HomeMy WebLinkAbout10-2969Supreme Could of Pennsylvania
Cou Com Pleas
CUMBER ) R? County
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For Prothonotary Use Only:
Docket No:
/a- JAO
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required bylaw or rules of court.
Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARYCASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort)
? Intentional
? Malicious Prosecution
? Motor Vehicle
? Nuisance
? Premises Liability
? Product Liability (does not include
mass tort)
? Slander/Libel/ Defamation
? Other:
CONTRACT (do not include Judgments)
? Buyer Plaintiff
? Debt Collection: Credit Card
? Debt Collection: Other
? Employment Dispute:
Discrimination
? Employment Dispute: Other
Other:
Transfer of ownership for unpaid debt
CIVIL APPEALS
Administrative Agencies
? Board of Assessment
? Board of Elections
? Dept. of Transportation
? Zoning Board
? Statutory Appeal: Other
Judicial Appeals
? MDJ - Landlord/Tenant
? MDJ - Money Judgment
? Other:
B
Commencement of Action:
? Complaint ? Writ of Summons Q Petition ? Notice of Appeal
? Transfer from Another Jurisdiction ? Declaration of Taking
Lead Plaintiff's Name: Lead Defendant's Name:
Gretna G. Bear Ronald J. Lattemer, Jr.
? Check here if you are a Self-Represented (Pro Se) Litigant
Name of Plaintiff/Appellant's Attorney: Lindsay D. Baird
Are money damages requested? : ?Yes 19 No Dollar Amount Requested: within arbitration limits
(Check one) outside arbitration limits
is this a Class Action Suit? ? Yes 0 No
REAL PROPERTY
? Ejectment
? Eminent Domain/Condemnation
? Ground Rent
? Landlord/Tenant Dispute
? Mortgage Foreclosure
? Partition
? Quiet Title
? Other:
Pa.RC.P. 205.5
MISCELLANEOUS
? Common Law/Statutory Arbitration
? Declaratory Judgment
? Mandamus
? Non-Domestic Relations
Restraining Order
? Quo Warranto
? Replevin
? Other:
212010
NOTICE
Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part:
Rule 205.5. Cover Sheet
(a)(1) This rule shall apply to all actions governed by the rules of civil procedure except
the following:
(i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq.
(ii) actions for support, Rules 1910.1 et seq.
(iii) actions for custody, partial custody and visitation of minor children, Rules
1915.1 et seq.
(iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq.
(v) actions in domestic relations generally, including paternity actions, Rules
1930.1 et seq.
(vi) voluntary mediation in custody actions, Rules 1940.1 et seq.
(2) At the commencement of any action, the party initiating the action shall complete
the cover sheet set forth in subdivision (e) and file it with the prothonotary.
(b) The prothonotary shall not accept a filing commencing an action without a
completed cover sheet.
(c) The prothonotary shall assist a party appearing pro se in the completion of the form.
(d) A judicial district which has implemented an electronic filing system pursuant to
Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the
provisions of this rule.
(e) The Court Administrator of Pennsylvania, in conjunction with the Civil Procedural
Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be
published on the website of the Administrative Office of Pennsylvania Courts at www.pacourts.us.
GRETNA G. BEAR
Petitioner
RONALD J. LATTERNER, JR.
Respondent
IN RE: TITLE TO VEHICLE
VIN 9T02M193502
1969 MUSTANG, MACH 1
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
NO. CIVIL TERM
PETITION TO OBTAIN OWNERSHIP OF VEHICLE-
-77
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AND NOW, this th day of May, 2010, comes the Petitioner, Gre a C- a
Bear, (hereinafter "Petitioner' and throw h her attorney, Lindsay D. Baird,<Esq.?nd- ) Y g
files the following Petition to Obtain Ownership Of Vehicle, and in support thereof,
avers as follows:
1. Petitioner lives at 115 Mill Road, Mt. Holly Springs, Pennsylvania.
2. In February 1997, husband of Petitioner entered into an agreement with
Respondent, Ronald J. Latterner, Jr., to store the shell of a 1969 Mustang Mach 1 vehicle
in Petitioner's garage at 115 Mill Road, Mt. Holly Springs, PA for the monthly rent of
$40.00. Petitioner's husband died February 24, 2007. Petitioner cannot locate copy of
Agreement.
3. The vehicle shell does not have an engine, transmission, drive train, seats, nor
registration plate. The vehicle shell does have the original Vehicle Identification
Number.
