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TRUE RAILROAD ASSOC. LPI
TRUE TEMPER HARDWARE,
Petitioner
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
V8.
.
.
: NO. 95-6622
CUMBERLAND COUNTY BOARD
OF ASSESSMENT APPEALS, :
Re8pondent : CIVIL ACTION - LAW
ORDER
AND NOW, this "
~
day of April: 1996, 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
$7,100,000, and that the common level ratio applicable hereto Is 7.3%. The total
assessment of the property for tax years beginning January 1, 1996 and thereafter
until changed as provided by law, shall be $518,300. 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 promptiy notify
the appropriate taxing bodies of the change In assessment. /
BY THE COURT,
By:
~
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TRUE RAILROAD ASSOC. LPI
TRUE TEMPER HARDWARE,
Petitioner
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
.
.
V8.
.
.
: NO. 95.6622
CUMBERLAND COUNTY BOARD
OF ASSESSMENT APPEALS, :
Re8pondent : CIVIL ACTION . LAW
STIPULATION AND JOINT MOTION FOR AGREED ORDER
AND NOW, this day of April, 1996, it is hereby agreed and stipulated
between Petitioner, True Railroad Assoc., L.P./True Temper Hardware, a limited
partnership, by its attorneys, Garlppa and Davenport; and Respondents, Cumberland
County Board of Assessment Appeals and Cumberland County, by Its attorney,
Stephen D. Tiley, Esquire, Assistant County Solicitor; and Respondents, Cumberland
Valley School District and Township of Hampden, by their attorneys, Snelbaker &
Brenneman, Is as follows:
1. Petitioner flied a petition for assessment appeal from the assessment fixed
by the Cumberland County Board of Assessment Appeals by Petition for Review of
Real Estate Assessments dated November 17, 1995 and flied November 21, 1995, to
which an Order fixing a date and place for a hearing was entered on November 29,
1995. The hearing was scheduled for April 10, 1996.
2. The applicable year for which the above captioned assessment appeal
was flied Is the calender year 1996.
3. The property which is the SUbJect of this appeal is Cumberland County
Assessment Parcel Number 10-22-0527-155, and is known as 465 Railroad Avenue,
SlIpulallon and Joint Mallon lor Agread Ordar
Page 1 01 3
\
,
Shiremanstown, Pennsylvania. The property Is situate in Hampden Township,
Cumberland County, Pennsylvania.
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 $7,100,000.
5. The common level ratio applicable to this appeal for the 1996 tax year, as
certified by the State Tax Equalization Board on or before July 1, 1995, is 7.3%.
Applying the common level ratio to the total market value of the SUbJect property
results in its lawful total assessment being $518,300. 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 $518,300.
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 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 or rebllllngs of 1996 Cumberland County and 1996
Hampden Township real estate taxes. The change In assessment shall effect
Cumberland Valley School District taxes beginning July 1, 1996 for the 1996-97
school tax fiscal year.
8. The new assessment shall be effective January 1, 1996 and shall remain
unchanged unless and until changed as otherwise provided by law.
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 Joint Motion lor Agreed Order
Page 2 01 3
h..,.
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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,
PETITIONER, TRUE RAILROAD ASSOC.,
L.P./TRUE TEMPE ARDWARE
Date: LI/ L) Ie;, By:
RESPONDENT, CUMBERLAND COUNTY
BOARD OF ASSESSMENT APPEALS
and COUNTY OF CUMBERLAND
Date: I )?
~ A '
By:~/4_ ..;{) - 7 ~
S?eph n D. Tiley, Esquire
Frey & Tiley
Attomey for Respondents
RESPONDENT, CUMBERLAND VALLEY
SCHOOL DISTRICT and TOWNSHIP OF
HA~~E
Date: ~"/~.6
By:
Rich . nelbaker, Esquire
Snelbaker & Brenneman
Attomeys for Respondent
Stipulation and JoInt Motion lor Agreed Order
Page 3 or 3
,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTION. LAW
TRUE RAILROAD ASSOC. LPITRUE TEMPER
HARDWARE
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:: NO.: fp(P22 ~ I~
Petitioner,
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BOARD OF ASSESSMENT APPEALS
Respondent.
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ORDER
AND NOW, this ,Qq%ay of '-'IL,,~ 1995, at
o'clock,
upon consideration of the foregoing Petition, it is hereby ordered pursuant to the Act of
June 26, 1931, P.L. 1379, ~9, as amended (72 P.S. ~ 5350) that a hearing upon this
appeal shall be held on the 10 u... day of ~. P , 19 q b , at )J t.j 5 Q.,., .
o'clock, In Courtroom no. Tf . TI.v rlu._....I.." I__arlftll daM I.. fixed f... rale. J
~,.... _,~. ",,~.I ".1 J_~. to boo""'" ......,,,,,,, p",~.,,1 "'" ....._l ,,'.
pert) VI I'D' lie Iv l"I~loR.
