IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION

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1 IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION LAWRENCE W. DUNN and CAROL L. : DUNN, his wife, COIN FLIP ASSOCIATES, a Pennsylvania General Partnership, : MAYVIEW ROAD ASSOCIATES TRUST AGREEMENT, HIGHLAND FARMS : INCORPORATED, and LOWRIES RUN ROAD TRUST AGREEMENT, on behalf : of all similarly-situated taxpayers, : Plaintiffs, : vs. GD : GD THE BOARD OF PROPERTY ASSESSMENT, APPEALS AND REVIEW : OF ALLEGHENY COUNTY and COUNTY OF ALLEGHENY and ALL LOCAL : TAXING AUTHORITIES LOCATED IN ALLEGHENY COUNTY, : Defendants. : PLAINTIFFS' MOTION FOR RECUSAL FROM PLAINTIFFS' RECUSAL MOTION AND NOW, come Plaintiffs, by and through their attorneys, the law firm Pepper Hamilton LLP and Dusty Elias Kirk, Esquire, and the law firm Goldberg, Kamin, Garvin, and Samuel P. Kamin, Esquire and file the within Motion for Recusal from Plaintiffs' Recusal Motion, and in support thereof state as follows: 1. Plaintiffs previously have filed of record a Motion for Recusal, which matter is scheduled for argument before the Honorable R. Stanton Wettick on January 10, Said Recusal

of all similarly-situated taxpayers, : Plaintiffs, : vs.

2 G.D Motion is incorporated herein by reference thereto. 2. Based upon the holding of Municipal Publications, Inc., et al. v. Court of Common Pleas of Philadelphia County, 207 Pa. 194, 489 A.2d 1286 (1985), Plaintiffs request that the Honorable R. Stanton Wettick recuse himself from presiding over Plaintiffs' Recusal Motion. A copy of said case is attached hereto, marked as Exhibit "A" and made a part hereof. WHEREFORE, Plaintiffs respectfully request that the Honorable R. Stanton Wettick recuse himself from hearing Plaintiffs' Recusal Motion in the within Respectfully submitted, Samuel P. Kamin (Pa. I.D. No ) David A. Wolf (Pa. I.D. No ) Goldberg, Kamin & Garvin 1806 Frick Building 437 Grant Street Dusty E. Kirk (Pa. I.D. No ) Sharon F. DiPaolo (PA. I.D. No ) Pepper Hamilton LLP One Mellon Bank Center, 50th Floor (412) Attorneys for Plaintiffs LAWRENCE W. DUNN and CAROL L. DUNN, his wife, COIN FLIP ASSOCIATES, a Pennsylvania General Partnership, MAYVIEW ROAD ASSOCIATES TRUST AGREEMENT, HIGHLAND FARMS INCORPORATED, and LOWRIES RUN ROAD TRUST AGREEMENT, on behalf of all similarly-situated taxpayers Dated: January 10,

A copy of said case is attached hereto, marked as Exhibit "A" and made a part hereof. WHEREFORE, Plaintiffs respectfully request that the Honorable R.

3 G.D NOTICE OF PRESENTATION To all Counsel: Please take notice that Plaintiffs' Motion for Recusal from Plaintiffs' Recusal Motion will be presented to Judge R. Stanton Wettick, Jr., Courtroom 815, on Friday, January 10, 2003, at 12:45 p.m. CERTIFICATE OF SERVICE I hereby certify that on the 10th day of January, 2003 a true and correct copy of Plaintiffs' Motion for Recusal from Plaintiffs' Recusal Motion was hand-delivered to the Core Defense Committee as follows: COUNSEL FOR CORE DEFENDANTS Ira Weiss, Esquire (412) Fort Pitt Commons 445 Fort Pitt Boulevard weisslawiw@stargate.net Counsel for Borough of Bradford Woods, Montour School District, Borough of Franklin Park, West Allegheny School District, City of Pittsburgh School District, Carlynton School District, Municipality of Bethel Park, Keystone Oaks School District Alfred C. Maiello, Esquire (412) Maiello, Brungo & Maiello, LLP One Churchill Park McCrady & Rodi Roads 3301 McCrady Road Pittsburgh, PA maiellobrungo@aol.com Counsel for Bethel Park School District, North Allegheny School District, Penn Hills School District, Avonworth School District, Chartiers School District, Moon Area School District, Northgate School District, South Park School District, West Allegheny School District

815, on Friday, January 10, 2003, at 12:45 p.m.

4 G.D Timothy J. Bish, Esquire (412) Springer Bush & Perry Two Gateway Center, 15th Floor Pittsburgh, PA Counsel for Baldwin-Whitehall School District, Borough of Crafton, Mt. Lebanon School District, Frazer Township, Borough of Aspinwall Edward R. Lawrence, Jr., Esquire (412) Springer Bush & Perry 500 Cherrington Parkway, Suite 420 Coraopolis, PA Counsel for Baldwin-Whitehall School District, Borough of Crafton, Mt. Lebanon School District, Frazer Township, Borough of Aspinwall Ronald H. Pferdehirt, Esquire (412) Assistant City Solicitor City of Pittsburgh Department of Law 313 City-County Building 414 Grant Street Counsel for City of Pittsburgh Isobel Storch, Esquire (412) County Office Building 542 Forbes Avenue Counsel for Allegheny County Board of Assessment, Appeals and Review C. Donald Gates, Esquire (412) Babcock Boulevard Pittsburgh, PA Counsel for Ross Township

, Esquire (412) 269-4200 Springer Bush & Perry 500 Cherrington Parkway, Suite 420 Coraopolis, PA 15108-3193 E-MAIL: erl@sbandp.

