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UNITED MOBILE HOMES, INC., :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001- 5(P 3
CIVIL TERM
SHAWN L. FITZGERALD,
Defendant
CIVIL ACTION-INVOLUNTARY TRANSFER
OF MOTOR VEHICLE TITLE
ORDER OF COURT
AND NOW, this / .s-1day of ;;A1Z.Wld.l' , 2001, upon consideration of the
attached Petition For Involuntary Transfer Of Ownership Of A Vehicle By Court Order, it
is ordered and decreed that a hearing on this matter is set for the / 9 --t:A day of
-
In/) /GcA , 2001 at ~ in Courtroom No...!J of the
Cumberland County Courthouse, Carlisle, Pennsylvania.
Counsel for the Plaintiff is directed to provide notice of this hearing to the
Defendant 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, in accordance with the requirements of the
Pennsylvania Department of Transportation.
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Michael A. Scherer, Esquire
O'Brien, Baric & Scherer
17 West South Street
Carlisle, Pennsylvania 17013
. Shawn Fitzgerald
23 Marilyn Drive
Carlisle, Pennsylvania 17013
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UNITED MOBILE HOMES, INC., :
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001- 5(.,3
CIVIL TERM
SHAWN L. FITZGERALD,
Defendant
CIVIL ACTION-INVOLUNTARY TRANSFER
OF MOTOR VEHICLE TITLE
PLAINTIFF'S PETITION FOR INVOLUNTARY TRANSFER
OF OWNERSHIP OF VEHICLE BY COURT ORDER
AND NOW, comes the Plaintiff, United Mobile Homes, Inc., by and through its
attorney, Michael A. Scherer, Esquire and respectfully represents as follows:
1. The Plaintiff is United Mobile Homes, Inc., a New Jersey Corporation with
a local address of 147 Amy Drive, Carlisle, Cumberland County, Pennsylvania.
2. The Defendant is Shawn L. Fitzgerald, who is an adult individual with a
last known address of 23 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff is the owner of a mobile home park known as "Pine Ridge Mobile
Home Village," located in North Middleton Township, Cumberland County,
Pennsylvania.
4. For the last four months, a 1983 Conner mobile home, title number
48710226001 FI, VIN number CHCANC60141100215S2863 which is legally titled to
the Defendant, has been abandoned on Plaintiffs property at Pine Ridge Mobile Home
Village.
5. Efforts by the Plaintiff to locate the Defendant have been unsuccessful.
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6. On or about January 9, 2001, counsel for the Plaintiff conducted a records
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 the Plaintiffs mobile home park.
7. A vehicle record abstract provided by the Pennsylvania Department of
Transportation indicates that the owner of the mobile home is the Defendant, Shawn L.
Fitzgerald, with an address of 23 Marilyn Drive, Carlisle, Cumberland County,
Pennsylvania. A copy of the abstract has been attached hereto as "Exhibit A."
8. On November 13, 2000, United Mobile Homes, Inc., through its Vice
President, Thomas N. Stewart, directed a certified letter to the Defendant at his last
known address directing the Defendant to remove the mobile home from the Plaintiffs
premises. A copy of said letter is attached hereto as "Exhibit B."
9. Subsequently, the November 13, 2000 certified letter was returned to
Thomas N. Stewart marked "moved left no address." A copy of the returned envelope
is attached hereto as "Exhibit C."
10. Undersigned counsel has been in contact with L. Bruce Althouse of the
Cumberland County Probation Department, who is the probation officer for the
Defendant. Mr. Althouse reports that the Defendant is presently in violation of his
probation because he has not been heard from since early September, 2000, and is
believed to be in England. A bench warrant has been issued for the Defendant's arrest
and a missing persons report has been filed with the police.
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11. Plaintiff desires to obtain title to the above-described mobile home so as
to allow the Plaintiff to remove the mobile home from the premises without further loss,
lot rents, storage costs, delays and other charges while also eliminating a safety
hazard.
12. The Defendant's mobile home is an "abandoned mobile home" as set
forth in 68 P .S. 250.102 in that the Defendant has vacated the mobile home without
notice and he has not paid rent or resided in the mobile home for several months.
13. In order to obtain title to the above-described mobile home, Plaintiff is
required to commence the instant action, obtain a hearing date, attempt to
communicate the hearing date to the Defendant by certified and/or public notice and
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obtain an order of court following the hearing, all in accordance with the rules and
regulations promulgated by the Department of Transportation. A copy of the
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requirements issued by the Department of Transportation are attached hereto as
"Exhibit D."
14. Plaintiff has been granted possession of the mobile home and a judgment
has been entered against the Defendant in the amount of $1,126.00 by District Justice
Paula Correal at Docket No. L T -441-00.
15. Plaintiff is prepared to pay the delinquent real estate taxes on the mobile
home in the amount of $998.51.
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WHEREFORE, Plaintiff respectfully requests that this Honorable Court:
1. Schedule a hearing date at least sixty (60) days after the receipt of the
instant action so as to allow the Plaintiff to promptly complete all of the
required notice provisions for advertisement to the Defendant; and,
2. After such hearing, enter an order directing 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
submits all forms, taxes and fees in order to receive the appropriate
certificate of title for said mobile home.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
?lPt14~
Michael A. Scherer, Esquire
1.0. # 61974
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
mas.dir/genlitlunited.pet
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VERIFICATION
I verify that the statements made in the foregoing Plaintiff's Petition For
Involuntary Transfer Of Ownership Of Vehicle By Court Order are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pac
C.S. 34904, relating to unsworn falsification to authorities.
DATED: /1t/c)/
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PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
1/09/01
PAGE 1
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LESSEE
010090273000069 002
OWNER
SHAWN L FITZGERALD
23 MARILYN DR
CARLISLE PA 17013
NONE
TITLE NUMBER 48710226
TAG NUMBER TITLE DATE 08/22/95
VIN CHCANC6014110215S2863 REGISTRATION EXPIRY DATE:
BODY TYPE MH
MAKE CONNERS ODOMETER READING lE
MODEl lEEXEMPT BY FED LAW
RENEWAL WID DUPLICATE TITLE COUNT 0
PREVIOUS TAG VEHICLE YEAR 1983
LI ENS NO STOLEN DATE
STOPS NO
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
"EXHIBIT A"
AM TO 9: 00 PM)
1-800-932-4600
717-391-6190
1-800-228-0676
717"391-6191
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Pine Ridge Mobile Home VllIage
147 Amy Drive
Carlisle, PennsylvanIa 17013
(717) 249.3574 or 249.2751
FAX (717) 249.1753
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1'10 alve YOllliCJt\ce lha1)'OU have (15) fifteen days to claim property thaI you have · don.t!
)'II A'lvo. Tbe prOperty beina (I) 0118 mobile home and Dum~OlIS pa"sonal items and ouse~old
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Carlisle, Pennsylvania 17013
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Involuntary Transfer .of Ownership of ;1 Vehiclle by
Cc)urt Order
PURPOSE
This Fact Sheet outlines the procedures that must be followed when applying f.~r 8
Certificate of Title ilWolvin!J the in~oluntary transfer of a vehid'~'s ownership This
procedure Involves oblaining a court order and should be Llsed only in Ihose
circumstances where it Is irnpO$siblll to transfer ownership of II .",ghlcle by the use of II
Certificate of Title or Vehiclll Manuhictumr Certificate of Origin. Since every SElt of facts
and surrounding circumstances will be unique, a person attemptir~1 ':0 be declared owner
of II vehicle where proper ownership documents are not available E,r,ould seek Ihe advice
of a private attorney. THE DEP.l~RTMENT WILl.. NC:>T OFIFIER LEGAl.. ADVICE
REGARDING THE INVOLUNTARY TI~ANSFER OF OWNERSHII~OF A VEHICLE:.
PROCEDURES
1. A person attempting to obtain ownership of ,8 vehiclll must commence a
proceeding with a court of competent jurisdicti,~n setting forth the facts and
" circumstances of thEl case. The ownership of the vehicle will be determil1ed by the
CQurt. Please note tl'iat a sampl'e c:ourt order is provided 011 the reverse !lide of this
fact sheet. UNLESS THE COMMONWE..l..TH e,F' PENNS'Y'LVt\NIA,
DEPARTM.ENT OF TAANSI)~'rATION IS THE OWNER l:lF THE Vf:HICI..E IN
QVESTION, THE COMMO~lwEALTH OF PENN$YLVAI~II\. DEPARTMENT OF
TRANSPORTATION IS NUT AN INTERESTE:O PAF:1"r TO THI!~ COURT
PROCEEDING. THEREFO(~E. THE COMNlON\IVEALTli OF PENNS.YlVANIA,
DEPARTMENT OF TRANSI'ORTAT10N SHOUlIJ NOT I~E A NAMED PARTY IN
THE PROCEEOIN(~.
2. A person attemptin!~ to be declared owner of a v,.hicle by (:ourt order must notify
all persons with an,nterest il1 the vehicle ofthe pllndenc}' ,,"the court proceeding.
The notification mu..t be sent by certified mail, return rec~i~.t requestecI. anel must
include the following:
(1) A specifiC description of the vehicle (Le. year, ITalce. model i~nd \tIN);
(2) The court of competent jurisdiction where an a,;lion will be 01' has been
filed; and
(3) The lime, date and ~,Iace of any court proceeding.
AT A MINIMUM, THE NO'TICe MlJST iE SENT TO TliE PER.S()N(S) TO WHOIVl THE
VEHICLE IS PRESENTl.Y TITL~iD AND REGISTERI:D ANI) liVERY UE:NHCILDER
THAT IS LISTED ON TI>lE TITLE Rl:CORD. PLEASE NOT'E, THAT IF A PE.RSON
ATTEMPTING 10 BE DIECLAREiO OWNER OF A VIEHICI.E II> UNAWAI1:E OF ANY
PERSON WITH AN INUREST IN .THE VEHICLE, THE PEI~SON ATTEMPTING TO
OBTAIN OWNERSHIP OF THE VEHICLE MAY OBTAIN A CI:i'HIFIED COpy elF THE
VEHICLE'S COMPUTER RECOfl:OBY CQMPLETING, FORM ()/L.135 (RECIUES;T FOR
VEHICLE INFORMATION), AND 5USMITTING FORM DL-13!) TO THE OEIi>A.R'rMENT
ALONG WITH THE APPROPRIATE, FEES.
May 1999
~ over.
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Bureau 01 Motor Vehlcle:1 - R.",earch and Support Opll'alions Secli.,"
P.O. Box 68031, Harrisburg, PA 17106-8C131
Visit us al our wilbsite at www.de.l.sl.le.pa.u8 (click 011 Driver IIrtO Vehicle Services)
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, 3. Inth,e ellent the notice sent to a person with an ihteresrin the vehiclE! is returl1lKlas "Unclaimed';"
the person attempting to be declared owner of 11'111 ~'ehicle must advertise il IElgal notice at least
onCE in the county legal joumal(s) and .at leastl>nc:8 per week for three COn!lfl<:utive weeks in the
newllpaper(s) of general circulation where any pllrson known to claim an imereoS!: in the vehicle may
be IClcated and where the vehicle is locolled, if these two locations are, different. Please refE,r to the
Penl1sylvania Bar Ass()(;iation Lawyers Directory ,& Produce Guide ':0 determine the appropri;ate
lega' journal. The advertisement should inclUde 'Ihe fClllowing:
(1) A specific description of the vehicle (i.e, yelar, make, model and VIN);
(.1) The court of competent jurisdic:tion whE're an action will be c,r has be,e, filed: and
Pl The time. date and Place of any court proceeding.
4. WhE,n the above procedure is followed and the ';OlJl1 of competent jurisdictic>n enters a,n order
declaring an individual the rightful owner of the '~ehic:le, the Departnl'ant may issue II CeJ1ificatE! of
'Title to the person named in the court order upon rei;.ipt of the following:
(1) A certified copy of the court order entered declaring the individual cwner of the V!~hick!:
(:~) A notarized statement listing ll1e names .md addresses of all person's notified ani;! how
eaell-notiflcation was served:
(il) A copy of the notification sent to all pelrsons with an interesl: in the '/lIhicle, including the
certified mail return receipts;
(4) Copies of newspaper advertisements une! dates published;
(!S) Form MV.l, "Application for Certificate of Title: and check or money order payable to the
Commonwealth of Pennllylvania.
Unless the petitioner can Claim a Sales rax Exemption, 'lales tax must be I~aid on t1,e Fair Mari<e! Value
of the vehicle as listed in a curren! edition of a Department-approved publication. A~proved Department
publications Include the following: N.ADA. Tl'le Automobile Red Book, The Black 13,),)k Official Used Gar
Guide, America.n Used Car Guide, and The Kelley Blue t~ook Used Car Guide.
SAMPLE COURT ORDER
I:>.ND NOW, this day of , 19 __, afte'r reasonable notice
and an opportunity for hearing having been providfld to all interested parti'3'. the Cour; hereby
awards ownership of one 19 _' [make], [mod'sl], bearing whicle identification number
to [name of <Ipplicant), and the right. title
and intelt:!st of any other person to said vehicle is hereby extinguished. The, Commonwealth of
Pennsylvania, Department of Transportation may accept this order !IS evidl:!nce of ownl~rship in
lieu of a Certificate of Tille. The Petitioner shall submit the appropriate fOrm!l, taxes and I'ees and
comply with any other procedures of 'the Cornmonwealth of Pe,nnsylv;J',ia, Department of
Transportation in order to receive the appropriate Certificate of Title j:or said 'oi,=hicle,
BY THE couln:
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UNITED MOBILE HOMES, INC., :
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-563 CIVIL TERM
SHAWN L. FITZGERALD,
Defendant
CIVIL ACTION-INVOLUNTARY TRANSFER
OF MOTOR VEHICLE TITLE
ORDER OF COURT
AND NOW, this 19th day of March, 2001, after reasonable notice and an
opportunity for hearing having been provided to all interested parties, the Court hereby
awards ownership of one 1983 Conners mobile home, bearing vehicle identification
number CHCANC6014110215S2863 to "United Mobile Homes, Inc.," and the right, title
and interest of any other person to said vehicle is hereby extinguished. The
Commonwealth of Pennsylvania, Department of Transportation may accept this Order
as evidence of ownership in lieu of a 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.
BY THE COURT,
Michael A. Scherer, Esquire
O'Brien, Baric & Scherer
17 West South Street
Carlisle, Pennsylvania 17013
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Shawn Fitzgerald
23 Marilyn Drive
Carlisle, Pennsylvania 17013
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UNITED MOBILE HOMES, INC., :
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2001-563 CIVIL TERM
SHAWN L. FITZGERALD,
Defendant
CIVIL ACTION-INVOLUNTARY TRANSFER
OF MOTOR VEHICLE TITLE
INDEX TO PLAINTIFF'S EXHIBIT # 1
Paae Document
1 Copy of Certificate of Title to abandoned mobile home
2 PennDOT vehicle abstract to abandoned mobile home
3 Copy of November 13, 2000 letter from Plaintiff to Defendant
4 Copy of envelope returned to Plaintiff with November 13 letter.
Defendant moved and left no address.
5
Copy of Michael Scherer's February 6, 2001 letter to Defendant
notifying Defendant of date, time and location of hearing.
6 Copy of envelope returned to M. Scherer with February 6 letter
7 Copy of envelope returned to M. Scherer with February 6 letter
8 Copy of envelope returned to M. Scherer with February 6 letter
9 Proof of publication in the Sentinel
10 Proof of publication in the Cumberland County Law Journal
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PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
1/09/01
PAGE 1
010090273000069 002
SHAWN L FITZGERALD
23 MARILYN DR
CARLISLE PA 17013
LESSEE
NONE
TITLE NUMBER 48710226
TAG NUMBER TITLE DATE 08/22/95
VIN CHCANC6014110215S2863 REGISTRATION EXPIRY DATE:
BODY TYPE MH
MAKE CONNERS ODOMETER READING *
MODEL *EXEMPT BY FED LAW
RENEWAL WID DUPLICATE TITLE COUNT 0
PREVIOUS TAG VEHICLE YEAR 1983
C LIENS NO~ STOLEN DATE
STOPS NO
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
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Pine Ridge Mobile Home Village
147 Amy Drive
Carlisle, Pennsylvania 17013
(717) 249-3574 or 249-2751
FAX (717) 249-1753
November ]3, 2000
Shawn Fitzgerald
23 Marilyn Drive
Carlisle, PA 17013
Ref: Abandoned Property
This lelter is to give you notice that you have (15) fifteen days to claim property that you have abandoned
at 23 Marilyn Drive. The property being (]) one mobile home and nwnerous personal items and household
goods.
Failure to adhere to this notice will forfeit all rights to this property.
ion,
Certified Mail # - 00 0600 0025 15876982
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United Mobile Homes Inc.
Regional Office
147 Amy Drive
Carlisle, Pennsylvania 17013
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Law Offices
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle, Pennsylvania 17013
Robert L. O'Brien
David A. Baric
Michael A. Scherer
(7/7) 249-6873
Fax (717) 249-5755
E-mail: obs@obslaw.com
direct: mscherer@obslaw.com
February 6, 2001
VIA CERTIFIED MAil-RETURN RECEIPT REQUESTED
& REGULAR MAil
Shawn L. Fitzgerald
23 Marilyn Drive
Carlisle, Pennsylvania 17013
RE: 1983 Conners Mobile Home
Title No. 48710226001 FI
VIN No. CHCANC60141100215S2863
Dear Mr. Fitzgerald:
Enclosed for service upon you please find a true and correct copy of an Order of
Court scheduling a hearing on the United Mobile Home's Petition For Involuntary
Transfer of the above referenced mobile home. You are a named Defendant in the
above-captioned action. Please note that the hearing is scheduled for March 19, 2001
at 9:15 a.m. in Courtroom No.5 of the Cumberland County Courthouse, Carlisle,
Pennsylvania, before the Honorable Edward E. Guido.
In addition, I am enclosing a copy of the Petition filed in the above-captioned
case. 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 into my client's name for the reasons set for in the attached Petition.
Thereafter, my client will be the lawful owner of the mobile home.
Please contact me immediately to discuss this matter.
Very truly yours,
O'BRIEN, BARIC & SCHERER
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Michael A. Scherer
MAS/jl
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cc:~as Stewart, United Mobile Homes
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L\ W OFfiCES
O'BRIEN BARIC Ie SCHERER
[7 WEST SOUTH STREET
CARLISLE. PENNSYLVANIA 17013
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SHAWN FITZGERALD,
23 MARILYN DRIVE"
CARLISLE, PENNSYLVANIA 17013
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O'BRIEN BARIC" SCIIERER
17 WEST SOUTH STREET
CARLISLE. PENNSYLVANIA 17013
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l.et:r IV~O\leLSHAWN FITZGERALD
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CA~L1SLE, PENNSYLVANIA 17013
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PROOF OF PUBLICATION
State of Pennsylvania,
County of Cumberland.
Sherry Clifford, Classified Ad Manager of THE SENTINEL,
of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of
general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th,
1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice
or publication attached hereto is exactly the same as was printed and published in the regular editions and
issues of THE SENTINEL on the following dates, viz
Copy of Notice of Publication
.----c----c-I~,c,~c---~----~__c__L__
',' NOTICE
In'the CourtofCom"mon Pleas of
CUmberland County, Pennsylvania
. ::: CIvil Action .
". ':"'::\:,:: 2001-563 Civil Te'rm
:..unli~d.MobjJe I:la:mes, Inc., Plaintiff
........ v.'
shawn L. Fitzgerald, Defendant
"lNYOLUNTARY TRANSFER OF
., ,,:,'::..MOTORV~HJClETITLE
. TO:"SI),?i:Wn' L ~itzgera[d, 23 MarlJyn Drive,
. :<"\ . Carlisle, PA 17013 :
NOT1C~"OF HEARING FOR INVOLUNTARY
TflANSFEfI OF MOTOR VEHICLE BY
, ..: COURT ORDER
::":::",Yau,..shawn: L Fitzgerald have been sued in court,
. '..Re,cords of ~h~.:Pennsylvania Department of rransporta-
1_,: .Jlpn lndicate:that you are Ihe owner of a 1983 Conners
..:::,:,:MobH€d10inj::i,,::ntle No, 48710226001 Fr. VIN No.
i:,:.:,:.:CHCANC6tU:411 0021582863. Certified and regular
,::'.,:,:.rriail d1rect~g..t:o you at YOl.!r last known address have re-
i::::::::sl.lJied in t~e'-:r-~tut'n of an correspondence marked
[."::"':~,'MQYed, LeftN,o Address." An action docketed to No.
). :.2Q.td-563 ha:S::.be.en filed in the Court of ComnlOn Pleas
.6fCumberlad~, Coun,ty, Pennsylvania t.o obtain a Court
:Order tr~nsfE!:r:ring title of'the 1983 Conners"Mobrle
':!iame, 1)tl13 ffp. 48710226.001, FI,.VIN No.
