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Home My WebLink About10-2249EVELYN N. KILLIAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10 - )21q CIVIL TERM V. . N PNC BANK, N.A., Successor by V CIVIL ACTION 7'i? _°2 a ' -?-3 Merger to NATIONAL CITY INVOLUNTARY TRANSFER BANK, MOTOR VEHICLE TITLE rc Defendant .': ;- -T i NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the pleadings and Notice are served, filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the pleadings or for any other claim of relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 vl?'?-J- ;Z,-." Robert G. Frey, Esquire Supreme Court ID No. 46397 Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Tel. No. 717-243-5838 Attorney for Plaintiff 9a.oC? d-?r crC ? 9G s/ R 2-3`l 913 EVELYN N. KILLIAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. No. 10 - CIVIL TERM PNC BANK, N.A., Successor by Merger to NATIONAL CITY BANK, Defendant : CIVIL ACTION INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE PLAINTIFF'S PETITION FOR INVOLUNTARY TRANSFER OF OWNERSHIP OF VEHICLE BY ORDER OF COURT EVELYN N. KILLIAN, by and through her counsel of record, ROBERT G. FREY, Esquire, hereby petition your Honorable Court for involuntary transfer of ownership of a manufactured home by Order of Court in accordance with the requirements of law and respectfully represent, as follows: 1. Plaintiff, EVELYN N. KILLIAN, is an adult individual who resides at 35 Big Spring Terrace, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant, PNC BANK, N.A. is a banking corporation having its principal offices at PNC Financial Services, USX Tower, 600 Grant St., Mailstop P6-PUSX-36-1, Pittsburgh, PA 15219, and having regional offices at 2101 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011. Plaintiffs Petition for Involuntary Transfer Of ownership of Vehicle by Order of Court Page I of 7 3. On November 2, 2004, Plaintiff and her mother, ESTHER M. STONE, jointly purchased from Saundra K. Clugh, formerly known as Saundra K. Miller, a 1990 Fleetwood Gleneagle mobile home, VIN: PAFLL22AO1406GE. 4. Plaintiff believes and therefore avers that the mobile home was financed with National City when it was previously purchased in 1996 by a person by the name of Harold Liddick, Jr. Defendant is the successor by merger of National City which merged with Defendant on or about December 31, 2008. 5. Record ownership of the mobile home is indicated by a Pennsylvania Department of Transportation vehicle record abstract, a copy of which is attached hereto as Exhibit "A." 6. The Pennsylvania Department of Transportation vehicle record abstract indicates that the mobile home was repossessed from the said Harold Liddick, Jr. by National City and acquired by National City. 7. After unknown series of poorly documented or undocumented assignments or other transactions, evidently through varies bank mergers, the mobile home was purchased by Saundra K. Miller on February 4, 1998. Plaintiffs Petition for Involuntary Transfer Of ownership of Vehicle by Order of Court Page 2 of 7 8. After extensive investigation including inquiries to Saundra K. Miller, now Saundra K. Clugh, Plaintiff has no idea as to the identity of the seller to Saundra K. Miller. 9. Plaintiff believes and therefore avers that, when Saundra K. Miller purchased the mobile home on February 4, 1998, she financed the transaction with Onbank & Trust Company whose office address was P.O. Box 5218, Syracuse, New York. 10. Plaintiff believes, and therefore avers that when Saundra K. Miller purchased the mobile home on February 4, 1998, she gave a security interest in the mobile home to Onbank & Trust Company whose office address was P.O. Box 5218, Syracuse, New York. 11. Plaintiff believes and therefore avers that after the purchase of the mobile home by Saundra K. Miller, Onbank Trust Company merged operations with Manufacturers & Traders Trust Company, sometimes referred to as M & T Bank, on or about April 1, 1998. 