docket no: nnh-cv17-6072481-s : superior court …
TRANSCRIPT
{00054382.1 } 1
DOCKET NO: NNH-CV17-6072481-S : SUPERIOR COURT :
ELIYAHU MIRLIS : J.D. OF NEW HAVEN:
V. :: AT NEW HAVEN :
DANIEL GREER : MAY 17, 2018
OBJECTION TO MOTION FOR JUDGMENT OF STRICT FORECLOSURE
The defendant, Daniel Greer (“Greer” or the “Defendant”), hereby objects to the Motion
for Judgment of Strict Foreclosure (Doc. No. 109, the “Strict Foreclosure Motion”), filed by the
plaintiff, Eliyahu Mirlis (the “Plaintiff”). As set forth herein, the Strict Foreclosure Motion
should be denied because (a) there is a dispute as to the value of the property that is the subject
of the Strict Foreclosure Motion, 133 West Park Road, New Haven, Connecticut (the
“Property”) and (b) Greer has previously filed a Motion to Substitute Bond (Doc. No. 106, the
“Motion to Substitute”), which has not been acted on and, pursuant to statute, Greer is entitled to
bond off Plaintiff’s judgment lien. In support hereof Greer submits as follows:
I. FACTS AND BACKGROUND
A. Factual Background
On July 7, 2017, Plaintiff filed a certificate of judgment lien (the “Judgment Lien”)
against the Property with the Office of the City Clerk for the City of New Haven, Connecticut.
Thereafter, on July 31, 2017, Plaintiff initiated the instant action by filing a complaint seeking
foreclosure of the Judgment Lien. On November 8, 2017, Plaintiff filed his Motion for Summary
Judgment in the instant case. Greer did not oppose entry of summary judgment as to liability
only, but instead filed his Motion to Substitute. Plaintiff has now moved for judgment of strict
foreclosure.
{00054382.1 } 2
B. Procedural History
On June 6, 2017, final judgment entered against Greer and the Yeshiva of New Haven,
Inc. (the “Yeshiva”) in the U.S. District Court case styled Eliyahu Mirlis v. Daniel Greer, et al.,
Case No. 3:16-CV-00678 (the “District Court Case”) in the amount of $21,749,041.10 (the
“Judgment”). Subsequently, on June 28, 2017, Greer and the Yeshiva filed a motion for new
trial in the District Court Case pursuant to Fed. R. Civ. P. 59(a) (the “New Trial Motion”)
seeking either an order granting a new trial or remittitur of the Judgment on the basis that the
evidence could not fairly support the jury’s award of non-economic damages.
On October 27, 2017, Greer and the Yeshiva filed a motion for relief from final judgment
(the “Motion for Relief”) in the District Court Case on grounds that newly-discovered evidence
had been brought to the attention of Greer and the Yeshiva thereby warranting relief under Fed.
R. Civ. P. 60(b)(2).
The District Court heard oral argument on the New Trial Motion and Motion for Relief
on December 8, 2017, and denied both motions. As such, on December 15, 2017, Greer and the
Yeshiva filed a Notice of Appeal indicating that Greer and the Yeshiva seek review by the
United States Court of Appeals for the Second Circuit from the Judgment and the District
Court’s denial of the New Trial Motion and Motion for Relief.
II. LAW AND ARGUMENT
First, Plaintiff’s appraisal is too high. Attached hereto as Exhibit A is an appraisal
obtained by Greer demonstrating that the value of the Property is overstated.
Second, Greer is entitled to substitute a bond and discharge the judgment lien, thereby
ending this foreclosure action. See Gen. Stat. § 52-380e; Doc. No. 106. Thus, once the issue of
value is settled, the Court should set a value for the amount of the bond (i.e. ½ the value of the
{00054382.1 } 3
Property, which is jointly owned by Greer’s wife, less the $75,000 homestead exemption to
which Greer is entitled).
WHEREFORE, Greer hereby requests that the Court deny the Strict Foreclosure Motion
and set a hearing to determine the value of the Property and set a value for a bond, pursuant to
the Motion to Substitute.