4. Pursuant to the 1997 Agreement, Respondent made storage/ rental payments
through February, 2000, after which no payments were made.
5. Petitioner sent Respondent a registered letter dated March 6, 2004, demanding
all due payments and requiring that the vehicle shell be removed from her garage
immediately. The wife of Respondent signed for the letter, but Respondent did not
answer. Copy of letter and USPS signature card attached as Exhibit A.
,Q4 I Yl `f5-
6. Petitioner retained above counsel who sent a letter by regular U.S. mail to
Respondent dated November 12, 2009. The letter was not returned to sender.
Respondent did not answer this letter. Copy of letter attached as Exhibit B.
5. Counsel sent a letter by certified, return receipt mail to Respondent on
December 2, 2009. The letter was refused. Copy attached as Exhibit C.
6. The Pennsylvania Department of Transportation was contacted on January 19,
2010, requesting title history and a current record on the vehicle with VIN number
9T02M193502. A response was received stating that no record is available due to
records associated with the vehicle being over 10 years old. Attached as Exhibit D
7. The Pennsylvania Department of Transportation was contacted on March 12,
2010 in an effort to determine if the shell of a vehicle as described in paragraph 3 above
would be exempt from the rules and regulations of the Motor Vehicle code. The
Department of Transportation referred Counsel to the "Disposal of Abandoned
Vehicles From Private Property" Fact Sheet. Attached as Exhibit E.
8. Respondent has been provided ample opportunity to claim and remove the
vehicle shell he stored in Petitioner's garage, and has failed to do so for a period in
excess of 10 years. Petitioner is owed $4,640, and it appears that Respondent has no
intention of paying this debt.
WHEREFORE, Petitioner respectfully requests that this Honorable Court order
ownership of the vehicle to Petitioner so that she may dispose of the property as she
may choose.
Respectfully submitted,
Gndsay D. B 'r , Esq ire
Attorney ID No. 72083
37 South Hanover Street
Carlisle, PA 17013
(717) 243-5732
Attorney for Petitioner
I verify that to the best of my knowledge and belief, the statements in the foregoing
document are true and correct. I understand that false statements herein are made subject to
the penalties of 18 PaCS §4904 relating to unsworn falsification to authorities.
nx J',
Gretna G. Bear, Petitioner
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PS Form 3811, August 2001 DOM,e.s
LINDSAY DARE BAIRD
ATTORNEY AT Law
37 SOUTH HANOVER
CARLISLE, PENNSYLVANIA 17013-3307
TEL. (717) 243-5732
Mr. Ronald Latterner
115 Hickory Drive
Manchester, PA 17345
Dear Mr. Latterner:
FAX (717) 243-8110
November 12, 2009
My offices have been retained by Mrs. Gretna Bear concerning the Mustang automobile
shell currently stored in Mrs. Bear's garage at 115 Mill Road, Mt. Holly Springs,
Pennsylvania.
In 1997, you entered into an agreement with Mrs. Bear to store the automobile shell in
her garage for a monthly rent of forty ($40) dollars. You provided the monthly rent until
approximately September of 2000, after which you have failed to make any further
payment.
In accordance with the agreement, you are currently in arrears in the amount of
$4,360.00.
There are three possible courses of action at this time.
1. You provide Mrs. Bear a cashier's check ( mailed or delivered to this office) in
the amount of $4,360 and remove the shell from her garage, or,
2. You provide these offices the title to the automobile, properly signed and
notarized, with a sales price of $1.00, showing Gretna G. Bear as the purchaser, or,
3. My offices will file with the Commonwealth Court of Common Pleas for
ownership of the shell as payment for unpaid rents due. You will be charged court and
attorney fees for this action.
Please contact my office (717-243-5732), not later than December 15, 2009 to advise
me as to which of the above courses of action you wish to pursue.
Very truly yours,
ndsay D. Bad, squire
cc Gretna G. Bear
EXHIBIT"B"
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
SAFETY ADMINISTRATION
HARRISBURG, PA 17123
2/01/10 10:52
LINDSAY D BAIRD
37 S HANOVER ST
CARLISLE PA 17013-0000
Dear Customer:
100320752000099 001
The Bureau of Motor Vehicles has received your request for information.
We are not able to provide this information because the information you
requested does not exist in our files. The Bureau of Motor Vehicles, Record
Retrieval Unit, can only provide microfilm copies of records dating back ten
years.
If you have any questions concerning this information, please contact
Vehicle Record Services at the address or telephone number listed below.
Sincerely,
EXHIBIT "D"
Customer Service Team
Bureau of Motor Vehicles
ADDRESS CORRESPONDENCE TO: INFORMATION: (8:00 AM TO 6:00 PM)
Department of Transportation IN STATE 1-800-932-4600
Vehicle Record Services OUT-OF-STATE 717-412-5300
PO Box 68691 TDD IN STATE 1-800-228-0676
Harrisburg, PA 17106-8691 TDD OUT-OF-STATE 717-412-5380
www.dot.state.pa.us
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
VEHICLE RECORD ABSTRACT
2/01/10 10:52
PAGE 1
100320752000099 001
OWNER RONALD J LATTERNER JR LESSEE NONE
51 MILL ST
MT HOLLY SPGS PA 17065
TITLE NUMBER : 41868779
TAG NUMBER : VBF850
VIN : 9T02M193502
MAKE FORD
MODEL
RENEWAL WID :.901031711000107 001
PREVIOUS TAG
LIENS NO
STOPS NO
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
TITLE DATE : 05/30/89
REGISTRATION EXPIRY DATE: 04/91
BODY TYPE CP
ODOMETER READING 80,963*
*ACTUAL MILEAGE
DUPLICATE TITLE COUNT 1
VEHICLE YEAR 1969
STOLEN DATE
INFORMATION: (8:00 AM TO 6:00 PM)
IN STATE 1-800-932-4600
OUT-OF-STATE 717-412-5300
TOD IN STATE 1-800-228-0676
TDD OUT-OF-STATE 717-412-5380
WWW.DOT.STATE.PA.US
5ec C3) L-,- S?'rar? v-?L-9e.
FACT SHEET 1i
DISPOSAL OF ABANDONED VEHICLES FROM
PRIVATE PROPERTY
This Fact Sheet provides information on disposing of vehicles which have been left on private property.
ABANDONMENT.• Abandonment involves an intention to abandon together with an act or omission to act by which
such intention is carried into effect. "Abandoned property" is that to which an owner has relinquished all rights, title,
claim and possession, with no intention of reclaiming it or resuming ownership or possession.
ABANDONED VEHICLE: Section 102 of the Vehicle Code defines an abandoned vehicle in the following manner:
(1) A vehicle (other than a pedalcycle) shall be presumed to be abandoned under any of the following circumstances,
but the presumption is rebuttable by a preponderance of the evidence:
(i) The vehicle is physically inoperable and is left unattended on a highway or other public property for
more than 48 hours.
( ii) The vehicle has remained illegally on a highway or other public property for a period of more than 48
hours.
( iii) The vehicle is left unattended on or along a highway or other public property for more than 48 hours
and does not bear all the following:
(A) A valid registration plate.
(I3) A current certificate of inspection.
(C) An ascertainable vehicle identification number,
( iv) The vehicle has remained on private property without the consent of the owner or person in control of
the property for more than 24 hours.
(2) Vehicles and equipment used or to be used in construction or in the operation or maintenance of highways or
public utility facilities, which are left in a manner which does not interfere with the normal movement of traffic, shall
not be considered to be abandoned.
PRIVATE PARKING LOT: A parking lot open to the public or used for parking without charge; or a parking lot used
for parking with charge. (Section 3353(b) of the Vehicle Code).
SALVOR: A person engaged in the business of acquiring abandoned vehicles for the purpose of taking apart,
recycling, selling, rebuilding, or exchanging the vehicles or parts thereof. (Section 102 of the Vehicle Code).
WAREHOUSEMAN: A person engaged in the business of storing goods for hire. (As defined in the Uniform
Commercial Code U.C.C.).
October 2006
- over -
Bureau of Motor Vehicles - Research and Support Operations Section
P.O. Box 68031 Harrisburg, PA 17106-8031
Visit us at www.dmv.state.pa.us
EXHIBIT "E"
METHODS OF DISPOSING OF ABANDONED VEHICLES FROM PRIVATE PROPERTY
The following methods do not apply to private parking lots unless such lots are posted to notify the public of any parking
restrictions and the operator/owner of the vehicle violates such posted restriction.
(1) Pursuant to Sections 3352(c) and 3353(c) of the Vehicle Code, the landowner may request a police department
to declare the vehicle to be abandoned and to require a salvor to take possession of the vehicle.
(2) The landowner may personally remove the vehicle from his or her private property to a place of storage pursuant
to Section 3353(c) of the Vehicle Code and may bring an action before a District Justice to recover the costs of
removal and storage. The landowner must provide the vehicle owner reasonable notice of any action initiated
before the District Justice. Once judgment is entered on behalf of the landowner and reasonable notice is provided
to the vehicle owner, the vehicle may be sold at a Sheriff's sale in execution of the judgment.
