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Home My WebLink About00-01905 Richard J. Pierce Court Administrator OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURT OF COMMON PLEAS 1 Courthouse Square. Carlisle. PA 17013 Phone Taryn N. Dixon (717) 240-6200 Assistant Court Administrator (717) 697-0371 (717) 532-7286 (717) 240-6462 FAX March 30, 2000 Melinda S. Bower 660 Torway Road Gardners, PA 17324 RE: Ownership of 1987 Nissan Sentra Sedan 00-1905 Civil Term Dear Ms. Bower: A judge cannot act on the petition you filed at the above term and number. You must file a complaint against Nicole M. Thomas which you can do on this docket. You will then have to make an attempt to serve defendant. If service cannot be accomplished you will then have to seek an order for substituted service. Very truly yours, Richard J. Pierce Court Administrator RJP:saa f," ~ro~ i2t-Ocd ~ ..vn +J;F ~ --~ , < __ ".' 'e'- ~,,',,'. r - , I' __ MAR 2 8 2000 -..,=>. March 27, 2000 To Whom It May Concern: Attached is a petition and supporting documentation to obtain a court order awarding ownership of the referenced vehicle. This is to comply with the Pennsylvania Department of Transportation Application for Certificate of Title After Default by Owner. I became involved in this situation to lielp Ms, Thomas purchase the vehicle. Both of our names are on the title, but I hope the information I have given is sufficient reasoning to award sole ownership to myself, so that I may do as I need to with the vehicle. I have not been able to contact Ms, Thomas and understand she may be living out of state. The last known address I have for her is 512 Franklin Street, Carlisle, PA 17013, Thank you for your time and consideration, Sincerely, ~1- Melinda S. Bower 660 Torway Road Gardners, PA 17324 (717) 677-0024 =c~\S We.:::' aCcq)Ac.cl ="w \ '\\,O--".'l, 0<1\ Of <:1. e. \ L~- or e \\'SC.. \.~cS .J 1.0-.;::::.-= ~~--- - l:.--- "':-'-- r-- ")- No 0 acxn-1Q05 (wi) 1eN"\ tv\.e..\{ f\.do- S~O<Jl<2.' To: From: Commonwealth of Pennsylvania County of Cumberland Court of Common Pleas Melinda S. Bower 660 Torway Road Gardners, PA 17324 March 27,2000 70 /T/ of(} RE: Ownership of 1987 Nissan Sentra Sedan, VIN#JNIPB215IHUD008958 This is a Petition to request A Court Order awarding ownership of the referenced vehicle to myself, Melinda S. Bower. This is to comply with the Pennsylvania Department of Transportation Application for Certificate of Title After Default by Owner. Ownership should be awarded to myself due to the fact that, Nicole M. Thomas: 1) defaulted on the loan, which 1 have now paid in full (See EXHIBIT A - copy of receipt showing loan #174868-1 which I co-signed for at Members 1st Federal C. U. nlls been paid in full.) Incidentally, I have receipts showing that 1 paid most of the loan(all but $300 to $400) due to the fact the loan was in constant default. 2) abandoned the vehicle which I have now had possession of for over a year (See EXHIBIT B - copy of letter from the Middlesex Township Police Department regarding,., complaint of vehicle sitting on Route 11 unattended for 3 weeks. I was not aware the 'W vehicle was abandoned, and promptly had it picked up upon receipt of this letter. I have had the vehicle on my property since December 23, 1998,) 3) has not contacted me regarding the vehicle or our agreement concerning it/did not respond to the Notice from the District Justice Office (See EXHIBITS C & D, copies of these documents, respectfully.) Also attached is a copy of the Certificate of Title. ~ ;;iLJ$~ L3 - ,pi!- Or:) I... ""-'-.1" ,-'"~- , -~ . ,- t i~ !~ "I :~ :\1 .....,.....:.1 ;j .. ,<: ;; I;!; ". ~. , ."1 . 0 0 0 C 0 " :s:: :1: -00] ~ n1rn N ;'1"1 Z::Ci 2:["" !'-' n!-.m V-- 1::- CO ~:~6 -Cd:' ~O " ~~ ~O -'" s:;;o ;;:- (:Jm C: ~ -'j ,0 S5 0 -< '" R. ,,~~~r:--: , ~'" ,.,~''''[_.,.(';'_,__ ".',"~::'_""_,_~. ...~nl~'ffim-1'!>!!li!1,~~ Jl.ll.~~qfm~7'~_,. ~~ .'IIRI!l"~~ MV-217 (7-92) .,:"0::... t!n \':Y PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF MOTOR VEHICLES P.o. 8OX8672 HARRISBURG, PA 17105 APPLICATION FOR CERTIFICATE OF TITLE AFTER DEFAULT BY OWNER . FOR BUREAU USE ONLY. NOTE: When defauR occurs. the following three options are available for obtaining a certificate of title. Form MV-1 must be properly completed and accompany this application in all cases. CHECK APPROPRIATE BLOCK below indicating which option you are proceeding under: o 1. Judgment and execution ~ 0 2. Non-judicial sale or repossession and retention (U.C.C.) . Court Order FOllOW THE INSTRUCTIONS BELOW FOR THE APPROPRIATE BLOCK CHECKED ABOVE AND THE APPLICANT LISTED ON FORM MV-1 MUST SIGN THE APPLICATION BELOW. OPTION 1 - JUDGMENT AND EXECUTION The purchaser at the sheriff's sale may obtain certificate of title upon presentation of all the following items: . Certified copy of the judgment and writ of execution, or the court order of sale. · Bill of sale from the sheriff or duly authorized officer showing the date of sale, name of purchaser, make and VIN of vehicle. . Documentation that any existing lien is satisfied. OPTION 2 - NON-JUDICIAl SALE OR REPOSSESSION & RETENnON (Uniform Commercial Code) Certificate of tiUe will be issued in the name of the purchaser at the sale (who may be the lienholder) upon receipt of the following: . The original or an acceptable copy of the agreement which is the basis of the right to repossess. . The original or an acceptable copy of the filed fina'lcing statement. . The original or an acceptable copy of the notice of intention to sell, mailed to the debtor. (i) If a public sale, the notice must set forth the time and place of the sale. (ii) If a private sale, the notice must set forth the time after which the sale is to be made. . Bill of sale shOWing the date of sale, name of purchaser, make and VIN of vehicle, if the purchaser is not the lienholder. OPTION 3 - COURT ORDER Certificate of title will be issued upon receipt of the following items: . A certified copy of an order of a Court of Common Pleas listing the make and VIlli of the vehicle and naming the person to whom the court awarded ownership of the vehicle and proof that notice of the Court of Common Pleas proceeding was given to the prior owner and any other person who had an interest in the vehicle. . If the original certificate of title is available, it must be attached to your application and court order. If the title is not available, documentation must be included explaining why the title is not attached. NOTE: In questionable cases. the Department may require applicant for certificate of title to execute an indemnificatiOn agreement, or other forms as necessary. I/We hereby make application for a certificate of title and certify under penalty of law that IIWe have complied with the appropriate instructions listed on this form and have X 1 acted in accordance with the law. Applicant Signature Date 'm, ~~ ,r - ~ , =n, c :) - (.) ~ z " I- """"'1 oS -' .0 ~8 Cl)z ~ ~~ V~ ,.a 8~ u Q)~ ~~ ~"' 0c G <> ~, 0, .u__.~ '" a. '" ~ e'i p; ~! .5 Z ;:: ~ '" c C\l .... m _. g g -:: :::;: (j;e..~ "::::w; U o I w, -: :;-; 8:: :.: s--~...J u d!,:::5 0.: t::.1- :: "- '- .:' Z (> '. ~. ;'.' c- "" ,,.... P' C' ~ ". "- ("'.; ~. c', -..(, - . 