Loading...
HomeMy WebLinkAbout12-1542Jason A. Mitchell, Esquire Atty ID #85148 J.C. BAR Properties, Inc. 3100 Market Street Camp Hill, PA 17011 (717)761-7801 ,- r, p CO;??[Y t Attorney for Petitioner In Re: Petition for the Involuntary Transfer of Vehicle Title for Vehicle identification Number 002850019003041-001-6778 NOTICE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION (e /? NO. Owl a- ??7 Ol l?? You have been sued in Court. If you wish to defend against the claims set forth in this following pages, you must take action within twenty (20) days after this Petition and notice are served, by entering a written appearance personally, or by attorney, and 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 Petition or for any other claim of relief requested by the petitioner. You may lose money 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. Lawyer Reference Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 Q %X03-7 a Ck I acts 2, ga33 Jason A. Mitchell, Esquire Atty I D #85148 J.C. BAR Properties, Inc. 3100 Market Street Camp Hill, PA 17011 (717)761-7801 Attorney for Petitioner In Re: Petition for the Involuntary Transfer of COURT OF COMMON PLEAS Vehicle Title for Vehicle CUMBERLAND COUNTY, PA Identification Number 002850019003041-001-6778 CIVIL ACTION NO. PETITION FOR THE INVOLUNTARY TRANSFER OF A VEHICLE'S OWNERSHIP AND NOW, comes Petitioner, Robert V. Gothier, Jr. (hereinafter "Petitioner"), and Co- Petitioner, Jennifer Swisher (hereinafter "Co-Petitioner"), by and through counsel, Jason A. Mitchell, Esquire, and pursuant to 75 Pa.C.S. §§ 1114(a) and 1116(b), files this Petition for the Involuntary Transfer of a Vehicle Title, averring as follows: 1. Co-Petitioner resides in the Trebor Mobile Home Park ("Trebor"), 967 West Trindle Road, Lot 27, Mechanicsburg, Cumberland County, Pennsylvania (the "Property") 2. Petitioner is the owner of Trebor, which has a main address of 965 West Trindle Road, Mechanicsburg, Pennsylvania. 3. Co-Petitioner resides in a 1969 Azalea mobile home located on Lot 27' of Trebor; the home is registered with the Commonwealth of Pennsylvania; the mobile home's information is as follows: a. Titled in the name of "Steven L. Wert" (hereinafter "Wert"); b. Vehicle Identification Number 0028550019003041-001-6778 c. Year: 1969 d. Make of Vehicle: Azalea e. Title Number: 21353083007 WE f. Body Type: MH g. Date PA Titled: 4/23/70 h. Date of Issue: 11/09/00 i. First Lien Holder: Georganna J. Zink ("Zink") 1129 Cocklin Street Mechanicsburg, PA 17055 (Lien has been released as averred in Paragraph 5) (Hereinafter the "Mobile Home".) (See the "Commonwealth of Pennsylvania Certificate of Title for a Vehicle" attached hereto and made a part hereof as Exhibit A.) 4. Co-Petitioner is not acquainted with Wert, but has resided in the Mobile Home located at the Property owned by Co-Petitioner at all times relevant hereto. 5. Zink released her first lien on the Mobile Home on February 21, 2005, as evidenced on the Certificate of Title. 6. Neither Petitioner nor Co-Petitioner has located any other individuals and/or entities that have an interest in the Mobile Home. 7. Therefore, as of February 21, 2005, no individual or entity has any right, title or interest in the Mobile Home other than Wert. 8. On September 1, 2000, Wert and Petitioner entered into a Lease for Lot 27 of the Property. (See the "Lease of Mobile Home Space - Trebor Mobile Home Park", dated September 1, 2000, attached hereto and made a part hereof as Exhibit B.) 9. Prior to July of 2005, Wert ceased residing in the Mobile Home, stopped paying rent to Petitioner and ceased paying property taxes with regard to the Mobile Home. 10. In or about August of 2005, and based upon information received from Wert, Petitioner notified the Cumberland County Assessment Office that Wert was attempting to sell the Mobile Home. 11. Wert never sold the Mobile Home and Co-Petitioner was forced to maintain the tax payments to Cumberland County and rental payments to Petitioner in order to prevent the Mobile Home from being sold at a sheriff sale; therefore, as of August of 2005, and without the permission or consent of Petitioner, the Mobile Home has remained on the Property such that Wert has abandoned the Mobile Home pursuant to 75 Pa.C.S. §102. 