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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: