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Home My WebLink About01-06811 ~ PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 7/09/01 PAGE 1 011901796000120 002 OWNER DONNA G KRECHT HCR 1 BOX 343 BARTONSVIllE PA 18321 lESSEE NONE TITLE NUMBER TAG NUMBER VIN 40810733 NO A TITLE DATE 07/11/88 REGISTRATION EXPIRY DATE: BODY TYPE MH ODOMETER READING * *EXEMPT BY FED lAW DUPLICATE TITLE COUNT 0 VEHICLE YEAR 1988 STOLEN DATE 22111178X MAKE MODEL RENEWAL WID PREVIOUS TAG LIENS STOPS HAMPSHIRE TITLE BRAND INFORMATION NO TITLE BRANDS EXIST FOR THIS TITLE lIEN INFORMATION NO lIENS EXIST FOR THIS TITLE pLJ>.INilff'S EXHIBIi 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 '-4~\iI<lW;:r; ~_ ~.=~ ~~__ ~ . - c. " " ~ ~ ANDREW C. SHEELY ATIORNEY AT LAW COP'Y T '['phon" (717) 697,7050 127 South M",k,t Shoot P.O. Box 95 Mechanicsburg, Pennsylvania 17055 Pox, (717) 697,7065 October 25, 2001 Donna G. Krecht HCR 1, Box 343 Bartonsville, PA 18321 RE: 1988 Hampshire Mobile Home Title Number 40810733 VIN 22111178X Dear Ms, Krecht: Please be advised that the above-referenced mobile home has been abandoned for some time and located on the property of my client, Pocono Village Associates, owner of the Pocono Village Mobile Home Park, in Monroe 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 October 31, 2001, formal actions will be taken to obtain title to the mobile home and pursue any and all actions for damages incurred by the abandoned mobile home, Very truly yours, ANDREW C. SHEELY ACS/awm Enclosure c: Pocono Village Associates Certified Mail #7099 3220 0011 0105 7524 - j'~'\;Tii'Bfl"~~1"'( 01" C~ , " r ~ ~ ~~~.~~i' \\ ,~ "'n,~-~I. \~ ~~'<~i~ci~ ~." O,,~, 'Z C :;."'JZ a OJ. """i<,:..'1 :I.'~ ';~1' l>'i,. ::':J:l~iO ~', ....l\':::~ r:' ~ ~~i ~;, ;;'" \;i a~~m~ ::t: 0 I,,! :II 00 ..' m I..! o::tl::tlZ I">' ~....2 0- J> l~~ -"' >< ~ - w::tl ='; -..." -"" roo "" m \--"" - ~ C-.-- mwo ,,' <- ~:' -=-.:. ~~"tIw ~ ::.;-- :::;:"RO =-=-... "" ~= .... .0-IS9~9000 IlE81 0000 .r;~, ~~;~ 1111 ~~ ~r~ I'I~,!~II: .. '"~~;"~ll 1..11 _ '\ "'}'!~\<t 89 ~ ~ ~ " ~--~, =~ il ~~ ....f:'3 I'l"II"I'l c:::a_ ~ .. - ~ t:O :> >- () ,.,z ~"j,.,tI Z' O:d (l()~~ (J', Cd~. ^ I;'):l 0 ~ l..l C::~:>;;" ~~,.,::c w' en I""' m ~ > ~ ;.. ~>< - '" o '" '" "'" o .JJ .JJ UJ ru ru o t::I t::I !,-' !,-' o !,-' o lJ1 "'" lJ1 ru .s= "'\::'~i:s- CO?~ ANDl~EW C. SI.lEELY ATTORNEY AT LAW Telephone; (717) 697,7050 127 South Market Street P.O. B(l)(l)5 Mechanicshurg, PeIUisylv;'lllid 17055 p", (717) 697,7065 December 5, 2001 Donna G, Krecht HCR 1, Box 343 Bartonsville, PA 18321 RE 1988 Hampshire Mobile Home Title Number 40810733 VIN 22111178X Dear Ms, Krecht: Enclosed for service upon you please find a True and Correct Copy of an Order of Court and attached Petition scheduling a hearing for February 4, 2002 in Courtroom No, 4 at the Cumberland County Courthouse in Carlisle, Pennsylvania. The purpose of the hearing is to address the abandoned mobile home registered in your name located in the Pocono Village Mobile Home Park, Should you have questions or desire to avoid having to attend the hearing, please notify me accordingly. If you have an attorney, please have him or her contact me as soon as possible, Thank you for your attention to this matter. Very truly yours, ANDREW C. SHEELY ACS/awm Enclosure c: Pocono Village Associates Certified Mail # 7001 1940 0004 2599 8481 -.;v~_~ ,~," ." ~ "~~ ~'I ~ ~~~ , "_,""n.