-'? (3) The landowner may file suit in Common Pleas Court requesting that an order be entered that (1) awards ownership
of the subject vehicle to the landowner and, (2) extinguishes the right, title and interest of any other person to said
vehicle. Pursuant to Sections 1114(a) and 1116(b) of the Vehicle Code, the Department would be able to accept
such a court order as evidence of ownership in lieu of a certificate of title. In order for the applicant to obtain a
certificate of title, a certified copy of the court order must accompany a completed MV-1 form, along with taxes,
fees, and evidence satisfactory to the Department that reasonable notice of the court proceeding had been
provided to the vehicle owner, and any other interested party, including anyone whose lien is endorsed upon the
certificate of title for the vehicle according to the records of the Department. (NOTE: A sample court order is printed
below.)
A landowner may not repossess an automobile for the costs of storing the vehicle upon the landowner's private property
unless the landowner is a bona fide warehouseman as provided by the Uniform Commercial Code, 13 P.S. Section 7102,
et seq. A lien or bill incurred for repairs to a vehicle can be collected only by filing a complaint, obtaining judgment against
the owner and having the vehicle sold at a Sheriff's sale to satisfy the judgment. Notice of the proceeding must be provided
to any person who has a lien endorsed upon the certificate of title for the vehicle according to the records of the
Department.
SAMPLE COURT ORDER
AND NOW, this day of , 20 , after reasonable notice
and an opportunity for hearing having been provided to all interested parties,
the Court hereby awards ownership of one 20 , [make], [model], bearing
vehicle identification number
to [name of applicant], and the right, title and interest of any other person to said
vehicle is hereby extinguished. The Department of Transportation may accept this
order as evidence of ownership in lieu of a certificate of title. The Petitioner shall
submit the appropriate forms, taxes and fees and comply with any other procedures
of the Department of Transportation in order to receive the appropriate certificate
of title for said vehicle.
BY THE COURT:
, Judge
GRETNA G. BEAR : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
RONALD J. LATTERNER, JR. C-, '
-
Respondent
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IN RE: TITLE TO VEHICLE NO. 10-2969 CIVIL TERM m om-,
VIN 9T02M193502
1969 MUSTANG ; ?? rn a?
c' t c'
MOTION FOR FINAL JUDGEMENT
AND NOW comes Gretna Bear by and through her attorney Lindsay D. Baird, Esquire,
and avers as follows:
1. Plaintiff filed a "Petition To Obtain Ownership of a Vehicle" on May 4, 2010.
2. A hearing was held on June 17, 2010, at which Defendant appeared by
telephone.
3. Defendant stated that he was involved in a bankruptcy proceeding and This
Honorable Court granted a continuance until the bankruptcy could be investigated.
4. Plaintiff was able to determine that there was a bankruptcy proceeding at
Docket 10700387.
5. Plaintiff sent a retainer to Michael Pykosh, Esquire, to follow through with
filing with the Bankruptcy Court a Relief from the Automatic Stay.
6. Attorney Pykosh has determined that Defendant's case was dismissed on
October 7, 2010. (Copy of Attorney Pykosh's letter and Court Order are attached as
Exhibit A.
7. In that it is now evident that the Bankruptcy Court has no possible claim on
the vehicle at issue, Plaintiff seeks the original relief requested.
WHEREFORE Plaintiff respectfully requests this Honorable Court grant her
petition by signing the attached order. In the alternative, Plaintiff requests a hearing be
held to finalize the matter.
Respectfully submitted,
Lindsay D. Bait d, ;Esqu'
I verify that to the best of my knowledge and belief, the statements in the foregoing
document are true and correct. I understand that false statements herein are made subject to the
penalties of 18 PaCS §4904 relating to unworn falsification to authorities.
r
dsay D. Baird, Es uire
IDETHLEFS-PYKOSH LAW GROUP, LLC
Darrell C. Dethlefs* Of Counsel
Michael J. Pykosh* 2132 Market Street Robert J. DeSousa
Bryan W. Shook Camp Hill, PA 17011 Leeal Staff
Melanie L. Erb Phone: (717) 975-9446 Sherry L. Deckman*
Heather N. Orisko Toll Free: (800) 287- 1202 Danielle Winn
John R.Logan** Fax: (717) 975-2309 Susan Disbrow
Patrick D. Ivkovich E-mail: ddethlefs@aol.com Kaitlin Stiles
Paul D. Daggs www.dpiglaw.com Alicia Hoffman
David C. Dagle *Licensed PA Title Agents
Trudy A. Marietta Mintz*** **Admitted to the NJ Bar
Charles Thomas ***Admitted to MD Bar
Matthew J. Monahan
December 1, 2010
Lindsey Dare Baird, Esquire
37 S. Hanover Street
Carlisle, PA 17013
Re: Bear v Latterner
Dear Lindsey:
Thank you for referring the above-referenced matter to my attention. In
researching this matter for purposes of doing a Relief from the Automatic Stay, I found
that Mr. and Mrs. Latterner's case had been dismissed on October 7, 2010. 1 am
providing you with a copy of the Order dismissing the case as well as the original Motion
filed by the Chapter 13 Trustee. Since the case has been dismissed and has not been re-
filed, I do not believe that it is necessary to move forward with Relief from the Automatic
Stay. Therefore, I am forwarding the escrow check for $750.00 to your attention. My
office will not charge for the work we did on the matter.
VIcel /ykosh
M MJP/drw
Enclosure
204 N. George Street
York, PA 17401
P.O. Box 368
Camp Hill, PA 17001-0368
P.O. Box 213
Lancaster, PA 17608-0213
4*1
The Dethlefs-Pykosh Law Group, LLC - "Your Full Service Law Firm " A Debt Relief Agency
Order Dismissing Case (Form ordscs) (04/10)
UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF PENNSYLVANIA
In re: Debtor(s) (name(s) used by the debtor(s) in the last S years, including married, maiden, and trade):
Ronald J Lattemer Jr.
Kim M Lattemer
Chapter
13
Debtor(s)
Charles J. DeHart, III (Trustee)
Movant
vs.
Ronald J Lattemer Jr.
Kim M Lattemer
Respondent(s)
Case No
ORDER DISMISSING CASE
1:07-bk-00387-MDF
Upon consideration of the Trustee's Motion to dismiss case and it having been determined after notice and
opportunity for hearing, that the case should be dismissed, it is
ORDERED that the above-named case of the debtor(s) be and is hereby dismissed.
Dated: October 7, 2010
By the Court, yn
United States Bankruptcy Judge
Case 1:07-bk-00387-MDF Doc 106 Filed 10/07/10 Entered 10/07/10 13:24:24
Order Dismiccinn r,--
UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE: RONALD J & KIM M LATTERNER JR
Debtor(s)
Charles J. DeHart, III
Chapter 13 Trustee
vs Movant(s)
CHAPTER 13
CASE NO: 10700387
RONALD J & KIM M LATTERNER JR
Respondent(s)
TRUSTEE'S MOTION TO DISMISS CASE
COMES NOW /08/
Cha ter 13 NOW, on 09 10, Charles DeHart,
P Trustee for the Middle District of IPe Standing
this Honorable Court for dismissal of the Pennsylvania
, moves
above- case in accordance with Section 307( ) captioned Chapter 13
due to material default by the debtor(s) with respect to the terms
of
Notice of conference and other instructions are included
Motion. NOTICE OF YOUR DISMISSAL HEARING WILL BE SENT FR
OFFICE, with this
OM THE CLERK'S
WHEREFORE, your Trustee prays that s an Order dismissing the above-captionedhcaseoinraccoCourt enter
11 U.S.C. Sec. 1307(c). accordance with
RESPECTFULLY SUBMITTED,
/s/ Charles J. DeHart, III
Charles J. DeHart
III, Trustee
Case 1:07-bk-00387-MDF Doc 102 Filed 09/08/10
PaaP 1 of Q Entered 09/08/10 19:03-1-q
n?? .
DEC202010 3
GRETNA G. BEAR : IN THE COURT OF COMMON PLEAS OF
Petitioner : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
RONALD J. LATTERNER, JR.
Respondent
IN RE: TITLE TO VEHICLE NO. 10-2969 CIVIL TERM
VIN 9T02M193502
1969 MUSTANG
ORDER OF COURT
AND NOW, this day of , 2010, after reasonable notice and
an opportunity for hearing having been provided to all interested parties, the Court
hereby awards title and ownership of one 1969 Mustang, Mach 1, bearing vehicle
identification number 9T02M193502to Gretna G. Bear, 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 shall 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.
B Court,
D Baird Esquire
cc. ?T-c y ?Ronald J. Latterner, Jr.
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