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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 ,. 'a/ XYj Z0:91 8002/b0/ 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 v O C_ c? -rt m 3-3 i f Q n Liz {r., i ' SEP 3 0 ZOU84 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 is? J Q Q 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. c to col CC) u u --s 4 CI ?zj i 4 7 y ?r