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Home My WebLink About94-06451 " , ,'i. , , I , , , , I " \1,' .' ltl I , " ~ , , " I, , I, , " , " ' , '.' " , I , , , , I , ',,,", " ' , , , " '~ i~ ~ I'; , , , , " '!, , " , , , , " \1 , " ':0 '~\'~. ;~ -'-'1 "~ , " \ ~ ~ " , ' " " I'''; ~~ " " " ,I , , ", I,' ,i,,1 L ~ ,I I ,,' - I ' , ' I ' .; , ',' , ! '~ .~ ~ ~ . I ' , , , , , , ' ~ , " J \ \ . \ \ ..... ~ ' , ~ i ~ \ \ . . ~ v i " ( r Any person or governmental agency upon whom a copy of the Petition and this Order is required to be served as Htated above, may file a reply or 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 a petition and Order, either a response to the petition or a praecipe directing intervention as an appellant or appellee, as the case may be. If such response or praecipe has not been filed within the required twenty (20) day period, intervention thereafter shall be governed by Pennsylvania Rules of Civil Procedure 2326 through 2350 inclusive. , II J. ~!' I ~ "', '" ", , 1i , . ,~ I ~ ' 'I "I \~ II ! ~~ i Nav 11 10 33 aM '9~ -1 ft 1)1' . 'I':",!: ,_, , '. r liH' , ~IJI'lI' , .', . ".IM,y PI""I:" hJ ('I I. -~rY .NH .: (1.1 I.r 't. . ' -',-' 1',"" ,< (. ,{I .;.," -',\1',' ,F , ~",,'. ..,' , . L" ~, 'I . ,-' .~ , . '! tl" :1 r f ~; IN THB COURT OP COMMON PLBAS OF CUMBBRLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 'I II,' ,I' ,.;1 IN RS: , . ) APPEAL OP KINNEY SHOE CORPORATION FROM THE CUMBERLAND COUNTY BOARD OP ASSBSSMENT APPEALS TAX PARCEL NO.: 49-08-0579-006 MUNICIPALITY: BOROUGH OF CARLISLE ASSESSMENT FOR THE YEAR 1995 PROPERTY OF KINNEY SHOE CORPORATION NO. P.TITION WOR R.vI" ow R~ .STAT. ASS.SSNKRT TO THE HONORABLE, THE JUDGES OF SAID COURT: 1. The petitioner is KINNEY SHOE CORPORATION, a corporation duly authorized to transact business in pennsylvania with a principal place of business located at 1275 Ritner Highway, Carlisle, Pennsylvania 17013. 2. The Respondent is the Cumberland County Board of Assessment Appeals whose address is 1 Courthouse Square, Carlisle, Pennsylvania 17013. 3. The Petitioner is the owner of a property located at 1275 Ritner Highway in the Borough of C3rlisle, Pennsylvania 'I, I' I,:" : ~, t' i' which is identified for local real estate tax purposes as Parcel No. 49-08-0579-006 (hereinafter "Premises"). ,: 4. Sometime in 1994, the Petitioner was informed that the assessment of the Premises for local real estate tax purposes was fixed for the year 1995 at $ 272,750. 5. The petitioner timely filed notice of its intention to appeal this assessment to the Cumberland County Board of Assessment Appeals ("Board") and a hearing was subsequently held by the Board. 6. By notice dated October 21, 1994, the Petitioner was informed that the Board had affirmed the assessment. (See Exhibit "A" attached hereto) . 7. The assessment for the Premises as fixed by the Board is excessive, improper, unjust and contraIY 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 Premises. the ratio of assessed value to actual value applied in making the assessment is in excess of the ratio applied by the taxing authority. the assessment lacks uniformity. the assessment is discriminatory. the assessment is otherwise unjust and inequitable. ~ CERTIFICATION OF VERIFICATION 1. I, Stephen M. Howard, am an Attorney-at-Law of the Commonwealth of Pennsylvania and have been retained to represent the Petitioner, KINNBY SHOB CORPORATION, in the within cause ot action. 2. I have been authorized to file this Petition on behalf of the Petitioner. 3. This Certification of Verification is not executed by an officer of petitioner because the Verification could not be obtained within the time prescribed to effect this Appeal by statute and rules of the Court. 4. I am familiar with all of the tacts contained in this Petition. 5. I certify that all of the facts set forth in this Petition are true and correct to the best of my knowledge and beliet. I further certify that if any of the foregoing statements are willfully incorrect, I am subject to penalties as stated in the Pennsylvania Crimes Code, 18 PA.C.S. 4904, relating to unsworn falsification to authorities. .. EARL R, KELLER CH"'I"~"'N STEPHEN D. TILEY 'SIISTANT IClL.ICITOf' ROSERT H, C. LISSE ...sonISMINT' TAX ...O...'NuU.....rQA NANCY A. DESCH vlel CMAIIlIMAN RANDY L. WAGGONER CHilII' .'aulSo" MARCIA L. MYERS alc..IT....V HORACE A, JOHNSON lSOl.JCITOA WILLIAM E. DENNIS C"4II' Ct.IIlIK/COUHTV ADMINIIT"ATO" Clbnnbrrlanil Cltounty ioarilof ~Sfl1'9Smfnt anil ibutsUm of mUXtS 1 COUAT~OVSI SOU"A'. CA"LI'!... P.. 17013 (1t1lZ..o.&3f1O October 21. 19H lnt~rnatLonal Appraisal Company 110 Pleasant Avenue Upper Saddle River. NJ 07458 RE: Tax Parcel 49-08-0579-008 Kinney Sho~ Tlu Board of Asses5Inent Appeals Order IS as follows, No Change. Maintain Current Market Value. ANY PERSON AGGRIEVED BY THE ORDER Of THE BOARD MAY APPEAL TO THE COURT Of COMMON PLEAS BY fiLING A PETITION IN THE PROTHONOTARY'i OffiCE WITHIN JO DAYS fROM THE DATE Of THIS NOTifiCATION, (11/21/94) f..LdIl.l'.. ~ Robert H,C. LIsse Ass.ss~ent & Tax Admn. Exhibit "11" ~ . "i. ~ 0 . rn ~ ~ ~ if; >-~ ~ ~ ....,. . ''''r ~ -' ~ r ,.. IJ t t, . ~', ;I ':!:;.,','J'\ ~ 0 e. .. ... ,~ . '<:l :r ., ~ , r ~ - ~ \fi ~ - 'j- '~':' ..: -,r ... -- - " '"" ~ -- , , IN RE: APPEAL OF KINNEY SHOE CORPORATION FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS TAX PARCEL NO.: 49.08.0579.006 MUNICIPALITY: BOROUGH OF CARLISLE ASSESSMENT FOR THE YEAR 1995 PROPERTY OF: KINNEY SHOE CORPORATION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94.6451 CIVIL TERM CIVIL ACTION. LAW REPLY AND NOW, comes the County of Cumberland, and Cumberland County Board of Assessment Appeals, by Stephen D. Tiley, Esquire, its Assistant Solicitor, and files this Reply to the Petition for Review of Real Estate Assessment, as follows: 1. Admitted. 2. Admitted. 3. Admitted in part and Denied in part, The averments of this paragraph of Petitioner's Petition are admitted except that the owner of the property is the Cumberland County Industrial Development Authority. 4. Admitted. 5. Admitted. 6. Admitted. 7. Denied. The averments of this paragraph, and its lettered subparagraphs, contain conclusions of law to which no responsive pleading is required. Strict proof at trial is demanded. By way of further answer, Petitioner has the right to appeal de novo pursuant to The Fourth to Eighth Class County Assessment Law Section 7.04 (72 P.S. S5453.704). J' .',-'.'