12. Plaintiff believes and therefore avers that the Onbank & Trust Company loan of Saundra K. Clugh that was secured by the mobile home became the Manufacturers & Traders Trust Company loan number 82724940001. Plaintiff's Petition for Involuntary Transfer Of ownership of Vehicle by Order of Court Page 3 of 7 13. When Plaintiff and her mother purchased the mobile home from Saundra K. Clugh, they paid off the Manufacturers & Traders Trust Company loan number 82724940001 in the amount of $9,392.64. 14. In the cover letter with the loan payoff to Manufacturers & Traders Trust Company, counsel for Plaintiff and her mother stated: "It is critically important that your office forward the title with the release of lien to this office." 15. The only response that Plaintiff received from Manufacturers & Traders Trust Company was a statement that it called a lien release. 16. When Manufacturers & Traders Trust Company sent the lien release, it also sent a check payable to PennDOT which was indicated as being for a "DUP TITLE FEE." 17. When counsel for Plaintiff and her mother requested the title from Manufacturers & Traders Trust Company, he was told by representatives of Manufacturers & Traders Trust Company that it could not find a title. Plaintiff's Petition for Involuntary Transfer Of ownership of Vehicle by Order of Court Page 4 of 7 18. The letter from counsel for Plaintiff and her mother that covered the loan payoff to Manufacturers & Traders Trust Company identified the Manufacturers & Traders Trust Company loan number, but it did not identify the VIN of the mobile home. 19. The lien release from Manufacturers & Traders Trust Company identified the VIN of the mobile home confirming that Manufacturers & Traders Trust Company had the title information prior to the payoff of the loan to Saundra K. Clugh. 20. Although Manufacturers & Traders Trust Company kept Plaintiffs money, it never provided Plaintiff with a title to the mobile home in spite of repeated demands therefor. 21. After extensive, difficult investigation, Plaintiff obtained the attached Pennsylvania Department of Transportation vehicle record abstract which indicated that title to the mobile home is still registered in the name of NATIONAL CITY. 22. By letter of August 10, 2005, a copy of which is attached hereto as Exhibit "B" and incorporated herein by reference as though fully set forth, Plaintiff asked NATIONAL CITY to review its records and provide any possible assistance to enable Plaintiff to have the title transferred into the names of Plaintiff and her mother. Plaintiffs Petition for Involuntary Transfer Of ownership of Vehicle by Order of Court Page 5 of 7 23. Plaintiff never -received any response from Defendant. 24. On the basis of the foregoing facts, Plaintiff avers that the mobile home has been abandoned by the record title holder. 25. Plaintiff has invested substantial funds in the mobile home and will be seriously prejudiced in the event that she is unable to sell the mobile home in the future for lack of title. 26. Plaintiffs mother, Esther A Stone, died on December 8, 2009, thereby vesting ownership in the mobile home solely in Plaintiff as the surviving joint owner. 27. Saundra K. Clugh has assigned all of her claims with regard to the mobile home to Plaintiff. A copy of the assignment is attached hereto as Exhibit "C" and incorporated herein by reference as though fully set forth. WHEREFORE, Plaintiff respectfully requests that your Honorable Court issue an Order scheduling a hearing on this Petition and requiring counsel for Plaintiff to provide notice of hearing to Defendant at its last known address by certified United States mail, return receipt requested, restricted delivery, and by regular mail and further requiring that, if such notice is unclaimed, notice of the hearing be advertised one per week for three weeks in the County Legal Journal and in a newspaper of general circulation where any person known to claim an Plaintiffs Petition for Involuntary Transfer Of ownership of Vehicle by Order of Court Page 6 of 7 interest in the vehicle may be located and where the vehicle is located if those two locations are different in accordance with the requirements of the Pennsylvania Department ol4ansportation and that, after such hearing, an Order be entered indicating that the Commonwealth of Pennsylvania, Department of Transportation, may accept the Order as evidence of ownership in lieu of a Certificate of Title, provided that Plaintiff submits all forms, taxes and fee in order to receive the appropriate Certificate of Title. Respectfully Submitted, Robert G. Frey, Esquire Supreme Court ID #46397 v Frey and Tiley 5 South Hanover Street Carlisle, PA 17013 Telephone: 717-243-5838 Attorney for Plaintiff VERIFICATION 1, Evelyn N. Killian, depose and say that I am the Petitioner in the above matter; and that the facts set forth in the foregoing Plaintiff's Petition for Involuntary Transfer of Ownership of Vehicle by Order of Court are true and correct based partly upon personal knowledge and the remainder upon information and believe; I under that this Verification is made subject to penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Evelyn N. Killian Plaintiffs Petition for Involuntary Transfer Of ownership of Vehicle by Order of Court Page 7 of 7 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION SAFETY ADMINISTRATION HARRISBURG, PA 17123 4/14/06 WAYNE F SHADE ESQ 53 W POMFRET SDDT CARLISLE PA 17013-0000 CERTIFICATE A ATTESTATION 061040716000147 001 I hereby certify that Kurt J. Myers, Director of the Bureau of Motor Vehicles of the Department of Transportation, is the legal custodian of the Motor Vehicle Records of the Pennsylvania Department of Transportation. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL OF THIS DEPARTMENT ON THE ABOVE DATE IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA. Consolidated Statutes. - A4&, SECRETARY OF TRANSPORTATION I hereby attest that the documents attached hereto for the vehicle listed below are full, true, and correct photostatic and/or microfilm copies of which I have legal custody, and that the copies conform to the requirements of Section 6109 of the Judicial Code. TITLE: 44677514 VIN : PAFLL22AO1406GE CERTIFIED IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA. Consolidated Statutes. KURT J. MYERS, DIRECTOR BUREAU OF MOTOR VEHICLES R PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 4/14/06 PAGE 1 061040716000147 001 OWNER NATIONAL CITY 6750 MILLER RD P 0 BOX 94982 CLEVELAND OH 44101 TITLE NUMBER 44677514 TAG NUMBER VIN PAFLL22AO1406GE MAKE FLEETWOOD MODEL RENEWAL WID PREVIOUS TAG LIENS NO STOPS NO LESSEE : NONE TITLE DATE : 12/13/91 REGISTRATION EXPIRY DATE: BODY TYPE MH ODOMETER READING *EXEMPT BY FED LAW DUPLICATE TITLE COUNT 0 VEHICLE YEAR 1990 STOLEN DATE TITLE BRAND INFORMATION NO TITLE BRANDS EXIST FOR THIS TITLE ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-8691 INFORMATION: (8:00 AM TO 6:00 PM) IN STATE 1-800-932-4600 OUT-OF-STATE 717-412-5300 TDD IN STATE 1-800-228-0676 TDD OUT-OF-STATE 717-412-5380 WWW.DOT.STATE.PA.US , CEIUMATE 039222 gA/???•)??p ' 18".17'3 MtrNCIPAL OFFICE AT t .?Utf . ODES K WY CERTIFY TWIT THE FDLWln DESCRrom H" VEHICLE WAS SUZ O AN SOLD ACCORDING TO LAM TO THE Mqt WER NAIIfO KL0V.* DESC1t max OF anCLE am d vAc e?' * rBEET-(,tlpp? ADMtESS !0 7 SD / Z e. X I?DEL r 4 K 7 Loc. ?iia ?'[a??.hl „? 9 9yz WA'S No. 41:1C aA,rytlAl t MI?IIESS THE DUE E7tE MCR HEREOF TNis__ /=OAr pF ? Iyq (Bank By z 9ne ure, (Corporate Seal) -- IMF" RION FIONWITI LtaeKk ? wwvwi hl P241 3i V-Aza? -a A rte' i ?? d1?S Z p'y7-es MU !•IU1I Ma ?M?tnwlrNa??M??~ ?M: ?.?rrMlfa?NarM? u0 MM?yAO?r rrrlw?Mw?w ? i 0 Bm"OdOi-V Mt i M. ???A?r I . p"r?""MS" O eoD Irkham"So . aw" 7 f l •_ r . ?IAwMM?I na N ? 1'5 r off a ti 96 r-M P. Uhl t6nj . SEBRITE CORPORATION 039222 mpmlr mom. souLDAMi wXt W i M.N?Oh M11K l&wSw.vwlww 'SIG' T9.!/r1w4 Nuf 44?.4m ca NUMOF Alp WA CMIMM[i ow Pm!Um HWWLNO* eafteph"To"m fyrMAK PA 177 1 A WAN 11,1!47 AOomm • l1Mo4ti m You a1s adristd rwrt wa IIM nPo eoIslwal des=W bsiow Wwh we w? AIhIKk?O fbr yoli'ttle oe?l{ la.bwlq Itsld h M01apo ac fii??l fii? ? ? 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I" of OM l?Fbeew? ?t??TERAu rrpaaesssion...... frrisfl PA[sl.L AfitlMNOfif of *" of AoCltwd deflnquuleir ?.... i 1M? 144'R p? p?Np; YIEJIf><: 1N0 E1?penssr d nmilUl4 Cal mo ... iJIMtlMwn ? Ipra d I powr o CaN?U I I .. llnimt f mp one WW ehar0ee ..... ? OrMr Aar W kUwe . ........ fitsilwlee few .... ............ v" Mr1hr pUM. AMrftf" "PAW hr*WIy J Pagafro SNwib Colpal Jinn COMPOPATr of ANWA 1TIMS 11itO WJTw hWr IM I wilt 1111 1 1"a" Pf MN "401"T CERTDMTE OF N=GER 039222 hop Pow B? F Smm BI=W in ank, ? FhV NWWW to w o KcjsW= Bank Md)awdl Beak La dmak Saves Aaaodatiak and Equbnk waa mvarted to a aatioad bank charter under the acme of Nuional City Bank of Pamsylvama as May 31, 1996. Nadoaal City Bank of Pe ms* ma does hereby certify the authority. Power and Priv qm by way of oonversion to scH a actor vehicle. WMMS my hand this f A day of (?l) 2 srl1?_ 199 . NATIONAL CITY BANK OF PENNSYLVANIA D--- PAN iM. a ?r.ww. ??r G?iden Exc4ra Mc 1{, tlOa 1 f, a a 1 S S WAYNE F. SHADE ATTORNEY AT LAW 53 WEST POMFRET STREET CARLISLE, PENNSYLVANIA 17013 (717) 243-0220 (800) 243-0220 FAX (717) 249-0017 August 10, 2005 National City Bank Attention: 01-7103 6750 Miller Road Cleveland, Ohio 44141 Re: Type: Mobile Home Year: 1990 Manufacturer's Name: Fleetwood Model Name: Gleneagle VIN: PAFLL22AO1406GE Greetings: This office represents Esther M. Stone and Evelyn N. Killian. On November 2, 2004, they purchased the above mobile home. As part of the transaction, we paid off a loan to M&T Bank on November 2, 2,004, and requested returnof the title for the mobile home. By letter of November 15, 2004, we received a release of the M&T encumbrance with a letter from M&T Bank stating that it did not have the title to the mobile home. We understand from the Pennsylvania Bureau of Motor Vehicles that the title to this mobile home is registered in the name of National City Bank, 6750 Miller Road, Cleveland, Ohio 44141. It would be appreciated if you would review your records and provide us with any assistance that you can to enable us to have the title transferred into the names of the present owners. Very truly yours, w Wayne F. Shade WFS/cjt cc: Ms. Esther M. Stone Ms. Evelyn N. Killian WAYNE F. SHADE ATTORNEY AT LAW 53 WEST POMFRET STREET CARLISLE, PENNSYLVANIA 17013 (717) 243-0220 (800) 243-0220 FAX (717) 249-0017 November 29, 2005 Ms. Saundra K. Clugh 149 North Bedford Street Carlisle, Pennsylvania 17013 Re: Clugh to Stone and Killian Dear Ms. Clugh: As indicated in our telephone conversation yesterday, we have made every effort to obtain a title for the mobile home in the above matter without filing a lawsuit against the bank. Unfortunately, we have had no success. It appears that there are two banks involved, and they simply ignore our requests. Therefore, we have no alternative after more than a year but to file suit against the banks. Because you were the seller of the mobile home, it was actually your responsibility to make sure that the buyers received a title when they gave you the money. Accordingly, it would really be up to you to file suit against the banks to obtain a title that you could, in turn, transfer to Ms. Stone and Ms. Killian. However, Ms. Stone and Ms. Killian would be willing to have this office undertake the necessary litigation to attempt to obtain a title in their names, but you would need to assign your rights against the banks to Ms. Stone and Ms. Killian in order to give them full standing to proceed against the banks. This is because the banks do not owe any direct duties to Ms. Stone and Ms. Killian. They only owe direct duties to you as the borrower in the transaction in which the banks held your title. If it is necessary for us to file suit against the banks, it is possible that Ms. Stone and Ms. Killian could receive some monetary compensation for the trouble that we will have been put through. If you are satisfied to assign your claims against the banks to Esther M. Stone and Evelyn N. Killian, please simply endorse this letter below and return it in the enclosed self-addressed envelope. A copy of the letter is enclosed for your records. w Wayne F. Shade, Esquire, to Ms. Saundra K. Clugh November 29, 2005 Page 2 Should you have any questions in any respect, please do not hesitate to call. Very truly yours, Wayne F. Shade WFS/cjt Enclosures cc: Ms. Esther M. Stone Ms. Evelyn N. Killian Endorsed this day of r( Saundra K. Clugh EVELYN N. KILLIAN, Plaintiff vs. PNC BANK, N.A., Successor by Merger to National City Bank Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 10-2249 CIVIL TERM CIVIL ACTION INVOLUNTARY TRANSFER OF MOTOR VEHICLE TITLE PRAECIPE TO REINSTATE COMPLAINT To: The Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania Please reinstate the Complaint filed in the above-captioned action. Frey & Tiley, Attorneys for Plaintiff Dated: w ~ ~~ 2-° i ~ By: Robert G. Frey, Esquire Attorney for Plaintiff Supreme Court Number 46397 5 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243-5838 C ~~ -~, , m,~~~', ~~,. r--.: ~ ~:. ~ ,~ C:, =r~ to --t ttl ~/D.O~ ~.s~~ ~ ~~4s, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILEf~ ~~ { Imo`. Sheriff (}~'+ '(' (,~ ~g~y1S4x Ot ~{{INbCjy~~~, ~~ ~r~ 1-f ~l, J f 1 ~ ~~"~T~ / Jody S Smith , Chief Deputy ~' "-;~ ~ ~ Z~ ~ ~ ~~~ -$ ~~ ~~ 48 ,+~} .t~ ..,~TF. QFFI~.E iN.~. '~k¢R'F~v.T,iJi.. tL1-j'~+J~ T-ii~JL11Y1 J PEN~t~Y~.V.~'V;A Evelyn N. Killian Case Number vs. PNC Financial Services 2010-2249 SHERIFF'S RETURN OF SERVICE 05/13/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: PNC Financial Services, but was unable to locate then in his bailiwick. He therefore deputized the Sheriff of Allegheny County, PA to serve the within Complaint and Notice according to law. 05/21/2010 Allegheny County Return: And now May 21, 2010 at 0955 hours I, William Mullen, Sheriff of Allegheny County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: PNC Financial Services by making known unto Tom Combs, Financial Sales Accountant for PNC Financial Services at USX Tower, 600 Grant Street Ground Floor, Pittsburgh, PA 