HomeMy WebLinkAbout03-0953IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
STATE FARM INSURANCE
IN RE:
2001 Honda 929cc Motorcycle
VIN: JH2SC44301M100810
PETITION FOR THE RETURN OF PROPERTY HELD BY THE COMMONWEALTH
PURSUANT TO 75 PA. C.8.A. §7105
AND NOW, comes the Petitioner, 8tare Farm Insurance, by and through its attorneys,
Eager, Reinaker & 8pinello, respectfully requests that this Court issue an Order releasing the
above-referenced 2001 Honda 929c0 Motorcycle, based on the following:
1. A 2001 Honda 9292 cc Motorcycle was stolen and then subsequently recovered
by the Pennsylvania State Police.
2. The aforesaid 2001 Honda 929cc Motorcycle was titled in the state of
Pennsylvania.
3. A copy of the Certificate of Title, documenting current ownership, is attached
hereto and marked Exhibit "A".
4. The above-mentioned 2001 Honda 929cc Motorcycle is currently in the custody
of the Pennsylvania State Police in the Impound Yard at Newville, Pennsylvania.
5. State Farm Insurance is the rightful owner of the 2001 Honda 92cc Motorcycle.
6. The Pennsylvania State Police have stipulated to State Farm Insurance
ownership of the above-referenced 2001 Honda 929cc Motorcycle. A copy of said Stipulation is
attached hereto and marked Exhibit "B".
7. Pursuant to 75 Pa. C.S. §7105, State Farm Insurance is entitled to possession of
the 2001 Honda 929cc Motorcycle.
WHEREFORE, State Farm Insurance respectfully requests that this Honorable Court
issue an Order directing the Pennsylvania State Police to forthwith release the 2001 Honda
929cc Motorcycle to the custody of State Farm Insurance, through its lawful designee.
EAGER, REINAKER & SPINELLO
Dated:
BY:
iI~. No=e~p,~er
La3n4c7aF~.er, '~ I:;'k7; 01
(717) 290-7971
i JH2SC 44301 M1008 10~ ,u,~ ~.~ _,
2001 H0N ~
SALVAGE
20.00 10-24-2002
S~ FARM 'rND]~,INZTY 'CO
300 KIMBALL DR
PARS IPPANY NJ 0705,
TYPE'
FUEL
"fsIwss-1 (R6/Ol)
I, THE ACTING DIRECTOR OF MOTOR VEHICLES, DEPARTMENT (
PURCHASE OF OWNERSHIP. IN COMPLIANCE WITH THE LAW~ OF ~IE STATE , {30 HEREBY CERTIFY THAT EVIDENCE OF
WITH ME. AND I DO HERE'By ISSUE THIS CERTIFICATE OF OWNERSHIP ! DESCRIBED ARTICLE HAS BEEN RECORDED AND FILED
OR LIEN. IF ANY AS STATED.
=,,::L 03356~ S
MOTOR VEHICLES
: · ~ :-v ~ ............. ":~:~' DG V320022970275
VIN: 1 JH2SC44301M100810
HON 2001 MC CBR
83033 54610 70540
STATE FARM INDEMNITY CO
300 KIMBALL DR
PARSIPPANY NJ 07054 2180
DG V320022970275 20.00 I
1' FOLD AND TEA. AT PEnFORATION ~'
THIS IS A RECEIPT DOCUMENT ONLY
MILEAGE: 2800 A DUP:
0 AXLE: 2
TITLE I :
SALES TAX :
TOTAL :
SALVAGE
STATUS:
20.00
20.00
S
Exhibit B
In Response:
2001 Honda 929cc Motorcycle
YIN: JH2SC44301M100810
In the Court of Common
of Cumberland County
Pennsylvania
NO.
STIPULATION
IT IS HEREBY AGREED AND STIPULATED by and between the
Pennsylvania State Police and State Farm Insurance as follows:
1. The above-referenced 2001 Honda 929cc Motorcycle, bearing
the Vehicle Identification Number JH2SC44301M100810, which
was recovered by the Pennsylvania State Police, Incident
No. 02-01-016470 and is currently being held by the
Pennsylvania State Police.
o
State Farm Insurance is the rightful owner of the 2001
Honda 929cc Motorcycle.
The Pennsylvania State Police, upon receipt of a Court
order, shall voluntarily release the 2001 Honda 929cc
Motorcycle to State Farm Insurance's custody.
Central Penn Sales on behalf of State Farm Insurance shall
remove the above referenced 2001 Honda 929cc Motorcycle
from Pennsylvania State Police Impound yard in
Newville, PA.
DATE:
DATE:
Central Penn Sales on behalf of State Farm Insurance agrees
to promptly pay all charges incurred in the repossession,
°r;t~eeVvael~ict~eWing and st°rage NZ
I. D./:7740
{7~7) 290-797~
CERTIFICATE OF SERVICF
I HEREBY CERTIFY that I have this day served a true and correct copy of the foregoing
Petition upon the person set forth below and in the manner indicated:
First class mail, postage pre-paid:
Barbara L. Christie, Chief Counsel
The Pennsylvania State Police
1800 Elmerton Avenue
Harrisburg, PA 17110
DATE:
EAGER, REINAKER & SPINELLO
Attornl
I.D. No.
1347 Fruitville Pike
Lancaster, PA 17601
(717) 290-7971
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
STATE FARM INSURANCE
IN RE:
2001 Honda 929cc Motorcycle
VIN: JH2SC44301M100810
ORDER
AND NOW, this I~ '~ day of 1.,~: 7~,I~.. ,2003, upon
consideration of the Petition of State Farm Insurance, and the Stipulation by and between the
Pennsylvania State Police, Trooper Hurly, it is hereby Ordered that the Pennsylvania State
Police shall release the 2001 Honda 929cc Motorcycle originally bearing the Vehicle
Identification Number JH2SC44301 M100810, to the custody of State Farm Insurance.
BY THE COURT: