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HomeMy WebLinkAbout02-1310IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW COLLEGE PARK APARTMENTS Petitioner, VS. BOARD OF ASSESSMENT APPEALS Respondent. :: PETITION FOR REVIEW OF REAL ESTATE ASSESSMENTS TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The Petitioner is College Park Apartments and is represented by Garippa, Lotz & Giannuario, 66 Park Street, P.O. Box 1584, Montclair, New Jersey 07042. 2. The respondent is the Board of Assessment Appeals, whose address is Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. 3. The petitioner is the owner of the premises known as Tax Map No. 06-19-1645-060, Borough of Carlisle, Pennsylvania. 4. Sometime in 2001, the petitioner was informed that the assessment for the above premises was fixed for the year 2002 at $6,266,450. 5. The petitioner filed notices of its intention to appeal to the Board the assessment referred to in paragraph 4 hereof. A hearing was held by the Board at which such time the appeal was heard. 6. By notice dated February 26, 2002, the petitioner was informed that the Board had affirmed the assessment. (See Exhibit A attached hereto). 7. The assessment of the premises known as Tax Map No. 06-19-1645-060, Borough of Carlisle, Pennsylvania, as fixed by the Board is excessive, improper, unjust and contrary to law for the following reasons: (a) The assessment is based in whole or in part upon an appraisal that does not represent the actual value of the said premises. (b) The ratio of assessed value to actual value applied in making the assessment is in excess of the ratio applied through the taxing authority. The assessment lacks uniformity. (c) (d) The assessment is discriminatory. (e) The assessment is otherwise unjust and inequitable. WHEREFORE, the petitioner requests that the Court review and reduce the assessments fixed for the taxable year 2002, for the premises known as Tax Map No. 06-19- 1645-060, Borough of Carlisle, Pennsylvania, and make such other orders and decrees with respect thereto as shall be just and proper. GI~GORY ~r. Ld~rz, ESQ. Garippa, Lotz & Giannuario 66 Park Street, P.O. Box 1584 Montclair, New Jersey 07042 973-744-1688 Attorney for Petitioner Attorney ID No. 43603 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 Chlsf Assessor STEVEN D. TILEY Assistant Solicitor CORRECTED DECISION ORDER COLLEGE PARK APARTMENTS C/O AIMCO EPROPERTY TAX PO BOX 4900 DEPT #101 SCOTTSDALE AZ 85261-4900 Dear Property Owner: MAILING DATE: February 26, 2002 PARCEL N UMBER: 06-19-1 545-060. 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: 02/13/2002 DATE DECISION RENDERED: 02/23/2002 EFFECTIVE FOR TAX YEAR: DECISION RENDERED: [ ] Withdrawn By Applicant [ ] Abandoned For Failure To Appear [X] Denied - No Change [ ] Approved Review Appraiser's Changes [ ] Revised Assessment Based on Hearing [ ] Other: TOTAL VALUE FAIR MARKET CLEAN AND GREEN CLEAN AND GREEN STATUS Old Assessed Value: 6,266,450 NOT New Assessed Value: 6,266,450 APPLICABLE THIS IS A CORRECTED DECISION ORDER OF ORIGINAL DATED NOVEMBER 2, 2001 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 March 28, 2002. LETTER, OF AUTHORIZATION KNOW ALL MEN BY THESE PRESENTS that Ganppa, Lotz & Giannuario and its designee(s) are l~ereb¥ authorized to represent and act on behalf of COLLEGE PAR}( ^PARTMENTS/AJMCO, with lull power of authority to take any and all action which is iidvisable or necessary in appealing the assessments levied on mai estate [axes owned by the undersigned as follows and such authority shall include, but not be limited to preparation, filing and negotiation of all at,peals and to preSent a~¥ evidence which may be I~e~nent to these filings. This authorization is applicable to the 2002 tax year until the term~atfo~ of said apl~eal. Property Identification Number(a): Parcel No. 06-t9-1645-060 Borough of Carlisle. Cumberland County, PA Typed signature: Corporate title: ~ o~[ P~~ O; ~ Sworn to me this ~'~ day of~ 2001 NOTARY PUBLIC CERTIFICATION OF VERIFICATION 1. I, Gregory G. Lotz, am an Attorney-at-law of the State of Pennsylvania and have been retained to represent the plaintiff in the within cause of action. 2. I have been authorized to file the within Petition on behalf of College Park Apartments. 3. The Certification of Verification is not executed by a corporate officer of College Park Apartments because said verification could not be obtained within the time prescribed by the statute and the rules of the court. 4. I am familiar with all of the facts contained in the within Petition. 5. I certify that all of the facts set forth in the within Petition are true and correct to the best of my knowledge and belief. I certify that if any of the foregoing statements contained within Petition are willfully false, I am subject to punishment. Garippa, Lotz. & Giannuado 66 Park Street, P.O. Box 1584 Montclair, New Jersey 07042 973-744-1688 Attorney for Petitioner Attorney ID No. 43603 Sworn and Subscribed to before me this Iqr'Wday of ~NX0uc,~V ,2002 LINDA C. JONES NOTARY PUBLIc OF NEW JERSEy MY COMMISSION EXPIREs NOV 18, 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :: COLLEGE PARK APARTMENTS :: No. Petitioner, :: :: V. :: :: BOARD OF ASSESSMENT APPEALS :: :: Respondent. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the Petition for Review of Real Estate Assessment and proposed Order in the entitled action has been served upon the following by way of certified mail: Board of Assessment Appeals Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 Stephen Tiley, Esq. Solicitor for Board of Assessment Appeals 5 S. Hanover Street Carlisle, Pennsylvania 17013 Chief Clerk's Office Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 Robert C. Saidis, Esq. Solicitor for Cumberland County 26 W. High Street Carlisle, Pennsylvania 17013 Clerk of Carlisle Borough 53 West South Street Carlisle, Pennsylvania 17013 Edward L. Schorpp, Esq. Solicitor for Carlisle Borough 10 E. High Street Carlisle, Pennsylvania 17013 Business Manager Carlisle Area School District 623 West Penn Street Carlisle, Pennsylvania 17013 James D. Flower, Jr., Esq. Solicitor for Carlisle Area School District 26 W. High Street Carlisle, Pennsylvania 17013-2922 G REGO'~Y ,~LO Garippa, Lcj~z.)8, Giannuar'j~ 66 Park Stl~t, P.O. Box ~1584 Montclair, Iqew Jersey 07042 973-744-1688 Attorney for Petitioner Attorney ID # 43603 COLLEGE PARK APARTMENTS Petitioner VS. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSESSMENT APPEAL PARCEL NO. 06-19-1645-060 AND NOW, comes the Cumberland County Board of Assessment Appeals by its attorney, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor, and files this Answer to Petitioner's Petition for Review of Real Estate Assessments of which the following is a statement: 1. Admitted. (Petitioner is actually College Park Apartments, L.P.) 2. Admitted. 3. Admitted. 4. Admitted. 6. Admitted. 7. Denied. The averments set forth in paragraph seven of the Petition for Review of Real Estate Assessments, and each of its sub-paragraphs, set forth conclusions of law for which no responsive pleading is required. Strict proof at trial is demanded. WItEREFORE, Respondent, Cumberland County Board of Assessment Appeals, Prays Your Honorable Court for an Order denying Petitioner's appeal Or fixing the value of the real estate at such other value as the Court may deed just and proper. Respectfully submitted, Dated: S{~phen~). Tiley, Esquire Attorney for Cumberland County Board of Assessment Appeals and Cumberland County 5 South Hanover Street Carlisle, PA 17013 (717) 2430-5838 Supreme Court I.D.#32318 COLLEGE PARK APARTMENTS Petitioner CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ASSESSMENT APPEAL PARCEL NO. 06-19-1645-060 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing Answer to the Petition for Review of Real Estate Assessments by placing a certified true and correct copy of the same in the United States mail, postage pre-paid, addressed to: Gregory G. Lotz, Esquire Garippa, Lotz & Giannuario 66 Park Street Montclair NJ 07042 Date: March 21,2002 St6phen'D. Tiley, Esquire Assistant Cumb. Co. Solicitor 5 S. Hanover Street Carlisle, PA 17013 (717) 243-5838 Attorney I.D.