5 G.D W. Theodore Brooks, Esquire (412) Tucker Arensberg, P.C One PPG Place Pittsburgh, PA Counsel for Borough of Swissvale, Borough of Sewickley, Municipality of Bethel Park, Shaler Area School District, Brentwood Borough School District, South Fayette Township School District Charles P. McCullough, Esquire (412) County Solicitor Allegheny County Law Department 300 Fort Pitt Commons 445 Fort Pitt Boulevard Counsel for County of Allegheny I have also posted this pleading on Pepper Hamilton LLP's web-site at Dusty E. Kirk (Pa. I.D. No ) Sharon F. DiPaolo (PA. I.D. No ) Pepper Hamilton LLP One Mellon Bank Center, 50th Floor (412) Samuel P. Kamin (Pa. I.D. No ) David A. Wolf (Pa. I.D. No ) Goldberg, Kamin & Garvin 1806 Frick Building 437 Grant Street Attorneys for Plaintiffs LAWRENCE W. DUNN and CAROL L. DUNN, his wife, COIN FLIP ASSOCIATES, a Pennsylvania General Partnership, MAYVIEW ROAD ASSOCIATES TRUST AGREEMENT,

P. McCullough, Esquire (412) 350-1120 County Solicitor Allegheny County Law Department 300 Fort Pitt Commons 445 Fort Pitt Boulevard E-MAIL: cmccullough@couty.allegheny.pa.us Counsel for County of Allegheny I have also posted this pleading on Pepper Hamilton LLP's web-site at www.

6 HIGHLAND FARMS INCORPORATED, and LOWRIES RUN ROAD TRUST AGREEMENT, on behalf of all similarly-situated taxpayers IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION LAWRENCE W. DUNN and CAROL L. DUNN, his wife, COIN FLIP ASSOCIATES, a Pennsylvania General Partnership, MAYVIEW ROAD ASSOCIATES TRUST AGREEMENT, HIGHLAND FARMS INCORPORATED, and LOWRIES RUN ROAD TRUST AGREEMENT, on behalf of all similarlysituated taxpayers, Plaintiffs, vs. THE BOARD OF PROPERTY ASSESSMENT, APPEALS AND REVIEW OF ALLEGHENY COUNTY, and COUNTY OF ALLEGHENY and ALL LOCAL TAXING AUTHORITIES LOCATED IN ALLEGHENY COUNTY, Defendants. No. GD GD CLASS ACTION PLAINTIFFS MOTION FOR RECUSAL FROM PLAINTIFFS' RECUSAL MOTION Filed on behalf of Plaintiffs, LAWRENCE W. DUNN and CAROL L. DUNN, his wife, COIN FLIP ASSOCIATES, a Pennsylvania General Partnership, MAYVIEW ROAD ASSOCIATES TRUST AGREEMENT, HIGHLAND FARMS INCORPORATED, and LOWRIES RUN ROAD TRUST AGREEMENT, on behalf of all similarlysituated taxpayers, Counsel of Record for these Parties: SAMUEL P. KAMIN, ESQUIRE PA. I.D. # SamK@gkgattorneys.com DAVID A. WOLF, ESQUIRE PA. I.D. # DavidW@gkgattorneys.com GOLDBERG, KAMIN & GARVIN 1806 Frick Building, 437 Grant Street (412) DUSTY ELIAS KIRK, ESQUIRE Pa. I.D. # kirkd@pepperlaw.com SHARON F. DiPAOLO, ESQUIRE Pa. I.D. # dipaolos@pepperlaw.com

DUNN, his wife, COIN FLIP ASSOCIATES, a Pennsylvania General Partnership, MAYVIEW ROAD ASSOCIATES TRUST AGREEMENT, HIGHLAND FARMS INCORPORATED, and LOWRIES RUN ROAD TRUST AGREEMENT, on behalf of all

7 PEPPER HAMILTON LLP Pa. Firm No. #143 website: 50th Floor, One Mellon Bank Center (412) IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA CIVIL DIVISION LAWRENCE W. DUNN and CAROL L. : DUNN, his wife, COIN FLIP ASSOCIATES, a Pennsylvania General Partnership, : MAYVIEW ROAD ASSOCIATES TRUST AGREEMENT, HIGHLAND FARMS : INCORPORATED, and LOWRIES RUN ROAD TRUST AGREEMENT, on behalf : of all similarly-situated taxpayers, : Plaintiffs, : vs. GD : GD THE BOARD OF PROPERTY ASSESSMENT, APPEALS AND REVIEW : OF ALLEGHENY COUNTY and COUNTY OF ALLEGHENY and ALL LOCAL : TAXING AUTHORITIES LOCATED IN ALLEGHENY COUNTY, : Defendants. : AND NOW, to-wit, this ORDER day of January, 2003, upon consideration of Plaintiffs' Motion for Recusal from Plaintiffs' Recusal Motion, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiffs' Motion is GRANTED, and the case is referred back to the Administrative Judge of the Civil Division of the Court of Common Pleas of Allegheny County, Pennsylvania for further disposition. Administrative Judge. All proceedings in this matter are stayed pending reassignment of this matter by the

8 BY THE COURT: G.D

Realty Transfer Tax Rates

1 of 6 1/19/2015 1:19 PM Realty Transfer Tax Rates Common Level Ratio Factor (CLR) for Real Estate Valuation Allegheny County 1.10 PA Department of Revenue - All PA Counties Act 77 In 1986, the State Legislature