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Home My WebLink About00-06053 , '" ,'.- .. ib..c . _',,~' ",.' -", ~"h'-" ~""-'.-C '~';' ','""'" """'lj . CARLISLE PIKE ASSOCIATES, plaintiff/Petitioner VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 00 - t O~3 0...;J I..L- . . JOHN H. BOWERS, JR, Defendant/Respondent CIVIL ACTION - INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE AND NOW, this ORDER OF COURT 7-rA f. ~ day of ~ , 2000, upon consideration of the attached petition for Involuntary Transfer of Ownership of a Vehicle by Court Order, it is ORDERED AND DECRF.1<n ~hat a hearing on this matter is set for the IleA day of ~N ':. ,_ ~c __ . 2000, in Court Room No. t , at q; nJ o'clock -il::-.:- M . Counsel for Plaintiff is directed to direct Notice of this Hearing to Defendant/Respondent at his last known address by certified mail, return receipt requested and by regular mail and, if such notice is unclaimed, advertise Notice of such hearing once per week for three consecutive weeks, all in accordance with the requirements of the Pennsylvania Department of Transportation. BY THE COURT, 7- /I ;1 . .~ J. 0Z ~ tP U '\ '\'~ Andrew C. Sheely, Esquire Attorney for Plaintiff --,""'," ! I ~j I ~ f " ." e > ,~ , ~" C,") cr".") ',' ~}U .:.;,:__;" - 1 f\'~1 L}': l5 CU(\/.~:,i:J:~:,Lj.->;0 CUUNTY PENr~SYLWN!/\ . - ,":.'--,,- <~, --'" _ ~,,' ., n, _ ~,,,,--, ~'--"::>,,'- " 'hi ;-,'~'__'"',' ^,'" ""1 -"~oj _,J y CARLISLE PIKE ASSOCIATES, Plaintiff/petitioner VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I 00 - &0.0 C T JOHN H. BOWERS, JR, Defendant/Respondent CIVIL ACTION - INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE NOT ICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 Date: August 31, 2000 BY dwJC. Andrew C. Sheely, uire PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for plaintiff , ,~ -_='0' < " -";"'~'''~i,:';i', " < - _',_ -",jd"" " :,::::1 . CARLISLE PIKE ASSOCIATES, Plaintiff/petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. 00 - (,() 5 3 ~ '"I L..-. JOHN H. BOWERS, JR, Defendant/Respondent CIVIL ACTION - INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE PLAINTIFF'S PETITION FOR INVOLUNTARY TRANSFER OF OWNERSHIP VEHICLE BY COURT ORDER Carlisle pike Associates, Plaintiff/petitioner, by and through counsel of Andrew C. Sheely, Esquire, hereby files this petition for Involuntary Transfer of OWnership of a mobile home by Court Order in accordance with procedures required by the pennsylvania Department of Transportation, respectfully stating as follows: 1. plaintiff/petitioner is Carlisle pike Associates, a duly registered fictitious name, with an address of 155 Salem Church Road, Mechanicsburg, Cumberland County, Pennsylvania and also having a Post Office Box Number of 124, Carlisle, pennsylvania, 17013. 2. Defendant/Respondent John H. Bowers, Jr. is believed to be an adult individual with a last known address of 6280 Carlisle Pike, Lot 201, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff is the owner of a mobile home park known as Salem Acres located in Hampden Township, Cumberland County, pennsylvania. 4. For the past eight months, a 1974 Hillcrest mobile home, ,~"'~- .--;'.'" -".,~ ;'.-. ,~,;;:,," Title Number 25902279, Vin Number 021120ll4H has been abandoned on Plaintiff's property located in Cumberland County, Pennsylvania. 5. Efforts by Plaintiff to locate the owner of the mobile home have been unsuccessful as the home has been abandoned for many months and the owner left no forwarding address. 6. On or about August 18, 2000, counsel for Plaintiff conducted a record search at the Pennsylvania Department of Transportation to determine the owner of the above-described mobile home for the purpose of contacting the owner to have such person remove the mobile home from Plaintiff's mobile home park. 7. A Vehicle Record Abstract provided by the Pennsylvania Department of Transportation, a copy of which is attached hereto as Exhibit uAu, indicates that the owner of the mobile home is Defendant/Respondent John H. Bowers, Jr., with a address of 6280 Carlisle Pike, Lot 201, Mechanicsburg, Pennsylvania. 8. On or about August 21, 2000, counsel for Plaintiff directed a letter to the address of Defendant/Respondent for the purpose of contacting Defendant/Respondent to advise him to remove said mobile home from Plaintiff's premises. A copy of the letter is attached hereto as Exhibit UBU. 9. Subsequently, the August 21, 2000 letter was returned to counsel for plaintiff indicating that the letter was undeliverable as addressed forwarding order expired. A copy of the returned envelope is attached hereto as Exhibit HCU. 2 "-" ' ;-,~ ,::~ ~-,',' -';-':<",'--'~-~" ' 10. Plaintiff desires to obtain title to the above-described mobile home so as to allow Plaintiff to remove the mobile home from the premises without further lost lot rents, storage costs, delays, other charges while also eliminating safety issues. 11. In order to obtain title to the above-described mobile horne, Plaintiff is required to commence the instant action, obtain a hearing date, attempt to communicate the hearing date to Defendant/Respondent by certified mail and/or public notice, and obtain an Order of Court following the hearing, all in accordance with rules and regulations promulgated by the pennsylvania Department of Transportation. A copy of the requirements issued by the pennsylvania Department of Transportation are attached hereto as Exhibit "D". WHEREFORE, Plaintiff/petitioner, Carlisle pike Associates, respectfully requests that this Honorable Court: (1) Schedule a hearing date at least sixty (60) days after receipt of the instant action so as to allow Plaintiff, Carlisle Pike Associates, to properly complete all required notice provisions for advertisement to Defendant/Respondent; and (2) After such hearing, enter an Order of Court indicating that the Commonwealth of pennsylvania, Department of Transportation may accept the Order of Court as evidence of ownership in lieu of a Certificate of Title, provided plaintiff/petitioner submits all forms, taxes and fees in order to 3 c' -- .~, ~~'~""-"~-'""",\~ 'J~',,--,,, "~ ,-".,_.; . ,',,',>!,' ".-.''- ." '~<I ": receive the appropriate certificate of title for said mobile home. (3) Any other relief deemed just and equitable. Respectfully submitted, Date: August;)l , 2000 ~~c.~ Andrew C. Sheely, Esquire Attorney for Plaintiff, Carlisle pike Associates 127 S. Market Street, P.O. Box 95 Mechanicsburg, PA 17055 717-697-7050 4 ,-- " J,., " - --,' ,,'~ " . -,'--- PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 8/18/00 PAGE 1 002311148000124 004 OWNER JOHN H BOWERS JR 6280 CARLISLE PK LOT 201 MECHANICSBURG PA 17055 LESSEE NONE TITLE NUMBER TAG NUMBER VIN 25902279 NO NO l' nTLE DATE 06/05/74 REGISTR4T~ON EXPIRY DATE; BODY,JYPE MH o~O,~~T,ER READING * *ACTUAL MILEA,GE ,DUPLICATE TITLE COUNT 0 ,,vEHICLE YEAR 1974 STOLEN DATE 02112014H MAKE MODEL RENEWAL WID PREVIOUS TAG LIENS STOPS HILLCREST LIEN INFORMATION NO LIENS EXIST FOR THIS TITLE . ;,- ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-8691 INFORMATION: (7:00 IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE www.dot.state.pa.us AM TO 9:00 PM) 1-800-932-4600 717-391-6190 1-800-228-0676 717-391-6191 - '- - , , ^^ ;~ .:.. ',= ,~ Telephone, (717) 697-7050 . ANDREW C. SHEELY ATTORNEY AT LAW 127 Soutb. Market Street P.O, Box 95 Meohanic,burg, Pennsylvania 17055 ce' r-",y , __.) t- .J Fax, (717) 697-7065 August 21, 2000 John H. Bowers, Jr. 6280 Carlisle Pike Lot 201 Mechanicsburg, PA 17055 RE: 1974 Hillcrest Mobile Home Title Number 25902279 VIN 02112014H Dea.r Mr. Bowers: Please be advised that the above-referenced mobile home has been abandoned for some time and located on the property of my client, Carlisle Pike Associates, in Hampden Township, Cumberland County, Pennsylvania. The mobile home is registered in your name with the Commonwealth of Pennsylvania. As an abandoned mobile home, my client has the right to have the mobile home towed and removed from the property. Any towing, storing or other related charges, in addition to the other damages, would remain your responsibility. In addition, it is possible that other proceedings could be initiated against you for abandoning a mobile home on another's property. Please contact me immediately to discuss these matters. If I do not hear from you on or before August 30, 2000, formal actions will be t€\ken to obtain title to the mobile home and pursue any an all actions for damages incurred by the abandoned mobile home. Very truly yours, ANDREW C. SHEELY ACSlawm Enclosure c: Carlisle Pike Associates ! ) .I \ l \ I' ~ ~ t ) . , , , I I . , ~ j l,i,1 ' #? ,; j J I i I! , I,l' ", I, I, I c, ~ t ~ ~ ~ " ~ 1\ ~ '~ t ~ 1 .!i" ~:Cf: ',' \. . -/, .. It, '~A, " 6 l~i Q lIJj.;j ;, !/)~' ~ I.", /1.. t~}~ co: "7{ e: ~~ u;o ..JCJ Ill", '<(B tE!.l: ~~ uI- ~~ ;:) '" '" o " ,..; b~ ~ ffi;S",,, :I1E-<a,~ <Il<?<O . >< 0 ~ ~~":S2 gjoq~ OE-<P-<iIl ~ ~ ~ ".t ('..., on on C "I c. ~~V~ .CC',... " a:W e.. ~~ Cl (/)e.. a: a:W ::l W...J 113 :=(/) (/) O::i 0 113a: Z '<(.-<( :I:O~:I: ZCI-O :I:Cl)OW 0C'l...J:E ~Cl) ,"c'_ - " , .,-, ~t1 ." I" <t (\j ~" I 1SI ~~ 1St I" .. ~ .Wav-Z.-ZDDO 09:39 r A' e T' 8~ f c. T~ . ) L " , ~' From-OFFICE OF CHIEF COUNCIL .+7177051122 HEIS P. 002/003 . H6! Involuntary Transfer 'of Ownership of;1 Vehiclle by CC)urt Order I'URPO$E This Fact Sheet outlines the procedures that must be followed when applying for a Certili~te of Title involvln!~ the involuntary transfer 01' a vehic:ll!'s ownership. This procedure Involve$ obtaining a court order and ShCIUld be used only in those Circum~nces where It is irnpossible tlJ tl'\1nsfer ownership of a '~ehicle by the use of a Certific~te of Title or Vehickl Manufllctufllr Certificate of Orfgin. Since every SElt offects I and sUl!Toundingcireumstences will be unique, a person attemptirlllJ ':0 be declared owner of a veliiicle where proper ownership documents are not available $rlould seek the advice of a private attorney. THE DEP,l,RnIENT WILL HCn OFIFIER L.EGAL AD'IICE REGARDING THE INVOLUNTARY TRANSFER OF OWNERSt-llII~ OF A VEHICLE,. PROCEDURES 1. A person attempting to obtain ownership of ,~ vehlc:ill must commence a proceeding with a court of competent jurisdictil~n setting forth the facts and cirCl.lmstanees of thEI eas.e. The ownership of the vehicle will be determil1ed by lhe court. Please nQte tl'lat a sampl.e court order is provided on the reverse lIide of this faelsneet. UNLESS THE: COIIIIMONWEALTH OIF PENNSYLVANIA, OEPARTMENT OF TRANS1)QIRTATIONIS TI'lE OWNEiR {)F THE VE:HICI.E IN QUESTION, THE COMMO~IWEALTttO.F PENNS'VLVANII~, DEPARTMENT OF TMNSPORrATIOI' IS NC)T AN INTERESTE:D PAFlrY TO THll~ C()URT PROCEEDING. THEREFOIIE, 1I'HE COMMONWeALT,.. I:)F PENNSiYLW,NIA, DEPARTMENT OF TRANSF'ORiAT10NSHOULI:I IIIOT I~E A NAMED PARTY IN THE PROCEED'NC~. 2. A person altemptin!} to be declared owner of a vlahiele by (lOUr! order must notify all persons with an ~ntere$t 111 the vehicle of the p\lndenc~' I)" the court proceeding. The notification must be sent by .certifled mail, retum rec'elpt reque5t$lil, and must include the fOllowing: (1) A specific de5criptilofl of the vehicle (i.e.., year, 1T1ls.ke, model i~nd \lIN); (2) The court of competont. jurisdiction where an a,;:1km will be or has been filed; and (3) The lime, date an(1 place of any court ~'roceeding. AT A MINIMUM, THE NOTICIE MUST BE SENT TO TliE PER:Si()N(S) TO VlIHOIWl THE VEHICLE IS PRESENTLY TITUlD AND REGISTERI:D ANI) I;VERY UE:NHCILDER THAT IS LISTED ON Tt~e TITLE RECORD,PLEA~IE NOH: THAT IF J' PE:RSON ATTEMPTING TO BE DIECLAREiD OWNER OF A V1EHICI.E: IIi UNAWA":E OF ANY PERSON WITH AN INTi!:REST IN THE VEHICLE, THE PEI~SON ATTEMPTING TO OBTAIN OWNERSHIP a,F THE ~'EHICLe MAY OBTAIN A Cr:RTlFIEO COpy elF THE VEHICLE'S COMPUTER RECOI'l:D BY COMPLETINGi FORM 1)IL-135 (RECIUESiT FOR VEHICLE INFORMATION), AND SUBMITTING FORM DL-131; 1'0 THE DEIF'AR"rMENl ALONG WITH THE APPROPRIATE FEES. . May 1999 - over. Bureau of MotOI' V'l'Ilcllll::;...a~h and suppon O,"~;uons sectic;-J P.O. Box 68031, Harrf$burg, PA 1I7106-8(~,1 Visit us at our websj'le at www.dcot.$IaIe.pa.US (clielc on Driver ~lrld Vehi~l. Services) -- -- ~ -...... .....-""~."~'""~ ~. " ~= liIiWIIl' - WaY-25-Z000 09: 41) Frcm-OFFICE OF CHIEF COUNCIL .H177051122 HEIB P.O01/003 H61 ; 3. In th,e event the notice sent to a person with an interest in tine vehlclEI is retumcldas 'Unclalmed';" tine person attempting to be declared owner of thCl .'ehiele must ad.'ertise .1 IElgal notice at le'~st onCE, in the! county legal journal(s) and :illleast (lIlC:e per week for three COllllEK:utive weeks in the newllpaper(s) of general circulation where any pEirson known to claim an inter,e,sl: In the vehicle lTIay be ICleated and where the vehicle is lOCi/led, if these two locations are. different, Please refElr to I:he Pent1sylvania Bar Association Lawyers Directory ,& I"roduce Guide 'to determine the approprll~te legal! journal. The advertisement should include l:he f(lllowing: (1) A speCific description of the v8,hicle (Le., :Iear, mllke, modelllnd VIN); (:,~) The court of competent jurisdic:tion whElre an action will be cor has Dele 1 filed; and (<l) The time, date and place of any court prcceeding. 4. Whe,n the above procedure is foliowed and the ';OIJrt of competent jurisdi.cl:ic,n enters aln o,,~er declaring an individual the rightful owner of the '~ehic:le, the Departml3nt ma~' issue a CertificatE! of 1111e to the person named in the court order upon receipt of the following: ('1) A certified copy of the court order ante red declaring the individual c,wrler of the vllhick!; (:?) A notarized statement Il$ling ll1e names ilnd addr8ss8$ of all pen;oni$ notified and how each notification war; served; (:1) A copy of the notification sent to all pel~s(lm; with an interest In the ,{llhiele. including the certified mail return receipts; (4) Copies of newspaper advertis.ements line! dlates published; (i5) Form MV-1, "Application for Certificate ot' Title,' and check or money order payable to the Commonwealth of Pennsylvania. Unless the petitioner can Claim a Sales Tax Exemption. 