#32318 I verify that the statements made in the foregoing Answer are tree 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 unswom falsification to authorities. 'Bonnie M. M~lhoney Chief Assessor COLLEGE PARK APARTMENTS, : IN THE COURT OF COMMON PLEAS OF Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA BOARD OF ASSESSMENT APPEALS, : Respondent · 02-1310 CIVIL TERM AND NOW, this day of March, 2002, a hearing on the merits of the within petition shall be conducted in Courtroom No. 2, Cumberland County Courthouse, Carlisle, Pennsylvania, at 8:45 a.m., Thursday, July 25, 2002. By th~.C uo"u~', Edgar ey, J. /'G~regory G. Lotz, Esquire For Petitioner /~tephen Tiley, Esquire Solicitor For Board of Assessment Appeals ,/~obert C, Saidis, Esquire Solicitor for Cumberland County ,'L~dward L. Schorpp, Esquire Solicitor for Carlisle Borough J./~ames D. Flower, Jr., Esquire Solicitor for Carlisle Area School District :prs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COLLEGE PARK APARTMENTS :: No. 2002-01310 :: Petitioner, :: :: V. :: :: BOARD OF ASSESSMENT APPEALS :: :: Respondent. :: :: CERTIFICATE OF SERVICE The undersigned hereby certifies that a time-stamped and filed copy of the Petition for Review of Real Estate Assessment and proposed Order in the entitled action has been served upon the following by way of regular mail: Board of Assessment Appeals Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 Stephen Tiley, Esq. Solicitor for Board of Assessment Appeals 5 S. Hanover Street Carlisle, Pennsylvania 17013 Chief Clerk's Office Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013 Robert C. Saidis, Esq. Solicitor for Cumberland County 26 W. High Street Carlisle, Pennsylvania 17013 Clerk of Carlisle Borough 53 West South Street Carlisle, Pennsylvania 17013 Edward L. Schorpp, Esq. Solicitor for Carlisle Borough 10 E. High Street Carlisle, Pennsylvania 17013 Business Manager Carlisle Area School District 623 West Penn Street Carlisle, Pennsylvania 17013 James D. Flower, Jr., Esq. Solicitor for Carlisle Area School District 26 W. High Street Carlisle, Pennsylvania 17013-2922 Gafippa, Lotz ~nuario 66 Park Street, P.O. Box 1584 Montclair, New Jersey 07042 973-744-1688 Attorney for Petitioner Attorney ID # 43603 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COLLEGE PARK APARTMENTS .. Petitioner, BOARD OF ASSESSMENT APPEALS Respondent. NO. 2002-0'1310 ORDER AND NOW, on this ~ day of ~'d 2002, it is ORDERED that the hearing scheduled for July 25, 2002 at 8:45 a.m. is lenerally until discovery is completed. Upon completion of discovery, a trial date ma~q/~ed by a party. HON. E~A~. ~YLEY, J. VtNV/f]ASNNP, d ALHFiO,,q. JOHN E. GARIPPA o PHILIP J. GIANNUARIO GREGORY G. LOTZ LEE W. TURNER ~- BRIAN A, FOWLER LAW OFFICES GARIPPA, LOTZ & GIANNUARIO A PROFF~qSIONAL COR~OIL~TION 66 PARK STREET MONTCLAIR, NEW JERSEY 07042 (973) 744-1688 TELECOP1ER (973) 744-1641 E-MAIL: glg~taxappe~l.com WEB SITE: www.tax~ppesl.com ONE WORLD TRADE CENTER SUITE 7967 NEW YORK, N.Y. 10048 (21'~) 52,1-7714 12TM FLOOR, EAST TOWER CENTRE SQUARE 15o0 MARKET STREET PHILADELPHIA, PA 19102 (215) 66~-5657 May 28, 2002 Hon. Edgar B. Bayley Cumberland County Courthouse One Courthouse Square Carlisle, Pennsylvania 17013-3387 Re: College Park Apartments v. Cumberland County Board of Assessment Appeals Docket No. 2002-01310 Our File No. 5656 Dear Judge Bayley: Enclosed herein please find an original Order concerning the above captioned matter. I am requesting that you execute the Order and return a copy to my office in the self-addressed stamped envelope provided. Please note that my adversaries have consented to same. Thanking Your Honor for your anticipated cooperation, I remain, GGL/mt Enclosures cc: Stephen Tiley, Esq., w/enclosure James D. Flower, Jr., Esq., w/enclosure Robert C. Saidis, Esq., w/enclosure Edward L. Schorpp, Esq., w/enclosure COLLEGE PARK APARTMENTS Petitioner VS. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1310 CIVIL ASSESSMENT APPEAL : PARCEL NO. 06-19-1645-060 ~OTIO~-~._O_~A~~ AND NOW, this /J~ day of.