12. By agreement, and so not to evict Co-Petitioner from the Mobile Home, Petitioner and Co-Petitioner have agreed that so long as Co-Petitioner continues to pay rent on the pad for the Mobile Home and continues to pay the relevant taxes with regard to the Mobile Home, Co-Petitioner may remain a tenant of Trebor. (See the "Agreement - Lot 27 - Trebor Mobile Home Park, dated July 26, 2005, attached hereto and made a part hereof as Exhibit C.) 13. The above agreement notwithstanding, Petitioner has not consented to Wert abandoning the Mobile Home at Trebor, and Petitioner continues to object to such abandonment. 14. After repeated attempts over the past six (6) years, neither Petitioner nor Co- Petitioner has been able to locate Wert. 15. Petitioner and Co-Petitioner desire to have the ownership and title to the Mobile Home transferred to Co-Petitioner. WHEREFORE, Petitioner, Robert V. Gothier, Jr., and Co-Petitioner, Jennifer Swisher, respectfully request that this Honorable Court enter an order awarding Co-Petitioner ownership of the 1969 Azalea Mobile Home bearing a vehicle identification number of 002850019003041- 001-6778, and therefore terminating and extinguishing any right, title and/or interest of any other person in the Mobile Home. Further, Petitioner and Co-Petitioner similarly respectfully request that this Honorable Court enter an order that the Commonwealth of Pennsylvania Department of Transportation may accept the order as evidence of ownership ' ieu of a Certificate of Title. Date: I? By: Jas A. Mitchell, Esquire Attorney for Petitioner VERIFICATION 1, Jennifer Swisher, do hereby verify and state that the facts above set forth are true and correct (or are true and correct to the best of my knowledge, information and belief) and that I expect to be able to prove the same at a hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 (relating to unsworn falsification to authorities). m Date: 2-4 ? 20 l Z By: .L? ennife wisher VERIFICATION I, Robert V. Gothier, Jr., do hereby verify and state that the facts above set forth are true and correct (or are true and correct to the best of my knowledge, information and belief) and that I expect to be able to prove the same at a hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 (relating to unsworn falsification to authorities). Date: o? 077 By: Robert thier, Jr. R?Iol,41"FICA'T'E OF TITLE FOR A VEHICLE CE fr 54 4 b 774& VEHICLE IDENTIFlCAI°;wit NUMBER YEAR MAKE OF VEHICLE TITLE NUMBER Er 1` lvi' :E EMT TIT[ E STATE ODOM PROCD DATE ODOM MI[ S CPOM STATUS BGDY^?TYPE ,[7 DUP SEAT CAP PRIOR (? DATE PA TITLE- T -TE OF ISSUE UNLADEN WEIGHT GVWR GCWH TITLE BRANDS CD CD M ODOMETER DISCLOSURE ytF4WT,,'4X X_fEDERAL LAW REGISTERED OWNEWS)w.. .'r• :.' ( ,r. $TEVEN L WERT r 4167 W Tit I LADLE RD LOT 27 MECHANICSBURG PA 17OSS IBM- 3 TtTL_,E BRANDS - = ANTIQUE VEHICLE =CLASSIC VEHICLE F = COLLECTIBLE VEHICLE -: COT W COUNTRY .. = ORIGINALLY MFGD. FOR NON-U S DISTRIBURON AG-ICU _T"JRdL VEHICLE - TICGING VEHICLE = ISWAS A POLICE VEHICLE F = RECONSTRUCTED = STREET ROD 'r = RECDVERED THEFT VE HIC_F V = VEHICLE CONTAINS REISSUED VI': V1 = FLOOD VEHICLE %. = I, VA S A TAXI / - If a second lienholder is listed Lyon s5hsta(l c r t f lienholder must forward this Title ]o the, Bu au of im . e.. ?. - FIRST LIEN RELEAS G=__ - appropriate forth and tee. DATE / %"I3 ?'" y `?"? 'ft'?F??? SECOND LIEN RELEASED ORIZED REPRESENTATIV ?? DATE MAILING ADDRESS BY_ ??.... AUTHORIZED REPRESENTATIVE GEORGE ANNA INK IN ? Sr CvII ' 11?? pc _ ,1, I,I MECHANICS`BURG PA 17055 FIRST LIEN FA\'OR OF SECOND LIEN FAVOR OF. GEORGEANNA J ZINK I certify as of the, date of issuethe official records of the Pennsylvania Department of Transportation reflect that the person(s) or company named herein is the lawful owner of the said vehicle. SUBSCRIBED AND SWORN TO EEFORE .•dE: BRADLEY L NAUORY Secretary of Transportation If a co-purchaser other than your spouse is listed and you want the title to be listed as "Joint Tenants With Right of Suly,' orship" (pn death of one YEAR owtler, title goes to surviving: owner.) CHECK. H PIE ?. rwt56I?IiP wilts issued as "Tenants in Common f0-i death of one owner it,,,& r rtf .;deceased owner goes to his/her heirs or e_statei. 