'lales tax must be paid on t,h,e Fair Marl<et Value of the vehicle as listed in a current edition of a Oepa~tment.approved publication. A.j;proved Department publications Include the following: N.A.DA. TI'!e Automobile Red Book, The' Black j~I",k Official Used Car Guide, American Used Car Guide. and The Kelley Blue 1300k Used Car Guide. SAMPI.E COURT ORDER /),ND NOW. this day of , 19 __, afte'r reasonable notice and an opportunity for hearing having been provided to all interested partllEl:s the COU~i "ereby awards ownership of one 19 _' [makel. [model], bearing whicle idEntification number _ to [name OfElpplicsnt], and the right, title and interlest of any other person to said vehicle is hereby extinguished. ThE! Commonwealth of Pennsylvania, Department of Transportation may accept this order lIS evid.ence of ownl~rship In lieu of a Gertiflcate of Title. The Petitioner shall sublni't the appropriate formll, taxes and fees and comply with any other procedures of 'the Commonwealth of Pe,nnsylv:lnia, Department of Transportation in order to receive the appropriate Certificate of Title I,'or said vl~hicle. BY THE COUI~T: L Jud!le -=~~. -,,',>:," -b .~~.--, .~, ""'-"1 " VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that unsworn statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. 1chael E. ienkiewic, Agent for Carlisle pike Associ tes DATE: August 3rt, 2000 .F' IF"" n': ..... r~ -- (s. .,J ~ r\ ,,"" ~ v. ~ -....."""'lIi':'.../~ ^ r(: 0-'~',,"-, -~~-.- ' !,' ~;,~. ' ',_ f". ~ I .' "'""-,,,,',, --'~-',",," 9~IL: z (f. -< c-~ ~~~:! z ~ C1 ::- C.__' ',") --.j ---:;: " ~""'. ~ ..' ~ .. . , Ij:i 1'1 ',j &J ~ 11 11 t1 II il ! (I Ii I I ! ! I I I . . ;;~ :D -< ~ ~ \. , .{:. ~ ~ "'l ..c:. ~ c ~~ ~ ~ \ ~"" ., . ,',.__L_:-~_ , " - j. ~"~, "--~ , '. " ...> T,l'phone: (717) 697-7050 ANDREW C. SHEELY ATtORNEY AT LAW 127 South Mork,t SIre,t P.O. Box 95 Mechanicsburg, Pennsylvania 17055 C'r- p 'I!J y, Fax: (717) 697-7065 VIA CERTIFIED MAIL. RETURN RECEIPT REOUESTED AND REGULAR MAIL September 19, 2000 John H. Bowers, Jr. 6280 Carlisle Pike, Lot 201 Mechanicsburg, PA 17055 RE: 1974 Hillcrest Title Number 25902279 VIN Number 02112014H 00-6053 Cumberland County Dear Mr. Bowers: Enclosed for service upon you please find a True and Correct Copy of an Order of Court scheduling a hearing on Carlisle Pike Associate's Petition for Involuntary Transfer of the above-referenced mobile home. You are the named defendant in the action. Please note that the hearing is scheduled for December 11, 2000, at 9:00 a.m., before the Honorable Kevin A. Hess, in Courtroom NO.4 of the Cumberland County Courthouse. In addition, I am enclosing a copy of a Complaint/ Petition filed in the above- captioned docket. Please be advised that my client continues to incur substantial losses due to your maintaining the mobile home on the lot and due to accruing taxes. If you do not attend the hearing, the above-referenced mobile home will be transferred for the reasons set forth in the attached Complaint/Petition. Thank you for your attention to these matters. Very truly yours, ANDREW C. SHEELY ACS/bmk Enclosure c: Carlisle Pike Associates CARLISLE PIKE ASSOCIATES, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. 00 - 6053 JOHN H. BOWERS, JR, Defendant/Respondent CIVIL ACTION - INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE ORDER OF COURT AND NOW, this I/~ day of December, 2000, after reasonable notice and an opportunity for a hearing having been provided to all interested parties, the Court hereby awards ownership of a 1974 Hillcrest Mobile Home, Title Number 25902279, VIN 02112014H, to Petitioner, Carlisle Pike Associates, and the right, title and interest of any other person to said vehicle/mobile home is hereby extinguished. The Commonwealth of pennsylvania, Department of Transportation may accept this Order of Court as evidence of ownership in lieu of Certificate of Title. The Petitioner shall submit the appropriate forms, taxes and fees and comply with any other procedures of the Commonwealth of Pennsylvania, Department of Transportation, in order to receive the appropriate Certificate of Title for said vehicle/mobile home. BY THE COURT, Andrew C. Sheely, Esquire Attorney for Plaintiff/Petitioner //4-. J. Ccfies pmJnc.fr liver) Of)(/( MO J}d ~ " ~' T i:~~~~.-' 'OJ ,_ .~,~ " .~- < ~;<",,;; - , ~~ , _~J -,-,>, ,"'" ",,,, ", ,'," "" l) C ,~ -oee nlrr ZJ,"J Z.." C"',,. -z"'"~-~ ,,,,,- ~O ~() --0 5>C ~ .,,~. , "'~ ~ ~ It i~ " I <::> a o ("q c, I=i -n Ftl -' -~~ ~:r; ,:..c.:'l'- ,~'---- . {<~...J ~~~ ::;;J :n -< J.~~ 3: ':? N .r:- JJ ...'~- - .' . CUMBERLAND LAW JOURNAL 2 LIBERTY AVENUE CARLISLE, P A 17013 NOVEMBER 3. 2000 Cumberland Law Journal is published every Friday by the Cumberland County Bar Association and is designated by the Court of Common Pleas as the official legal publication for Cumberland County and the legal newspaper for publication oflegal notices. TO: Andrew C. Sheely, ESQUIRE RE: Carlisle Pike Associates vs Bowers Legal ad'iertisementsmust be received by Friday Noon. All legal advertising must be paid inadvance, Make all checks payable to: Cumberland Law Journal. =========================================== Advertisement inserted on following dates: NOVEMBER 3, 2000 8"0 Total Lines Printed -35 Lines for $ 60.00 r.5' Lines at $1.55 Advertising Cost $ 60.00 Additional per lines charge $ ~ 9. 7s-' Second Proof Request $ 0.00 Payment received $ 0.00 Total Amount Due $ 1~9. 1.5 ------ ~--- Payment received " ' ByBecky Morgenthal/ Executive Director ,'~ ~ , . .--," PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor ofthe Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regnlar editions and issues of the said Cumberland Law Journal on the following dates, Viz NOVEMBER 3, 2000 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are ROg~ditor ........ SWORN TO AND SUBSCRIBED before me this ~day of NOVEMBER. 2000 NOTARIAL SEAL LOIS E. SNYDeR, Notary Public Carli". Boro, Cumborlond Caunty. PA My Commission Expires Mqrch 5~ 2(X)1 c, ~ " ;11. .. . , "'0, ~ -';-.'j. ::2J CUMBERLAND LAW JOURNAL NOTICE In -the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action 00-6053 CARLISLE PIKE ASSOCIATES. Plaintiff/Petitioner vs. JOHN H. BOWERS. JR.. Defendant/Respondent INVOLUNTARY TRANSFER OF MOTOR VEHICLE TIlLE To: JOHN H. BOWERS. JR.. 6280 Carlisle PIke. Lot 201. Mechan- icsburg. PA 17055 NanCE OF HEARING FOR INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE BY COURT ORDER You. JOHN H. BOWERS. JR.. have been sued in court. Records of tl1e Pennsylvania Department of Transportation indicate that you are the owner of a 1974 Hillcrest Mo- bile Home. TItle Number 25902279. VIN 02112014H. Certified and regu- lar maiI dlrected to you at your last known address have resulted in the return of all correspondence marked "Attempted. Not Known". An action docketed to 00-6053 has been filed in the Court of Common Pleas of CUIIlberland County. Pennsylvania. to obtain a Court Order transfer- ring title of the 1974 Hillcrest Mo- bile