~y, 2003, it is hereby agreed and stipulated between Petitioner, College Park Apartments, by its attorney's, Garippa, Lotz & Giannuario; and Respondent, Board of Assessment Appeals of Cumberland Count), and County of Cumberland, Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor; and Borough of Carlisle, by its attorneys Martson, Deardorff, Williams & Otto; and Carlisle Area School District by its attorneybsy Saidis, Shuff, Flower & Lindsay; as follows: Hearing date. · Y der dated March 25, 2002 the Court set a By Order dated May 30, 2002 the Court continued the Hearing generally. parties have now settled this case.The 2. The applicable year for which the above captioned assessment appeal was filed is the calendar year 2002. 3. The property which is the subject of this appeal is Cumberland County Assessment Parcel No. 06-19-1645-060. The property is situate in the Borough of Carlisle, Cumberland County, Pennsylvania, and consists of a 209 unit a Apartments. The ,,ro,-~----: .... partment complex kno n as College Park ~, ~,~Ly ~ s~tuate oft' of Waggoner's Gap Road. w_, 4. The parties stipulate that the total market value of the subject property as of the date the original petition to the Cumberland County Board of Assessment Appeals was filed shall be fixed at $5,600,000. 5. The common level ratio applicable to this appeal for the 2002 tax year, and following years, is inapplicable as it does not vary by more than 15% from the predetermined ratio. As a Stipulation and Joint Motion for Agreed Order College Park Apartments Page I of 3 result of the year 2000 Cumberland Countywide Reassessment, the predetermined ratio for Cumberland County is now 100% of year 2000 market value. Therefore, the assessment for the subject property shall be $5,600,000. 6. The Cumberland County Assessor's Office shall allocate the total assessment between land and improvements as provided by law and the procedures of the Cumberland County Assessment Office. 7. The new assessment shall be effective for tax years beginning on and after January 1,2002, including, therefore, tax years beginning on and after January 1,2002. The first taxes effected by this stipulation shall be year 2002 County and Municipal taxes and year 2002-2003 school real estate taxes. 8. The Cumberland County Assessment Office shall promptly notify the appropriate taxing bodies of the change in assessment, and instruct the taxing bodies to make appropriate refunds. 9. Each party to this appeal shall bear its own costs. 10. The Court is requested to enter the proposed Order' attached hereto. 11. The undersigned Attorneys each hereby warrants to the other and to the parties and to the Court that he has reviewed this Settlement Stipulation with his client or clients and that he has specifically been authorized to enter into this Settlement Stipulation by his client or clients. Respectfully Submitted, Date: ~-~/~ I/0...~ PETITIONER, COLLEGE PARK APARTMENTS By: C-~gory G. Ljafz, ~squ~e /' GARIPPA.,~OTZ a C~,I~"NUARIO 66 Park Street Montclair New Jersey 07042 (973) 744-1688 A~O~y FOR PETITIO~R Stipulation and Joint Motion for Agreed Order College Park Apartments Page 2 of 3 RESPONDENT, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS and COUNTY OF CUMBERLAND By: St'~phe,~eD~ Tiley, Esq ' Assistant Cumberland County Solicitor 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D. 321318 ATTORNEY FOR RESPONDENT RESPONDENT, BOROUGH OF CARLISLE Date: Edward L. Schorpl: MARTSON, DEARDORFF, WILLIAMS & OTTO 10 East High Street Carlisle, PA 17013 SOLICITOR FOR BOROUGH OF CARLISLE RESPONDENT, CARLISLE AREA SCHOOL DISTRICT Ja[nesD. Flower, Egqmre [ ,/ S$IDIS, SHUFF, FLOWER, & LINDa/~Y ~.~2~ West High Street -Carlisle, PA 17013 SOLICITOR FOR CARLISLE AREA SCHOOL DISTRICT Stipulation and Joint Motion for Agreed Order College Park Apartments Page 3 of 3 COLLEGE PARK APARTMENTS Petitioner VS. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1310 CIVIL ASSESSMENT APPEAL PARCEL NO. 06-19-1645-060 ORDER AND NOW, this ~ tT'~' day of ~ 2003, 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 as of the date applicable to this proceeding is $5,600,000. The common level ratio not varying by more than 15% from the predetermined ratio of 100%, 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 $5,600,000. 