HomeMy WebLinkAbout08-6211F:\F[LEMClients\12312 LabeMor\12312. Lpetition\tde
Revised: 10/14/08 2:30PM
10613.4
Katie J. Maxwell, Esquire
I.D. No. 206018
MARTSON LAW OFFICES
10 East High Street
Carlisle, PA 17013
(717) 243-3341
IN RE: : IN THE COURT OF COMMON PLEAS OF
1999 CASE BACKHOE, : CUMBERLAND COUNTY, PENNSYLVANIA
MODEL 580
VIN: JJG0273891 : NO.2008 - (p o? CIVIL TERM
PETITION FOR POSSESSION OF A SEIZED VEHICLE
AND NOW, comes the Petitioner, Shawn M. Liberator, by and through his attorneys,
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, and avers the following:
1. Shawn Liberator bought a 1999 Case backhoe, Model 580, with VIN JJG0273891
in October 2004.
2. This backhoe was stolen on October 17, 2007.
3. Mr. Liberator promptly informed the Pennsylvania State Police of the theft, and an
incident report was filed at Incident No. H02-1646478.
4. The Pennsylvania State Police recovered the backhoe on September 16, 2008.
5. The backhoe currently remains in the impound lot at the Carlisle Barracks of the
Pennsylvania State Police.
6. Trooper Greg McCoombs and Trooper Tim Longenecker are investigating this matter
for the Pennsylvania State Police.
7. Mr. Liberator has not received any insurance proceeds in connection with this case.
WHEREFORE, Mr. Liberator respectfully requests that this Court enter an Order to the
Pennsylvania State Police to relinquish custody of the backhoe to Mr. Liberator.
MARTSON LAW OFFICES
By:?
Katie J. Mjx4ell, Esquire
I.D. No. 206018
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: / oll C/ /,O G Attorneys for Petition
CERTIFICATE OF SERVICE
I, Mary M. Price, an authorized agent for Martson Deardorff Williams & Otto, hereby certify
that a copy of the foregoing Petition was served this date by depositing same in the Post Office at
Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Trooper Timothy Longenecker, PSP
1538 Commerce Avenue
Carlisle, PA 17013
MARTSON LAW OFFICES
C
By ?f , GLe,'
Mar? Price
Ten E t High Street
Carlisle, PA 17013
(717) 243-3341
Dated: /0 /if/at
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OCT 17 2008
IN RE. : IN THE COURT OF COMMON PLEAS OF
1999 CASE BACKHOE, : CUMBERLAND COUNTY, PENNSYLVANIA
MODEL 580
VIN: JJG0273891 :NO. 2008- a CIVIL TERM
ORDER OF COURT
AND NOW, this z ?'' day of October, 2008, upon consideration of the attached
Petition. The Pennsylvania State Police are hereby ordered to release the backhoe with VIN:
JJG0273891 to Shawn M. Liberator.
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