Home. TItle Number 25902279. VIN 02112014H to Plaintiff. You. JOHN H. BOWERS. JR.. are hereby notUled that a hearing on Plaintifl's Petition for Involuntary Transfer of Ownership of Motor Vehicle by Court Order has been scheduled for December 11, 2000, at 9:00 a.m., in Courtroom No.4 of the Cumber- land County Courthouse, Carlisle, Pennsylvania. Failure to attend the hearing could result in an Order of Court declaring that Plaintiff is the owner of the 1974 Hillcrest Mobile Home. TItle Number 25902279. VIN 02112014H. ANDREW C. SHEELY. ESQUIRE Attorney for Plaintiff 127 S. Market Street P.O. Box 95 Mechanicsburg. PA 17055 717-697-7050 Nov. 3 8 .- ~.r~' PENNSVLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 8/18/00 PAGE 1 002311148000124 004 OWNER JOHN H BOWERS JR 6280 CARLISLE PK LOT 201 MECHANICSBURG PA 17055 LESSEE NONE TITLE NUMBER TAG NUMBER VIN 25902279 NO NO TITLE DATE 06/05/74 REGISTRATION EXPIRY DATE, .' , BODY TYPE MH ODOMETER READING * *ACTUAL MILEAGE ,DUPLICATE TITLE COUNT 0 ..VEHICLE YEAR 1974 STOLEN DATE 02112014H MAKE MODEL RENEWAL WID PREVIOUS TAG LIENS STOPS HILLCREST LIEN INFORMATION NO LIENS EXIST FOR THIS TITLE PLAtNT1FF'S ' I . ,ex,HIBIT .. ""~ ; ADDRESS CORRESPONDENCE TO, DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-8691 INFORMATION: (7,00 IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE www.d~t.state.pa.us AM TO 9:00 PM) 1-800-932-4600 717-391-6190 1-800-228-0676 717-391-6191 100000H Ih-.J>."hli'''<.ll I1II 11I1;~.IlIII~IOlHII III ,.~.il,.iljliil_liIi,,*~:JlillJiflIl'jJliI;iuIWI"h~~b'_J*",,:""'''~III1I' :It ;'1111:1 I-l,-Iiiij- II ,li..~IJj_IM" li~1 j ,y-c"i Ll~ildl""bjlli ,_d 1,11,111I'1 ii:,illii'III"ili'dlil:ii;;'~ _ ,,': ':', .!"i,k . J '. CLASSIFIED ADVERTISING INVOICE Questions regarding this invoice call (717) 255-8138 ~t~t-NtbJ5 BilLING DATE 11210",,00 I To Place your ad Call Classified (717) 255.8121 Tearsheet Request call (717) 255-8417 ANDREI-l C. SHEELY An OR'VEY AT UHoI PA 17055 n. ," , AccouJilrNO.' , " ., ",.__n. , ,..,""__,,, n__.'.. .__ ,-'n,;;;;);;;;;:;;I' .m E:::;=iml:Hrz::i~:({: "'" ,.,-- ,_ .!> HH.m, ::;fI:ii::;;H:;rHL';t"t:',H-.. -- :: ':ff:;!:::;!;;::rm,<J-:~';::;;':::: -, , '"'''' ",,:t,,!; id,~ .~JJ"')-' , i-;', ;lml~!~~i;l"':, ;'" DISCOVNT,~ ' I 6977050AND I -,,, ,,' '. ," ADVANtiC;PAY!Jt\'iN:r SHEELY ":'_:''''''''''''':';''''''';:''::;:':.1.' '" ;::: .. '. '::, $ .. "'" -,',", ',:::,:i:':,;':",,": ,:;:', -:: ,:," '~';:;,::;r;:::!J;,: J." ' 2.57.03 I I -- "''',,, "m;:l;;m;:;:l:~:;li;;,r: ,~,~ ". .,', , ;;-,';;,;' . , DESCRIPTIQNOFiTAGLI1'l8 ---'--",,'.. ,,,,--,,,,,, ;." --.:, r~~U=6053 CARLISLE p I TERMSI DUE UPON RECEI?T :is'':;'''' ",:.;";i;';;;;:;;Z0,:;,;:;;,,,,,iliili!;;;;i:llii:,,l:::i1;';,,;:;',;,:;;;:,;'':';is;;;;;.:;~;,,,,,.::;;;:, "':;".:'I;j :""""",~.,,~,;; "l;;''':'';c,,,,::,,,; ,.:,;,;,;,;C.:,:;l;",. '" ~ THE THE PATRIOT NEWS SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since: That the printed notice or publication which is securely attached hereto Is exactly as printed and published in their regular dally and!or _Sunday! Metro editions which appeared on the 21 st and 28th day(s) of November and the 5th day(s) of December 2000. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds In and for said countn of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 1I PUBLICATION ............... ...... .. .. r~.................................. COpy Sworn to 1------ ,- '--'-' _.. , Miscellaneous Notices I I his 7th da of Dec~er 2000 A.D. Nomr~(Se~, ~ Te"y L. Russell. Nota b .