THE DEFENDANT: Daniel Greer By: /s/ Lauren McNair Jeffrey M. Sklarz Lauren McNair Green & Sklarz LLC 700 State Street, Suite 100 New Haven, CT 06511 (203) 285-8545 Fax: (203) 823-4546 [email protected] [email protected]
{00054382.1 } 4
CERTIFICATE OF SERVICE
This is to certify that on May 17, 2018, a copy of the foregoing Objection to Motion for
Judgment of Strict Foreclosure was sent to all appearing parties and counsel of record as follows
via electronic email:
Matthew Beatman John L. Cesaroni Zeisler & Zeisler, P.C. 10 Middle Street, 15th Floor Bridgeport, Connecticut 06604 [email protected] [email protected] /s/ LaurenMcNair
{00059009.1 }
EXHIBIT A
CONFIDENTIAL
GREER000186
\ *eport J.J. Kyle & AssociatesCONFIDENTIAL
Client File#: Appraisal File #:N/A 1801009
Summary Appraisal Report • Residentialll III,.I i Appraisal Company: J J Kyle & AssociatesAI Reports' Address: 49 Neck Road, Clinton, CT 006413
Form 100.04 Phone: (203) 927-3125 Fax: (860)669-9977 Website:Appraiser: Jim Kyle Co-Appraiser:AI Membership (if any): SRA MAI SRPA AI Membership (if any): SRA MAI SRPAAI Status (if any): Candidate for Designation ] Practicing Affiliate AI Status (if any): Candidate for Designation D Practicing AffiliateOther Professional Affiliation: Other Professional Affiliation:E-mail: [email protected] E-mail:Client: Greer, Daniel & Sarah Contact: Daniel GreerAddress: 133 West Park Avenue
Phone: 203-777-2200 Fax: E-mail:SUBJECT PROPERTY IDENTIFICATION
Address: 1 33 W Park Ave
City: New Haven County: New Haven ZIP: 06511State: CTLegal Description: Vol. 5373, p. 320
Tax Parcel#: ID: 22834 RE Taxes: $9,774.44 Tax Year: 17/18Use of the Real Estate As of the Date of Value: Residential
Use of the Real Estate Reflected in the Appraisal: Residential
Opinion of highest and best use (if required): Current UseSUBJECT PROPERTY HISTORY
Owner of Record: Greer, Daniel & Sarah
Description and analysis of sales within 3 years (minimum) prior to effective date of value:Sales price not known.
No transfer of the subject since 9/18/98.
Description and analysis of agreements of sale (contracts), listings, and options: None known
RECONCILIATIONS AND CONCLUSIONS
Indication of Value by Sales Comparison Approach $ 270,000
$ N/AIndication of Value by Cost Approach
Indication of Value by Income Approach $ N/AFinal Reconciliation of the Methods and Approaches to Value:Approach was not developed due to the age of the subject and the lack of recent land sales. The Income Approach was considered but notdeveloped because residential dwellings are not typically bought and sold on the basis of the income that they might produce. The SalesComparison Approach was developed and was relied upon to indicate a value for the subject. This is typical in the appraisal of single familyresidential properties.
See "Comments and Reconcilliation of the Sales Comparison Approach" in this report.
All three approaches to value were considered in this appraisal. The Cost
Opinion of Value as of: February 1 , 201 8 $ 270,000Exposure Time: Exposure time is estimated to be three to six months.
The above opinion is subject to: IE! Hypothetical Conditions and/or Extraordinary Assumptions cited on the following page.
GREER000186need to provide additional data, analysis and work product not called tor in this form. The Appraisal Institute plays no role in completing the form ana disclaims any responsibility forthe data, analysis or any other work product provided by the individual appraiser(s).AI Reports® AI-1 00.04 Summary Appraisal Report ' Residential © ADDraisal Institute 9M3 All Rinhte Doeon/oH
CONFIDENTIAL
GREER000187
CONFIDENTIALfoient: Client File#:Greer, Daniel & Sarah N/A
Subject Property: Appraisal Rle #:133 W Park Ave, New Haven, CT 0651 1 1801009
ASSIGNMENT PARAMETERS
Intended U8er(s): The client
Intended Use: Estimate a current opinion of value
This report isnot intendedbythe appraiser foranyotheruse orbyanyotheruser.
Type of Value: Effective Date of Value:Market Value February 1, 2018
Interest Appraised: E Fee Simple Leasehold Other
Hypothetical Conditions: (A hypothetical condition is that which is contrary to what exists, but is asserted by the appraiser for the purpose ofanalysis. Any hypothetical condition may affect the assignment results.)