J)HCANCeO.r4',11 002158289310 plaintiff. You, Sflawn
'::'.L.:Fltz:gerald,,:ifre hereby notified that a hearing on Plain-
:,:~iff':;; Pet,i.!Joll ,F6r ,Involuntary Transfer Of Ownership .of'
..:Mot6rVefiicle .?y'Cour'forderl1as been scheduh~d for
. ..Monday,..Ma.'l"ch .19,2001 at 9:1'5 a.m. in Courtroom No.
:::::,:':::S:::t\rthe.'Q'Lih.l..~:i:j.rlgl.nd County CourthQl,l$,e, Carlisle,
;'::..:P.ertn'syJvan!<.t;'.Faifure to attend the neai'ing could result
;::' "jrl ~n O,rqer ot,Court declaring -that Plaintiff is the owner
~:":ofthe 1983 COl1ners Mobile Home, TItle No.
. '-48710226.001. Fl, VIN No. CHCANC60 141'1 0021582863.
I.. Michael A, Scherer, E:squire
f:':" O'Brien, Ba_rie & Scherer
17 West South St, Carlisle, PA ,17013
(717) 249-6873
February 16, 23 and March 2, 2001
Affiant further deposes that he is not interested in
the subject matter of the aforesaid notice or
advertisement, and that all allegations in the
foregoing statement as to time, place and character
of publication are true.
Sworn to and subscribed before me this 8th
day of March , 2001.
~~o.~
Notary Public
My commission expires:
, NOTARIAL SEAL
~~~;~Y8~;?:~~~~r7~~dt~~~,liC
M Commission Ex 'res Au . 9, 20~3
Cf
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16,1929), P. 1..1784
STATE OF PENNSYL VANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the 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 regnlarly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Viz
FEBRUARY 23, 2001
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 subj ect
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are
A
RogerM. Morgenthal, Editor
-
SWORN TO AND SUBSCRIBED before me this
23 day of FEBRUARY. 2001
NOTARIAL SEAl'
LOIS E. SNYOfR, Notary PublIc
Carlitl. 1000, COHnboriond-(:Oufny, PA
My Cammitlion Expi... Morch 5, 2001'
:10
;:(i?~
.
"'
",' iIll!i""'"~ w$;('.~^
CUMBERLAND LAW JOURNAL
NOTICE
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Civil Action
2001-563 Civil Term
United Mobile Homes, Inc.,
PlaJntlff
v.
Shawn L. Fitzgerald.
Defendant
INVOLUNTARY TRANSFER OF
MOTOR VEHICLE TITLE
TO: Shawn L. Fitzgerald
23 Marilyn Drive
Carlisle. PA 17013
NOTICE OF HEARING
FOR INVOLUNTARY TRANSFER
OF MOTOR VEHICLE
BY COURT ORDER
You, Shawn L. Fitzgerald have
been sued in court. Records of the
Pennsylvania Department of Trans-
portation indicate that you are the
owner of a 1983 Conners Mobile
Home, 'TItle No. 48710226001 FI,
VIN No. CHCANC60141 100215-
S2863. Certified and regular maJl di-
rected to you at your last known ad-
dress have resulted in the retum of
all correspondence marked "Moved,
Left No Address." An action dock-
eted to No. 2001-563 has been filed
in the Court of Common Pleas of
Cumberland County, Pennsylvania
to obtain a Court Order transfer-
ring title of the 1983 Conners Mo-
bile Home, Title No. 48710226001
FI, VIN No. CHCANC60141100215-
S2863 to PlaJntlff. You, Shawn L.
Fitzgerald, are hereby notifled that a
hearing on Plaintiff's Petition For In-
voluntaIy Transfer Of Ownership of
Motor Vehicle By Court order has
been scheduled for Monday. March
19. 2001 at 9: 15 a.m. in Courtroom
No. 5 of the Cumberland County
Courthouse, Carlisle, Pennsylvania.
Fa1lure to attend the hearing could
result in an Order of Court declar-
ing that Plaintiff is the owner of the
1983 Conners Mobile Home, Title
No. 48710226001 FI. VIN No.
CHCANC60141100215S2863.
MICHAEL A. SCHERER,
ESQUIRE
O'BRIEN, BARIC & SCHERER
17 West South Street
Carlisle. Pennsylvania
17013
(717) 249-6873
Feb. 23
13