Within twenty (20) days after the date of entry by the Court of the Order
fixing the hearing date on the appeal the Petitioner shall mall, by certified mall, a copy of
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the Petition and Order to the following: The Board of Assessment; the County Solicitor;
the municipality In which the tax parcells loceted; the school district in which the tax
parcel Is loceted; and the property owner (if different then Petitioner). Within thirty (30)
days after the date of this Court Order the Petitioner shall file an affidavit of service with
the Prothonotary.
Any person or governmental agency upon whom a copy of the Petition and Order
is required to be served under paragraph mentioned above, 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 the Petition and Order, a praecipe directing Intervention either
as an Petitioner or Respondent. If such praecipe is not filed by said person or
governmental agency within the said twenty (20) day period Intervention thereafter shall
be govemed by Pennsylvania rules of Civil Procedure 2326 through 2350 Inclusive.
BY THE COURT:
//
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
TRUE RAILROAD ASSOC. LP.I TRUE TEMPER
HARDWARE,
NO. qb-~~ 2L ~r~
PETITIONER,
VS.
BOARD OF ASSESSMENT,
RESPONDENT
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the Petition for
Review of Real Estate Assessmen, and Proposed Order in the entitled action, have been served
upon the following by way of certified mall:
HOnlce A. Johnson, Esq.
Solicitor for Cumberland County
3rd and Market Streets
Post Office Box 109
Lemoyne, PA 17043
John E. SlIke, Esq.
Solicitor for Shlremanstown
2109 Market Street
Post Office Box 737
Camp Hill, PA 17011
Steven Tiley, Esq.
Solcitor for Board
5 S. Hanover Street
Carlisle, PA 17013
Richard Snelbaker, Esq.
Solicitor for Mechanlcsburg S.D.
44 West Main Street
Post Office Box 31
Mechanlcsbu A 17055
DATED:
November 17, 1995
GREGORY G. LOTZ,
.
Garippa & Davenpo
P.O. Box 1584
66 Park Street
MontclaIr. New J
(201) 744-1688
Attomey for Petitioner
Momey 10#43603
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
TRUE RAILROAD ASSOC. L.P.I TRUE TEMPER
HARDWARE,
NO. 95-6622
PETITIONER,
VS.
BOARD OF ASSESSMENT.
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, have been served
upon the following by way of certified mail:
Richard Snelbaker, Esq.
Solicitor for Hampden Twp.
44 West Main Street
Post Office Box 318
Mechanlcsbur9. PA 17055
DATED:
November 30. 1995
<4t~doa
LAW oP'P',cla
SNELBAKER
8r
BRENNEMAN
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TRUE RAILROAD ASSOC. LP/
TRUE TEMPER HARDWARE,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95-6622 CIVIL TERM
I
.
.
I
.
.
VS.
I REAL ESTATE TAX ASSESSMENT
I APPEAL
BOARD OF ASSESSMENT APPEALS,
Respondent
PRAECIPE TO ENTER APPEARANCE
TO: Prothonotary of Cumberland County
Please enter and note the appedrance of the undersigned as
attorneys for Cumberland Valley School District and Township of
Hampden in the above captioned matter.
, P.c.
B
chard C. Snelbaker
44 West Main street
Mechanicsburg, PA 17055-0318
(717) 697-8528
Date: December b
, 1995
LAW a"leu
SNELDAKER
a
BRENNEMAN
.
'"
.
CERTIFICATE OF SERVICE
I hereby certify that I am this date serving a true and
correct copy of the within Praecipe to Enter Appearance upon the
following attorneys by sending the same by first-class mail
postage paid addressed as follows:
Gregory G. Lotz, Esquire
Garippa and Davenport
66 Park Street
Monclair, NJ 07042
(Attorney for Petitioner)
Steven D. Tiley, Esquire
5 South Hanover Street
Carlisle, PA 17013
(Attorney for Respondent)
R chard C. Snelbaker
NELBARER & BRENNEMAN, P. C.
Attorneys for Cumberland Valley
School District and Township of
Hampden
Dated: December 6 ,1995
TRUE RAILROAD ASSOC. LP/
TRUE TEMPER HARDWARE,
Petitioner
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I No. 95-6622 CIVIL TERM
vs.
REAL ESTATE TAX ASSESSMENT
I APPEAL
.
.
BOARD OF ASSESSMENT APPEALS,
Respondent
PRAECIPE TO INTERVENE
TO: Prothonotary of Cumberland County
Cumberland Valley School District and Township of Hampden,
local taxinq bodies with reqard to the subject real estate in
this matter, hereby intervene in accordance with law as parties
respondents-appellees.
, p.e.
By
hard C. Snelbaker
Attorneys for Intervenors:
Cumberland Valley School
District and Township of Hampden
Date: December t ,1995
LAW O"ICk.
SNELDAKER
a
BRENNEMAN
LAW O'P',CC8
SNELDAKER
a
BRENNEMAN
. 0
CERTIFICATE OF SERVICE
I hereby certify that I am this date serving a true and
correct copy of the within Praecipe to Intervene upon the
following attorneys by eending the same by first-class mail
postage paid addressed as followSl
Gregory G. Lotz, Esquire
Garippa and Davenport
66 Park Street
Honclair, NJ 07042
(Attorney for Petitioner)
Steven D. Tiley, Esquire
5 South Hanover Street
Carlisle, PA 17013
(Attorney for Respondent)
chard C. Snelbaker
SNELBAI<ER & BRENNEMAN, P. C.
Attorneys for Cumberland Valley
School District and Township of
Hampden
Dated: December (.
, 1995
. .
TRUE RAILROAD ASSOC. LPI
TRUE TEMPER HARDWARE,
Petitioner
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
NO.
9.5- 0&>11 C. rI ,
0/..0( ~4.t..':""/ k/\.,'Y"l
BOARD OF ASSESSMENT APPEALS,
Respondent CIVIL ACTION. LAW
REPLY
AND NOW, comes the Respondent. Cumberland County Board of Assessment Appeals,
by Stephen D. Tiley, Esquire, its Assistant Cumberland County Solicitor, and replies to
Petitioner's Petition for Review of Real Estate Assessments. as follows:
I. Admitted.
2. Admitted. By way of further reply, the Respondent is the Cumberland County Board
of Assessment Appeals.
3. Admitted in part, Denied in part. It is admitted that True Railroad Associates. L.P. is
the owner of the premises known as Cumberland County Parcel Number 10-22-0527-155.
Respondent has no information with which to affirm or deny that True Temper Hardware has an
ownership interest in said property and strict proof at trial is demanded. By way of further reply,
the property is situate in the municipality of Hampden Township, Cumberland County,
Pennsylvania.
4. Admitted.
5. Admitted.
6. Admitted. By way of further reply, the indicated market value of the property under
the old assessment of $605,830 was $8.299.041. Petitioner appealed that assessment to the
Cumberland County Board of Assessment Appeals which found that the value of the property was
in excess of the value indicated by the old assessment. The Cumberland County Board of
Assessment Appeals therefore raised the value of the property, which would result in an increase
in assessment.
7. Denied. The averments of this paragraph. nnd each of its subparagraphs, contain
conclusions of law to which no responsive pleading is required. By way of further reply, the
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Increased value set by the Cumberland County Board of Assessment Is the fair and proper
valuation for the subJcct property and the assessment resulting therefrom Is the proper assessment
according to all constitution and statutory requirements.
WHEREFORE, the Respondent, Cumberland County Board of Assessment Appeals,
requests Your Honorable Court to affirm the market valuation of the subject premises as set by the
Cumberland County Board of Assessment Appeals, In the amount of $8,299,041 for the premises
known as Cumberland County Parcel Number 10-22-0527-155.
Oalcd: ~ .:z~ I~S-
Respectfully submitted,
~ey.~:e 7 /j
Assistant Cumberland County Solicitor
5 South Hanover Street
Carlisle, PA 17013
(717) 243-5838
Attorney 1.0. No.: 32318
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TRUE RAILROAD ASSOC. LPI
TRUE TEMPER HARDWARE,
Petitioner
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
I PENNSYLVANIA
VS.
NO.
CUMBERLAND COUNTY BOARD
OF ASSESSMENT APPEALS,
Respondent
CIVIL ACTION. LAW
The undersigned hereby certified that a true and correct copy of the within Reply has been
served by regular, United States mail, deposited on the date shown below, postage prepaid, to the
fo\1owing:
Gregory G. LolZ, Esquire
Garippa and Davenport
66 Park Street
P. O. Box 1584
Montclair, NJ 07042
Richard C. Snelbaker, Esquire
Snelbaker and Brenneman
44 West Main Street
P. O. Box 318
Mechanicsburg, PA 17055
Dated:# OZ-;;tn'r
~LJ<,7~
Stephen D. Tiley, Esquire
Assistant Cumberland County Solicitor
5 South Hanover Street
Carlisle, PA 17013
(717) 243-5838
Attorney I.D. No.: 32318
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL ACTiON. LAW
..
..
TRUE RAILROAD ASSOC. LP I TRUE
TEMPER HARDWARE
Petitioner,
;; NO.: CJ5 - l.Q (q ~ ~ ~"leAfY)
..
