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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN RE
APPEAL OF PRINCETON TOWER
DEVELOPMENT CORPORATION
FROM THE
CUMBERLAND COUNTY BOARD OF
ASSESSMENT APPEALS
l
TAX PARCEL NO.: 09-12-2989-001.-LL001
PROPERTY: 290 PINE HILL ROAD
ENOLA, PA 17025
ASSESSMENT FOR THE YEAR 2007 AND
ALL SUBSEQUENT YEARS
PETITION FOR APPEAL
AND NOW, PRINCETON TOWER DEVELOPMENT CORPORATION, by and
through its counsel, Michael S. Grab, Esquire and Nikolaus & Hohenadel, LLP, appeals from the
decision of the Cumberland County Board of Assessment Appeals dated October 25, 2006 and in
support thereof, avers as follows:
1. Appellant is Princeton Tower Development Corporation, with a mailing address
of 156 Tamarack Circle, Skillman, NJ 08558.
2. On or about September 1, 2006, Appellant filed with the Board of Assessment
Appeals, an appeal from the assessment of the property situate at 290 Pine Hill Road, Enola,
Cumberland County, Pennsylvania 17025, Tax Parcel No.: 09-12-2989-001.-L1,001, with an
assessment for 2007 in the amount of $240,000.00, multiplied by a Common Level Ratio Factor
for Cumberland County in the amount of 1. 14, resulting in an assessed fair market value of
$273,600.00.
3. On October 25, 2006, the Board of Assessment Appeals made its final decision in
connection with the assessment appeal, fixing the final assessment for the above parcel, for 2007,
at $240,000.00.
4. Appellant believes and therefore avers that the real estate, which consists of a
communication tower, has an actual fair market value of $92,000.00.
5. Appellant believes and therefore avers that the Board of Assessment Appeals
abused its discretion and committed an error of law by fixing the 2007 assessed value of the
property at $240,000.00.
WHEREFORE, Appellant requests that your Honorable Court reverse the decision of the
Board of Assessment Appeals of Cumberland County, and fix the fair market value of the
property, and accordingly the assessed value for 2007, and all subsequent years, at $92,000.00.
Respectfully submitted,
NIKON & HO
DATE:
By:
chael S. )Grab, Esq
X. No. 5 987
327 Locust et
Columbia, PA 17512
(717) 684-4422
2
VERIFICATION
PURSUANT TO PA RCP NO 1024(c)
MICHAEL S. GRAB, ESQUIRE, states that he is the attorney for the party filing the
foregoing document; that he makes this affidavit as an attorney, because the party he represents
lacks sufficient knowledge or information upon which to make a verification and/or because he
has greater personal knowledge of the information and belief than that of the party for whom he
makes this affidavit; and/or because the party for whom he makes this affidavit is outside the
jurisdiction of the Court, and verification of none of them can be obtained within the time
allowed for the filing of the pleading; and that he has sufficient knowledge of information and
belief, based upon his investigation of the matter averred or denied in the foregoing document;
and that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
DATE: // ?a ?i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN RE
APPEAL OF PRINCETON TOWER
DEVELOPMENT CORPORATION
FROM THE
CUMBERLAND COUNTY BOARD OF
ASSESSMENT APPEALS
TAX PARCEL NO.: 09-12-2989-001.-LL001
PROPERTY: 290 PINE HILL ROAD
ENOLA, PA 17025
ASSESSMENT FOR THE YEAR 2006 AND
ALL SUBSEQUENT YEARS
CERTIFICATE OF SERVICE
I, MICHAEL S. GRAB, ESQUIRE, do hereby certify that I have this day, served a true
and correct copy of the foregoing document upon the following person(s) and in the following
manner, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure.
SERVICE BY CERTIFIED MAIL ADDRESSED AS FOLLOWS:
Cumberland County Board of Assessment Appeals Stephen D. Tiley, Esquire
Old Courthouse Assistant Solicitor
One Courthouse Square Frey & Tiley
Carlisle, PA 17013 5 South Hanover Street
Carlisle, PA 17013
East Pennsboro School District
98 South Enola Drive
Enola, PA 17025
SERVICE BY HAND DELIVERY
Princeton Tower Development Corporation
156 Tamarack Circle
Skillman, NJ 08558
NIKOLAUS I-IQ1jENA )EL, LLP
DATE: ?i eta az;
i¢hael L.Grab,
No. 7
7 Locurea
Columbia, PA 17512
(717) 684-4422
Y l
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V --
1
Curtis R. Long
Prothonotary
office of the Vrotbonotarp
Cumberlanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573