~..1\l \ ",,,,,~w-,,,,,, " "-" , ~ '<"r--' _ _. is; -g. ~::lCI -'~ am 3 l ~ ~<n'Ani "nce :!l(52);; O:r f. mZ'Am 2:;; ze-Iooz~ ....if: :rJO~C) )>10 rn ,iz fm!'1~ 0 :D !R~a~ c: Zrrl tI) (J)~"'i CI) ~~. " Z-u&7 .~, :;;(b OJ :So >00 JJJJZ .....Z > cn~p _x" rwJJ r4'>>m wo -, ::I: -I '" -.- ;i ~<'>'I"'. t- .. . -- f -- + , -- I - '" -,- 1,"J- I,;.Y r~;r~. ""'S> i!.l. ('v ~<::. U " ~ r- :>-> j ...,z t'< >->>-< ~'"'j.-\"'" ::;0;;:;1;'; (')' z:;; tI.l~t.r'Ir--, t;; 0 >< " C:X:>-~ :-;"''''':r; ""'r<trl ~ ~t"ti :>- :;;t;; >-< " o '-" '-" co ~ :5f;A. ~-t::. too 0i0") 'i'W Oi -,J Cl ru tn ..D ..D Cl> +" Cl> ""' o o o o gg~' , ~& ~ ~ I ~ a . ~I 1- '~,,.lU~i_ ...4*,,,. Lillr"~IDJl!illfl;,.JIL"., ~ ~ ~1mw!1""" ; , o :r: c I" :I' . ~-:J....~;"tJ~ CO"-J('"l::r> CO)OVI~"O ~.' .fIl,~o~ ':=l '-I - '''' '" 1~ IT1 ~,~~~~~='""" No. .......1.Qn.9..8.B..................................Term, 19........ Proof of Publication of Notice in The Pocono Record Under Act No. 587, Approved May 16, 1929 State of Pennsylllania County of Monroe 55: ...,.P.AYl.P....A.~...}~~~.?g.............h.....".....".............".m..An Executive of Pocono Record, of the County and Stale aforesaId. being duly sworn, deposes and says thai THE POCONO RECORD, a newspaper at general circulation published at 51 1 Lenox Sueet, Borough of Stroudsburg, County and State aforesaid, was established April 2, 1894, since which date THE POCONO RECbRO has been regularly Issued in said County, and Ihat the printed notice of publication a!lached hereto is exactly the same as was ptlnled and published in Ihe regular editions and issues of the said THE POCONO RECORD on the following dates, vlz:- ,."DEC...."2JL",.J,A~"..,4.,,... and Ihe""",JJJ::.):L"day of ..... ..".'}'A~":"."",,, ." 19,,,2.002 Affiant further deposes tha! he is duly authorized by the POCONO RECORD. a newspaper of general circulation, 10 verify the foregoing statement under oath, and afftant is not Interested In the subject matter ot the aforesaid notIce or advertisement, and that all atlegatlons tn the foregoIng statements as to time, place and character of p~n f!;;~ufJ ______ "...........~........,.................. ... For The Pocono Record . ""Y~." ., '"'. "". ,haVe'" be€ln'" in court. R8COi'ds of.the P~anla Department af\tans.~ pOrt3.tlon lndlcato that you are the : 'own'er.of a 19.~. Hampshire Mobile.. "Home, 11t[& Number 40810733,-VIN . 2211117SX:-certifl~ mlJIl and regu-', lar mall dIrected to yo~ ~ YO!Jl" last_ knOWlJ.8,ddr€lSS-h,liNEl ~ul1;ed [11 the return .': .of' "'-aU . 'corr&SP9n~en~ marked "Att.empted;' Now Known"; An !1Cl:lon dockatecHo 01.,68" has ~n filed In the Court ot-,Common Plea$"df"',:CuirIb8rland 'Couf'!ly, ,. Penn~ani~to'ob~l,r\,aCouttQ(- ~ :: der: "trriferT.lng titre; Of the" :l9SS Hampshlre'Mobile-' Hct11l!1, rrtle Number'40B107$3, V1N'22-111178X to ::Plttlntlff. You, '. DONNA G. ",', ..,KREc;'t;t;'ai'eherebYhotlfledthata . . heaJ'\ng on Plalntlff's PetitIon f~ In- . ',"Io[ul1ta1Y T~fer of OVJnl3;I'5hlP of. ':. .Mobile Home by Court Order has 'beeri"" . 'edf01''F,E~~4, ,", 2OD2;..8 - - a.m.; In OourtrQom 'Nq. 4 .~rlSnd County ': Cou lisle, ,Pen(lSylvanla. . -..: Faili.i~ "frtteni:l~' ~~I09 could '-resuff {n an Or:der~' Cout:fdecjarlng that "Plafritlff 'l~ 'the 'owner' of _the ::":1'<188 HampShire M1Jb\\& Hon'If)j Utle: ' '.:'Nl.lITiber40'Bl01~ VJN2i1.t11,~.' . t'.'~,~~;7~~'~~<~u~te_~', ..... ...;,:: ::::MechallJdsbu.....;-pA.170~ 'l1i)).q\l~706Qq.. ,.'.' r..~~~~l;t':-::::<":!:::. 4,11' Receipt for Advertising Costs COpy OF NOTICE OR PUBLICATION ---._.''-' ::..-."~'1.,'~'.~'!"._,1~..,"f, -~ . IN THE COURT 'OF COMMON PLEAS OF CUMBE.RLAND COUt-lTY. ", ::': ,":"PENNSYLVANIA 0-1~6811 . ,':'~~IL ACTlON~INVOLUNTAflY ,.-:::'.,,,.:..'....:,rAANS~ER,PF'^OT9R .. .......,,::,.... ","':'''VE,HLCLE'l'ITtt:: ',:X.,:.' BOBEFl;1' EJJoCQD\-lN.C; :',', tnul~~ ~Tngbusi~s .-:.~~~~~~,:.-::,;:.;):,?:, . :OO~~:(,3:_~EC!'IT~~ ~'~" ':':T9:::'~N~~~br:, -P::?;~: ,:~"':,,::, ,..,,'. ':~~~, .... ,"i<''-.:~';:'': . Sworn 10 and subscribed before rnelhis ..".l6j~02""...".'''''m.''7?' daYOf""""JAN.,,,,,,,,,,m,,nm,,',m.'/i1;j' ') ; /..~ My COmmission Expires: .~ 'N~~P~li\'. . C' Notarial Seal Barbara A. Keller, Notary Public Stroudsburg Bore, Monroe County My CommissJon Expires Se~t. 4, 2003 Member, PennsylvanfaAssociation ot Notaries Statement of Advertising Costs .mANDREW,..G..,oo.SJIEELY ..COURToo.oF.oo,COMMONm PLEA .Ro.BERToo..GOOD.LING VS. DONNA KRECHT To POCONO RECORD For publishing the notice or publication attached hereto on the above stated dates .m.....................,............,........ I i I Probating Same.. .......... ..... ... .......,......." ............. ..... ......... .......... ..,...... $,U:U.".\i,Z.... $"00,..7.:,,..90,00, $.18.9..,62".. Total............................................... THE POCONO RECORD. a newspap-er 01 general circulation, hereby acknowledges receipt of the aforesaid notice and publication cost and certifies that the same have been duly paid. The Pocono Record a Newspaper of General Circulation By ..0000''''''00. .",,00'"'' .00". ,. ,,,.... ."oom'...... .OOoom. .....00..... ,"'.00..00..0000 -,,-',,*,,1iW~~,~.....,...1, ~~-' Proof of Publication of Notice in the Monroe Legal Reporter State of Pennsylvania, County of Monroe-ss: Michael R. Muth, Editor of the Monroe Legal Reporter, having been duly sworn according to law, deposes and says that the Monroe Legal Reporter is the official legal newspaper for Monroe County with its place of business at Stroudsburg, Monroe County. The Monroe Legal Reporter was established on May 6, 1938 and has been regularly published and issued in Monroe County since that time. The printed notice attached to this affidavit is exactly the same as was printed and published in the regular editions and issues of the Monroe Legal Reporter on the 11th of January, 2002. I certifY that I am duly authorized to verifY this statement under oath and am not interested in the subject matter of the aforesaid notice or advertisement. All allegations in this affidavit as to time place, and character of publication are true. Copy of Notice or Publication IN THE COURT OF COMMON PLl5A$ Of CUMB,ERLAND COUNTY, PENNSYLVANIA 01-6811 CiVIL ACTION-INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE ROBERT E. GOODL.ING, trading and doing business as POCONO VILLAGE ASSOCIAT!:-S, MONROE LEGAL REPORTER ~h' Edito, VS. DONNA G. KRECHT, TO: DONNA G. KRECHT HCR 1, BOX 343 BARTONSVILlE., PA 18321 rJM{~ TITLE ~v COURT ORDER You, DONNA G. KR CHT. have been sued in court. Record'i of the Pennsylvania Departmant 01 Transportation Indioate that you are the owner 01 a 1988 'Hampshire Mobile Home, Title Number 40810733, VIN 221'1,78X. Certified mail and regu- lar mail directed to you at your last known address have result&d In the return of all correspondence ma~ep "Attempted, Now Known". An action dock. eted to 01.6811 has been filed in the Court of Com- mon Pleas of Cumberland County, pennsrlvanla, to obtain' a Court Order transferring title 0 Ihe 1988 Hampshire Mobile Home. Title Number 40810733, VIN 22111178X to Plaintiff. You, DONNA G. KREC!iT, are hereby notified that a hearing on , Plaintiff's Petition for Involuntary Transfer of Ownership 01 Mobile Home by Court Order has been scheduled lor FEBRUARY 4, 2002, at 9:00 a.m., in Courtroom No, 4 of the Cumberland County Courthouse, Carlisle, Pennsylvania. Failure to attend the hearing could result in an Order 01 Court'declaring that Plaintiff is the owner of the 1988 HampShire Mobile Home, Title Number 40810733,I/IN 22111178X. Andrew C. Sheely, Esquire P.O. Box 95 Mechanicsburg, PA 17055 {711l 697-7050 Attorney for Plaintiff PR . December 28, January 4, 11 Defendant/Respondent .6v Sworn to and subscribed before me h' th d t IS 11 ay of January, 2002 NOTARIAL SEAl. . NNY, NOTARY PUBlIC COUNTY, PA, ION EXPIRES JULY 7, 2005 ,~'" , =~ .U ROBERT E. GOODLING, trading and doing business as POCONO VILLAGE ASSOCIATES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. 01 - ~~II DONNA G. KRECHT Defendant/Respondent CIVIL ACTION - INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE AND NOW, this ,;; ~l4 ORDER OF COUR';t' day Of~, 20eJ/ , upon consideration of the attached petition for Involuntary Transfer of Ownership of a Vehicle by Court Order, 2002, in Court Room No. i it is ORDERED AND DECREED that a '1-64 day of ,/~}L/U/F ' 9:~-v o'clock ~M. hearing on this matter is set for the , at Counsel for Plaintiff is directed to direct Notice of this Hearing to Defendant/Respondent at her 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, Andrew C. Sheely, Esquire Attorney for Plaintiff :7 ftd. J.~ I~J%f( RKs "~~ !"IW~_~~~__~.w;~"'I~~ " _1 -"-- -'-f """'""!" ,~ ~." ,. 'iMifjjl"',:,>;jt!l_"J*~~~J~lili'iUl!*;;;';1t~"!i'''li.~",i;.,_,-L-. ':"',",,",;',i, ~_",,,,'Wj,}.-'i~;"'-{"";~';';'~"->>~~~~"~ . ~"JJ;~_,_." _~,~...,,_~_>_ ,<,< > 3_'_~~'~= "'''''''''''.W~",~", '~" ,....~c ,; .'C-; '<_ ",,,.'..."'''''''~"''' """" _"_~ "'.,~, ~,.,.. .ii.lr.~.iR:~i~$J~jj.l:~f ,~'~ . v~ .., C) c: ~"'" '"rJD'; g,r/; -?;'F-T' (j" ;:$13:: ~::-C ::-ci;" ~Q ::;:;:. '_.J' c- -S <. ~ "" ;"\). ;/:", =<: C) "<::: ,c,,,,,) <::) "'1:> -- -" Iillil9li~lili"jj <::) o 'rj - ~,~ ',,,, r~::n ~ t?/ '-, )::.. :u -< , . , , ROBERT E. GOODLING, trading and doing business as POCONO VILLAGE ASSOCIATES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. 01 - G/~{( DONNA G. KRECHT 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: November~1, 2001 BY Andrew C. Sheely, Es PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff m,Il!I!\W'_~ -. '-~'," "" ~- P,~Q ~,~ ~ =~. ~ ,_1IIIll :- !\aJ~JJ~" > ' ROBERT E. GOODLING, trading and doing business as POCONO VILLAGE ASSOCIATES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. 01 - DONNA G. KRECHT Defendant/Respondent CIVIL ACTION - INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE PLAINTIFF'S PETITION FOR INVOLUNTARY TRANSFER OF OWNERSHIP VEHICLE BY COURT ORDER Robert E. Goodling, trading and doing business as Pocono Village 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 Robert E. Goodling, an adult individual trading and doing business under the duly registered fictitious name of Pocono Village Associates, with an address of 258 West Baltimore Street, Carlisle, Cumberland County, pennsylvania, 17013. 2. Defendant/Respondent Donna G. Krecht is believed to be an adult individual with a last known address of HCR 1, Box 343, Bartonsville, PA 18321. 3. Plaintiff is the owner of a mobile home park known as Pocono Village located in Monroe County, Pennsylvania. 4. For a period in excess of twelve months, a 1988 Hampshire ~- -~--- ': c "'I , " -- ~ ~. , ' Mobile Home, Title Number 40810733, Vin Number 22111178X has been abandoned on Plaintiff's property located in Monroe 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 July 9, 2001, 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 llAll, indicates that the owner of the mobile home is Defendant/Respondent Donna G. Krecht, with a address of HCR 1, Box 343 Bartonsville, Pennsylvania. 8. On or about October 25, 2001, counsel for Plaintiff directed a letter to the address of Defendant/Respondent by certified mail for the purpose of contacting Defendant/Respondent to advise her to remove said mobile home from Plaintiff's premises. A copy of the letter is attached hereto as Exhibit llBll. 9. Subsequently, the October 25, 2001 letter was returned to counsel for Plaintiff indicating that the letter was unclaimed. A copy of the returned envelope and mail charge are attached hereto 2 '-.~~(m[1l~ , - -. """"'1'-- 'r u. ..... ~'~ -,- as Exhibit "C". 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 loss of lot rents, storage costs, delays, other charges while also eliminating safety issues. 11. 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 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, Pocono village 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, Robert E. Goodling, trading as and doing business as Pocono Village 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 3 <\'i'T~'-">"--' "",1;,_'_ .;,,.~,," ~'-~""-,.- .' ""--' J H , - r_", -~ ," ','~'M1~;e, ownership in lieu of a Certificate of Title, provided plaintiff/Petitioner submits all forms, taxes and fees in order to receive the appropriate certificate of title for said mobile home. (3) Any other relief deemed just and equitable. Date: November 27, 2001 Respectfully submitted, ff!J/d~, Attorney for Plaintiff, Robert E. Goodling, trading as and doing business as Pocono village Associates 127 S. Market Street, P.O. Box 95 Mechanicsburg, PA 17055 717-697-7050 4 11 r ,_, ,.. ", ,~ . - " '!I!!lIJIl!!I'. ",""""" ";:~,,,~ ."- -T " EXHIBIT "A" . " ~"- "~ PENNSYLVANIA DEPARTMENT OF T~ANSPORTATION VEHICLE RECORD ABSTRACT 7/09/01 PAGE 1 011901796000120 002 TITLE DATE 07/11/88 REGISTRATION EXPIRY DATE: BODY TYPE MH ODOMETER READING * *EXEMPT BY FED LAW DUPLICATE TITLE COUNT 0 VEHICLE YEAR 1988 STOLEN DATE OWNER DONNA G KRECHT HCR 1 BOX 343 BARTONSVILLE PA 18321 LESSEE NONE TITLE NUMBER TAG NUMBER VIN 40810733 22111178X MAKE MODEL RENEWAL WID PREVIOUS TAG LIENS STOPS HAMPSHIRE NO A TITLE BRAND INFORMATION NO TITLE BRANDS EXIST FOR THIS TITLE 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 '-"~*"!'''?~W.l r ,~ ~ ,~ ~ " " AM TO 9:00 PM) 1-800-932-4600 717-391-6190 1-800-228-0676 717-391-6191 - "",~""",'~o;l"'lk"~J _ ~ -,.., ~," ,.