-;'....":,.1"'; , .. , .. , , WHEREFORE, the Respondent prays Your Honorable Court for a Judgment In It I favor affirming the fair market value of the property at the value indicated by the prior as.essment, or such higher amount as the Court may deem proper. Dated:~,,_~L- :2,,2./ / Pl'r #~~,/~1 StePh::6. Tiley, Esquire Assistant Cumberland County Solicitor Attomey for Board of Assessment Appeal. 5 South Hanover Street Carlisle, PA 17013 (717) 243.5838 Supreme Court 1.0. No.: 32318 ,,' . ... IN RE: APPEAL OF KINNEY SHOE CORPORATION FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS TAX PARCEL NO.: 49.08.0579.006 MUNICIPALITY: BOROUGH OF CARLISLE ASSESSMENT FOR THE YEAR 1995 PROPERTY OF: KINNEY SHOE CORPORATION . ~ .. . : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 94.6451 CIVIL TERM CIVIL ACTION. LAW CERTIFICATE OF SERVICE I, Stephen D. Tiley, Esquire, do hereby certify that on this date I have served a copy of the Reply of the Respondent, Cumberland County Board of Assessment Appeals, and County of Cumberland. by sending the same to the Petitioner's attorney of record by regular United States Mail. postage prepaid. to: Stephen M, Howard, Esquire 605 North Broad Street Lansdale, PA 19446. Dated:..24- ......,A..... 2.~, /9rfl ~~~.?A St phe D. Tiley. Esquire Assi8tant Cumberland County Solicitor Attorney for Board ot Assessment Appeals 5 South Hanover Street Carlisle. PA 17013 (717) 243-5838 Supreme Court 1.0. No.: 32318 " :',:-. ., " -~ , ".) <<, ~ ..:t ~ Q Z~ i:l:l 0", < ::I!z ::I! ~~gcn ::I!p 0= ..:t 00 ~ :t:"'><< Uu ~~ cn::l!"'~ PooQ ..:t< ><oz~ ~ i ~i~; Oz >..:t ~~pQ., ..:t "'<:!: ZPooO< ~ -' z. U'" i:l:l..:tZ Uz :;a:Z:QZ p~< -0 oz~ .11'i o~> ~r.:: Poo!= ::I! ual..:t o<:3cn ~::I!> 'flU ...< ..:t~i:l:lcn =pcn <O~; i~!11 ",uZ "'..:t .. ~ ~~a:I zPooi:j 0> i:l:l ~~::I!< _o~ zu z ~opPoo ... <uuo JOHN S. WARD COOl' CUlM LLOYD W. BUCHER ctR.CTOR '" FlNANCI lAfIL R, KELLER CH_ NANCY A. BESCH VIC& CHAlNIAN RANDY L, WAOOONER CHIIF AS...1C)IIt MARCIA L. MYERS IICMT,MY HORACE A, JOHNSON IOUClTOA STEPHEN D. TILEY ""STANT IOUCITOR .( [umbcrland [ountg ~oQrd of gssusmcnt Ii, I. i;, , t. [.1 , , ~. f' F ~~ Ii" l. \'1 f"; 'd' OFFICE OF ASSESSMENT' FINANCE December 2, 1997 " 11)';' Hon. Edgar B. Bayley Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 "\'j , ,.. Re: Kinney Shoe Corporation Assessment Appeal No. 94.6451 .'. Dear Judge Bayley: .', , '. ' The above referenced case, which is scheduled for trial on Friday, Decomber 12, 1997, has been settled. I ask that the hearing be continued generally. We are now circulating a draft Stipulation for review and signatures. We will hopefully have a Stipulation and proposed Order to you within the next few weeks. , ., I/~: '''., '-<'1 ,"I ~: ".1.,', ..",: , :'. Sincerely yours, A L .'l7'/'/ . " ~'N fi;I., Stephen D. Tiley 'F- '" ' ,-,"\ ',' If V ,..,r il\1 -:.?.'" ;:::."1': ~!, WI I';.:J' Mi ~J~l ~":i I [rJ'i' ,-_t.,. i .f~,~ r,r' SDTlttb co: Steph.n M. Howard, Esquire Richard C. Sn.lbak.r, Esquire Edward L. Schorpp, Esquire ONE COURTHOUSE SQUAIlE. CAALISLE, PA 11013 fE ..:t f:; ~. l~ c: ... .:i !'.t; "'1 ~: ; ).<(, 1;- L" .... C,:' -2~ ... . ,,::~ ~. ....... C' (.,"j .. ~: N :'. '.>- " I """ r4: ;;; ..1:';' Z ....- -;ii ~, -) '.1~ "') l.Q ~ a:: .J: 0' d f' a. ~ :z: ~~ 0 < co i= Q 0 ::I:Z: :I i:Illoli:1 % :I Ill: 05 0= ... ~Iol III :=1-<1><< ..... ~~ 00 ~. Cll:ll-<Iol i' ~~H ~i:::l ~~ I><OZQ., 00 00 i:Illll:::lQ., i' ~~ :z: >1 z"'o< tic:; ~ ... :z: 01-< ... Zi:Il ~r' \:);~ oz Si!~~ffi ...0 .. <Ill: O~> ~~ ~I=z~ 0 zO 0::1>= o~~ Z 0< il~il - !ij\:)!Il :< ...:l Ill: QI i=1ll: ..,oZ "'~ ~ :iOi:llia ~ <0 ~~ffi g5 Ill: Q.,~;< ~~ ::l Olio ~ Q.,0::l~ ~ Q., <000 ~ " . IN RE: APPEAL OF KINNEY SHOE CORPORATION FROM THE CUMBERLAND COUNTY : BOARD OF ASSESSMENT APPEALS: TAX PARCEL NO.: 49.08.0579.006 MUNICIPALITY: BOROUGH OF CARLISLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 94.6451 CIVIL TERM . . ASSESSMENT FOR THE YEAR 1995: PROPERTY OF: : KINNEY SHOE CORPORATION: CIVIL ACTION. LAW QRDER AND NOW, this \A..... day of j \J\-- 0 ,19'1:- 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 $3,250,000, and that the common level ratio applicable hereto is 7.5%. The total assessment of the property for tax years beginning on and after January 1, 1995, and thereafter until changed as provided by law, shall be $243,750. 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. 'rhe Cumberland County Assessment Office shall promptly notify the appropriate taxing bodies of the change in assessment. BY THE COURT, / ./ By: ~ Edgar B. Bayley, J. / . , . I: .1.C~~ C,~,. TI,'. ;c.' . I.., ' , .,.;I.'"t'"; :, ;':~:<::Irrs 90 JU;! -ll hI 2: 47 1'1 "'" ," "II'" \J ..(". .J! I 1..1': ~ II. t' I \, '\ \ 11 'I ...1'ilh,I;I_~1 1.1' " .', , .. . ." . . . , . . IN RE: APPEAL OF KINNEY SHOE CORPORATION FROM THE CUMBERLAND COUNTY : BOARD OF ASSESSMENT APPEALS: . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TAX PARCEL NO.: 49.08.0579.006 MUNICIPALITY: BOROUGH OF CARLISLE NO. 94.6451 CIVIL TERM . . ASSESSMENT FOR THE YEAR 1995: PROPERTY OF: : KINNEY SHOE CORPORATION: CIVIL ACTION. LAW STIPULATION AND JOINT MOTION FOR AGREED ORDER AND NOW, this I,) i., day of.D~e)~;4er, 19~ it is hereby agreed and stipulated between Petitioner, Kinney Shoe Corporation, by its attorney, Stephen M. Howard, Esquire; and Respondents, Cumberland County Board of Assessment Appeals and Cumberland County, by its attornoy, Stephen D. Tiley, Esquire; and Respondent, Borough of Carlisle, by its attorney, Edward L. Schorpp, Esquire; and Respondent, South Middleton School District, by its attorney, Richard C. Snelbaker, Esquire, is as follows: 1. Petitioner filed a petition for assessment appeal from the assessment fixed by the Cumberland County Board of Assessment Appeals by Petition for Review of Real Estate Assessment dated November 10, 1994 and filed November 14. 1994. The parties have now settled this case. 2. The applicable year for which the above captioned assessment appeal was flied is the calender year 1995. 3. The property which is the subject of this appeal is Cumberland County Assessment Parcel No. 49-08-0579-006 and is known 8S the Kinney Shoe Stipulation and Joint Motion 101 Agreed Order Page 1 0' 3 t , . , . warehouse situate at 1275 Ritner Highway, Carlisle, Pennsylvania. The property Is situate In the Borough of Carlisle, Cumberland County, Pennsylvania, but Is taxed to the Borough of Carlisle and South Middleton School District. 4. The parties stipulator) 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 flied shall be fixed at $3,250,000. 