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 THEcouR~T,~.~ By: Edgar B. Bayley, COLLEGE PARK APARTMENTS Petitioner VS. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-1310 CIVIL ASSESSMENT APPEAL PARCEL NO. 06-19-1645-060 STIPULATION AND JOINT MOTION FOR AGREED ORDER o~".~.~ ~..- AND NOW, this /J~ day of ~.~.ay, 2003, it is hereby agreed and stipulated between Petitioner, College Park Apartments, by its attorney's, Garippa, Lotz & Giannuario; and Respondent, Board of Assessment Appeals of Cumberland County and County of Cumberland, by Stephen D. Tiley, Esquire, Assistant Cumberland County Solicitor; and Borough of Carlisle, by its attorneys Martson, Deardorff, Williams & Otto; and Carlisle Area School District by its attorneys Saidis, Shuff, Flower & Lindsay; as follows: 1. On or about March 14, 2002, Petitioner began this action by filing a Petition for Review of Real Estate Assessments to the Court. By Order dated March 25, 2002 the Court set a Hearing date. By Order dated May 30, 2002 the Court continued the Heating generally. The parties have now settled this case. 2. The applicable year for which the above captioned assessment appeal was filed is the calendar year 2002. 3. The property which is the subject of this appeal is Cumberland County Assessment Parcel No. 06-19-1645-060. The property is situate in the Borough of Carlisle, Cumberland County, Pennsylvania, and consists of a 209 unit apartment complex known as College Park Apartments. The property is situate off of Waggoner's Gap Road. 4. The parties stipulate that the total market value of the subject property as of the date the original petition to the Cumberland County Board of Assessment Appeals was filed shall be fixed at $5,600,000. 5. The common level ratio applicable to this appeal for the 2002 tax year, and following years, is inapplicable as it does not vary by more than 15% from the predetermined ratio. As a Stipulation and Joint Motion for Agreed Order College Park Apartments Page 1 of 3 result of the year 2000 Cumberland Countywide Reassessment, the predetermined ratio for Cumberland County is now 100% of year 2000 market value. Therefore, the assessment for the subject property shall be $5,600,000. 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 new assessment shall be effective for tax years beginning on and after January 1,2002, including, therefore, tax years beginning on and after Jannary 1, 2002. The first taxes effected by this stipulation shall be year 2002 County and Municipal taxes and year 2002-2003 school real estate taxes. 8. The Cumberland County Assessment Office shall promptly notify the appropriate taxing bodies of the change in assessment, and instruct the taxing bodies to make 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 warrants to the other and to the parties and to the Court that he has reviewed this Settlement Stipulation with bis client or clients and that he has specifically been authorized to enter into this Settlement Stipulation by his client or clients. Respectfully Submitted, Date: PETITIONER, COLLEGE PARK APARTMENTS By: o. GARIPPr~rLOTZ & ~~O 66 P~ ~eet Montclair New Jersey 07042 (973) 744-1688 A~O~Y FOR PETITIO~R Stipulation and Joint Motion for Agreed Order College Park Apartments Page 2 of 3 RESPONDENT, CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS and COLrNTY OF CUMBERLAND St~ph0tl"D'~ Tiley, Esquire Assistant Cumberland County Solicitor 5 South Hanover Street Carlisle, PA 17013 (717) 243-5838 Supreme Court I.D. 32:318 ATTORNEY FOR RESPONDENT RESPONDENT, BOROUGH OF CARLISLE Date: Edward L. Schorpp, Esquire MARTSON, DEARDORFF, WILLIAMS & OTTO 10 East High Street Carlisle, PA 17013 SOLICITOR FOR BOROUGH OF CARLISLE RESPONDENT, CARLISLE AREA SCHOOL DISTRICT Date: y: · 9 U S~IDIS, SHUFF, FLOWER, & LINDS.P3/f ~ West High Street Carlisle, PA 17013 SOLICITOR FOR CARLISLE AREA SCHOOL DISTRICT Stipulation and Joint Motion for Agreed Order College Park Apartments Page 3 of 3