~ EXHIBIT "B" , '1M{<"'" ~~~, r _ ,'''''~ , ANDREW.c. SHEELY ATTORNEY AT LAW C""" OP'Y T elepban" (717) 697,7050 127 South Market Sheeet P.O. Box 95 Mechanicsburg, Pennsylvania 17055 p,,, (717) 697,7065 October 25,2001 Donna G, Krecht HCR 1, Box 343 Bartonsville, PA 18321 RE: 1988 Hampshire Mobile Home Title Number 40810733 VIN 22111178X Dear Ms, Krecht: Please be advised that the above-referenced mobile home has been abandoned for some time and located on the property of my client, Pocono Village Associates, owner of the Pocono Village Mobile Home Park, in Monroe 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 October 31, 2001, formal actions will be taken to obtain title to the mobile home and pursue any and all actions for damages incurred by the abandoned mobile home, Very truly yours, ANDREW C, SHEELY ACS/awm Enclosure c: Pocono Village Associates Certified Mail #7099 3220 0011 0105 7524 -"4;~WHlh,I_" ,~_~"~ _ '~', <o~., ,I"" ~ ' . .. EXHIBIT "e" ""it-'{t"~,~ ,. ,.^- - 'I , .1' - _'I ." c: c ; i:.., ,a t\ "'(')('}_~i ',. ), g,i;;;~~1ft ~r~ Zc-lO ~ ...' .... s: ,:',[J!! . a ~. E; ", "1:~ ~Io, [; o !{i "q; :JI!t' " ;' ,;) C' . ," (TI (I) , .......'>0 g; ~ ~\II:r 0 ~.,. (") 0 o::tl::tlz -I...z ~ l~: ~., -" j:.' .~, ....-.::DNt........ ~&:#t':: =,~ f;a::" T I~I ;J~ 'i .... l/l' (J IV .. ... iii 0...1_ 0\'*, ...~:::~ u C C) I":' - ';;&_":~llJ]I!!fI~!'mI _ ,"r F1!1 oli =- =P! '"'" =- "'CS ... ... .0-IS999000 ll9'[$ INnow~ 10. '9Z DO SSOLI od'~~n8SJIN~HJ3W Ol~d . 3~~lSOd 's'n :' ' ~ t>i :>;.- (") >-3Z tE.,,>-3t1 z. 0" _O~~ ~t,,~::iS OlO><() ex:>;" :::;<>>-3:r: -" '" r t>i - ;>>tTi v '" l'"' :> <;><: :::r ru U'J l'- U'J J:J r'I J:J \ - " o '" '" Postage $ Certified Fee .,J J:J ..ll ..ll W III III J:J J:J J:J 10-' 10-' J:J 10-' J:J In .,J In III "" Return ReceIpt Feel (Endorsement Required) Restricted OaUvery Fee (Endorsement Required) Total Postage & Fees $ Name (Please Print Clearly) (To be completed by mal An~rew C. Sheely, Es lre -st;iie~-A;;i.-N;;:;-(;;.~po"jiox--No:-----_._-_._-~--"-------""U___"'U_'"___~m____~ ---.. 127 S. Market St., PO Box 95 'cjt~~$ii,i;':-ZiP+~4-~----'no_---_._------~-----------------u------..----------------r---- \',\ ,I "'I " " J' "-~ ----- ~ - -~ IZE81 0000 ~:=1.9~ . \,', lI"7" , -.' -~ - - ""'1""'" ,'t \,~ i " -.;:/- ~)f.jc:.r\\\,.. ~ '"" - ~,~~ J";"'Rn~~,~!", '-'- ,~ EXHIBIT "D" , ~h . ,., ~ "''''"''"'''~~~ ~'" May-25-200a 09:41, r-. A e T' 8~ f~ f~ T~ -):~~'W1 "-,", , ,,~ ., . ",. Frcm.OFFICE OF CHIEF COUNCIL H117051122 T-m P,002/00S H60 Involuntary Transfe-r (llf 'Ownership 01: n Vehic:le by COUlrt Order' PURPOSE This Fa~ Sheet outlines the prOCEldures that must be followed when app1lling for a certifica of Title. involving the invCllul~tary transfer of a vehicle's ownerl;~ip. This procedu involves obtaining a (;ourt order and should bllJsed only In those circumst, ncas whlilre it is impossible 1:0 transfer ownership of a vehicle by thl! use, of a Certifica1je of Title or Vehicle Manuf;aet,ur,er Certificate of Origin. Since every ~!!t of facts and surrc!>unding circumstances willloe unique, a person elttemptin!l to be declared owner of;! ve~i ,Ie wh, ere P, roper ownershj~, d',cu,ments are not available: :lhould seek the a,dvice of a 'ate attorney. nlE DEP/Ul:n.ENT WILL NIOT OFFE:R L.EGAl ADVICE REGAR 'ING THE INVOL.UNTARY TI~Jl,NSFER OF OWNERSHIP OF A VEIUCLE:. PROCE~URES 1, A person attempting to obtain ownership of a vehl(:l" must commence a proceeding with II court of o'l1'lpetent jurisdiction se1ti,ng forth the facts; and circumstances ofttll! case. The ownership of the vehicle will be determined by the court. Please note that a sample c:ourt order is provided 011 ~'e reverse llide of this fact sheet UNLESS THE! COMMONWE,lI~lTH OIF: PENNSYLVI\NIA, DEPARTMENT OF TRANSI'OIRTATION IS T~E OWNER: lJF THE VE:HICI.E IN QUESTION, THE COMMO~IWEAlTH OF PENNSYLVANI.l', DEPARTMENT OF TRANSPORTATION IS NOT AN INTERESTED PAFitW TO THIU COURT PROCEEDING. THEREFOIlE, THE COMMONWEALTli IJF PENNSYlVj~NIA, DEPARTMENT OF TRANSf'ORTATION SHOULI) NOT I!IE A NAMED PARTY IN THE PROCEEDING. 2 A person attempting to be d,eclared owner of a vlthiCle b'f court order Inust notify all persons with an interest in the vehicle of the pelOdency of the court proce'Kllng, The notification must be sent by certified mail, retum recoipt requested, and must include the followinsr (1) A specific description of the vehicle (i,e,i'year, make, model ilnd VIN); (2) The court of cOmPl~tE'nt jurisdiction whel'e 'an a(:\ilc,n will be or has been filed; and (3) The time, date and place of any court proceedil'i~ AT A MINIMUM, THE NOTICE MLlST UE SENT TO THIE PER:SCIN(S) TO WHOM TilE VEHICLE IS PRESENTLY TITLED AI.D REGISTERE!D ANti EiVERY LIENHOLDER THAT IS LISTED ON THE TITLI" IRECORD. PLEASE NOTE THAT IF A. PEiI~SON ATTEMPTING TO BE DECLAREIO OWNER OF A VE!HICLE IS UNAWARE OF' ANY PERSON WITH AN INTE!REST II.., THE VEHICLE, TI~E PEFit~;c)N ATTEMP1IIIIG TO OBTAIN OWNERSHIP OF THE VleHIICLE MAY OBTAIN A CEr;:rIFIED COPY OIF THE VEHICLE'S COMPUTER RECORI::l I~Y COMPlETINO FORM DL,-135 (REQUEST FOR VeHICLE INFORMATION), AND nUBftllTTING FORM DL.1351rf) THE DEPARTMENT ALONG WITH THE APPFIOPRIATE FEES. May 1999 . Oller. - ---J . 6u,,"u of Motor Vehicles - Flesearch and SUPPDrt Oper~altj;on!l Section P.O. Bolt 68031, Harrisburg, PA 11'106-80:11 Visit us al our webslte at \\IWW.(~~'le.pa.us (click on Driver al:~~ehICle Servi~ / , . ~ ~ ;:,(i" May-/S-/OOO 09 :4" From-OFFICE OF CHIEF COUNCil Hi170S1122 T-I!9 p,003/a03 F-SSa 3,' In the event the notice sent to a person with iH\ intelrest in the vehid:e is retlJl"r1ed as "Un(:laim'3d;" the person attempting to be declared owner of the vehicle must advertise a l~al notice at I~last oncle in tile county legal journal(s) and atlOllst O~lce per week for three conseoutive weel~s in the newspaper(s) of general circulation whElm any pel1;O'1 known to claim an interEII,t In the vehicle may be I,:x;ated and where the vehicle is 10Cllted, if tllene two locations arle d,ifferent. Please refer to the Pennsylvania Bar Association Lawye~1 Directory & Produoe Guide to determine the appropriate legsll joumal. The advertisement should include the following: ('\) A $pElCific description of the '\1t~hic\e (HI., year, make, model and VI N); (:2) The court of competent jurisdictior! whl9rEl an action will be ()r has been filed; and (:>) The time, date and place of allY court pr()CE,eding. 4, WhEm the above procedure is followed and the COlurt of competent jurisdic;a,:m enters .m order declaring an individual the rightful owner of the vehi('~e, the Department ma~' Is,sue a Certifiesto of Title to the person named in the court (I'rder upo n I'e(:eipt of the following: ('I) A certified copy of the court order ,entered declaring the individual coWller of the VI!hickl; (:1) A notarized statement listing the names 'Ind addresses of all person:s notified and how each notification was served; ('I) A copy of the notification sent to all pel'sclne with an interest in the I/llhicle, including the certified mail return receipts; (4) Copies of newspaper advertisements 21nd dates published; (!i) Form MV-1, "Application for C.srtificate of Title," and ctlecf< elf money clrder payable to the COmmonwealth of Pennsylvan'ia, Unless the petrtioner can claim a Sales Tall: Exemptlorl, sales tall: must be paid on tho Fair Marl<,et Value of the veh~;Ie as listed in a current edition of a Department-approved publi.;alion, Aiporoved Department publlcatiol1ls include the follOWing: N.A.D.A., nre Automot</ls' Red BoOl<, The Black flook Official Used Car Guide, Arnt~ric8n Used Car Guide, and The Kelley BlulI flook Used Car Guide. SAMPLE COUI~" CIRDER AND NOW, this day of , 19 , aftm' 'easonabll! notice and an opportunity for hearing having beem provkjetl1to all interested parties, the Court hereaby awards ownership of one 19 _' [mClke], [model], bearing vehicle IclEmtlflcation l1umber to [name of applicant], and the ri\lht, title and interest of any other person to said vehicle il. hereby extinguished. Thl~ GommonWl~alth of Pennsylvalnia, Department of Transportati()n may accept this order a:. evidence of ownership in lieu of a Certificate of Title, The Petitioner :shall submit the appropriate, forms, itClxes and fl!eS elnd comply with ;!Iny other procedures of the Commonwealth of Pennsylvaniu, Departnnent Of Transportation in order to receive the appropriate CElrtificate of Title for said v,ahiate. BY THE COURT: J ud9'~ --...--.---- ';~j'jll.. "--', """',- -'--,~- ., . ;:""""'''"'''''''" "~"~\"'''-''~ '. %":~;l\.~~ 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. DATE: November ~7, 2001 '.~'" . ~r ~~~~ Robert. . g . ~ ~ - ~, ~.-~~ ""~ - - '"'-T~c.~'~'~~^, ;."_,,c~ .f' "$'-"""-''-'-- - '''''~''-"'-'"~~<-'~''~_Y-''--_,"~,o.:_,"- T""-'-"-"""'''~i~'~~JlJlir--r'''''N~~rurnnr-TI'' :'f't"ffr'i" -'""""~--,'ir~J!S . .:I> (') c.;) ~:;; ~ 0 h ~; ~ ' ~,,~ ~ -r.j1-'''i ~ nlh~t !.' ~} ~ Z:}J '" ~f'J ~ _71 1'<) L'le) ~ ~ v, ~~~ I..J"::- '-~ ~ , C c:\...) , ~ ~ "'\:) ~:;: (-) 50 ~ ~ ~:.... ,"" - >':::=~ ,,:.. ..... f",} .:..~) ~ '-- ~ .c':: 0"1 ~~~ ::< r::; =< It ~"'_,.-" ~_ ,",',..~,_~""'""l"~~~~~j1~~~';'W""i'-'fi',id'i!"~~~"'F"-i'-,";'~"'i#-~%~fffl&'Iffi:I"1t_;'-:!:ijI";~i"'W~F'r"*""'~~-ffji~!!1iJi]~<i ROBERT E. GOODLING, trading and doing business as POCONO VILLAGE ASSOCIATES, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : VS. 01 - 6811 DONNA G. KRECHT, Defendant/Respondent CIVIL ACTION - INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE ORDER OF COURT AND NOW, this 'I' day of February, 2002, after reasonable notice and an opportunity for a hearing having been provided to all interested parties, the Court hereby awards ownership of a 1988 Hampshire Mobile Home, Title Number 40810733, VIN 22111178X, to petitioner, Robert E. GOOdling, 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/Petitidner .,4 ~ J. .~~-&O ~, M.~" _" ,-',1""'" ,1,-, T'''~ , L"!f:1,_~=_"~_.__,.IJt~\,JA1'j~I1M,, ,_ ~- - ~ - '-I-"':'~'-, ~ _, 'o>"~' """" _, ,-,--~,",,_- - _,_::-~,_""., _t'il!,~_,_.,~~,~,.,.,""~"l1!("T"._!Jl~,~11r;~*~"9c,,,!jl'i!l0:4'l.l\'~~\'~~.-: o C ~'t~; 111j~.;~ ~t'~~-: (u.,;- -<>:-- ~8 Pc.: 3 , Cf f"..) -" n, ,,-~,-, 5: V) ii_..) ~ -T! 3~ ~~ _0 -< '0 5 811 ,- -''fT'' C~.:I ,