HomeMy WebLinkAbout09-3531JACOB O'HARA,
Petitioner
vs.
PENNSYLVANIA STATE POLICE,:
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
CIVIL ACTION
MISCELLANEOUS DOCKET
NO. S'`3 I G `c u ? 'f 4'K
PETITION FOR RETURN OF MOTOR VEHICLE
AND NOW, Jacob O'Hara by and thru Gan Law Group respectfully requests this
Honorable Court order the return of Petitioners Motor Vehicle form the Pennsylvania State
Police (Carlisle Barracks) and in support thereof, avers as follows:
1. On or about January 28, 2009, Petitioner purchased a certain 1991 Honda Civic
Hatchback from Justin Barclay.
2. That Petitioner traded a truck for this vehicle and this was confirmed with the
State Police by Barclay.
3. That on or about March 11, 2019, Pennsylvania State Police (in conjunction with
Carlisle Police Department) conducted an investigation regarding stolen car parts.
4. In pursuit of this investigation, Petitioner was interrogated for approximately 45
minutes at 414 Glenn Avenue, Boiling Springs, where he resides.
5. That during the course of this interrogation, Trooper Tallman of the Carlisle State
Police Post observed that Petitioners vehicle was missing the VIN dash plate.
O'Hara, final petition for return of motor vehicle
6. That as a result of his observation, Petitioner was advised this was potentially a
criminal offense.
7. Petitioner was asked if he had any objection to his car being search, to which he
expressed that he did not.
8. Petitioner was advised that the State Police wanted to conduct a complete search
and to do so the vehicle would have to be towed and impounded.
9. Again, Petitioner consented and cooperated fully with PSP (Carlisle Barracks)
and specifically Trooper Tallman.
10. A complete inventory search of the vehicle was conducted with no adverse
findings or criminal charges resulting.
11. This has been confirmed with Cumberland County Assistant District Attorney
Michelle Filbert who has no objection to the return of the vehicle.
12. Petitioner sought return of the vehicle.
13. Petitioner was advised by Trooper Tallman that PSP would need a court order for
return of his vehicle.
14. Petitioner was further advised he would have to obtain a substitute VIN dash
r
plate, insurance and pay tow charges incurred in transport of the vehicle to
impound.
15. A copy of Petitioners registration, proof of insurance and substitute VIN plate are
marked exhibits A-C and appended hereto.
16. A copy of the paid tow bill is also appended hereto and marked exhibit D.
O'Hara, final petition for return of motor vehicle
WHEREFORE, Petitioner respectfully requests this Honorable Court enter an
Order requiring Pennsylvania State Police return a 1991 Honda Civic Hatchback
bearing VIN 2HGED6353MH553880 to him, forthwith.
Respectfully Submitted,
GAN LAW GROUP
Richard R. Gan
Attorney ID 68721
64 South Pitt Street
Carlisle, Pennsylvania 17013
717-241-4300
O'Hara, final petition for return of motor vehicle
VERIFICATION
I, JACOB O'HARA, hereby certify that the facts set forth in the foregoing PETITION FOR
RETURN OF MOTOR VEHICLE are true and correct to the best of my knowledge, information
and belief, I understand that false statements herein are made subject to the penalties of 18 Pa.
C.S.A. §4904 relating to unworn falsification to authorities.
te-elm
COB O'HARA
Date:
Document #: 163765.1
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JACOB W. O'HARA
414 GLENN AVE
BOILING SPRINGS PA 17007
Play it Safe! --
Policy Number
PA00600036A-00
IMPORTANT NOTICE Regarding your Financial Responsibility Insurance Identification Card.
The Safe Auto Insurance Company is required by Pennsylvania law to send you an I. D. card. The card shows that an insurance policy
has been issued for the vehicle(s) described satisfying the financial responsibility requirements of the law.
If you lose the card, contact your insurance company or agent for a replacement.
The I. D. card information may be used for vehicle registration'anb replacing license plates. If your liability insurance policy is not in
effect, the I. D. card is no longer valid: - -
You are required to maintain financial responsibility on your vehicle. It is against Pennsylvania law to use the I. D. card fraudulently such
as using the card as proof of financial responsibility after the insurance policy is terminated.
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JACOB O'HARA, IN THE COURT OF COMMON PLEAS
Petitioner CUMBERLAND COUNTY PENNSYLVANIA
VS. CIVIL ACTION
MISCELLANEOUS DOCKET
3 5 ( C r,,:` I ?L?M
PENNSYLVANIA STATE POLICE,. NO. 3
Respondent
ORDER
AFTER REVIEW of the attached Petition and the Court being otherwise fully advised in the
Premises, IT IS ORDERED THAT Pennsylvania State Police shall return a certain 1991 Honda
Civic Hatchback bearing VIN number 2HGED6353MH553880 to Petitioner Jacob O'Hara,
forthwith.
IT
HONORABLE
Dated:
Document #: 205730.1
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