2012-12-27 / Legal Notices

Legal Notices

LEGAL NOTICE
NOTICE OF PETITION
PURSUANT TO CPLR
ARTICLE 78
TOWN OF CARMEL V.
COUNTY OF PUTNAM
INDEX NO. 3187/2012
At a I.A.S. Term of the
Supreme Court of the State
of New York held in and
for the County of Putnam
at the Putnam County
Office Building located at
20 County Center, Carmel,
New York, on the 20th day
of December, 2012.
PRESENT: Hon. Francis
A. Nicolai, Supreme Court
Justice of the Supreme
Court
========x
ORDER TO SHOW
CAUSE
In the Matter of the
Application of THE TOWN
OF CARMEL Petitioner,
-against-
THE COUNTY OF
PUTNAM and MARY
CONKLIN, AS CHAIR
OF THE PUTNAM
COUNTY LEGISLATURE,
Respondents.
Index No. 3187/2012
For a Writ of Mandamus
Pursuant to Article 78 of
the Civil Practice Law and
Rules.
========x
Upon the Verified Petition
filed simultaneously
herewith duly verified on
the 19th day of December,
2012 upon the Memorandum
of Law submitted
simultaneously herewith;
and upon ail of the papers
and proceedings heretofore
had herein,
LET Respondents show
cause before me at an I.A.S.
Part of this Court to be
held at the Putnam County
Courthouse, 20 County
Center, Carmel, New York
10512 on the 3rd day of
January, 2012 at 9:30o’clock
in the forenoon or as soon
thereafter as counsel can be
heard, personal appearances
are not required, why an
Order should not be made
and entered granting to
Petitioner the following
relief:
A. That this Court issue a
writ of mandamus pursuant
to Article 78 of the Civil
Practice Law and Rules
ordering and directing
Mary Conklin, Chair of the
Putnam County Legislature,
to accept, as a final warrant
for collection of taxes,
the updated assessment
roll, including the tax
assessments for the Carmel
Garbage District that were
not included in the final
assessment roll filed by THE
TOWN OF CARMEL.
B. That this Court authorize
Lisa Johnson, acting Director
of the Putnam County Real
Property Tax Services, to
enter the correction of errors
and, should anyone submit
a tax grievance regarding
their corrected assessment,
to address such grievance
upon approval of the Court.
C. That pending a final
determination of this matter,
that this Court grant a
temporary restraining order
and preliminary injunction
restraining and enjoining
the County of Putnam from
forwarding the tax bills to
the owners of the affected
parcels reflected on Garbage
District rolls which are
attached as Exhibits “I”
(RG-005) and “J” (RG-
006) attached to the Verified
Petition; and
D. Granting Petitioner
such other and further relief
as this Court may deem just
and proper.
SUFFICIENT CAUSE
APPEARING THEREFOR,
IT IS ORDERED that
pending the hearing and
final determination of this
action and further order,
Respondent COUNTY
OF PUTNAM is hereby
restrained and enjoined from
forwarding the tax bills to
the owners of the affected
parcels reflected on the
Exhibit “I” and “J” attached
to the Verified Petition; and
it is
FURTHER ORDERED that
service pursuant to Section
308 of the Civil Practice Law
and Rules of a copy of this
Order to Show Cause and
the Verified Petition shall
be made upon Respondents
COUNTY OF PUTNAM
and Mary Conklin, as
Chair of the Putnam County
Legislature, and to Lisa
Johnson, acting Director
of the Putnam County Real
Property Tax Services, on
or before the 21st day of
December, 2012, which
shall be deemed good and
sufficient service hereof;
and it is
FURTHER ORDERED that
this Order to Show Cause
and the Verified Petition,
without exhibits (except
Exhibits “I” and “J”), be
published one time within
fourteen (14) days of the
date of this Order to Show
Cause in the Putnam County
Press, which is the official
newspaper designated by
THE TOWN OF CARMEL*
and it is
FURTHER ORDERED
that proofs of the abovereferenced

service and
publication shall be filed
with the Court on or before
the return date of this Order
to Show Cause.
Honorable FRANCIS A.
NICOLAI,
Justice, Supreme Court
SUPREME COURT OF
THE STATE OF NEW YORK
COUNTY OF PUTNAM
========x
VERIFIED PETITION
In the Matter of the
Application of
THE TOWNOF CARMEL,
Petitioner,
-against-
THE COUNTY OF
PUTNAM and MARY
CONKLIN, AS CHAIR OF
THE PUTNAM COUNTY
LEGISLATURE,
Respondents.
For a Writ of Mandamus
Pursuant to Article 78 of
the Civil Practice Law and
Rules.
Petitioner TOWN OF
CARMEL (hereinafter
referred to as “Petitioner”),
by its attorneys, COSTELLO
& FOLCHETTI, LLP, upon
information and belief,
alleges as follows:
1. This is an action seeking
relief pursuant to Article 78
of the Civil Practice Law
and Rules for a writ of
mandamus.
2. In 1985, petitioner
previously established a
Town-wide garbage district
in the Town of Carmel.
Said district was duly
established pursuant to NY
Town Law Article 12-A,
wherein all necessary public
hearings and referenda were
conducted and completed,
as set forth below.

HISTORICAL
PROCEDURE AND
BACKGROUND
ESTABLISHING
A RESIDENTIAL
GARBAGE AND REFUSE
COLLECTION DISTRICT
IN THE TOWN OF
CARMEL
3. A resolution and order
of the Town Board of the
Town of Carmel setting
a public hearing on “The
Establishment of a Refuse
and Garbage District for
the Town of Carmel” was
duly passed at a meeting of
the Carmel Town Board on
January 9, 1985. A certified
copy of the order setting
public hearing is attached
hereto as Exhibit “A”.
4. After conduct of public
hearings regarding the
establishment of the Town
of Carmel Garbage District
for Residential Properties,
the Town Board of the
Town of Carmel established
said district, subject to
permissive referendum. Said
action was taken at a duly
held meeting of the Town
of Carmel Town Board on
February 13, 1985.
A certified copy of the
resolution making findings
and establishing the
aforesaid district subject
to permissive referendum
is attached hereto as Exhibit
“B”.
5. As can be seen from the
language of the establishing
resolution designated as
Exhibit “B”; the properties
included in the established
Garbage District were
limited to single family
residence, two family
residences, three family
residences, rural residences,
estates, seasonal residences,
apartments, mobile homes,
multiple residences and
condominiums in accordance
with the then-corresponding
property classification
codes assigned by the New
York State Division of
Equalization and Assessment
(now known as Office of
Real Property Tax Services).
6. At its duly-held meeting
of March 27, 1985, the
Town Board of the Town of
Carmel unanimously moved
to conduct the referendum
on the establishment of the
aforesaid Garbage District
on April 20, 1985 between
the hours of 9:00 a.m. and
6:00 p.m. at three designated
polling places within the
Town of Carmel. In addition,
the Town Board set an
informational meeting and
session on April 18, 1985
in advance of the scheduled
referendum. A certified copy
of the resolution meeting
minutes reflecting these
proceedings is attached
hereto as Exhibit “C.
7. The aforementioned
referendum was duly held
at the referenced polling
places. The establishment of
the Garbage District passed
by a margin of 1,517 voting
“YES” to 416 voting “NO.”
A certified copy of the
Certifications of Voting for
the referendum regarding the
establishing the aforesaid
Garbage District is attached
hereto as Exhibit “D”. A
Certificate of Referendum
from Louis, Town Clerk of
the Town of Carmel dated
April 24, 1985 is attached
hereto as Exhibit “E”.
8. A Final Order of the
Town Board establishing the
aforesaid Garbage District
was adopted by the Town
Board of the Town of Carmel
at its duly held meeting of

April 24, 1985. A certified
copy of this Final Order is
attached hereto as Exhibit
“F”.
9. Your petitioner is aware
of no order of any Court, nor
any action of any subsequent
Town of Carmel Town Board
modifying, extending,
dissolving, annulling or
otherwise affecting the
establishment and/or
existence of the Garbage
District has been issued or
exists.
10. For the past several
years, residential and
commercial collection and
hauling of garbage refuse
and recyclable materials
within the Town of Carmel
had been provided by
private, independent haulers
and licensed pursuant to
Chapter 95 of the Town
Code and based upon
individual agreements with
the respective property
owners within the Town of
Carmel. In 2010 and 2011
the Town of Carmel licensed
10-12 different garbage
hauling companies for
residential garbage, refuse
and recyclable pickup each
year.
11. In 2011, in an effort
to provide cost savings
and cost certainty to the
residents of the Town of
Carmel, the Town Board
of the Town of Carmel
established maximum rates
to be charged for residential
garbage, refuse and recycling
pickup by private licensed
garbage haulers.
The rates established
by resolution of the Town
Board on August 24,2011
were as follows:
• For once-per-week
collection/pickup of up to
96 (ninety six) gallons of
household refuse/garbage
in quantity or less, the
maximum monthly rate
charged shall not exceed
$29.00 (Twenty-Nine
Dollars).
• For twice-per-week
collection/pickup of up to
an aggregate of 192 (one
hundred ninety-two) gallons
of household refuse/garbage
in quantity or less, the
maximum monthly rate shall
not exceed$34.50 (Thirty-
Four Dollars and 50/100).
12. In 2012, in an effort
to further provide costs
saving to the residential
taxpayers of the Town of
Carmel, The Town Board
decided to solicit bids for
the collection and hauling of
residential garbage, refuse
and recycling within the
existing Town Garbage
District. Preliminary inquiry
of such services as available
and utilized in surrounding
municipalities indicated
that a substantial savings
to the residents could result
from municipal garbage
collection. In addition,
infrastructure maintenance
issues and quality of life
concerns could be addressed
by minimizing the number
of garbage hauling vehicles
utilizing Town roads and
circulating within the
residential neighborhoods
of the Town.
13. In 2012 the Town Board
directed the preparation of
proposed bid specifications
and solicited competitive
bid proposals pursuant to
NY General Municipal
Law for collection and
hauling of refuse for all
improved single family,
two family, multifamily,
condominium, cooperative
and affordable residential
housing parcels within the
Town-wide Carmel Garbage
District. Vacant properties,
properties zoned/classified
as commercial, industrial,
retail or any combination
thereof were specifically
excluded from the contract
bid specifications, as well
as the bid solicitation and
award process.
14. Preparation of the
bid specification as well
as authority to solicit bids
was duly authorized by your
petitioner through resolution
passed at its regularly held
meeting of
August 15th, 2012.
(Certified Copy of
Authorizing Resolution
attached hereto as
Exhibit “G”). Award of
the contracts to the low
responsible bidders meeting
specification pursuant to
NY General Municipal Law
§103 was authorized by
petitioner through resolution
passed at its regularly held
meeting of November 8th,
2012. (Certified Copy of
Authorizing Resolution
attached hereto as Exhibit
“H”). In addition, the
topic of the proposed bid
specifications, municipal
garbage hauling contracts
and the potential cost to
taxpayers, as well as the
projected savings associated
therewith were discussed
by the Town Board with an
open forum to the residents
for commentary at no less
than three other regularly
held Town Board meetings
prior the August 15, 2012

and November 8th meetings.
15. For the purposes of
the bid as well as for the
anticipated tax assessment,
all properties within the
Garbage District and
subject to the proposed
bid improved with one
and two-family residences
were designated “SINGLE
FAMILY HOMES”.
All such properties
improved by condominiums,
cooperative apartments,
three-family (or greater)
residences and affordable
housing were designated as
“CLUSTER”.

THE 2012 TOWN OF
CARMEL TAX ROLLS
16. This Petition is
submitted to the Court as
a result of a clerical error,
in that the tax assessments
relating to the Carmel
Garbage District were
not included in the final
assessment roll filed by the
Town of Carmel.
17. The tentative
assessment roll is to be
filed with the Town Clerk
on or before the first day
of May each year. The final
assessment roll is to be
filed on or before the first
day of July of each year.
Such tentative and final
assessment rolls were, in
fact, filed by the Town of
Carmel pursuant to New
York State Real Property
Tax Law. However, the
tax assessments to the
Carmel Garbage District
were not included in the
tentative or final assessment
rolls. The omission of the
garbage assessments for
the residential properties
within the Garbage District
constitutes a clerical error
on the part of the Town of
Carmel.
18. The assessment for
the Carmel Garbage District
will result in the addition
of benefit units for each
residential parcel deriving
a benefit from the Garbage
District. The benefitting
units assigned by the Office
of the Town Assessor to
each type of property are
as follows:
A. SINGLE FAMILY
HOME PARCELS:
• Parcels containing single
or two-family residences:
1.0 units total assigned;
B. CLUSTER PARCELS:
• Parcels containing
condominiums of cooperative apartments:
assigned 1.0 units
per residence within
condominium or cooperative
development;
• Parcels containing threefamily or greater residences:
1.0 units assigned per
residence located on parcel;
• Trailer/Mobile/
Manufactured Home parcels:
0.5 assigned units per pad
site;
• Affordable multi-family
housing: 0.5 units assigned
per apartment residence.
19. The additional
assessment to be imposed per
full unit assigned is $257.00
(Two Hundred Fifty-Seven
Dollars) annually for parcels
containing single or two
family residences. A list
of the approximately 9,600
residential “single-family
home” parcels, including
tax map, street address and
owner names is contained
within the assessment roll
attached hereto as Exhibit
“I” with each parcel
designated “RG005.” hat
private licensed garbage
haulers charge sales tax as
well above the maximum
rates.
20. The additional
assessment to be imposed
per full unit assigned is
at $165.00 (One Hundred
Sixty-Five Dollars) annually
per unit assigned for each
residence, condominium or
cooperative unit, trailer/
mobile/manufactured home
or affordable housing unit.
A list of the approximately
1,500 “cluster” parcels,
including tax map, street
address and owner names
is contained within the
assessment roll attached
hereto as Exhibit “J” with
each parcel designated
“RG006.”
21. It is noted that the
standard cost of private
collection of garbage and
refuse for a single family
home for twice-weekly
pickup based upon the
maximum rates set by the
Town Board for private
haulers would be as high as
$414 annually. Thus, for the
typical single family home,
the annual cost savings
for twice-weekly garbage
collection under the Garbage
District’s municipal contract
is projected to exceed $154
annually. For once weekly
pickup based upon the
maximum rates set by the
Town Board for private
haulers the annual cost
savings for once-weekly
garbage collection under the
Garbage District’s municipal
contract is projected to
exceed $94 dollars. These
projected and anticipated

figures are exclusive of the
additional savings realized
by residential taxpayers
when considering that
private haulers must impose
sales tax in addition to their
weekly rate.
22. New York State Real
Property Tax Law, Section
553(1)(a) provides a
mechanism by which a Town
Tax Assessor may correct
errors on the final assessment
rolls. However, in this case,
the clerical errors that were
made by Carmel were not
discovered by the Town of
Carmel Assessor’s Office
and brought to the attention
of the Town Board until
after the time to correct
such errors under Section
553 of the New York State
Real Property Tax Law
had expired. Accordingly,
this Verified Petition and
the Order to Show Cause
submitted herewith is filed
with the Court seeking a
writ of mandamus ordering
and directing Mary Conklin,
Chair of the Putnam County
Legislature, to accept, as a
final warrant for collection
of taxes, the updated
assessment roll, including
the tax assessments that
were not included in the final
assessment roll provided by
the Town of Carmel. Such
assessments are reflected in
Exhibit “I” attached hereto.
23. Section 553(1)(a) of
the Real Property Tax Law
provides as follows:
1. An assessor shall execute
and transmit a petition to the
board of assessment review,
as prescribed by subdivision
two of this section, for
correction of any of the
following errors:
(a) a clerical error on
the assessment roll for
the current or preceding
year which has resulted
in an assessed valuation,
or a special assessment
or other charge based on
units of service provided
by a special district which
is less than that actually
appearing upon the property
record card, field book or
other final work product of
the assessor;...
24. Accordingly, the law
would permit a correction
of the error that was made
by the Town of Carmel.
However, as the time frames
that the assessor is given
to make such corrections
pursuant to Section 553(1 )
(a) of the Real Property Tax
Law have expired, the Town
submits this Petition to this
Court seeking to correct
such clerical errors.
25. Accordingly, in order
to resolve this matter and
to correct the assessment
roll to reflect the actual tax
assessment, which includes
the tax assessment for the
extension of the Carmel
Garbage District, the Town
of Carmel seeks from this
Court pursuant to Article
78 of the Civil Practice
Law and Rules, a writ of
mandamus ordering and
directing Mary Conklin,
Chair of the Putnam County
Legislature, to accept as a
final warrant for collection
of taxes, the updated
assessment roll which
includes the assessment for
the extension of the Carmel
Garbage District.
26. It is important to note
that all public hearings
required pursuant to Article
12-A regarding the original
establishment of the Carmel
Garbage District were held
and all public notices
required with regard to
the same were published.
The certified results of
the permissive referendum
conducted prior to the
final order establishing the
Carmel Garbage District are
included herewith.
27. All bid activity and
the award thereof for the
Garbage District contracts
has been conducted in
compliance with New York
General Municipal Law.
Upon information and
belief no proceedings have
with this Court or with the
Town Clerk Town of Carmel
seeking judicial intervention
with respect to these actions.
28. Throughout the
process of preparation of
the bid specifications, bid
solicitation and bid award,
the public was informed of
the proposed actions at Town
Board meetings conducted
pursuant to the Article
7 of the Public Officers
Law (Open Meetings
Law). At those meetings
the Board discussed on
several occasions that the
proposed costs of financing
the municipal contract for
the Garbage District would
be through assessments
which were projected be
levied against the affected
residential properties within
the Carmel Garbage District.
A press release and mailer
regarding the award of the
bid for the Garbage District,
the estimated tax assessment,
as well as the services to
be rendered to the affected
and benefitted parcels was

sent to the owners of the
more than 10,000 parcels
within the Garbage District
(Exhibit K).
29. It is important to
note that on December
12th the Town of Carmel
held a public hearing on the
special district assessment
rolls including the Garbage
District. The public hearing
closed after less than ten
minutes and there was only
one member of the public
who commented on the
Garbage District at all.
30. Further, the Town of
Carmel seeks an order of
this Court authorizing Lisa
Johnson, acting Director
of the Putnam County Real
Property Tax Services, to
enter the correction of errors
and, should anyone submit
a tax grievance regarding
their corrected assessment,
to address such grievance
upon approval of the Court.
31. Further, the Town of
Carmel seeks a temporary
restraining order and
preliminary injunction
restraining and enjoining
the County of Putnam from
forwarding any tax bills to
the owners of the affected
parcels contained on
Exhibits “I” and “J” hereto.
32. In order to obtain a
temporary restraining order
and preliminary injunction,
it is necessary for the Town
to show: (1) a likelihood
of success on the merits;
(2) irreparable injury; (3) a
balancing of equities in the
Town’s favor; and (4) that
there is no adequate remedy
at law.
33. First, the Town is
likely to succeed on the
merits in this matter, as the
Carmel Garbage District was
duly formed and established
by Order of the Town Board
of the Town Of Carmel
pursuant to Article 12-A of
the New York State Town
Law. The public was made
aware of the amount of
the assessment that would
be levied on the affected
parcels. Accordingly, the
Town of Carmel is entitled
to include the assessment for
the extension of the Carmel
Garbage District on the tax
rolls for the affected parcels.
34. The Town of Carmel
will certainly suffer
irreparable injury if a
preliminary injunction is not
granted by the Court in this
matter. Upon information
and belief, the tax bills
with regard to the affected
parcels will be forwarded to
the owners of the affected
parcels within ten days. Once
the tax bills are mailed, the
Town will have no remedy
which would permit the
Town to correct the error
in the assessment rolls.
Accordingly, if the owners
of the affected parcels are
not obligated to pay the
assessments the Carmel
Garbage District for 2013,
the Town would have to pay
the same. The 2013 Town
budget does not designate
funds to pay the significant
contract costs the Carmel
Garbage District, which
would otherwise be paid by
the taxpayers. Such costs
would be in excess of$2.5
million dollars. Once that
injury has been suffered by
the Town, it could not be
corrected. The only way in
which said injury could be
prevented is by including the
assessment on the tax rolls
prior to the tax bills being
forwarded to the owners of
the affected parcels.
35. There is certainly a
balancing of the equities
in the Town’s favor as
the Carmel Garbage
District was duly formed
pursuant to Town Law
Article 12-A proceeding
and all matters involving
the preparation of the bid
specification, authorizing
of the solicitation of bids
as well as the awards of
the respective bids for the
garbage collection and
hauling contracts all were
conducted at duly noticed
and conducted Town Board
meetings during the course
of 2012. In addition the
matter was discussed as
a regularly noticed Town
Board agenda item at
multiple regularly-held
Town Board work session
meetings during 2012. The
only challenge that may
be raised by a taxpayer at
this point is the calculation
of the benefit units to be
applied to that particular
parcel. However, such
challenge may be submitted
to and addressed by Lisa
Johnson, acting Director
of the Putnam County Real
Property Tax Services,
upon approval of the Court,
pursuant to the relief sought
herein.
36. The Town has no
adequate remedy at law in
this matter. If the County of
Putnam is not enjoined or
restrained from forwarding
tax bills to the owners often
affected parcels until this
matter is resolved by the
Court, the Town would not
be able to recoup the cost
to the Town in paying the
portion of the assessment
that the taxpayers would

have otherwise paid for the
year 2012. This would result
in a significant financial
burden on the Town of
Carmel.
37. Accordingly, for
the foregoing reasons, it
is respectfully requested
that this Court grant the
temporary restraining order
and preliminary injunction
restraining and enjoining
the County of Putnam
from forwarding the tax
bills to the owners of the
affected parcels reflected
on the attached Exhibits
“I” and “J” pending a final
determination by this Court
with respect to this action.
38. The Order to Show
Cause submitted herewith
provides for service of
process to the County of
Putnam, as well as by
publication in the official
newspaper of the Town of
Carmel for the purpose of
noticing the owners of all
affected residential property
owners within the Town of
Carmel. The publication
which would inform the
owners of the affected
parcels that they may submit
any tax grievance in relation
to this matter to the Director
of Real Property Tax
Services, Putnam County,
who would then address such
grievances upon approval of
the Court.
39. Accordingly, the
owners of the affected
parcels would have a
mechanism by which to
challenge the tax assessment
should they choose to do so.
WHEREFORE, Petitioner
respectfully requests that
this Court make and enter
an order and judgment as
follows:
A. That this Court issue a
writ of mandamus ordering
and directing Mary Conklin,
Chair of the Putnam County
Legislature, to accept, as a
final warrant for collection
of taxes, the updated
assessment roll, including
the tax assessments that
were not included in the final
assessment roll provided by
the Town of Carmel for the
extension of the Carmel
Garbage District, as such
assessments are shown on
Exhibits “I” and “J” attached
hereto.
B. That this Court authorize
Lisa Johnson, acting Director
of the Putnam County Real
Property Tax Services, to
enter the correction of errors
and, should anyone submit
a tax grievance regarding
their corrected assessment,
to address such grievance
upon approval of the Court.
C. That pending a final
determination of this matter,
that this Court grant a
temporary restraining order
and preliminary injunction
restraining and enjoining
the County of Putnam from
forwarding the tax bills to
the owners of the affected
parcels reflected on the
attached Exhibits “I” and
“J”; and
D. That this Court grant
such other and further relief
as this Court may deem just
and proper.
Dated: Carmel, New York
December 19, 2012
COSTELLO &
FOLCHETTI, LLP
By: Gregory L. Folchetti
Esq.
Attorneys for Petitioner
1875 Route 6
Carmel, New York 10512
(845)225-1900
TO: THE COUNTY OF
PUTNAM
Putnam County Office
Building
40 Gleneida Avenue
Carmel, New York 10512
Mary Conklin, AS CHAIR
OF THE PUTNAM
COUNTY LEGISLATURE
Putnam County Office
Building
40 Gleneida Avenue
Carmel, New York 10512

TOWN OF CARMEL
TOWN HALL
60 McAlpin Avenue
Mahopac, New York 10541
Tel. (845) 628-1500 • Fax
(845) 628-6836
www.carmelny.org
CERTIFICATION
STATE OF NEW YORK )
COUNTY OF PUTNAM
) ss.:
I, ANN SPOFFORD, Town
Clerk of the Town of Carmel,
Putnam County, New York,
DO HEREBY CERTIFY that
the attached Resolution and
Order of the Town Board of
the Town of Carmel is a true
and exact copy of the whole
original on file in my office
and that said Resolution and
Order of the Town Board
of the Town of Carmel was
adopted by the Town Board
of said Town at a duly called
and held meeting on the 9th
day of January, 1985.
IN WITNESS WHEREOF,
I have hereunto set my hand
and affixed the seal of the
said Town of Carmel this
12th day of December, 2012.
Ann Spofford
Town Clerk
Town of Carmel
(CORPORATE SEAL)

RESOLUTION AND
ORDER OF THE TOWN
BOARD OF THE TOWN

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