1ST LIEN DATE: ? IF NO LIEN CHECK- 1ST LIENHOLDER STREET CITY STATE. ZIP FINANCIAL INSTITUTION NUMBER ID LIEN DATE: - --; _.IF NO LIEN, CHECK J? .The umlerslarwr. -rar 1-11 c I. of Tpe I. the veMCB Ave. s.ie-r it rcra harms eel mrih Here. 2ND. LIENHOLDER - t STREET - I iCkIT DR 1111HOR12En SIGNER, I CITY ST 4TE INSTITUTION LEASE OF MOBILE HOME SPACE TREBOR MOBILE HOME PARK THIS INDENTURE, made this_1^day of 2000, BY AND BETWEEN Trebor Mobile Home Park, party of the first part, Lessor, and Steven wort , party of the second part, Lessee. WITNBSSETH, that the said party of the first part, for and in consideration of the covenants and agreements hereinafter mentioned and to be kept and performed by the said party of the second part, their executors and administrators, does hereby demise and lease, to the said party of the second part, the premises in the Township of Monroe, County of Cumberland, and State of Pennsylvania, known and described as lot or street number Lot #27 in Trebor, a mobile home park, to be occupied solely as a private dwelling place. TO HAVE AND TO HOLD the same for a tenancy from month-to-month commencing on the -1-day of October 2000 Either party may terminate this lease by providing in writing to the other written notice, which notice is delivered to the other party at least thirty (30) days prior to the end of the month at which termination is to take place. In all events, if notice of termination is provided by either Lessor or Lessee, Lessee shall remove his or her mobile home from the leased premises no later than the termination date. If such removal does not occur, Lessee hereby grants to Lessor the absolute right and power to remove said mobile home, and hereby releases Lessor from any and all claims, damages or liability incident to said removal. 1. Lessee shall pay to the Lessor at the office of the latter, rent as follows: A. Lessee shall pay to Lessor upon execution of this document the sum of 4258.00 representing rental for the first month of occupancy which begins on the first day of a month; Lessee shall also pay to Lessor the sum of $ which represents the proportionate amount of one month's rent if the lease is executed on a dray other than the first of the month. B. $ 258.00 on the first day of this instrument thereafter in advance during the remainder of the lease. C. Said rental shall be paid promptly on the 1 at of each month, it being agreed by the parties hereto that the time of each and all payments is of the essence of this agreement. A late charge of $1.50 per day shall be due and payable with respect to any amount of rent that is not received by the seventh day of the month, said charge to be computed beginning with the first day of month, until the balance is paid. However, the imposition or payment of this late charge shall not be taken to prevent Lessor from terminating this lease or otherwise proceeding against Lessee on account of failure to pay the rent on the 1 st of the month, and no waiver shall occur by accepting rent and late payment after the first of each month. 2. The leased space shall be used only for the parking of a mobile home. It is mutually understood for the purpose of this agreement, that said mobile home is personal property and not realty. 3. As additional rent hereunder, Lessee agrees to pay the following, which is due at the same time the basic rental is due as set forth in Paragraph 1 above: (a) $10.00 per month per pet which is maintained by Lessee for any part of the month; (b) $10.00 per month for each automobile or motor vehicle, including campers, trucks, trailers and other similar vehicles, in excess of two (2), which are owned, used or possessed by any occupant of the premises during part 6f each month. 4. Lessee shall not sublet the demised premises, or any part thereof, or assign this agreement, or any rights pursuant to this agreement. In the event a termination of this lease agreement occurs, the Lessee shall have absolutely no right whatsoever to sell or otherwise transfer his rights in the lot demised herein to any person, and shall have the obligation to remove his mobile home at this own expense by the termination date, unless express written approval is granted by Lessor pursuant to terms and conditions to be set forth in such document. Lessee hereby signifies his understanding that the leasing of the space in the mobile home park from Lessor, and his right to place a mobile home on said lot, does not give him any rights to retain said mobile home on the lot m the event of termination of this lease, excepting only in strict accordance with the earlier provisions of this paragraph. 5. Lessee shall pay for all gas, heat, light, water, power, telephone and any other public utility services that may be obtained or supplied to the demised premises. 6. No storage shall be allowed outside the mobile home unless the space is attractively enclosed in a manner specifically approved by the Lessor. 7. Lessee agrees to maintain the demised premises, and all parts thereof, in good condition and repair. Trees, shrubs and flowers may be planted, posts may be installed, driveways and cabanas added, but only with the prior written consent of the Lessor. Lessee agrees to properly cultivate and care for the lawn, shrubbery, trees and grounds. In addition, Lessee agrees to properly maintain in good condition and repair the mobile home and storage enclosures, which might be placed upon the premises. Lessee specifically authorizes Lessor to come upon the premises at all reasonable times for the purpose of inspecting the exterior of the mobile home and enclosures, and herewith agrees to comply with all directives of the Lessor with respect to maintenance and repair of said facilities. Lessee recognizes that failure to abide by these obligations with respect to maintenance and repair will be an additional basis upon which Lessor may terminate this lease. 8. Lessee agrees not to erect or display either on the lot or within the mobile home, any business sign unless written authority is previously obtained from Lessor. 9. Lessor expressly releases and quit claims to Lessee any and all right, title and interest in or to the mobile home as realty which may, during the term of this lease, become attached to the real property. 10. Inasmuch as Lessors mobile home park is maintained as a private enterprise, its streets and lanes are private and not public thoroughfares. Lessor may, therefore, at his discretion, and in the interest of safety and traffic control as well as for the well-being of tenants therein, restrict the delivery of certain products and services to designated suppliers. These controls may or may not include such goods and services are the furnishing of dairy products, fuel, bakery goods, laundry and dry cleaning. Where such limitations exist, the information shall be posed in the office of the park and such posting made part of this lease. 11. It is expressly understood between the parties hereto that the posted rules and regulations, to be found in the office of the mobile home park, are a part of this lease at the time of execution. Lessor may alter, add or amend said rules and regulations from time to time but said rules shall not take effect until a written notice to this effect has been given to the Lessee. Lessee acknowledges receipt, at the time of execution hereof, of a copy of the applicable rules and regulations dated as of io - t - oo acknowledges also that he/ she has read and understands same, and agrees to abide by the terms and conditions thereof in the same manner as the written provisions of this lease. 12. The Lessee will in every respect comply with the ordinances of Monroe Township, with the rules and orders of the Board of Health thereof, with the orders and requirements of the police department, with the requirements of the Underwriters' Association so as not to cause any raise in the rate of insurance upon the building and contents thereof, and with the rules and orders of the fire department in respect to any matters coming within their jurisdiction. 13. At the termination of the lease, by lapse of time or otherwise, the party of the second part shall yield up immediate possession to the party of the first part and failing to do so shall pay as liquidated damages for the whole time such possession is withheld, in addition to all of the monies due pursuant to this lease, the sum of $10.00 per day, plus any and all expenses, including attorney's fees and costs before a justice of the peace or a court, incurred by Lessor because of such failure on the part of Lessee. 14. References to the masculine shall include the feminine as well, and the singular shall include the plural if there are more than one party who executes this Lease. IT IS EXPRESSLY AGREED, between the parties hereto, that if default be made in the payment of the rent herein agreed or any part thereof, or in any of the covenants and agreements herein contained, to be kept by the party of the second part, it shall be lawful for the party of the first part, or the legal representatives of said party, at any time thereafter, at the election of said first party of the legal representatives thereof, without notice, to declare said term ended, and to re-enter said demised premises, or any part thereof, either with or without process of law, and the said party of the second part of any person or persons occupying the mobile home, to expel, remove and haul said mobile