22, 2016 and an exterior viewing from the street on February 1, 2018. The exterior of the subject appeared comparable to the prior
inspection. The interior is assumed to be comparable as well. If there is a material change, this could alter the opinions and conclusions in
this report.
This appraisal is based upon a full interior inspection on September
Extraordinary Assumptions: (An extraordinary assumption is directly related to a specific assignment and presumes uncertain information to be factual.If found to be false this assumption could alter the appraiser's opinions or conclusions. Any extraordinary assumption may affect the assignment results.)
None
In accordance with Standard Rule 2-2(b) of the Uniform Standard of Professional Appraisal Practice (USPAP), this is a summary appraisal report.SCOPE OF WORK
Definition: The scope of work is the type and extent of research and analysis in an assignment Scope of work includes the extent to which the
property is identified, the extent to which tangible property is inspected, the type and extent of data research, and the type and extent of analysis
applied to arrive at credible opinions or conclusions. The specific scope of work for this assignment is identified below and throughout this report.
Scope of Subject Property Inspection/Data Sources Utilized Approaches to Value Developed
Appraiser
Property Inspection: IE! Yes
Date of Inspection: 2/1/18
Describe scope of Property Inspection, Source of Area Calculations
and Data Sources Consulted: Interior and exterior inspections,
Interior 9/22/16; Exterior 2/1/18.
Data source was the assessor's files and inspections.
Cost Approach:
Is necessary for credible results and is developed in this analysis
E Is not necessary for credible results; not developed in this analysisIs not necessary for credible results but is developed in this analysis
No
Sales Comparison Approach:
El Is necessary for credible results and is developed in this analysisIs not necessary for credible results; not developed in this analysis
Is not necessary for credible results but is developed in this analysisCo-Appraiser
Property Inspection: Yes No
Date of Inspection: N/A
Describe scope of Property Inspection, Source of Area Calculations
and Data Sources Consulted: N/A
Income Approach:
Is necessary for credible results and is developed in this analysis
E Is not necessary for credible results; not developed in this analysisIs not necessary for credible results but is developed in this analysis
Additional Scope of Work Comments: Based upon an interior and exterior inspection, the subject is in typical/average condition with no
serious deferred maintanence observed.
Significant Real Property Appraisal Assistance: Ei None Disclose Name(s) and contribution:
was provided to the appraiser by any other parties.
No professional appraisal assistance
The Appraisal Institute publishes this form for use by appraisers where the appraiser deems use of the form appropriate. QgQsEQiiEf p EfefMSdhnrleA'Ihe appraiser mayneed to provide additional data, analysis and work product not called for in this form. The Appraisal Institute plays no role in completing^EramhirraNMMms'fflTy 'responsibility forthe data, analysis or any other work product provided by the individual appraisers).
Al Reports® AI-1 00.04 Summary Appraisal Report - Residential ~ "
* NOTICE:
© Appraisal Institute 2013. All Riahts Reserved January 2013
CONFIDENTIAL
GREER000188
CONFIDENTIALtiient: Client File#;Greer, Daniel & Sarah N/ASubject Property: Appraisal File#:133 W Park Ave, New Haven, CT 0651 1 1801009
MARKET AREA ANALYSIS
Location Built Up
Under 25%25-75%
X Over 75%
Growth
RapidX Stable
Slow
Supply & Demand
ShortageX! In Balance
Over Supply
Value Trend Typical Marketing Time
Under 3 MonthsX 3-6 Months
Over 6 Months
X UrbanSuburbanRural
Increasing
X StableDecreasing
Neighborhood Single Family Profile
Price
under 100k Low
Neighborhood Land Use Neighborhood Name: EdgewoodAge
20% PUD Condo H0A:$
% Amenities: N/A
1 Family
Condo
Multifamily
10% Commercial
05% Vacant
60% park
/300 High
Predominant 50+ yrs 5%none
Market area description and characteristics:
residential section with good access to most urban and suburban amenities. Major employers and the central business district are nearby,many within walking distance. Good access to major roads and public transportation. Edgewood Park is across the street. Proximity tothe park is offset by busy fronting traffic.