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US~ < l -tI--li8 !t+xj , ,i I i , '1- COUNTY CONTROL 24304121 - 2311-9676 OFFICE 249-7191 Barty L. Sherman Chief of Police MIDDLESEX TOWNSHIP POLICE DEPARTMENT 350 North Middlesex Road SuRe 3 Car"sle, PA 17013 DECEMBER 20, 1998 NICOLE M. THOMAS MELINDA S. BOWER 660 TORWAY ROAD GARDNERS, PA. 17324 DEAR NICOLE AND MELINDA, THIS DEPARTMENT HAS RECEIVED NUMEROUS COMPLAINTS IN REGARDS TO A 1987 NISSAN 'iENTRA BEARING PA. REGISTRATION BRG-2180 WHICH IS REGISTERED IN THE PA. DEPARTMENT OF TRANSPORTATION COMPUTER SYSTEM AS BEING OWNED BY YOU. THIS VEHICLE HAS BEEN LEFT SETTING UNATTENDED ON RT. #11 ACROSS FROM THE GIANT FOODS OFFICE COMPLEX IN MIDDLESEX TWP SINCE THE FIRST WEEK OF DECEMBER. BE ADVISED, UNDER SECTION 3352 OF THE PA. VEHICLE CODE, THAT YOU HAVE SEVEN (7) CALENDAR DAYS FROM THE DATE OF THIS LETTER TO REMOVE THE ABOVE MENTIONED VEHICLE OR IT WILL BE REMOVED BY A LICENSED SALVOR, RESULTING IN ADDITIONAL COSTS AND FINES TO YOU wHICH ARE PRESCRIBED UNDER LAW. SHOULD YOU HAVE ANY QUESTIONS, PLEASE CONTACT ME AT THE ADDRESS OR PHONE NUMBERS LISTED ABOVE. SINCERELY, ~., ~ 5FT. ~..,(;:!) L1' SGT. STEVEN D. INGSBOROUGH MIDDLESEX TWP. POLICE DEPT. ~x fife !FE ~ _'< --"-' -,,-- --~" -, ~ ~ ..1 THE BELOW OUTLINES A LEGAL BINDING AGREEMENT BETWEEN NICOLE M. THOMAS AND MELINDA S. BOWER RE: LOAN No. -174868-01 in the amount of $1,771.54 being held at Members First Federal Credit Union and c(H)wned vehicle -1987 Nissan Sentra Sedan-VIN #JN1PB21S1HU008958 1. Nicole will maintain complete accountability for the above reference loan. Full repayment for the loan must be made regardless of any future situations related or unrelated to the vehicle. 2. Nicole will hold complete accountability for maintaining insurance coverage. At present time Company v1( Lskt:L , Policy No. has ' been named as the insurance carrier. Melinda is to be informed within ten (10) days of any changes to this information. At any point insurance coverage lapses, registration tag will be immediately revoked by Co-owner. 3. ReSpOnsibility for inspection. registration, maintenance and any needed repairs to , . the afore mentioned vehicle will remain the complete responsibility of Nicole. 4. Payments in the amount of $200 will be made on the above referenced loan by the 16th of each month until paid in full, beginning September 16, 1998. Receipts for above said payments are to be forwarded to Melinda each month. 5. Nicole is to reapply for the amount of the remaining loan on or before December 16, 1998 to determine eligibility for sole responsibility of the loan, 6. Melinda will remain co.owner on vehicle so long as she is co-maker on the loan. At which time Members First Federal Credit Union releases Melinda of any responsibility for the afore mentioned loan, she will immediately sign over title of the said vehicle. 7. As of today's date. August 24, 1998, the above said loan is past due in the amount of $93.56. This amount must be paid by Friday, August 28, 1998. I, Nicole M. Thomas, have read and agree to the terms outlined in this agreement. I . understand that failure to comply with the terms of this agreement may result in appropriate action. Date:~-,..9~ ~ l.Jt;,fiJ 0 '--rv\. .:)t'\~.f'mr..;C') NICOLE M. THOMAS Sworn and subscrjtled to ~ton:;phiS~ /Yl. NOTARIAL SEAL DAWN M. SHUGHART. Notary Public C8r1IsIe, Cumberland Counly My Commission Expires Nov. 28. 1998 fJ( filE I T-C COMMONWEALTH OF PENNSYLVANIA COUNT{DR COM6~ Mag. CIs:. No-.: _~-" _ 09-2-0~ . OJ Name: HOfL.' -:~ ~;~ -~d '._ .i;~:g,~~?~..~~~__ Add''''~;~~~WING.-COURTHOUSE . ;,~_.COURTHOUSE SQUARE ~tSi;.R,.PA T.'.pIoo~.ll1'7)-240:':65~4 ~70~3-0000 CIVIL ACTION . HEARING NOTICE fi:~fj\jTfF~: , u' __ NAME and ADDRESS BOWER, MELDIDA 831 E. LOu~t1.lSK ST CARLISLE, PA17013 L 'I -.J ~-'" VS. NAME and ADDRESS !THOMAS, NICOLE . .512 FRANKLIN ST CARLISLE, PA 17013 L. 'I DEFENDANT: . '. ;.. '~ll" ,,' ,,:-.<~,_~. .MELINDABOWER 83~ E. LOUTHER ST . CARLISLE, PA.17013 -.J Docket No.: cv- 0000576 -98 Date Filed: 1.2/28/98 ,. .l ill . .-~ ~-~ ~_h""","",",-_ ~.,! .P' .~.,::-:--__._ . -, ,.....~ ~. L _~". " - ""- A civil complaint has been filed against you in the above captioned case. A hearing has been set in this matter for: Date: 2/08/99 Place: DISTRICT COURT 09-2-01 EAST WING - COURTHOUf?E Time: 9:00 AM 1 COURTHOUSE SQUARE CARLISLE PA 17013-0000 NOTICE TO DEFENDANT If you intend to enter a defense to this complaint, you should so notify this office immediately at the above phone number. You must appear at the hearing and present your defense. UNLESS YOU DO, JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim againsi the plaintiff which is within district justice jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office afleast five (5) days before the date set for the hearing. If you have a claim against the plaintiff which is not within district justice jurisdiction. you may request information from this office as to the procedures you may follow. NOTICE TO PLAINTIFF If the defendant enters a Notice of Intent to Defend, you will be notified of the date and time of the scheduled hearing and must appear. If you are disabled and require assistance, please contact the Magisterial District office at the address above. DATE PRINTED: 12/28/98 Rtl-UBI T .8) - [ AOPC 308B-94 =.:....:'~-~._-, ,,"-'.>. COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CtJMBERLAND CIVIL COMPLAINT Mag. Cis\. No.: 09-2-01 PLAINTIFF: r NAME ana ADDRESS Melinda S. Bower 660 Torway Rd Gardners, PA 17324 -, OJ Name: tiOn. pA'iJIiA P. CORREAL -'gaT" WING - COURTHOUSE ..1 COOll'ftIOUSE SQUARE CARLiSLE, PA 17013-0000 T.~pho...;{71.7) 240-6564 ' L .J DEFENDANT: r VS. NAMe and ADDRESS Nicole Thomas 512 Franklin Street Carlisle, PA 17013 -, L Docket No.: CV-576-98 Date Filed: 12-28-98 .J It \.~, AMOUNT FILING COSTS $ 47.50 SERVING COSTS $ 6. 00 TOTAL $ 53.50 DATE PAID / / / / 12/28/98 TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ 1655.65 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): In May of 1998 I agreed to co-sign for a loan for Nicole Thomas for the purchase of a vehicle. The loan (#174868-1) was obtained from Members 1st Federal Credit Union at the MJ Mall, Carlisle. I believe the original amount of the loan was $2000.00. The purchase of a 1987 Nissan Sentra was made listing both or us as owners until the loan was paid. Attached is a notarized agreement from 8/98 to clear up any misunderstandings. Nicole has not complied with this agreement, has been consistently late paying on the loan and is now not paying on it at all. I, {Y7e.!; lie&- S .50(,0 U" verify that the facts set forth in this complaint are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. S.C.A. 9 4904) related to unsworn falsification to authorities. . ' Plaintiffs Anomey: !f)j cl7r:u/ r;)ci.ncH-L ;{J{.3 - 33'1/ Address: /() E .lZgfL 50 (bri'i~ Telephone: IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT WILL BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within district justice jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the date set for the hearing. If you have a claim against the plaintiff which is not within district justice jurisdiction, you may request information from this office as to the procedures you may follow. If you are disabled and require assistance, please contact the Magisterial District office at the address above. k)(~(B1T 7)-;L AOPC 30BA.94 '-." ~ - j ......,.. 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