home from the premises, using such force as may be necessary so to do, and the said premises again to repossess and enjoy, as before this demise, without prejudice to any remedies which might otherwise be used for arrears of rent or preceding breach of covenants said party of the second part hereby expressly waiving all right to any notice or demand under any statute of this state, relating to forcible entry and detainer, and said party of the second part further covenants and agrees that said party of the fast part, or the representatives or assigns of said ;party, shall have, at all times, the right to distrain for rent due, and shall have a valid and fast lien upon all property of said party of the second part, whether exempt by law or not, as security for the payment of the rent herein reserved. IT IS FORTE R AGREED, by the parties hereto, that after the service of notice, or the commencement of a suit, or after final judgment for possession of said premises, the first party may receive and collect any rent due, and the payment of said rent shall not waive or affect such notice, said suit, or said judgment. The party of the second part further covenants and agrees to pay and discharge all reasonable costs, attorney's fees and expenses that shall be made and incurred by the party of the fast part in enforcing the covenants and agreements of this lease; and all the parties to this lease agree that the covenants and agreements herein contained shall be binding upon, apply and inure to their respective heirs, executors, administrators and assigns. Witness the hands and seals of the parties hereto, the day and year fast above written LESSOR LESSEE TREBOR MOBILE HOME PARK RULES AND REGULATIONS PURPOSE: PARKING A MOBILE HOME FOR RESIDENTIAL USE ONLY. BUSINESS HOURS: Business will be transacted at the Park Office at 1000 N. Front St. Wormleysburg. The office telephone number is 731- 0700. In case of an emergency after hours, the number will be answered by our service. ADDITIONAL PERSONS: Any persons in excess of three who will occupy a mobile home shall be reported in writing to the Lessor, and the full name and relationship, if any, of said party or parties to the Lessee shall be disclosed. PETS: NO PETS shall be allowed to run loose on the, premises or to be staked or tied outside. Animals being exercised on leash shall not be allowed on other tenants' premises. No pet's shall be housed outside the mobile home. All waste products of pets must be picked up and properly disposed of by the Lessee. There is a $10.00 charge per pet per month. REGISTRATIONS: All tenants must register at the office and check out before moving. RENTS: All checks are to be made payable to Trebor Mobile Home Park. Checks are due AT THE OFFICE by the seventh (7th) of each month. After that date a late fee of. $1.50 per day will be charged retroactive to the first of the month. PARKING: Parking spaces for two (2) cars (for Lessee and guests) in front of the lot will be provided at no charge. Lessees having more than two cars shall be charged $10.00 per month; per car. No repairing or overhauling of cars on premises shall be permitted. Washing of guests' autos is absolutely prohibited. Vehicles with oil leaks shall be moved from the premises immediately. Noisy motorcycles and vehicles shall be banned from the mobile home park. No trail bikes, three wheelers, snowmobiles or other type of all terrain vehicles are permitted in the park at any time. SPEED LIMIT: A five (5) mile per hour speed limit and all Sr cop signs must be observed at all times. MAINTENANCE: Lawns must be kept mowed, trimmed and raked, if necessary, at all times. • The Lessor reserves the right to mow any lawn that is neglected. Such mowing shall be subject to service charges. Shrubbery and plants permanently attached to the premises by tenants shall become the property of Lessor and cannot be removed after planting without the permission of management. It is required that painting shall be done by Lessee to steps, hitches, roofs, utility buildings and any other unpainted surfaces which appear to the Lessor to be unsightly. Steps shall be approved type. No cinder blocks shall be permitted. Any electrical hook-ups in excess of 50 amps will be charged at cost. MAINTENANCE DIFFICULTIES: When a maintenance problem is encountered, for instance a light out, leaky outside faucet, broken water or sewer pipe, tree limbs rubbing the trailer or lines, etc., REPORT IT TO THE PARK OFFICE. The orders for