The subject is located in the Edgewood section of the City of New Haven. It is a primarily
SITE ANALYSIS
Dimensions: Area: 020 Acresapproximately rectangular
View: average, park and busy road Shape: approximately rectangular
Drainage: appears adequate
Site Similarity/Conformity To NeighborhoodUtility: average
Zoning/Deed RestrictionSize: View:
Favorable
X Typical
Less than Favorable
Zoning: RS 1 Covenants, Condition & Restrictions
Yes No X Unknown
Documents Reviewed
Yes X No
Ground Rent $ N/A/
l i Smaller than Typical
X Typical
Larger than Typical
Legal No zoning
Legal, non-conforming
IllegalUtilities Off Site Improvements
X Public Other Public
X Public Other Public
X Public D Other Municipal
X Public Other Municipal
X Public Private
Public Private
X Public Private
X Public Private
Electric Street
Gas Alley
Water
Sewer
Sidewalk
Street Lights
Site description and characteristics:
conformity is a complex matter and is beyond the scope of this appraisal. The park view is offset by the location on a busy street.
The site is typical in the area, and adequately supports the current improvements. Zoning
HIGHEST AND BEST USE ANALYSIS
X Present Use Proposed Use Other
Summary of highest and best use analysis:
the subject site.
The current use, as is typical of most improved properties, is the Highest and Best Use of
GREERneed to provide additional data, analysis and work product not called tor in this form. The Appraisal Institute plays no role in completing the form and disclaims any responsibility forthe data, analysis or any other work product provided by the individual appraiser(s).Al Reports® Ai-100 .04 Summarv Appraisal Report - Residential
00018 may
(fit Annraioal Inoffhifa OHIO All DinMn
CONFIDENTIAL
GREER000189
CONFIDENTIALClient: Client File#:Greer, Daniel & Sarah N/A
Subject Property: Appraisal File #:133 W Park Ave, New Haven, CT 06511 1801009
IMPROVEMENTS ANALYSIS
Design: colonial No. of Stories: 2.5 Effective Age: 30-40 yrs
Modular
General No.ofllnit8: 1 Actual Age: 98
IX Existing Under Construction Proposed Attached X Detached Manufactured
Other: N/A
Exterior Elements Roofing: asphalt shingle Siding: wood Windows: double hung
Patio X Deck X Porch Pool Fence
Other: Typical of this type building in the neighborhood.
Interior Elements Flooring: wood & carpet X Firepi »# 2Walls: plaster & drywall
Kitchen: Refrigerator Range Oven Fan/Hood Microwave Dishwasher Countertops: typical
Other: Appliances are semi modern, but are considered as personal property.
Foundation Crawl Space Slab X BasementOther: Typical of this type building in the neighborhood.
[ 3 None Scuttle Drop StairAttic Stairway X FinishedMechanicals HVAC: central heat Fuel: oil/gas Air Conditioning: units, personal
Driveway X Garage 2 car Carport FinishedCar Storage
Other Elements n0 special improvments. Typical of this type building in the neighborhood.
The subject currently has a room on the first floor that was a deck and converted to living space.
Above Grade Gross Living Area (GLA)
Living Dining Kitchen Den Family Rec. Bdrms # Baths Utility Other Area Sq. Ft.
Level 1 1 1 1 1 1 1. 1,606
1.408Level 2 3 1
2 1 704
[Bath(9): 3Finished area above grade contains: hedroom(s):5 GLA: 3,718
Summarize Above Grade Improvements: Based upon an interior inspection of the subject, the improvements are typical of an older dwelling.
The exterior and interior showed some deferred maintanence but the subject is rated in overall average condition.
Below Grade Area or Other Area
Living Dining Kitchen Den Family Rec. Bdrms # Baths Utility % Finished rea Sq. Ft.
Below Grade
Other Area
Summarize below grade and/or other area improvements: No finish in basement.
Discuss physical depreciation and functional or external obsolescence:
modernization. Older outdated kitchen; the bathrooms are old style and typical of this type home in the area.
Average physical depreciation. No sign of recent updating or
Discuss style, quality, condition, size, and value of improvements including conformity to market area:
Generally average quality and condition. The subject is large in living area and substantially exceeds the size of a typical single family
home in the neighborhood. The improvements generally conform, other than in size, to this primarily non owner occupied market area.
The colonial style is typical in the area.
