HomeMy WebLinkAbout04-3563 ERNEST BEECHER
ONE 1989 FORD F-150 TRUCK
VIN: 1FTEF14N1KNB82104:
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
PETITION FOR TRANSFER OF OWNERSHIP OF VEHICLE
IN THE COURT OF COMMON PLEAS
OF CUMBERL,~ND ~OUNTY, PENN.
AND NOW, comes Ernest Beecher, by and through his attorney Gregory Barton Abeln,
who petitions for transfer of a motor vehicle and respectfully aw:rs as follows:
1. On July 30, 1999, The Commonwealth of Virginia issued title ora 1989 Ford F-150
pickup, Vehicle Identification No. 1FTEF14N1KNB82104, to Charles Reynolds of Gore,
VA. (Exhibit 1).
2. On June 28, 2002 Mr. Reynolds sold the vehicle to Hagerstown Ford, 1714 Massey
Blvd., Hagerstown, MD. (Exhibit 1).
3. On July 30, 2002, Hagerstown Ford sold the vehicle to Mike's Auto and Truck, 5100
Buchanan Trail East, Waynesboro, PA (Exhibit 2), Mike's Auto and Truck did not apply
for a Pennsylvania title for the vehicle.
4. On August 1, 2002 Mike's Auto and Truck sold the vehicle to Mr. Gregory myers of
Myers Auto Sales, 1203 Ritner Highway, Shippensburg, PA (Exhibit 2). Myers did not
apply for a Pennsylvania title for the vehicle.
5. On August 13, 2002, Myers Auto Sales sold the vehicle to Petitioner, Mr. Ernest
Beecher, 10 Beecher Drive, Carlisle, PA. (Exhibit 3). Mr Myers gave a temporary title
to Mr. Beecher, pending Mr. Myers application for Mr. Beecher's permanent title.
6. Mr. Myers did not file for a Pennsylvania title until October 28, 2002, but Pennsylvania
Department of Transportation claims never to have received Myers' title application.
7. Myers Auto Sales went out of business on or about November 2002, without having
received Mr. Beecher's title for the vehicle, and at the expiration of the temporary title,
Mr. Beecher was in possession of the vehicle without legal title and without a way of
obtaining title through normal title process.
8. Mr. Myers, the last legal owner of the vehicle, agrees with the above stated facts and
makes no claim of ownership to the vehicle.
WHEREFORE, Ernest Beecher, by and through his attorney, Gregory Barton Abeln,
Esquire, requests this Court to award ownership and the right, title and interest.
Respectfully submi~ted,
ABELN LAW OFFICESt~
Gregory Barton Abeln, Esquire
37 E. Pomfret Street:
Carlisle, PA 17013
Dhte [ --
717/245-2851
CERTIFICATE OF TITLE
T~ 0~;~T~;;~ Or uOrO~ v;~ KEEP IN SA_ .FE... PLACE - ANY ALTERATION OR ERASURE VOIDS THI~ 'rrtl r: '~
~-'L~S. CC.~,U~,~ v~ , RE VOIDS THIS TITLE ~
~'~'~ :" M^.S 638 6
............. L.%~89 FORD PZ Ck~3P 56212482
............... .2_ ....... GAS
240.00 *5~B* a
=.-. ~.= ~.. ...... _o3 ./.~_o _/..~..%
............ AC-~AL 56100026
R-EYNOLDS, CHA/~ES W,AND
R~YI~OLDS, SH~.WN -~*a--O-I~, OP. SLrRV
Lp O BOX 183
GORE~ VA 22637-0183
09~1S/2005 15:14 717-530-0680 SHIPPENSBURG A A PAC~5 83
RECE]VED TIME SEP. 16. 2:57PM, PRZNT TIME SEP. 16. 3:00PM
on
~ ~ C~ ~ ~EROFm~YI~UED~ m~L~O ~ 10.
NOTE: If a co-purc.aser other.than your spouse is listed .nd you ~nt the title ,o be listed as 'Joint. Tenants With
Right of Survivorship' (On death of one owner, title goes to surviving owner.) CHECK HERE ~, Qtherwise, the title
will be issued as 'Tenants in Common' (On death of one owne~, interest of deceased owner goes to his/he~ heirs o~
estate).
Ho
~w~~'' ~gist~s, ;X, aase con~a:~ Fm~00T ~ JMESSENGER NUMBER:
3. APPLJCANT'S COPY/TEMPORARY REG/~ON (VALID FOR 90 DAYS) I
MAI( OF VEI'IICL~ ~EHICk~ IDENlqFICATION NUMBER (VIN), IF TRACING BODY TYPIC[ (SON, T~ MOOEL YEAR
EQU O TAP $ RELY TO R
NOTE: It a ~r o~er th~ your spou~ ~ ~is~ ~ you
A SIGN IN PRESENCE OF NOTARY MESSENGER
CABOD7-05911 - NLETS
,RR.VADMVRH99
05:49 05/01/2003 02079
05:49 05/01/2003 02070 PAPSP1023
*SCLDLAFR7K
TXT
LIC/, LIY/ /. ISS/ / /.
CHARLES W REYNOLDS , SHAWN MARIE REYNOLDS
CUST ADDR: P O BOX 183
GORE VA 226370183
VIN/1FTEF14N1KNB82104. VYR/1989. VMA/FORD.
VST/PK. SSN/224196613 223376572 .
*EXP/ / /. WGT/3888/6500. REG STATUS/.
VEH USE/. VEH DISP/.CUR VCO/WHI.ORI VCO/WHI.
INTERLOCK/.VOA/.VOAT/,
05/01/03 08:49:52 - 05/01/03
PLT STATUS/.
DP/.
PAGE 1 OF .1
08:49:50 6HHOHAFR7K$7
** NOTICE **
INFORMATION OBTAINED FROM VCIN MAY BE USED FOR
CRIMINAL JUSTICE PURPOSES ONLY
ERNEST BEECHER
ONE 1989 FORD F-150 TRUCK
VIN: 1FTEF14N1KNB82104:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENN.
NO.:
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing PETITION FOR TRANSFER
OF OWNERSHIP OF VEHICLE by mailing a true and exact copy addressed to the following:
Gregory Myers
160 Ginkgo Court
Chambersburg, PA 17201
AND
Ernest Beecher
10 Beecher Drive
Carlisle, PA 17013
Respectfully submitted,
ABELN LAW OFFICES
Darlene I,. ' t, //
Legal Assistant
37 East Pomfret Street
Carlisle, PA 17013-3313
717/245-:2851
ERNESTBEECHER
ONE 1989 FORD F-150 TRUCK
VIN: 1FTEF14NIKNB82104:
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENN.
NO.: 0c[- 356,30~,i[
ORDER OF COURT
AND NOW, this .~ ' day of /t~ ,2004, after reasonable
notice and an opportunity for hearing having been provided to all interested parties, the Court
hereby awards ownership of one 1989 Ford F-150 pickup truck, bearing vehicle identification
number 1FTEF 14N 1KNB82104 to Ernest Beecher, and the right, title and interest of any other
person to this 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.
By the Court,
CC:
~rregory Myers
t.~E'mest Beecher