5. The common level ratio applicable to this appeal for the 1995 tax year, as oertified by the State Tax Equalization Board on or before July 1, 1994, is 7.5%. Applying the common level ratio to the total market value of the subject property results in its lawful total assessment being $243,750. The common level ratio varies by more than 15% from the Cumberland County predetermined ratio, which is 25% and therefore the common level ratio is applicable to this appeal and the assessment shall be fixed at the said $243,750. 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 1,1995 and shall remain unchanged unless and until changed as otherwise provided by law. 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 any appropriate refunds lor 1995 and subsequent calendar year Borough and County real estate taxes and lor 1995.96 and subsequent fiscal year South Middleton school district taxes. 9. Each party to this appeal shall bear its own costs. 10. The Court is requested to enter the proposed Order attached hereto. Stipulation and Jolnl Mollon lor Agreed Order Page 2 of 3 IN RE: APPEAL OF KINNEY SHOE : IN THE COURT OF COMMON PLEAS OF CORPORATION FROM THE CUMBERLAND COUNTY, PENNSYLVANIA. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS TAX PARCEL NO. 49-08-0579-006 MUNICIPALITY: BOROUGH OF CARUSLE 9~ 6451 CIVIL TERM QflDER OF COURT AND NOW, this 13th day of October, 1997, a hearing In this tax ......ment appeal is scheduled for Friday, December 5, 1997, at 1:30 p.m., in Courtrcom Number 2, Cumberland County Courthouse, Carlisle. ) Stephen M. Howard, Esquire For KInney Shoe Corporation Richard Snelbaker, Esquire For South Middleton School District Stephen Tiley, Esquire For Cumberland County :saa ~~,..,"" ,,"'o.&.L ,011'1/ q,. . ..J. -:1Y. 1 ' ,"'-'('~ f \r.\};l::\"'.~;:,. ,,\1 Of- 'f, '. ,I., fIr"~, 1"1"" \ 'J C\ \." ' \ I ~ . .' I\! ".' C\jt;',,~. t(:.>\' , )' \'''-1 ... ~_...., '" I' \ \ . ,; ,\' I' -I""~' '..)'0..., .1 " .il,:,\I" OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT OF COMMON PLEAS 1 CourthOlllo Squero . Cartlalo. PI. 17013 RlohanlJ. ,..,.. , Phone Court AdmInloltotor (717) 240-8200 (717) 897-0371 Taryn N. DIxon (717) 532-72118 Mt'","", Court AdmInlltrator (717) 240-8482 FAX Dorto J. MlnII Stall ~"""nl ICINft .. IIarrIH Logol Sec:rolIIy ....... J. Raudlllo. LogolSacretary MEMORANDUM FROM: The Honorable Judge Edgar B. Bayley Taryn N. Dixon, Assistant Court AdministratOr~ .{;2J TO: DATE: October 8. 1997 INRE: 645 I Civil 1994 I !, , \ KINNEY SHOE CORPORATION 1'j ~. VI. CtJMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS The above ClISCI is sssigned to you for II non-jury trial. Plesse provide me with copies of your scheduling orders lIDd finlll disposition date so I ClID monitor the ClISCI for statistical purpolCS. i \, ~r:", ,t '. ,: v' , (b;(Q)[}5_Y't1 ~AECIPE FOR LIS'l'XNG CASE }'OR 'l'IIIA!. (Must be typewritton and !.lub'llltted in duplicote) OCT 0 8 1997 '1 !, " ,( ~, ro THE PfUl'HOt-mARY Of <.'UM8EIu..MD COtMI'Y P. 'J.:l 0 Pll.laue list tllo following case: _",,' ,~ "ll " '.') "i' (Check onal for JURY trial at the next term of c:\.vil'l!lllurt,;1 ,i)) .-J i~9 (xx) for tr ia.l wi thout <l jury, ..,., ,0 , .-, ',;:.8 _ __ _ _. _ _ _ _ _ _ __ _._ _ _ _ _ _ _ _ _ ._ _ _ _ - - - - - - -.... - - ......,~ -''''l''''..)- ...,,:.rr4 CJ\PTION Of CASE ':.: .. ~~! (entire caption must be St6tOO in full) (check one) -< ;;: ~~ Civil Action - Law Kinney Shoe Corporation Tax Parcel No. 49-08-0579-006 Borough of Carlisle Appeal from Arbi.tration Assessment Appeal (ottY.lr) (X) (Plaintiff) VS. Cumberland County Board of Assessment Appeals The trial list will be called on 1200/97 and Trials comrence on 2/2/98 (Defendant) pretrials will be held on 1/7/98 (Briefs art1 due 5 days before pretrials.j (The party listing this case for trial shAll provide forthwith a copy of the proecipe to all counsel, pursuant to local Rule 214.1.) V5. ',\ No. 6451 Civil 2~ 19~ I I Indic/lte the attomey who will try case for the party who files this praecipe. (215) 362-2572 ~~phen M. ~oward, ~sq., 605 N. Broad street, Lansdale, FA 19446 Tnn,l ""t~ ~rial C':lUt\sel for other part.ic(l if known. ~'rEPHEN 'rILEY, ESQ.. Soliei tor for Board of Assessment, RICHARD SNELBAKER, eSQ., Sol ici tor for south Middleton School Distr1c~ HO~ACE A. JOHNSONi ESQ., Solicitor for ciJmoer'1and County and EDWARD L. SCHORPP, ESQ. ,--Sol citor for Borough of Carlisle. -.--..--. This case is rE<ldy for trial. Si~led. ~L/L~ I'rint N!;lITe; STEPHEN M. HOWARD, ESQ. Datl!' III In ICJ~ --./"-f4-.CLL-..--- Attomey fori ,~!NNEY_SHOE CORPORATION 1: 1 IN RE: APPEAL OF KINNEY SHOE CORPORATION FROM THE CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS TAX PARCEL NO. 49-0&0579-006 MUNICIPAUTY: BOROUGH OF CARUSLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 91 6451 CIVIL TERM QRDE~ Of COURT AND NOW, this 3rd day of December, 1997, upon relation by counael that the cue II HttIed and that the parties are circulating a Itlpulatlon to .rfectuate that settlement, the heering scheduled for December 5, 1997, 18 CONTINUED GENERALLY to the call of any party. Stephen M. Howard, Esquire For KInney Shoe Corporation Richard Snelbaker, Esquire For South Middleton School District , I, \ i Stephen Tiley, Esquire For Cumberland County :saa to-;d...., rr........j..,L 1:1./31'1'1, ...s ."P. ( , ,.' I, " - AI r;o-C>FFICE OF T\.:rr r '''1'' 'C "}rl~.RY 91 m:r: ,. .. ,~ rli 12: 52 CU' ' . . (' 'I "Y ',\" I...j ,'. "/ "~ ~ F,C; .~:. \~-'} r'L:,';'- ,;! /\ " , , i, .11> IN THB COURT OP COMKlN PLBAS OP CUMBERLAND COUNTY, PINNSYLVANIA CIVIL AGTION - LAW IN RB: APPBAL OF KINNBY SHOE CORPORATION PROM THE CUMBERLAND COUNTY BOARD OF ASSBSSMENT APPEALS TAX PARCEL NO.: 49-08-0579-006 MUNICIPALITY: BOROUGH OF CARLISLE NO. 94-6451 ASSESSMENT FOR THE YEAR 1995 PROPERTY OF KINNEY SHOE CORPORATION CERTIFICATE OF SERVICB The undersigned hereby certifies that a true and correct copy of the Petition for Review of Real Estate Assessment and Order in the entitled action has been served upon the following by way of certified mail return receipt requested: Horace A. Johnson, Esquire Solicitor for Cumberland County 301 Market Street Lemoyne, PA 17043 Stephen Tiley, Esquire Solicitor for Board of Assessment 5 South Hanover Street Carlisle, PA 17013 Bdward L. Schorpp, Esquire Solicitor for Borough of Carlisle 36 South Hanover Street CUlisle, PA 17113 James D. Plower, Bsquire Solicitor for Carlisle School District 11 B. High Street Carlisle, PA 17013 The foregoing Btatement is true and correct and I under'tand that if it is not, I am subject to penalties as Btated in the pennsylvania Crimes Code, 18 PA. C.S. 4904, for unsworn falsification to authorities. Dated: November 30, 1994 . owa <1, Esqu At orney for Petitioner I. . 1132179 605 North Broad Street Lansdale, PA 19446 215/362-2572 ~. ....w o".c.. .NIL.Alelll . ...INN.MAN , I' I I' IN RE: APPEAL OF KINNEY SHOE CORPORATION, trom the CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS Tax Parcel No. 49-08-0579-006 : . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 94-6451 CIVIL TERM REAL ESTATE TAX ASSESSMENT APPEAL I . . . . . . PRAECIPE TO ENTER APPEARANCE TO: prothonotary ot Cumberland County Please enter and note the appearance ot the undersigned as attorneys tor south Middleton School District in the above captioned matter. Date: February /' , 1995 , P.C. By card C. Sne baker 44 West Main Street Mechanic.burg. PA 17055-0318 (717) 697-8528 ~.. CERTIFICATE OF SERVICE I hereby certify that I am this date serving true and correct copies of the within Praecipe to Enter Appearance upon each of the attorneys indicated below by sending the same by first-class mail postage paid addressed as follows: stephen M. Howard, Esquire 605 North Broad Street Lansdale, Pa 19446 (Attorney for Petitioner/Owner) Stephen D. Tiley, Esquire Assistant County Solicitor 5 South Hanover street Carlisle, PA 17013 (Attorney for Respondent/Board) Edward L. Schorpp, Esquire Landis, Black & Schorpp 36 South Hanover Street Carlisle, PA 17013 (Attorney for Borough of Carlisle) James D. Flower, Esquire Flower, Morgenthal, Flower & Lindsay 11 East High street Carlisle, PA 17013 (Attorney for Carlisle Area School District) R C. Snelbaker SNELBAKER , BRENNEMAN, P.C. Attorneys for South Middleton School District LAW o..,.c.. 8NIL..U:.N . ."INN'MAN Osted: February /, , 1995 IN RE: APPEAL OF KINNEY SHOE CORPORATION, trom the CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS Tax Parcel No. 49-08-0579-006 . . IN THE COURT OF COMMON PLEAS or CUMBERLAND COUNTY, PENNSYLVANIA No. 94-6451 CIVIL TERM REAL ESTATE TAX ASSESSMENT APPEAL PRAECIPE TO INTERVENE TO: prothonotary of Cumberland county South Middleton School District, a local taxing body with regard to the subject real estate in this matter, hereby intervenes in accordance with law as a party respondent-appelle.. J'-. , , p.e. By chard C. Sne a er rney. for Interv.nor: South Middleton School Di.trict Date: F.bruary /, , 1995 I( ';.1 { ~ r' L.AW O"lC.. .NI.......K... . .J11INNIMAN t,J I, " " ;" "' CERTIFICATE OF SERVICE I hereby certity that I am this date serving true and correct copies ot the within Praecipe to Intervene upon each ot the attorneys indicated below by sending the same by tirst-class mail postage paid addressed as tollows: Stephen M. Howard, Esquire 605 North Broad Street Lansdale, Pa 19446 (Attorney tor Petitioner/Owner) stephen D. Tiley, Esquire Assistant County Solicitor 5 South Hanover Street Carlisle, PA 17013 (Attorney for Respondent/Board) Edward L. schorpp, Esquire Landis, Black , Schorpp 36 South Hanover Street carliSle, PA 17013 (Attorney for Borough ot Carlisle) James D. Flower, Esquire Flower, Morgenthal, Flower' Lindsay 11 East High Street carlisle, PA 17013 (Attorney for Carlisle Area School District) R card C. Sne ba er NELBARER , BRENNEMAN, P.C. Attorneys for South Middleton School District .....w O""IC.' SNILIIAJCI" . ."INNIMAN Dated I February I~ . 1995 . . IN THB COURT OF COMK:>N PLBAS OF CUMBBRLAND COUNTY, PBNNSYLVANIA CIVIL ACTION - LAW IN RB: APPBAL OF KINNEY SHOE CORPORATION FROM THB CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS TAX PARCEL NO.: 49-08-0579-006 MUNICIPALITY: BOROUGH OF CARLISLE ASSBSSMENT FOR THE YEAR 1995 PROPBRTY OF KINNEY SHOE CORPORATION NO. 94-6451 , 1: , , :r,' .i CERTIFICATE OF SERVICE , , The undersigned hereby certifies that a true and correct copy ot the Praecipe For Listing Case For Trial in the entitled action has been served upon the following by way of first class mail at the below listed addresses: Horace A. Johnson, Esquire Solicitor for Cumberland County 301 Market Street Lemayne, PA 17043 Stephen Tiley, Esquire Solicitor for Board of Assessment 5 South Hanover Street Carlisle, PA 17013 Bdward L. Schorpp, Esquire Solicitor for Borough ot Carlisle 36 South Hanover Street Carlisle, PA 17113 1: p I"~ ,_. , .... <,.), c;;J 'Q; ~ ~..;) .. ( , .,.., '. J ~-;' ',1:,,;; "')~ .' 'f... -~~ I,' 'Ill) t..\'\'''''' ';3 U'l I.l. ~ " ~? I ~"j:;. : ;.. ~ ' tl;;,' n' >: (. G')l., ~~..1 ~ . _"1\ 1:':"', i~~ H. o ,:; .,.' b:'. , ' . ./ . , . Richard C. Snelbaker, Bsq. Solicitor tor South Middleton School District 44 W. MAin Street Mechanicsburg, PA 17055 The toregoing statement is true and correct and I understand that it it is not, I am subject to penalties as stated in the Pennsylvania Crimes Code, 18 PA. C.S. 4904, for unsworn talsification to authorities. Dated: October~, 1997 Step Atto 1.0. #32179 605 North Broad Street Lansdale, PA 19446 ~15/362-2572 !r: Lf) ~ Lr. 'S (.1 r'1.... ~.) r.)~-~t '''5:'' ..,.' ':_J:".~ ~l:' . - ,'~) ;.:.: ~?~ a... r.... .<(.:l I "~ ~.; fi,,, ~. ';1rL) . -' t' 'na.. tl_ ':._ 1...' ~ Q a 1I_ I"- 0 0" , , , " . , -I ~~IPB ~R LISTING CASE fOR TRIAL (Must be typewri.tton &ld slItJnltted in duplicate) 'TO 'l'tlE PR.7l'llOlmARV OF CU1BERLAND COUNr'( PleCiSe list the following case: (Cheek one) for JURV trial at the next tem of civil l."Curt. (XX) for tridl without a jury. ----.-----------------.-------------------- CAPTION OF CASE (enUre coption rTUst be !!,toted in full) (check one) Civil Action - Law BEARINGS, INC. Tax Parcel No. 21-08-0575-003C Borough of Carlisle Appelll fl"Ol1l Arbitration ( X) lLssessment tDDeal ( other (Plaintiff) vs. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS TOe trial list will be called on..1l./30/97 anQ Trials c~nce on 2/2/98 (Defenc:1ant) Pretrials will be held 011 1/7/98 (Briefs aro due 5 days before pretrials.) (The party listing this case for trial shall provide forthwith a copy of the praecipe to all counsel. pursuant to local Rule 214.1.) vs. No. ~~__ Civil Term 19~_ Indicate the attorney who will try case for the party who files this praecipe: (215) 362-2572 Stephen M. Howard, ~~05 N. Broad street, Lansdale, PA 19446 Jnrl.i""t~ trial co:>unsel for other partie," if known. STEPHEN TILEV, ESQ., Solicitor for Board of Assessment, JAMES D. FLOWER, ESQ., SoIlcltOr for Carlisle School District, HORACE A. JOHNSON, ESQ., Solicitor for Cumberland county and EDWARD L. SCHORPP, ESQ., Sollcltor lor Borougn of Carlisle. This case is ruody for trial. Signed. _.~'- /J;'~ .(J - Print N!IlIel ~~:~- M: HOWARD, ESQ. . - Datel --.LGJ'3111 Attorooy for. BEARIN_G~ INC.