correction of maintenance difficulties are disbursed from the office only. SKIRTING: Removal of mobile home hitches is mandatory. All skirting shall be installed at the direction of the park owner. This will include the type, the color, the installer, the workmanship; etc. The park owner reserves the :right to remove or have removed or reject any color or workmanship which does not conform to specifications. Any coach without. skirting at the end of thirty (30) days shall pay a fee of $10.00 per day until skirting is installed. See Lessor before purchasing or installation to avoid problems. AWNINGS: Awnings, cabana rooms,'carports, etc. must be discussed with the park owner to make sure construction meets with park standards. UTILITY BUILDINGS: Must be approved by park owner. All sheds (new, or being replaced) must be wood. CLOTHESLINES: Will not be permitted outside on premises. Drying of clothes on premises will be permitted with an umbrella-type pole. FENCING: Is prohibited on the lot. GARBAGE CANS: No garbage cans will be permitted outside the mobile home. ALL garbage must, WITHOUT FAIL, be placed in plastic bags and deposited in the central containers provided by the park owner. There are to be no grass, leaves or tree trimmings placed in the dumpsters unless they can be cut up in small pieces and tied in bundles or placed in bags and then put in dumpsters,. No household appliances are to be placed in trash building. You may contact the office and we will make arrangements with you for their disposal free of charge. RESPONSIBILITIES: Parents,shall be held responsible for the conduct of, and any damage caused by, their children and guests. The Lessor reserves the right to take any corrective measures necessary in such instances. The Lessor is NOT RESPONSIBLE for any damage, injury or loss by accident, theft or fire to either the property or person of Lessor or guest, and Lessee will assume all risk in such matters. RESTRICTIONS: No peddling, soliciting or commercial enterprises are allowed on the park premises. No subletting is permitted. The Lessor reserves the right to remove with or without prior notice any property or person(s) who create a disturbance by drunkenness, fighting, immoral conduct or loud parties. Residents are expected to be considerate of their neighbors and keep all sounds (radios, TV, stereos, voices, etc.),_at a moderate level. Anyone who becomes a nuisance shall be evicted immediately by the Lessor. The Lessor will be the sole judge of the need for such action. CHILDREN IN THE STREETS: No children should be allowed to play or :participate in games on any of the streets or drives of the park, without specific advance written permission of the Lessor. All* persons shall be respectful of the rights and property of each of the other Lessees, and shall not trespass upon their premises or otherwise disturb their quiet possession thereof. REPORTING: All Lessees shall report to the Manager of the park immediately concerning changes in the number of their pets, occupants and vehicles so that proper rental can be calculated. These rules and regulations herein contained constitute a part of the lease and are hereby binding. Regulations of the Park have been established fo:- your protection and to help make living here happy and pleasant for you and your neighbors. The management reserves the right to add or delete rules and regulations when necessary. RVG Management and Development Co. 1000 N. Front Street, Suite 240 Wormleysburg, PA 17043 Dated: ???/?00?5 tom. ( l? AGREEMENT LOT #27 TREBOR MOBILE HOME PARK This agreement made this a- (?" day of July 2005 between Trebor Mobile Home Park and Scott Watson and Jennifer Swisher, The parties have agreed that so long as title is obtained from the State of Pennsylvania for the home located at Lot #27 in Trebor Mobile home park, Trebor Mobile Home park will transfer title of the home to Scott Watson and Jennifer Swisher at no charge. A lease for the lot must be signed and monthly lot rent will be paid to Trebor Mobile Home Park. All back taxes owed on the home (approx. $346.68) will be paid prior to signing this agreement and a lease for the lot. The home must be repaired and maintained at the standards as required of other homes in the park. The home is given to Scott Watson and Jennifer Swisher in as-is, where-is condition. If for any reason we are unable to obtain title to the home, the home will still be given to Scott Watson and Jennifer Swisher and all of the above stated terms apply. Therefore, as of this date, the home now belongs to Scott Watson and Jennifer Swisher. Date: 7& Date: aG o kqa?4 , ?J? Date: 120 ,?i? S Jennifer Swisher Scott. Watson IN RE: PETITION FOR THE INVOLUNTARY TRANSFER OF VEHICLE TITLE FOR VEHICLE IDENTIFICATION NUMBER 002850019003041- 001-6778 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 12-1542 CIVIL TERM IN RE: PETITION FOR THE INVOLUNTARY TRANSFER OF A VEHICLE'S OWNERSHIP ORDER OF COURT AND NOW, this 3rd day of. 