HomeMy WebLinkAbout03-2776 SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High $1reet
Carlisle, PA
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: PETITION OF
GREGORY R. WANTLAND
CIVIL ACTION
No. of 2003
PETITION FOR
INVOLUNTARY TRANSFER
OF OWNERSHIP OF A
VEHICLE
Filed on behalf of:
Gregory R. Wantland
Counsel for Petitioner
Kirk S. Sohonage, Esquire
Attorney I.D. #77851
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
Phone: 717.243.6222
SAIDIS
SHUFF, FLOWER
& LINDSAY
26W. High Street
Carlisle, PA
IN RE:
PETITION OF GREGORY R.
WANTLAND,
PETITIONER
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION
: No. ,~ ?7~of 2003
PETITION FOR INVOLUNTARY TRANSFER OF OWNERSHIP OF A VEHICLE
AND NOW, this ~3 day of June, 2003 comes the Petitioner, GREGORY R.
WANTLAND, by and through his counsel, SAIDIS, SHUFF, FLOWER & LINDSAY, and
Kirk S. Sohonage, Esquire, and files this Petition for Involuntary Transfer of Ownership of a
Vehicle and in support thereof avers the following:
l. The Petitioner is Gregory R. Wantland, whose address is 201 Stetler Road, New
Cumberland, Cumberland County, Pennsylvania.
2. That in May 2002, the Petitioner obtained an abandoned 1970-1971 MG Midget
bearing Identification Number GAN5UB91853G.
3. At the time Petitioner obtained the aforementioned vehicle it had been abandoned
in a field for a number of years, and no Certificate of Title could be located. The
Petitioner did note what appeared to be a Pennsylvania inspection sticker from the
early 1980s; however, after numerous contacts with the Commonwealth of
Pennsylvania Department of Transportation (Penn DOT), the Petitioner learned
that Penn DOT could not trace a vehicle using such inspection information.
4. The Petitioner has unsuccessfully attempted to obtain a Certificate of Title from
Perm DOT for the aforementioned vehicle.
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
5. The Petitioner has unsuccessfully attempted to identify to whom the
aforementioned MG Midget was ever titled and no vehicle record abstract exists
with Penn DOT for the aforementioned vehicle.
6. The Petitioner has made numerous attempts to locate any previous owner of the
aforementioned vehicle without success, including placing an advertisement in the
Patriot News Newspaper, which ad appeared two consecutive days on April 1st
and April 2nd' 2003. Please see a copy of proof of publication, which is attached
hereto and marked as Exhibit "1".
7. The present value of the aforementioned vehicle, which is currently disassembled
and inoperable, is approximately One Hundred ($100.00) Dollars.
8. If the vehicle were totally refurbished and in decent condition its value would be
approximately Four Thousand ($4,000.00) Dollars.
WHEREFORE, the Petitioner, GREGORY R. WANTLAND, pursuant to 75 PA
C.S.A. § 1114, asks this Honorable Court to transfer to him ownership of the aforementioned
1970-1971 MG Midget bearing Identification Number GANSUB91853G in order that he
may obtain a Certificate of Title from Penn DOT for such vehicle.
AND HE WILL EVER PRAY ...
Date:
Respectfully submitted,
SAIDIS SHUFF FLOWER & LINDSAY
Kirk' ~.. ~ohonage, Esquire
Attorney I.D. #77851
Saidis, Shuff, Flower & Lindsay
26 West High Street
Carlisle, PA 17013
Phone: 717.243.6222
THE PATRIOT NEWS
THESUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst.
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 Sunday 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 Mamh 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 daily and/or Sunday/ Metro editions which appeared on the 1st and 2nd day(s) of April 2003. That
neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that ali 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 County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
My Commission Expires J u~e 6, 2006
Member, Pennsylvania AssOCiation Of Notates
NO4ARY ~UBLIC
My commission expires June 6, 2006
GREGORY R. WANTLAND
201STETLER ROAD
NEW CUMBERLAND, PA.
17070
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
$ 55.16
$ 1.75
$ 56.91
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News. newspapers of general
simulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
IN RE: PETITION OF
GREGORY R. WANTLAND,
Petitioner
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
:
:
:CIVIL ACTION
:
: No. OF 2003
VERIFIC.~TION
I verify that the statements made in the foregoing PETITION FOR INVOLUNTARY
TRANSFER OF OWNERSHIP OF A VEHICLE are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom
falsification to authorities.
SAIDIS
SHUFF, FLOWER
& LINDSAY
26W. High Street
Carlisle, PA
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
IN RE: PETITION OF
GREGORY R. WANTLAND,
PETITIONER
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
: CIV1L ACTION
: No. OF 2003- 277G
ORDER
AND NOW, this / 7 ' day of (ftn,,.. ,2003, after reasonable
notice, the Court hereby awards ownership of a 1970-1971 MG Midget bearing
Identification Number GANSUB91853G to GREGORY R. WANTLAND, and the right,
title and interest of any other person to said vehicle is extinguished. Pursuant to 75 PA
C.S.A., §1114, 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.
ATTEST:
Prothonotary
BY THE COURT: