitor, Borough Administration Bldg. Camp Hill School District 2145 Walnut Street 2627 Chestnut Street Camp Hill, Pennsylvania 17011 Camp Hill, Pennsylvania 17011 B y. /Ze" j ayne ek, Esq. 341 Br d Street Clifton, New Jersey 07013 (973) 594-9292 Pennsylvania Bar #209150 ? r NF LEASING CORPORATION IN THE COURT OF COMMON PLEAS DBA NEIL FUNERAL SERVICES CUMBERLAND COUNTY, PENNSYLVANIA c/o SCI FUNERAL SERVICES Petitioner V. : o CUMBERLAND COUNTY BOARD zM c::) M - OF ASSESSMENT APPEALS, -°? „ BOROUGH OF CAMP HILL AND THE -<> Cn C-5 CAMP HILL SCHOOL DISTRICT, Respondent NO. 10-7139 CIVI L v ? ORDER OF COURT AND NOW, this 16th day of November, 2010, upon consideration of Petition for Appeal from the Decision of the Cumberland County Board of Assessment Appeals, IT IS HEREBY ORDERED AND DIRECTED that a hearing on this matter will be held on Friday, May 20, 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 May 6, 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. I . -P 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, ?Wayne C. K ruzek, Esquire Attorney for Petitioner tephen Tiley, Esquire For Cumberland County bas Ld Wayne C. Kruzek, Esq. Stavitsky & Associates LLC 341 Broad Street Clifton, New Jersey 07013 (973) 594-9292 ATTORNEY FOR PETITIONER 1LE0-?,k r 1 , E11MC?' 181?Iw 13 P NF LEASING CORPORATION DBA NEIL FUNERAL SERVICES c/o SCI FUNERAL SERVICES, Petitioner, V. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, BOROUGH OF CAMP HILL AND THE CAMP HILL SCHOOL DISTRICT, Respondents. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW NO. 7139 of 2010 CERTIFICATE OF SERVICE I, Wayne C. Kruzek, Esq., hereby certify that on the _IS- day of _Nove'ut 2010, I served a copy of the Petition directed to the Respondents by First Class United States Mail, postage prepaid addressed to: Cumberland County Board of Assessment Solicitor, Cumberland County Appeals I Courthouse Square Old Courthouse, First Floor Carlisle, Pennsylvania 17013 One Courthouse Square Carlisle, Pennsylvania 17013 Camp Hill Borough Solicitor Solicitor, Borough Administration Bldg. Camp Hill School District 2145 Walnut Street 2627 Chestnut Street Camp Hill, Pennsylvania 17011 Camp Hill, Pennsylvania 17011 By: Wayne C. Kruzek, Esq. 341 Broad Street Clifton, New Jersey 07013 (973) 594-9292 Pennsylvania Bar #209150 NAUMAN, SMITH, SHISSLER & HALL, LLP By: J. Stephen Feinour, Esquire Supreme Court ID#24580 200 North Third Street, P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 Facsimile: (717) 234-1925 2110 DEC 22 AN 10: t;. ;j CUMBERLAND CG'!,N '' EN14s YLVAtgja e-mail: sfeinournnssh.com NF LEASING CORPORATION DBA NEIL FUNERAL SERVICES c/o SCI FUNERAL SERVICES, Petitioner vs. Attorneys for Borough of Camp Hill IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, BOROUGH Docket No. 2010-7139 OF CAMP HILL AND THE CAMP HILL SCHOOL DISTRICT, Respondents PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of J. STEPHEN FEINOUR, ESQUIRE, of Nauman, Smith, Shissler & Hall, LLP on behalf of the Borough of Camp Hill, in the above-referenced proceeding. NAUMAN, SMITH, SHISSLER & HALL, LLP Step en Feinour, Esquire upreme Court ID #24580 200 North Third Street, 18`h Floor P. O. Box 840 Harrisburg, PA 17108-0840 Phone: 717-236-3010 Fax: 717-234-1925 E-Mail: sfeinour@nssh.com Solicitor for the Borough of Camp Hill Date: December 21, 2010 CERTIFICATE OF SERVICE AND NOW, on the date stated below, I, J. Stephen Feinour, Esquire, of the firm of Nauman, Smith, Shissler & Hall, LLP, hereby certify that I this day served the foregoing "Praecipe for Entry of Appearance" by depositing a copy of the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pennsylvania, addressed to the following: Wayne C. Kruzek, Esquire Attorney for Petitioner Stavitsky & Associates, LLC 341 Broad Street Clifton, NJ 07013 Richard W. Stewart, Esquire Solicitor for Camp Hill School District Johnson Duffle 301 Market Street P. O. Box 109 Lemoyne, PA 17043 Stephen D. Tiley, Esquire Solicitor for Cumberland Co. Board of Assessment Appeals 5 South Hanover Street Carlisle, PA 17013 Edward L. Schorpp, Esquire Cumberland County Solicitor 35 Thrush Drive Carlisle, PA 17013 NAUMAN, SMITH, SHISSLER & HALL, LLP B- J. Stephen Feinour, Esquire Supreme Court ID# 24580 200 North Third Street, P. O. Box 840 Harrisburg, PA 17108-0840 Telephone: (717) 236-3010 E-Mail: sfeinour@nssh.com Counsel for the Borough of Camp Hill Date: December 21, 2010 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 NF LEASING CORPORATION : IN THE COURT OF COMMON PLEAS, DBA NEIL FUNERAL SERVICES, : OF CUMBERLAND COUNTY, c/o SCI FUNERAL SERVICES, : PENNSYLVANIA Petitioner VS. : CIVIL ACTION - LAW CUMBERLAND COUNTY BOARD OF NO 2010-7139 . ASSESSMENT APPEALS, BOROUGH c ? OF CAMP HILL AND THE CAMP HILL ' ,., ` SCHOOL DISTRICT zF ' r= Respondents REAL ESTATE TAX ASSESSMENT APPEAL Parcel No. 01-21-0273-378 5(-- -- o -' ANSWER AND NOW, comes Respondent, 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 Petitioner's "Petition for Appeal from the Decision of the Cumberland County Board of Assessment Appeals," of which the following is statement: Admitted. By way of further Answer, taxpayer's address on the assessment records is different than in paragraph 1 of its Petition. No change of address will be made on the assessment records without specific direction. 2. Admitted in part. Denied in part. The averments of this paragraph are admitted except that Petitioner is incorrectly identified in the caption of the Petition, and at paragraph 1 of the Petition as "NF Leasing Corporation." The deed into the owner of this property recites as the Grantee: "NFH Leasing Corporation." 3. Admitted. By way of further Answer, the Board is more specifically a Board of Assessment Appeals within The Fourth to Eighth to Class County Assessment Law (72 P. S. §5453.101 et sic) replaced effective January 1, 2011 by The Consolidated County Assessment Law (53 Pa. C.S.A. 8301 et sic.) 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted except that the Board issued a single decision denying the requested reduction in assessment, as set forth in Exhibit "A" of the Petition. 9. 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 the appeal, or, in the alternative, fixing the fair market value, and assessment, of the property, in such amount as the Court may deem just and proper. Dated:M /( Respectfully submitted, Y 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: onnie 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 NF LEASING CORPORATION : IN THE COURT OF COMMON PLEAS, DBA NEIL FUNERAL SERVICES, : OF CUMBERLAND COUNTY, c/o SCI FUNERAL SERVICES, : PENNSYLVANIA Petitioner VS. : CIVIL ACTION - LAW CUMBERLAND COUNTY BOARD OF NO. 2010-7139 ASSESSMENT APPEALS, BOROUGH OF CAMP HILL AND THE CAMP HILL SCHOOL DISTRICT, Respondents REAL ESTATE TAX ASSESSMENT APPEAL Parcel No. 01-21-0273-378 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing Answer to by placing a true and correct copy of the same in the United States mail, postage pre-paid, addressed to: Wayne C. Kruzek, Esquire STAVITSKY & ASSOCIATES, LLC Attorney for Petitioner 341 Broad Street Clifton, NJ 07013 Tel. No. (973)-594-9292 J. Stephen Feinour, Esquire NAUMAN SMITH SHISSLER & HALL, LLP Attorney for Camp Hill Borough 200 N. Third Street, P.O. Box 840 Harrisburg, PA 17108-0840 Richard W. Stewart, Esquire JOHNSON DUFFIE STEWART & WEIDNER Attorney for Camp Hill School Dist. 301 Market St., P.O. Box 109 Lemoyne, PA 17043 Date: ysr? c?7 Stephen D. Tiley, Esquire Assistant Cumb. Co. Solicitor 5 S. Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney I.D.#32318 John C.Hyon,Esq. d Stavitsky&Associates LLC 350 Passaic Ave ' , Fairfield,New Jersey 070041 • (973)227-1912 r'UM ERRAND COUNry ATTORNEY FOR PETITIONER P 'NNS YL IVA N Jk NF LEASING CORPORATION d/b/a NEIL IN THE COURT OF COMMON PLEAS OF FUNERAL SERVICES c/o SCI FUNERAL CUMBERLAND COUNTY SERVICES, Petitioner, CIVIL ACTION-LAW V. NO. 10-7139 CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, BOROUGH OF CAMP HILL AND THE CAMP HILL SCHOOL DISTRICT, Respondents. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY/CLERK OF SAID COURT: Enter my appearance on behalf of NF Leasing Corporation d/b/a Neil Funeral Services c/o SCI Funeral Services, Papers may be served at the address set forth below: John C. Hyon, Esq. Attorney for Parry Named Above Supreme Court ID No.: 310683 Firm: Stavitsky & Associates LLC Address: 350 Passaic Ave, Fairfield,New Jersey� 7004 Telephone No.: 973-227-1912 Facsimile: 973-227-1925 Date: 113 Signature• C. hn o n,, Esq. John G. French, Esquire Attorney for Cumberland County Board of Assessment Appeals 1 Courthouse Square, Room 107 Carlisle, PA 17013 Attorney I.D. No. 90788 APPEAL OF NF LEASING CORPORATION DBA NEIL FUNERAL SERVICES CIO SCI FUNERAL SERVICES, Petitioner VS. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, BOROUGH OF CAMP HILL AND THE CAMP HILL SCHOOL DISTRICT, Respondents MUNICIPALITY: BOROUGH OF CAMP HILL Parcel No. 01-21-0273-378 Tel.: 717-759-5297 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA rn rn r— n NO. 10-7139 CIVIL TERMS •` REAL ESTATE TAX ASSESSMENT APPEAL PRAECIPE FOR WITHDRAWAL/ENTRY OF APPEARANCE PURSUANT TO PA. R.CIV.P. 1012(b) -a Please withdraw my appearance on behalf of the Appellee Cumberland County Board of Assessment Appeals, in the above captioned matter. Dated: ,t-nq 817569.1 Respectfully submitted, Byc �-7 Stephen IL 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, By 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 APPEAL OF NF LEASING CORPORATION DBA NEIL FUNERAL SERVICES C/O SCI FUNERAL SERVICES, Petitioner vs. : IN THE COURT OF COMMON : PLEAS OF CUMBERLAND : COUNTY, PENNSYLVANIA • • • CUMBERLAND COUNTY BOARD OF • ASSESSMENT APPEALS, BOROUGH OF CAMP HILL AND THE CAMP HILL • SCHOOL DISTRICT, Respondents REAL ESTATE TAX MUNICIPALITY: ASSESSMENT APPEAL BOROUGH OF CAMP HILL NO. 10-7139 CIVIL TERM Parcel No. 01-21-0273-378 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: Wayne C. Kruzek, Esquire STAVITSKY & ASSOCIATES, LLC Attorney for Petitioner 341 Broad Street Clifton, NJ 07013 J. Stephen Feinour, Esquire NAUMAN SMITH SHISSLER & HALL, LLP Attorney for Camp Hill Borough 200 N. Third Street, P.O. Box 840 Harrisburg, PA 17108-0840 Richard W. Stewart, Esquire JOHNSON DUFFLE STEWART & WElDNER Attorney for Camp Hill School District 301 Market Street, P.O. Box 109 Lemoyne, PA 17043 John G. French, Esquire Andrew W. Hood, Esq. Stavitsky & Associates LLC 350 Passaic Avenue Fairfield, New Jersey 07004 (973) 227-1912 ATTORNEY FOR PETITIONER Jj ED - T, pRoTHoNorAi;if 20111 SEP 15 ss CUNBERL/ PENNsVP COUNT y IN THE COURT OF COMM ON PLEAS OF NF LEASING CORPORATION d/b/a NEIL FUNERAL SERVICES c/o SCI FUNERAL SERVICES Petitioner, V. CUMBERLAND COUNTY BOARD OF ASESSMENT APPEALS, BOROUGH OF CAMP HILL and THE CAMP HILL SCHOOL DISTRICT, Respondents. PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY/CLERK OF SAID COURT: CUMBERLAND COUNTY CIVIL ACTION -LAW NO. 10-7139 Enter my appearance on behalf of NJ Leasing Corporation d/b/a Neil Funeral Services c/o SCI Funeral Services. Papers may be served at the address set forth below: Andrew W. Hood, Esq. Attorney for Party Named Above Supreme Court ID No.:34640 Firm: Stavitsky & Associates LLC Address: 350 Passaic Ave, Fairfield, New Jersey 07004 Telephone No.: 973-227-1912 Facsimile: 97 7-1925 Date: kt9 Signature: Andrew W. Hood, Esq. • Andrew W. Hood, Esq. Stavitsky & Associates LLC 350 Passaic Ave Fairfield, New Jersey 07004 (973) 227-1912 ATTORNEY FOR PETITIONER NF LEASING CORPORATION d/b/a NEIL FUNERAL SERVICES c/o SCI FUNERAL SERVICES, Petitioner, v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW NO. 10-7139 CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, BOROUGH OF CAMP HILL and THE CAMP HILL SCHOOL DISTRICT, Respondents. CERTIFICATE OF SERVICE I, Andrew W. Hood, Esq., hereby certify that on the 1 day of , 2014, I served a copy of the Entry of Appearance directed to the Respondents by First Class United States Mail, postage prepaid addressed to: Cumberland County Board of Assessment Appeals Old Courthouse, 1st Floor One Courthouse Square Carlisle, PA 17013 Camp Hill Borough Solicitor Borough Administration Bldg. 2145 Walnut Street Camp Hill, PA 17011 By: Solicitor, Cumberland County 1 Courthouse Square Carlisle, PA 17013 Solicitor, Camp Hill School District 2627 Chestnut Street Camp Hill, PA 17011 ANDREW W. HOOD, ESQUIRE 350 Passaic Ave Fairfield, New Jersey 07004 (973) 227-1912 Supreme Court ID No.: 34640