'April, 2012, upon consideration of the Petition for the Involuntary Transfer of a Vehicle's Ownership, the Petitioner and Co-Petitioner are granted leave to amend the petition to set forth the details of the attempts that were made to contact and locate Owner Steven L. Wert. Petitioner is further ordered to submit a proposed order for service by mail to the last known address and by publication of the notice to the Owner of the vehicle. o? Jason A. Mitchell, Esq. 3100 Market Street Camp Hill, PA 17011 Attorney for Petitioner BY THE COURT, Christyle . Peck, J. f" j hJ i r 4A' -<. Yf ?? Jason A. Mitchell, Esquire a'r ft•, Y,j (t� Atty ID#85148 J.C.BAR Properties, Inc. 4,,ijsrp 25 no 4 n 3100 Market Street Camp Hill, PA 17011 CUMBERLAND cr r, Attorney for Petitio pe NJA� k'? S YLVA Y (717)761-7801 ri In Re: Amended Petition for the Involuntary Transfer of COURT OF COMMON PLEAS Vehicle Title for Vehicle CUMBERLAND COUNTY, PA Identification Number 002850019003041-001-6778 CIVIL ACTION NO. 2012-1542 AMENDED PETITION FOR THE INVOLUNTARY TRANSFER OF A VEHICLE'S OWNERSHIP AND NOW, comes Petitioner, Robert V. Gothier, Jr. (hereinafter "Petitioner"), and Co- Petitioner, Jennifer Swisher (hereinafter "Co-Petitioner"), by and through counsel, Jason A. Mitchell, Esquire, and pursuant to 75 Pa.C.S. §§ 1114(a) and 1116(b), files this Amended Petition for the Involuntary Transfer of a Vehicle Title, averring as follows: 1. Co-Petitioner resides in the Trebor Mobile Home Park ("Trebor"), 967 West Trindle Road, Lot 27, Mechanicsburg, Cumberland County, Pennsylvania (the "Property"). 2. Petitioner is the owner of Trebor, which has a main address of 965 West Trindle Road, Mechanicsburg, Pennsylvania. 3. Co-Petitioner resides in a 1969 Azalea mobile home located on Lot 27 of Trebor; the home is registered with the Commonwealth of Pennsylvania; the mobile home's information is as follows: a. Titled in the name of"Steven L. Wert" (hereinafter "Wert"); b. Vehicle Identification Number 0028550019003041-001-6778 c. Year: 1969 d. Make of Vehicle: Azalea e. Title Number: 21353083007 WE f. Body Type: MH g. Date PA Titled: 4/23/70 h. Date of Issue: 11/09/00 i. First Lien Holder: Georganna J. Zink ("Zink") 1129 Cocklin Street Mechanicsburg, PA 17055 (Lien has been released as averred in Paragraph 5) (Hereinafter the "Mobile Home".) (See the "Commonwealth of Pennsylvania Certificate of Title for a Vehicle" attached hereto and made a part hereof as Exhibit A.) 4. Co-Petitioner is not acquainted with Wert, but has resided in the Mobile Home located at the Property owned by Co-Petitioner at all times relevant hereto. 5. Zink released her first lien on the Mobile Home on February 21, 2005, as evidenced on the Certificate of Title attached as Exhibit A. 6. Neither Petitioner nor Co-Petitioner has located any other individuals and/or entities that have an interest in the Mobile Home. 7. Therefore, as of February 21, 2005, no individual or entity has any right, title or interest in the Mobile Home other than Wert. 8. On September 1, 2000, Wert and Petitioner entered into a Lease for Lot 27 of the Property. (See the "Lease of Mobile Home Space — Trebor Mobile Home Park", dated September 1, 2000, attached hereto and made a part hereof as Exhibit B.) 9. Prior to July of 2005, Wert ceased residing in the Mobile Home, stopped paying rent to Petitioner and ceased paying property taxes with regard to the Mobile Home. 10. In or about August of 2005, and based upon information received from Wert, Petitioner notified the Cumberland County Assessment Office that Wert was attempting to sell the Mobile Home. 11. Wert never sold the Mobile Home and Co-Petitioner was forced to maintain the tax payments to Cumberland County and rental payments to Petitioner in order to prevent the Mobile Home from being sold at a sheriff sale; therefore, as of August of 2005, and without the permission or consent of Petitioner, the Mobile Home has remained on the Property such that Wert has abandoned the Mobile Home pursuant to 75 Pa.C.S. §102. 