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1. IN THE OHIO BOARD OF TAX APPEALS
UNITED LOCAL SCHOOLS BOARD OF ) Case No. 2016-828
EDUCATION )
)
Appellant, )
) (REAL PROPERTY VALUE)
v. )
)
COLUMBIANA COUNTY BOARD )
OF REVISION, et al., )
)
Appellees. )
APPELLEES COLUMBIANA COUNTY BOARD OF REVISION AND COLUMBIANA
COUNTY AUDITOR’S RESPONSE IN SUPPORT OF UTICA EAST OHIO
MIDSTREAM LLC’S MOTION FOR SANCTIONS AGAINST GEORGE E. SANSOUCY
Appellees Columbiana County Board of Revision and Columbiana County Auditor,
though undersigned counsel, hereby indicate their support of Appellee Utica East Ohio
Midstream LLC’s Motion for Sanctions against George E. Sansoucy. A Memorandum in
Support is attached hereto.
Respectfully submitted,
Robert L. Herron, Reg. #0022159
Prosecuting Attorney
Columbiana County, Ohio
/s/ Krista R. Peddicord
Krista R. Peddicord, Reg. #0089117
Assistant Prosecuting Attorney
kpeddicord@colcoprosecutor.net
105 S. Market Street
Lisbon, OH 44432
(330) 420-0140
Attorneys for Appellees
Columbiana County Board of Revision
and Columbiana County Auditor

2. 2
MEMORANDUM IN SUPPORT
I. Introduction
On November 14, 2018, Appellee Utica East Ohio Midstream, LLC (“hereinafter
“Utica”) moved this Board (hereinafter “BTA”) to sanction George E. Sansoucy by
suspending his ability to appear and testify as an expert witness before the BTA for a
period of five (5) years and to publicly reprimand or censure Mr. Sansoucy for his conduct
in this matter. Utica’s Motion is based upon Mr. Sansoucy’s testimony during the course
of a seven-day hearing before the BTA.
The Columbiana County Auditor and the Columbiana County Board of Revision
(hereinafter referred to collectively as “County”) wish to indicate their support and
concurrence with Utica’s Motion for Sanctions against Mr. Sansoucy.
Nevertheless, it is important to note that, the County agrees that the Board of
Education and its legal counsel are merely blameless victims and were misled and
deceived by Mr. Sansoucy.
II. Argument
Utica’s statement of facts regarding Mr. Sansoucy’s egregious conduct and the
legal authority supporting the BTA’s authority to sanction Mr. Sansoucy as set forth in its
Motion are accurate recitations of law and fact.
It is clear from the record that the lengthy seven-day hearing in this matter was the
result of Mr. Sansoucy misleading the BTA, repeatedly changing his testimony, and
evading simple questions in order to bolster his appraisal report and his exaggerated
expertise.

3. 3
Utica is correct in that Mr. Sansoucy spent days testifying about the numerous
piping systems present on the property, which he claimed to have reviewed a total of 56
piping systems in-depth to determine whether they were real or personal property. (See,
Motion for Sanctions, p. 27-28, 30). Mr. Sansoucy testified that he viewed and studied all
56 piping systems, either on-site or from the plant drawings, and applied his methodology
to each system to determine whether it was real or personal property. (E.g., H.R. Vol. V:
1044). However, after being questioned extensively regarding the piping systems on day
5, Mr. Sansoucy returned after a weekend break and changed his testimony. Mr.
Sansoucy’s sudden change of testimony on day 6 wherein he concluded that only 30
piping systems existed on the property, instead of the 56 he testified he personally
viewed, cannot be written off as a misunderstanding or misstatement. More than half of
the piping systems Mr. Sansoucy spent days testifying were present on the property did
not actually exist. Thus, there is no way Mr. Sansoucy could have viewed these piping
systems either on-site or in the drawings.
Additionally, had Utica concluded its cross examination on day 5, when Mr.
Sansoucy was still testifying as to the existence of 56 piping systems and his extensive
review of the same, both the BTA and the parties may never have learned the truth—that
the majority of the piping systems did not exist and Mr. Sansoucy could not possibly have
seen them at the site or in the drawings. It is worth noting that, Mr. Sansoucy did not
return to the witness stand on day 6 and immediately and voluntarily rectify what he
claimed to be an error in his report and prior testimony. Rather, it was not until Utica
revisited Mr. Sansoucy’s prior testimony well into day 6 that Mr. Sansoucy confessed that

4. 4
there were not actually 56 piping systems on the property. The fact that Mr. Sansoucy
knew his prior testimony was incorrect and did not voluntarily take action to immediately
correct that testimony when given the opportunity would alone warrant sanctions.
However, Mr. Sansoucy’s conduct goes well beyond that due to the fact that he
deliberately lied about viewing all 56 piping systems, only coming clean when it became
apparent that his deceit was known by Utica. Such conduct constitutes perjury as set forth
in Section 2921.11(A) of the Ohio Revised Code.
Utica further asserts in its Motion that the testimony of Grant Hammer, an
employee of the Kensington plant, will reveal that Mr. Sansoucy claimed to view and
classify a number of other plant components, which also do not exist. If Mr. Sansoucy’s
false statements are in fact supported by Mr. Hammer’s testimony at the hearing on
Utica’s Motion, this would be yet another instance of Mr. Sansoucy engaging in perjury.
See, R.C. §2921.11(A).
During cross examination it became apparent that Mr. Sansoucy was aware of a
number of other errors with respect to his appraisal report, which he did not correct or
voluntarily bring to the attention of the parties and/or the BTA. Instead, he actively
concealed these errors and continued to advocate as to the soundness and reliability of
his appraisal report. (E.g., H.T. Vol. VII: 1479).
It was clear to those in attendance at the hearing that Mr. Sansoucy repeatedly
changed his testimony as the hearing progressed. For example, on the first day of the
hearing, Mr. Sansoucy’s testified as to the importance of knowing the “physical
interrelated characteristics” of the plant as follows:

5. 5
Q. So when you discuss the "research required to understand
the physical interrelated characteristics of the property and
improvements," in your opinion if you don't do that research,
could an appraisal of a property like this be credible?
A. If you don't research it, it's not going to be credible; starting
with what constitutes real and what constitutes personal.
(H.T. Vol. I: 192).
However, after Mr. Sansoucy’s weekend realization that there were not 56 piping
systems and his convenient explanation for that realization (i.e. that he made this error
because it was not necessary to study the personal property), Mr. Sansoucy again
changed his testimony to indicate that a thorough understanding of each part of the plant
was unnecessary to his analysis:
Q. All right. Moving on. Listening to your testimony it
appears you have to have a thorough understanding of what
each part of the plant is used for in order to determine what
is real and personal property. Would you agree with that?
A. No. And the reason is the following: The person -- that
which we determine is a business fixture or personal
property, we discard.
It is not cost effective or reasonable to then go into an
extraordinary study on what that piece -- that personal
property is and how it works and how it functions. That is not
relevant to the report.
The real property designation, our theory on the real
property, we identify it, that is the property that we want to
know what it does and why.
Now, the gray area that touches it, we have been clear
about that, is it touches it -- you want some sense of what
that property that's personal is -- that it's touching is to know
if you should go -- say no, this is a business fixture, which
we did do.

6. 6
Q. So there are parts of the plant that you would need to
have an understanding of what it does in order to make the
determination that it's real property?
A. Parts of the plant, yes. But not -- you know, in this
particular instance it is essentially under 30 percent or
under.
(H.T. Vol. VII: 1483-84). Mr. Sansoucy’s testimony on days 1 and 7 is clearly
contradictory and is just one of many instances of Mr. Sansoucy continually altering his
testimony to support his claimed expertise and promote the credibility of his appraisal
report. Additional, statements demonstrating Mr. Sansoucy’s deception and
misrepresentations are present throughout the record of this proceeding.
During the course of the hearing, Mr. Sansoucy presented himself as an expert in
all aspects of the Kensington facility. Mr. Sansoucy not only exaggerated his expertise,
but he buried his lack of expertise within an appraisal report more than 1,000 pages in
length intending that the BTA and the parties blindly rely on it. Very rarely did Mr.
Sansoucy admit he lacked knowledge or did not know the answer to a question. Rather,
when significant substantive defects contained in his report became apparent on cross
examination, Mr. Sansoucy repeatedly and conveniently altered his testimony.
Mr. Sansoucy’s evasive and ever-changing testimony consumed significant time
and resources of both the parties and the BTA. Had Mr. Sansoucy been honest and
straight-forward in his testimony, it is unlikely his testimony would have taken seven days.
In addition to the resources expended by Utica and the Board of Education, the County
had to exhaust significant financial resources to defend against Mr. Sansoucy’s
unsupported attack on the Auditor’s valuation of the property.

7. 7
The BTA should not allow its tribunal to be used for the purpose of enriching out of
state tax professional witnesses at the expense of tax payers. The BTA must protect
Ohio’s tax valuation process by taking action to prevent Mr. Sansoucy from peddling his
services to the next unsuspecting victim. Addressing the credibility of Mr. Sansoucy on a
case-by-case basis and “battle of the experts” will not be sufficient to address Mr.
Sansoucy’s conduct, as his appraisals often appear adequate on the surface and can
only be attacked by resources and knowledge that many parties simple do not have
access to or cannot afford. As such, the BTA must take action both to protect the integrity
of the tax valuation process and establish that this type of conduct will not be tolerated not
only from Mr. Sansoucy, but by any expert appearing before the BTA.
III. Conclusion
Based on the foregoing, the County requests that the BTA grant Utica’s Motion for
Sanctions against Mr. Sansoucy, thereby suspending his ability to appear and testify as
an expert witness before the BTA for a period of five (5) years and publicly reprimand or
censure Mr. Sansoucy.
Respectfully submitted,
/s/ Krista R. Peddicord
Krista R. Peddicord, Reg. #0089117
Assistant Prosecuting Attorney
Columbiana County Courthouse
105 S. Market Street
Lisbon, OH 44432
(330) 420-0140
Attorney for Appellees
Columbiana County Board of Revision
and Columbiana County Auditor

8. 8
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and complete copy of the foregoing
was sent via e-mail this 28th day of November 2018 to:
Anthony Ehler, Esq.
Vorys, Sater, Seymour and Pease LLP
52 East Gay Street P.O. Box 1008
Columbus, Ohio 43216-1008
TLEhler@vorys.com
Gary Stedronsky, Esq.
Ennis Britton Co., L.P.A.
1714 West Galbraith Road
Cincinnati, Ohio 45239
gstedronsky@ennisbritton.com
/s/ Krista R. Peddicord
Krista R. Peddicord #0089117
Assistant Prosecuting Attorney
Attorney for Appellees