15219 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.44 June 07, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF jc7 CountySuito Shenft, 7eieosutT. Inc. In The Court of Common Pleas of Cumberland County, Pennsylvania Evelyn N. Killian vs. PNC Financial Services USX Tower 600 Grant Street Ground Floor Pittsburgh, PA 15219 Civil No. 2010-2249 Now, May 13, 2010, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Allegheny County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~ of Cumberland County, PA Affidavit of Service Now, 5 - c~ 1 , 20 ~ ~ , at a'~S o'clock (a M, served the within upon_ at by handing to ~a ~~ CGri,~s ~ '~~c~.~ ~c1~~ ~c_r_c;~ ~~~. ~-,~ a copy of the original and made known to the contents thereof. So answers, Sheriff of County, P COSTS Sworn and subscribed before SERVICE $ me this day of ,20_ MILEAGE AFFIDAVIT EVELYN N. KILLIAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff . No. 10 - 2249 CIVIL TERM V. PNC BANK, N.A., Successor by CIVIL ACTION Merger to NATIONAL CITY INVOLUNTARY TRANSFER OF BANK, MOTOR VEHICLE TITLE Defendant ORDER OF COURT ~d. AND NOW, this ~~ day of t.Q , 2010, upon consideration of the within Petition for Involunta Transfer of Ownership of Vehicle by Order of Court, it is hereby ordered and decreed that a hearing is scheduled for -~ ,the ~o? ~" day of , 2010, in Courtroom No. ~ at (~3U o'clock ~.M., prevailing time. Counsel for Plaintiff is directed to provide notice of the hearing to Joel B. Gold, general counsel for the Defendant at its last known address by certified United States mail, return receipt requested, restricted delivery, and by regular mail and further require that, if such notice is unclaimed, notice of the hearing be advertised once per week for three consecutive weeks in the County Legal Journal and in a newspaper of general circulation where any person known to claim an interest in the vehicle may be located and where the vehicle is located if those two locations are different in accordance with the requirements of the Pennsylvania Department of Transportation and that, after such hearing, an Order be entered indicating that the Commonwealth of Pennsylvania, Department of Transportation, may accept the Order as evidence of ownership in lieu of a Certificate of Title, provided that Plaintiff submit all forms, taxes and fees in order to receive the appropriate Certificate of Title. ~- cv ~7 ~=~ c= .~ _ ~r G~' ~ ~ N ~-.~ --, ~`_ ,.-_ ._ ~.. J - ~~ ~'Q,s .n a l l~ c .,}~ 2-~ ~~~ J ~Y ~~ ~~~~1lt0 BY THE COURT, --~ J. EVELYN N. KILLIAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff No. 10 - 2249 CIVIL TERM V. PNC BANK, N.A., Successor by CIVIL ACTION Merger to NATIONAL CITY INVOLUNTARY TRANSFER OF BANK, MOTOR VEHICLE TITLE Defendant ORDER OF COURT AND NOW, this day of July, 2010, upon consideration of the within Petition for Involuntary Transfer of Ownership of Vehicle by Order of Court, and upon hearing held thereon, it is hereby ordered and decreed that Evelyn N. Killian is hereby found to be the owner of a 1990 Fleetwood Gleneagle mobile home having a vehicle identification number of PAFLL22A01406GE. The Commonwealth of Pennsylvania, Department of Transportation, may accept this Order as evidence of ownership in lieu of a Certificate of Title, provided that Plaintiff submit all forms, taxes and fees in order to receive the appropriate Certificate of Title. BY THE COURT, C~ alb de(~vP~ Rabe~t G- FrY ~S y ~ h n~'~'~ S Sa ~ t h l~~ /a/~ r' Sr• d K~ C a /' ~,• S / -C Pq /70/3 ON~e Pa1C ~Pla zu. 2.~9 F~'ffh A/~tiJ~ p•'ttsa~~~-h pry isaaa-a~a~ ~~' ~! ~~~d z! i,Ir 0lOZ Ali{ _ ~;~-;- ,.~-~!~?l~~ Pig ~p~ ,~a:l~d 7/ia/i~