GREER000189 ™»the data, analysis or any other work product provided by the individual appraiser(s).Al Reports® AI-1 00.04 Summary Appraisal Report - Residential © Appraisal Institute 901 3 All Rinhts Reserved .Innnnrv
CONFIDENTIAL
GREER000190
CONFIDENTIALClient:
Client File#:Greer, Daniel & Sarah
N/ASubject Property:
Appraisal File#:133 W Park Ave, New Haven, CT 0651 1 1801009
SALES COMPARISON APPROACH
ITEM SUBJECT COMPARISON 1 COMPARISON 2 COMPARISON 3Address 133 W Park Ave
New Haven, CT 0651 1
165 Norton St
New Haven, CT 06511
245 W Park Ave
New Haven, CT 0651 1
450 Ellsworth Ave
New Haven, CT 06511Proximity to Subject
Data Source/
Verification
7 blocks same street 7 blocksVision & Assessor & MLS Vision & Assessor & MLS Vision & Assessor & MLS
Original List Price
Final List Price
$ N/A $ unknown $ unknown $ unknown$ N/A $_ 279,900 $ 294,000 $ 229,900
Sale Price $ N/A 285,000 $ 270,000 $ 222,500Sale Price % of Original List % % % %Sale Price % of Final List % 101.8% 91.8% 96.8 %Closing Date N/A 11/21/17 7/10/17 6/15/17Day? On Market 22 days per MLS 29 days per MLS 155 days per MJ.SPrice/Gross Living Area $ $ 94.34 $ 118.73 I 81.53
DESCRIPTION DESCRIPTION DESCRIPTION DESCRIPTION+(-) Adjustment +(-) Adjustment +(-) AdjustmentFinancing Type N/A N/A N/A N/AConcessions N/A N/A N/A N/AContract Date
Location
N/A N/A N/A N/Agood good good good
Site Size 0.20 Acres 0.15 acres +5,000 0.25 Acres -5,000 0.28 Acres -8,000Site Views/Appeal park/busy street comparable park/busy street comparable
colonial/avgDesign and Appeal colonial/avg colonial/a colonial/avgQuality of Construction average average average averageAge 98 years UI6_years 86 years 96 yearsCondition good -28,000 above averagt -14,000 below average +11,000
average
Bedrooms Bedrooms Bedrooms +5,000 BedroomsAbove Grade Bedrooms 5 5 4 4 +5,000
Baths Baths +3,000 Baths +3,000 BathsAbove Grade Baths 3 2.5 2.5 2.5 +3,000Gross Living Area 3,718 Sq.Ft. 3,021 Sq.Ft. +7,000 2,274 Sq.Ft 2,729 Sq.Ft,+21,700 +12,600Below Grade Area full full full fullBelow Grade Finish none none none noneOther Area
porches, decks, etc. deck comparable comparable comparableFunctional Utility updated -10,000 inferior +10,000
average average
Heating/Cooling central/no CAC central/no CAC central/no CAC central/no CACCar Storage 2 car 1 car +5,000 2 car 2 carFireplace 2 fireplaces 1 fireplace +3,000 1 fireplace +3,000 1 fireplace +3,000
+ BS- Kl+ - M_+ - $ 36,600Net Adjustment (total] $ -15,000 $ 13,700
Net Adj. 5.3%
Gross Ad|. 21.4%$
Net Adj. 5.1%
270,000 Gross Adj. 19.1%,$
11/13/13
Sold in 2013 for $260,000
Net Adj. 16.4%
283,700|GroS3Adi. 23.6%$ 259,1005/9/95
Sold in 1995 for $120,000
Adjusted Sale Price
Prior Transfer 9/18/98 12/27/84
Sales price in 1 984 unknownHistory
Comments and reconciliation of the sales comparison approach: All 3 sales were listed on the Multiple Listing Service and are recent sales.Sale #1 has been recently updated prior to this sale. Sale #2 is on subject street. Sale #3 was judged to be in inferior condition based on
the MLS. All sales are smaller in living area than the subject and have 1/2 less baths, they were adjusted accordingly. Subject is large forthe area. Comps were adjusted at $20/sf up to 3,000sf and $10/sf over 3,000sf. The condition of the subject is based upon interior andexterior inspections made by the appraiser (9/16 and 2/1 8 respectively). Sales were all similar construction to the subject. Comparablesales were selected based upon overall similarity to the subject and were adjusted for market reaction to differences.
Indication of Value by Sales Comparison Approach $ 270,000
GREER000190need to provide additional data, analysis and work product not called tor in this form. The Appraisal Institute plays no role in completing tnTform and" disclaims any responsibility forthe data, analysis or any other work product provided by the individual appraiser(s).Al Reoorts® AI-100.04 Summary Aooraisal ReDort Residential
may
© Annraisal Institute 9M3 All Rinhtc RocorwaH
CONFIDENTIAL
GREER000191
CONFIDENTIALClient Client File#:Greer, Daniel & Sarah N/A
Appraisal File #:Subject Property: 133 W Park Ave, New Haven, CT 06511 1608014
STATEMENT OF ASSUMPTIONS AND LIMITING CONDITIONS
This appraisal is subject to the following assumptions and limiting conditions:
This report is prepared using forms developed and copyrighted by the Appraisal Institute. However, the content, analyses, and opinions set
forth in this report are the sole product of the appraiser. The Appraisal Institute is not liable for any of the content, analyses, or opinions set
forth herein.
* No responsibility is assumed for matters legal in character or nature. No opinion is rendered as to title, which is assumed to be good and
marketable. All existing liens, encumbrances, and assessments have been disregarded, unless otherwise noted, and the property is
appraised as though free and clear, having responsible ownership and competent management.
I have examined the property described herein exclusively for the purposes of identification and description of the real property. The objective
of our data collection is to develop an opinion of the highest and best use of the subject property and make meaningful comparisons in the
valuation of the property. The appraiser's observations and reporting of the subject improvements are for the appraisal process and valuation
purposes only and should not be considered as a warranty of any component of the property. This appraisal assumes (unless otherwise
specifically stated) that the subject is structurally sound and all components are in working condition.
I will not be required to give testimony or appear in court because of having made an appraisal of the property in question, unless specific
arrangements to do so have been made in advance, or as otherwise required by law.
* I have noted in this appraisal report any significant adverse conditions (such as needed repairs, depreciation, the presence of hazardous
wastes, toxic substances, etc.) discovered during the data collection process in performing the appraisal. Unless otherwise stated in this
appraisal report, I have no knowledge of any hidden or unapparent physical deficiencies or adverse conditions of the property (such as, but
not limited to, needed repairs, deterioration, the presence of hazardous wastes, toxic substances, adverse environmental conditions, etc.)
that would make the property less valuable, and have assumed that there are no such conditions and make no guarantees or warranties,
express or implied, i will not be responsible for any such conditions that do exist or for any engineering or testing that might be required to
discover whether such conditions exist. Because I am not an expert in the field of environmental hazards, this appraisal report must not be
considered as an environmental assessment of the property. I obtained the information, estimates, and opinions furnished by other parties
and expressed in this appraisal report from reliable public and/or private sources that I believe to be true and correct.
I will not disclose the contents of this appraisal report except as provided for in the Uniform Standards of Professional Appraisal Practice,
and/or applicable federal, state or local laws.
The Client is the party or parties who engage an appraiser (by employment contract) In a specific assignment. A party receiving a copy of this
report from the client does not, as a consequence, become a party to the appraiser-client relationship. Any person who receives a copy of
this appraisal report as a consequence of disclosure requirements that apply to an appraiser's client, does not become an intended user of
this report unless the client specifically identified them at the time of the assignment. The appraiser's written consent and approval must be
obtained before this appraisal report can be conveyed by anyone to the public through advertising, public relations, news, sales, or other
media.
If this valuation conclusion is subject to satisfactory completion, repairs, or alterations, it is assumed that the improvements will be
completed competently and without significant deviation.
VALUE DEFINITION
C Alternate Value Definition (attached)B3 Market Value Definition (below)
MARKET VALUE is defined as the most probable price which a property should bring in a competitive and open market under all conditionsrequisite to a fair sale, the buyer and seller each acting prudently and knowledgeably, and assuming the price is not affected by undue stimulus.Implicit in this definition is the consummation of a sale as of a specified date and the passing of title from seller to buyer under conditionswhereby: •
1 . buyer and seller are typically motivated;
2. both parties are well informed or well advised and acting in what they consider their own best interests;
3. a reasonable time is allowed for exposure in the open market;
4. payment is made in terms of cash in U.S. dollars or in terms of financial arrangements comparable thereto; and
5. the price represents the normal consideration forthe property sold unaffected by special or creative financing or sales concessions granted by
anyone associated with the sale.
Source: The DictionaryofRealEstate AppraistfAh ed., Appraisal Institute
* NOTICE: The Appraisal Institute publishes this form tor use by appraisers where the appraiser deems use ot the form appropriate, toenail pi appraiser mayneed to provide additional data, analysis and work product not called for in this form. The Appraisal Institute plays no role in completin^ndmwITvMyms 'any responsibility forthe data, analysis or any other work product provided by the individual appraiser(s).Al Reports® AI-900 04 Certification. Assumptions and Limitina Conditions © Appraisal Institute 201 3. All Riphts Reserved January 201 3
CONFIDENTIAL
GREER000192
CONFIDENTIALClient Client File #:Greer, Daniel & Sarah N/ASubject Property: Appraisal File #:133 W Park Ave, New Haven, CT 0651 1
APPRAISER CERTIFICATION
I certify that, to the best of my knowledge and belief:
The statements of fact contained in this report are true and correct.
The reported analysis, opinions, and conclusions are limited only by the report assumptions and limiting conditions, and are my personal,unbiased professional analysis, opinions, and conclusions.
I have no present (unless specified below) or prospective interest in the property that is the subject of this report, and I have no (unlessspecified below) personal interest with respect to the parties involved.
I have no bias with respect to any property that is the subject of this report or to the parties involved with this assignment.
My engagement in this assignment was not contingent upon the developing or reporting predetermined results.
My compensation for completing this assignment is not contingent upon the development or reporting of a predetermined value or directionin value that favors the cause of the client, the amount of the value opinion, the attainment of a stipulated result, or the occurrence of asubsequent event directly related to the intended use of this appraisal.
My analysis, opinions, and conclusions were developed, and this report has been prepared, in conformity with the Uniform Standards ofProfessional Appraisal Practice.
Individuals who have provided significant real property appraisal assistance are named below. The specific tasks performed by those namedare outlined in the Scope of Work section of this report.
None Name(s)
As previously identified in the Scope of Work section of this report, the signer(s) of this report certify to the inspection of the property that isthe subject of this report as follows:
Property Inspected by Appraiser
Property inspected by Co-Appraiser
" Services provided, as an appraiser or in any other capacity, regarding the property that is the subject of this report within the three-yearperiod immediately preceding acceptance of this assignment: None 8] Specify services provided: An appraisal of the subjectwas made in September 2016 with an effective date of 10/1/06.
S3 Yes No
Yes No
ADDITIONAL CERTIFICATION FOR APPRAISAL INSTITUTE MEMBERS, CANDIDATES AND PRACTICING AFFILIATES
Appraisal Institute Designated Member, Candidate for Designation, or Practicing Affiliate Certify:
The reported analyses, opinions, and conclusions were developed, and this report has been prepared, in conformity with the requirements ofthe Code of Professional Ethics and the Standards of Professional Appraisal Practice of the Appraisal Institute, which include the UniformStandards of Professional Appraisal Practice.
The use of this report is subject to the requirements of the Appraisal Institute relating to review by its duly authorized representatives.
I am not a Member, Candidate or Practicing Affiliate of theAppraisal Institute.
APPRAISERS SIGNATURES
APPRAISER:
Signature
Name JimKyle
Report Date February 8, 2018
Trainee Licensed Certified Residential
License # RCG.000351
Expiration Date April 30, 2018 __
CO-APPRAISER:
_ Signature
Name
Report Date
Certified General 53 Trainee Licensed Certified Residential Certified General
State CT License #
Expiration Date
State
GREER000192need to provide additional data, analysis and work product not called tor in this form. The Appraisal Institute plays no role in completing tne form ana disclaims any responsibility forthe data, analysis or any other work product provided by the individual appraiser(s).Al ReDortS® AI-900 04 Certification Assiimntiona nnri I imttinn Cnnriitinnc (Ft Annraiool InnFiki ii<i OfHO All DlnktH n«i>iin»<l
CONFIDENTIAL
GREER000193
CONFIDENTIAL
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133 WEST PARK AV NEW HAVEN, CTTl
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1 inch = 51 feet-9'
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nsData and scale shown on this map are provided for planning and informational purposes only. NEW HAVEN (CT) and Vision
Government Solutions are not responsible for any use for other purposes or misuse or misrepresentation of this information. 8/11/2016