HomeMy WebLinkAbout08-5747NOE PERALES
Budget Auto Center
Petitioner
IN RE: TITLE TO VEHICLE
VIN 3VWFC81H35M047556
1995 VOLKSWAGEN GOLF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
dy- SIy7
: NO. CIVIL TERM
PETITION TO OBTAIN OWNERSHIP/ TITLE TO VEHICLE
AND NOW, this 29th day of September, 2008, comes the Petitioner, Noe
Perales, (hereinafter "Petitioner") by and through his attorney, Lindsay D. Baird, Esq.,
and files the following Petition to Obtain Ownershiip/Title To Vehicle, and in support
thereof, avers as follows:
1. Petitioner is the manager of a used car lot known as Budget Auto Center,
located at 319 South 3d Street, Lemoyne, Pennsylvania 17043.
2. On or about July 1997, Petitioner purchased the above-referenced vehicle from
PADE Auto Auction.
3. Any records of Budget Auto Center regarding said purchase are no longer
available.
4. PADE Auto Auction is no longer in business and no records can be obtained
from Adesa, Pennsylvania, the previous location of PADE Auto Auction, regarding said
purchase. See Exhibit "A".
5. On or about April 21, 2008, Petitioner contacted the Pennsylvania Department
of Transportation, Bureau of Motor Vehicles, and was informed that all records
regarding the above-referenced vehicle have been purged from its system. See Exhibit
"B„
6. Petitioner has been in continuous possession of the above-referenced vehicle
since July, 1997.
7. The Pennsylvania West Shore Regional Police Department, 510 Herman
Avenue, Lemoyne, Pennsylvania 17043 ran the above-referenced vehicle through its
inquiry system on May 29, 2008 and again on June 9, 2008 with negative results. See
Exhibit "C".
8. Upon information and belief, there is no party to contact to give notice of
Petitioner's intention to obtain title to said vehicle.
WHEREFORE, Petitioner respectfully requests that this Honorable Court order
ownership and title of the vehicle be issued to Budget Auto Center.
Respectfully submitted,
indsay D. B
Attorney ID No. 72083
37 South Hanover Street
Carlisle, PA 17013
(717) 243-5732
Attorney for Petitioner
further questions,
'lion, are no longer available
he Vehicle Identification
do Center, Inc, is
Mr. Perales with any
ADESA PENNSYLVANIA
PO BOX 41, YORK, PA 17408
717.266-6611 (PHONE) 717.266.7650 (FAQ
1995 VW Golf
To whom it may concern:
The data records from our previous owners,
for us to research the sale of the above refer
Number, as provided to me from Mr. N P
4X. TC81MSM047556. Atthistime
ation regarding the title to this
too/too e Ex A
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
SAFETY ADMINISTRATION
HARRISBURG, PA 17123
5/06/06
NOE C PERAIES
319 S THIRD ST
LEMOYNE PA 17043-0000
Deer Cumtomur:
081291338000047 001
The Bureau of Motor Vehicles has received your request for information.
We are not able to provide this information because the record you requested,
as indicated below, does not exist in our files.
VIN : 3VWFC81H3SM047556
If you have any questions concerning this information, please contact
Vehicle Record Services at the address or telephone number listed below.
Sincerely,
Customer Servioe Team
bureau of Motor Vehicles
ADDRESS CORRESPONDENCE TO:
Department of Transportation
Vehicle Record Services
PO Box 68691
Harrisburg, PA 17106-6691
INFORMATION: (8:00 AM TO 6:00 PM)
IN STATE 1-800-932-4600
OUT-OF-STATE 717-412-5300
TOO IN STATE 1-600-228-0676
TOO OUT-OF-STATE 717-412-5380
MWM.dot.state.pa.us
L001900 e Ck 1,8 ,.
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HOWARD E. DOUGHERTY
OI?icl of Police
WEST SHORE REGIONAL POLICE DEPARTMENT
510 HERMAN AVENUE • LEMOYNE, PA 17043 a (717) 737.9161 • FAX (717) 975-2794
June 10, 2008
Noe Perales
Budget Auto Center
319 S 3rd Street
Lemoyne PA 17043
Dear Mr. Perales:
On May 29*, 2008 you contacted the West Shore Regional Police Department
to have a vehicle that has been on your lot for 11 years to see if It was ever
reported stolen.
The vehicle in question is a 95 Volkswagen Gulf having a vehicle
identification number 3VWFC81 H3SM047b58 and a title #5080342. This vehicle
was run by the West Shore Regional Police Department thru NCIC JNET CLEAN on
5/29/08 and also on June 9, 2008 with the results being negative.
If you have any questions pertaining to this matter, please contact this office.
Sincerely,
West Shore Regional Police Department
Melissa J. Konyar
Administrative Assistant
cc: File
zoolvooz Cx "G "
C7507700 2MV07701 VEHICLE INQUIRY DETAIL BY VIN PDT06059 5/16/08
OWNER 0 Lessee: 000 Ckdt: Carrier: ARP: Fit:
Title: 50603423 0 Tag: GVW:
Tl Seq: 00 Exp Dt: GCWT:
T1 Dt: Rg Fee: .00 Unl Wt:
T1 Dup: Axle Tx. .00 Axles:
Non Pa Ti: Prv Rn: GVWR:
Reg Dups: GCWR.
VOLK Make: VOLKSWAGEN Tag Tp: AWR:
Model: P Tag:
LESSEE 1 Year: 95 Tag Color Code:
Body: Reg Pro:
VIN: 3VWFC81H3SM047556 PURGED RECORD
Dealer : Class: 00
Junk: Unclaimed: Equip No:
A/C: Stolen veh Dt:
Van: Stolen Tag Dt:
Purged Date: 03/12/ 05
Renew WID: 00000 0000 000000 000 ESt. WID; 00000 0000 000000 000
Stops:
?1-IMINFO 22-DETAIL2
16-NOTEPAD 18-LIENINFO 19-WIDHIST
L00/900@
15-RETURN
Xdj Z0:91 8002/b0/8
Verification
I, Lindsay D. Baird, hereby verify that the facts contained within this Petition are
true and correct to the best of my knowledge, information and belief and are made
pursuant to 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities.
dsay D. Bair
Attorney for Petitioner
Noe Perales, Budget Auto Center
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NOE PERALES : IN THE COURT OF COMMON PLEAS OF
Budget Auto Center : CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner
CIVIL ACTION - LAW
' jam- 577
IN RE: TITLE TO VEHICLE NO. CIVIL TERM
VIN 3VWFC81H35M047556
1995 VOLKSWAGEN GOLF
ORDER OF COURT
AND NOW, this day of October, 2008, upon consideration of the within
Petition, a hearing in the matter is scheduled for the &0( day of JQ4&e ?
2008 at
o'clock in Courtroom of the Cumberland County
Courthouse in Carlisle, Pennsylvania. Notice of the hearing shall be made to all
interested parties.
By the Court,
`1
Cc: ZLindsay D. Baird, Esquire
Court Administrator
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NOE PERALES
Budget Auto Center
Petitioner
IN RE: TITLE TO VEHICLE
VIN 3VWFC81H35M047556
1995 VOLKSWAGEN GOLF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. BS'' S7 YICIVIL TERM
ORDER OF COURT
AND NOW, this 3 cei day of wew.- , 2008, after reasonable notice and an
opportunity for hearing having been provided to all interested parties, the Court hereby
awards title and ownership of one 1995 Volkswagen Golf, bearing vehicle identification
number 3VWFC81H35M047556 to Budget Auto Center, 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 shad 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.
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