~- ~ /:; #" Hanisburg, Dauphin Cou MyComrnissionExplresJune6, 0 TARY PUBLIC Member, Pennsylvania Association at Notarirofy commission expire's June. 6,' 2002 IN THE COURT OF COMMON PLEAS OF :" CUMBERLANO COUNTY, PENN5YLVANIA 0(1-'053 I C;IYILACTION -INVOLUNTARY TRAI'!lSFER OF MOTOR VEHICLE TITLE' CARLISLE PIKE ASSOCIATES, . Plalntlffipetltioner V.5i. JOHN H. BOWERrJR. . OefenaantlRcspondent . 1:0: .JOHNH. BOWERS, JR. a2SQCARUSLE PIKE, [OT201 ..., MECHANICSBURG, PA 17055 . NOTICE; OF HEARING FOR INVOLUN-, TARYTRANSFER OF MOTOR VEHICLE TITLE BY COURT ... .:.. ORDER , ,'(QU',J"OHN H. BOWERS, JR., have been $lJed'ln'c:ourt. Records of the Pennsylvanlo : Depar:tment of TranspOrtatIon indicate thot ,you are the owner of a 19T4-HillcreSf Mobile i Home, Title Number 2590:2279, VI N 021121l14H. certlffed and regular mall dlrechx:l to YOU at 'Y!'ur ~st,known address hClV~ resulted in the rewrn of all correspondence marked "At- temJ::rmd:', Not Known". An action docketed to 00-6053 has been flied In the Court of Common . Pl~s _of CUmber-lana County; Pennsylvania, ,toobtaJQ:..o CourtOrder transferring tit/eof the ,1974 Hlllcrest Mobile Home, Title Number :-259f12279, V1N 112.1T2014H to I3lolntlff. You, r JOHN..H. BOWERS, JR., arc hereby potitfed i tl1d~a:l1enrJtl:gon Plall'l,tlff's P~titlonfor [nvol- I urnar;;r.Thirister of OWnership of Motor Vehl- 1-c.1~ J:)Y (:ourt Order has peen scheduled for : Dec~l1iber11,200lt,at9:00a_m., in Courfroom 0- No. 4 ~f f11e Cumberkmd County Courthouse, bi ~arllsle,_ Pennsylvania. Failure to attend the Lheorln!"l.co.uld result in an Order of Court de- : dari~ that Plainlltt is the owner of the-1974 l HIUcr.est Mobile Home, Title ,Number j25902279;VIN 02112014H. , Af1~rewC.Sheely,Esquire i 127 S. Market Straet P.O. Box 95 Mechanlcsburg, PA 17055 Tl7-69T-7(JSQ Attorney for PlaintIff ANDREW C, SHEELY ATTORNEY-AT-LAW P.O. BOX 95 MECHANICSBURG, PA, 17055 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 255.53 1.50 257.03 Publisher's Receipt for Advertising Cost )ubllsher of The Patriot-News and The Sundav Patriot-News, newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have By..........,....................................................,..., , ANDREW C. SHEELY ATTORNEY AT LAW (" .-.... r-" Y ~ ~'J l_J ~. ./ Tel'phon" (717) 697-7050 1.27 Soulh Mukel Sheeel P.O. Box 95 Meahal'l.icsburg, Pennsylvania 17055 Fax, (717) 697-7065 August 21, 2000 John H. Bowers, Jr. 6280 Carlisle Pike Lot 201 Mechanicsburg, PA 17055 RE: 1974 Hillcrest Mobile Home Title Number 25902279 VIN 02112014H Dear Mr. Bowers: Please be advised that the above-referenced mobile home has been abandoned for some time and located on the property of my client, Carlisle Pike Associates, in Hampden Township, Cumberland County, Pennsylvania. The mobile home is registered in your name with the Commonwealth of Pennsylvania. As an abandoned mobile home, my client has the right to have the mobile home towed and removed from the property. Any towing, storing or other related charges, in addition to the other damages, would remain your responsibility. In addition, it is possible that other proceedings could be initiated against you for abandoning a mobile home on another's property. Please contact me immediately to discuss these matters. if I do not hear from you on or before August 30, 2000, formal actions will be ta,ken to obtain title to the mobile home and pursue any an all actions for damages incurred by the abandoned mobile home. Very truly yours, ANDREW C. SHEELY ACS/awm Enclosure c: Carlisle Pike Associates