..
V.
BOARD OF ASSESSMENT APPEALS
Respondent.
TO THE HONORABLE, THE JUDGES OF SAID COURT:
1. The Petitioner is True Railroad Assoc. LPlTrue Temper Hardware, a limited
partnership organized under the laws of the state of Pennsylvania, c/o Garlppa &
Davenport, P.C. 66 Park Street, P.O. Box 1584, Montclair, New Jersey 07042.
2. The respondent is the Board of Assessment Appeals whose address Is, 1
Courthouse Square, Carlisle, PA 17013.
1
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3. The petitioner Is the owner of premises known as Tax Map No. 10-22-0527-
155,465 Railroad Avenue, Shlremanstown, PA.
4. Sometime In 1995, the petitioner was Informed that the assessment of the
above premises was fixed for the year 1996 at $605,630
5. The petitioner filed notices of Its Intention to appeal to the Board of 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 October 24, 1995, the petitioner was informed that the board
had revised the market value as follows, $8,329,000. (See Exhibit A attached hereto).
7. The assessment of the premises known as Tax Map No.10-22-0527-155, 465
Railroad Avenue, Shlremanstown, 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.
(c) The assessment lacks uniformity.
(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 1996, for the premises known as Tax Map No. 10-22-0527-155,
2
465 Railroad Avenue, Shiremanstown, Pennsylvania, and make such other orders and
Dated: November 17,1995
3
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EARL R. KELLER
Cl<Al1UWl
N"'NCY .... BESCH
VICICl<Al1UWl
"'...RCI... L. "'YERS
IlCIIITAII.
WILU...'" e. DENNIS
CHIU CLI.UUCOUNT't AOMIHllITRATOft
ROBERT H. C. LISSE
AIIIISMINT , TAX AOMINIIWTOR
R"'NOY L. W"'GGONER
CHI(/' "'11lO~.I""""
717 ~~()"3~:;
HOR"'CE .... JOHrlSON
IOUCITOR
STEPHEN O. TILEY
AIIIITANT IOUCITOft
Cltumbtrluub Cltl1Utttg Inarb nf .Asstssmtut uull IltutsUm of mUXtS
1 CoURTHOUSE SOU.... C'RUlLE. P. 17013
(117) zt0-6360
October 24. 199~
International APpraisal Company
110 Pleasant Avenue
Upper Saddle River. New Jersey 07458
RE: Tax Parcel 10-Z2-0527-155
True RaIlroad Assoc. L.P.. clo True Temper Hardware Co.
The Board of Assessment Appaals Order is as follows:
Market Value was set at 58.329,000.
ANY PERSON AGCRIEVED BY THE ORDER OF THE BOARD MAY APPEAL TO THE
COURT OF COMMON PLEAS BY FILINC A PETITION IN THE PROTHONOTARY'S
OFFICE ON OR BEFORE 11/23/95.
,f~!I.f!..~
Robert H.C. Llsse
Assessment & Tax Admn.
CERTIFICATION OF VERIFICATION
1. I, Gregory G. Lotz, Esq., 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 True Railroad
Assoc LPlTrue Temper Hardware.
3. The offices of True Railroad Assoc LPlTrue Temper Hardware are located In
New Jersey. The Certification of Verificetlon is not executed by a partner of True Railroad Assoc
LPlTrue Temper Hardware because said verification could not be obtained within the time
prescribed by the statute and the rules ofthe 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 In
the within Petition are willfully false. I am subject to punishment.
NOTARY
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LFTTFR nF AIITl-lnRI7ATlnN
KNOW ALL MEN BY THESE PRESENTS that Garlppa & Davenport. P.C.. and its
designee!s) is hereby authorized to represent and act on behalf of TRUE RAILROAD
ASSOCIATES clo TRUE TEMPER HARDWARE CO.. with full power and authority to take any
and all action which is advisable or necessary with regard to the hearing before the Cumbarland
County Board of Assessment on October 10. 1995. This authorization is applicable to the
1996 tax year.
Tax Map No. 10-220527-155
465 Railroad Avenue
Shiremanstown. Cumberland County. Pennsylvania
TRUE RAILROAD ASSOCIATES clo TRUE TEMPER
HARDWARE CO.
By: L.J,,;QD;o.., /. CC" ~
Typed Signature: WilliAm RlIgnn r. P M
Corporate Title: VI"" P,...lrf"nt M"t",IAI"
Subscribed and sworn to before me
this ~ day of October 1995.
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C:\W'1/M1M~ JAUTHDOC. II
NolIutII SolI
IIMdaJ.lJlrds.r~NlIo
HI/)'Ilden '1'ioll-. CU\'lllol1ar<I Colritf
MyCUl,.,~,e.pn&Ncv,:!7. 1005