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Verizon New York ..... _. . 1 STATE OF NEW YORK SUPREME COURT: COUNTY OF DUTCHESS In the Matter of the Application of VERIZON NEW YORK, INC. (formerly New York Telephone Company), 09002595 NOTICE OF PETITION INDEX NO. 0 cr.- ~I Cfo/ Petitioner, -vs.- R.J.I. NO. FILING DATE:"" -I r: 09 THE ASSESSOR, BOARD OF ASSESSMENT :g REVIEW AND THE TOWN OF W APPINGERS FALLS, JUDGE l?l NEW YORK, '" ~ Respondents. ;;: w z Z o >- :: ~ Upon the annexed verified Petition, an application will be made to the Dutchess County z a; ~ Supreme Court of the State of New York at the Courthouse on the 28th day of August, 2009, at >- m >- w g "" :r "' "' 9:30 o'clock in the forenoon ofthat day or as soon thereafter as counsel can be heard, for a ~ Review under Article Seven of the Real Property Tax Law ofthe assessments for 2009, upon !;{ >- w z ['; certain real property of the Petitioner as set forth and described in the annexed Petition, and for ~ o ~ such other and further relief as to the Court may seem just and proper together with the costs and it< a: -; ~ disbursements of this proceeding. !;{ a. Dated: Binghamton, New York July 1,2009 PATRICKJ. RAYMOND, ESQ. Attorney for Petitioner Office and Post Office Address 66 Hawley Street P.O. Box 607 WVS Binghamton, New York 13905 Tel. (607) 723-2223 RECEIVED JUL 2 3 2009 TOWN CLERK , ~ ? STATE OF NEW YORK SUPREME COURT: COUNTY OF DUTCHESS In the Matter of the Application of VERIZON NEW YORK, INC. (formerly New York Telephone Company), PETITION -vs.- Petitioner, INDEX NO. R.J.I. NO. FILING DATE: THE ASSESSOR, BOARD OF ASSESSMENT REVIEW AND THE TOWN OF W APPINGERS FALLS, :g NEW YORK, i1J Respondents. '" a: o >- ~ w z Z o .... ;;: .. J: CJ z in Petitioner, as and for Petition herein, alleges and states: 1. That at all times hereinafter mentioned, Petitioner was and still is ml\lIler/lessee of .... w w a: ~ property located in the Town ofWappingers Falls, County of Dutchess, State of New York, oJ ~ .. J: :g which property is designated on the municipal assessment roll as set forth on Schedule "A" ~ ~ annexed hereto. w z a: o ~ 2. That the Assessor and Board of Assessment Review, now and at all times hereinafter " z o ;;: ~ mentioned, were duly appointed and acting for and on behalf ofthe Respondent municipality, all -; '" " ii' \( 0. in cOl1l1ection with the assessment roll for the year 2009. The respondent municipality is a municipal corporation organized and existing under and by virtue of the laws of the State of New York. The Assessor and the Board of Assessment Review at such time were d.uly authorized by law to assess real property in said jurisdiction for Town, County, and School taxes, including the property of Petitioner herein. The said Board was duly authorized by law to review the action of 2 " . the said Assessor with respect to complaints filed concerning assessments appearing on the assessment roll of said municipality for the year 2009, and to finally correct and revise any and all assessments on said roll concerning such complaints. 3. Upon infOlmation and belief, the Respondent Assessor prepared and completed a general assessment roll of all real property in said municipality for the 2009 tax assessment roll. Thereafter such Respondent caused such assessment roll to be filed so that it might be seen and posted publicly and caused such to be published in said tax district a notice,tothat effect and :g further stating that on Grievance Day, May 26,2009, the Board of Assessment Review would l!l '" ~ meet at a time and place specified in said notice to hear complaints and grievances as to any ai z z ~ assessment appearing on such assessment roll. :; <{ J: " z iii 4. The assessment roll for the year 2009 named Petitioner as owner of the subject real 0- W W a: 0- ~ property setting forth the total assessed values of the said property as set forth in Schedule "A". ~ J: '" '" 5. That on Grievance Day Petitioner protested the said assessment by filing with the ~ ~ Assessor and Board of Review written application for cOlTection of such assessed valuation z a: o ~ incorrect together with a request for reduction of said assessment. -i '" o it t< "- 6. At the time and place specified in the notice for hearing 011 said assessment, your Petitioner submitted to the Respondent Board of Review the protest of the assessment and Ipade written application to have the same corrected upon the grounds that the assessment is erroneous, unlawful and unequal. 7. That the Board of Review refused and still refuses to correct and reduce the assessment. 3 . ~ 8. The application for correction of assessed valuation was received by the Board of Assessment Review, without objection, within the time fixed by law for the making and hearing of complaints, and upon information and belief, the aforesaid Board considered such application upon the merits. 9. Thereafter, the Board of Assessment Review made its final determination on Petitioner's application, and on or about July 1,2009 said assessment roll for the year 2009 was finally completed and filed by Respondents as required by law. "' o ~ 10. Respondent Board of Assessment Review duly gave the notice required by law by '" ~ posting and publishing noticeofthe completion and filing of said assessment roll. ffi z z o 0- :2 " J: <!l z in 11. The assessment of Petitioner's property as set forth on said assessment roll and as finally completed and filed aforesaid is erroneous, unconstitutional, unlawful and unequal. Iii UJ a: 0- V! >- W -' ~ J: '" '" 12. That to correct Petitioner's real property assessment, it is necessary to reduce the total assessment as set forth in Schedule "A". '" :5 l< >- w z a: o : injured thereby. If same is permitted to remain, Petitioner will be required to pay a greater z o :> ;;; cr 13. Petitioner is aggrieved by such erroneous, unlawful and unequal assessment and is portion ofthe share of taxes required to be raised by the Respondents than Petitioner would be -; '" o ii' l< n. required to pay if said assessment had been made correctly, fairly and otherwise properly. Such erroneous, unlawful and excessive assessment is confiscatory in nature and subjectsPetitioner to paying more taxes than Petitioner should be required to pay, legally or equitably. 14. Thitty days have not elapsed since the final completion and filing of said assessment roll as aforesaid. WHEREFORE, Petitioner respectfully seeks: 4 .- A. That the assessment roll be corrected and the assessment against Petitioner's property be stricken from the roll or be reduced to a proper amount; B. That this Court take evidence or cause same to be taken to enable Petitioner to show the assessment to be erroneous, unlawful, and excessive together with such other and further relief as to tlus Court shall seem just and proper, together with the costs and disbursements of this proceeding. Dated: Binghamton, New York July 1,2009. #J~ on o en ~ :< II: o >- >: w z Z o f- ::; <( J: Cl z iii PATRICK J. RAYMOND, ESQ. Attorney for Petitioner Office and Post Office Address 66 Hawley Street P.O. Box 607 WVS Binghamton, New York 13905 Tel. (607) 723-2223 Iii w II: f- <n >- w -' ~ J: :g >: :5 !< >- w z a: o ~ o z o ::; ~ a: -; :< U a: ~ 5 i TOWN OF W APPINGERS FALLS Schedule "A" ~ '" '" 0: o >- ~ z ;i o I- :;; '" r '" z [ij Address & Assessmellt Claimed Fair Market As,"iessmellt Demalld Tax Map Number Value at 100% 2620 South A venue $850,000 $400,000 $400,000 6158-18-358182-0000 I;; W 0: l- V> >- W ...J ~ r :8 ;: :5 t< >- w Z 0: o ~ " ~ :;; ~ 0: -; '" u 1i' ~ 6