12. By agreement, and so as to not evict Co-Petitioner from the Mobile Home, Petitioner and Co-Petitioner have agreed that so long as Co-Petitioner continues to pay rent on the pad for the Mobile Home and continues to pay the relevant taxes with regard to the Mobile Home, Co-Petitioner may remain a tenant of Trebor. (See the "Agreement — Lot 27 — Trebor Mobile Home Park, dated July 26, 2005, attached hereto and made a part hereof as Exhibit C.) 13. The above agreement notwithstanding, Petitioner has not consented to Wert abandoning the Mobile Home at Trebor, and Petitioner continues to object to such abandonment. 14. After repeated attempts over the past six (6) years, neither Petitioner nor Co- Petitioner has been able to locate Wert. 15. Petitioner and Co-Petitioner have published legal notice of the pendency of this action as required by 75 Pa.C.S. §§ 1114(a) and 1116(b) as follows: a. In the Patriot News, with publication dates of May 21, 2012; May 28, 2012 and June 4, 2012 (see the attached "Proof of Publication" from the Patriot News as Exhibit D); and b. In the Cumberland County Law Journal with a publication date of June 1, 2012 (see the attached Proof of Publication of Notice in Cumberland Law Journal" as Exhibit E). 16. To date, neither Petitioner nor Co-Petitioner have received any notification from any party in response to either of the above mentioned publications. 17. Petitioner and Co-Petitioner desire to have the ownership and title to the Mobile Home transferred to Co-Petitioner. WHEREFORE, Petitioner, Robert V. Gothier, Jr., and Co-Petitioner, Jennifer Swisher, respectfully request that this Honorable Court enter an order awarding Co-Petitioner ownership of the 1969 Azalea Mobile Home bearing a vehicle identification number of 002850019003041- 001-6778, and therefore terminating and extinguishing any right, title and/or interest of any other person in the Mobile Home. Further, Petitioner and Co-Petitioner similarly respectfully request that this Honorable Court enter an order that the Commonwealth of Pennsylvania Department of Transportation may accept the order as evidence of ownershi• • lieu of a Certificate of Title. Date: • -. 2.5 .2013 By: Jas. A. Mitchell, Esquire Att. ney for Petitioner VERIFICATION I, Jennifer Swisher, do hereby verify and state that the facts above set forth are true and correct (or are true and correct to the best of my knowledge, information and belief) and that I expect to be able to prove the same at a hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 (relating to unsworn falsification to authorities). Date: Sepi. 2-S1 �� 1.3 By: 1tn,�,ct., ennife wisher VERIFICATION I, Robert V. Gothier,Jr., do hereby verify and state that the facts above set forth are true and correct (or are true and correct to the best of my knowledge, information and belief) and that I expect to be able to prove the same at a hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 (relating to unsworn falsification to authorities). Date: vet . 2-z. ) 26 13 By: ./ Rob- V,- • ier,Jr. I-- t Ai /I -:,,, - .,, COMMONWEALTH' ) 11 I 6 I I ,, ,r,i „ , OF PENNSYLVANIA 4e.,,,,. ,.:::5-'i ,..,,=7; TLE Fc)R_A VrE111C1- E ,-.....,.., ,-,,,f;,..7t:i.:-:--./.: ? :)-:.,,,,\,•,\_. :.'„d'i„,,, 4;1';'';...,:r.15;:.F.. '' '',.'...' i.t.--- 777 •-,-.- '''" . '' ---• ----------- . ' ...,. :-,:-.. ,'„?:,,,:,....OLL-:r,:,-,..'„A t''...L'';' 'i .:f rit''' ''''''7' -'11:- ' -'-',..i.-,;.°••,,;,',..',..;'"-:..--7,,F:i4i'ii",-2:.',z,,' t:RcTiti.:40:7,,E;ligqg... I 5, :::;',F,... ,.:it4,44,m ::'-',::. ,..i.kFki.",i,„,'"zigl'EFAI:tiiirin. . ;:11:::44'.iiiYii: .,..:.1,:,:IF,,,,,.4,:iia:ig;:..44;,....,Agibi.:,,,,F,fr.:.t,:t,R2,, • -,-1.,:., ' r-::--;::.-ii0ft!*.r±ifTea''1.":::" — 4iwafift57.g.'4:: . :,T --114- -' r47!4:43°.7.'.Fi;',1-,F.:,NE',:;0.,:Fg..,:ir,fili-:,:),5,17,2411:;:f,F4. 'II ----- -7.7-;7174.7-7.'Hr.:. "' ''14.-4.-. '162i:::111111:314ti;; :-iiiitiiTIVEYt:131-Iiiii:::EgiV4 ' :4-7.1 ';i41-iiiir1111111111iiiillitilliP!!4!‘!111011iiirlliltie!"!!*:!!!!!!!1!i!!!!!!!!!!!!!!!: l=f,....-:::.1 ,1; ' ',.t:--. Nu"E" W'pi,:gti.eAo"deaOW-t";tkt'ikijlfajwi, ntiti. ttr:',--,iHFIgor;E:.411&:.]::+7 ,;t.. .,-,,-. aioc!„,,,.7., 't 'ODOM MU ss co7 :il•;:- '''- 6 6';'Tiiri4--Ita-, . '',..-,i:45A-T: Al'. ,,' ; '..L:,-,4-;:;..:,...,„:::Agiiiii,:;ic,;:,,,,,,i,;gp:ii.:,..*: ;:,:14-1:2tzi.T.;,:gaigg.1.?!.:,#,,F,-;:E.::•!.: Ar .... .--, ' 1.4,,,,Laa,41;Mi .., ii,',i3tr't..,,,,,i.:1.3.ioji j:fz,Ek6:iE,:,2,;jii,:;Ei674+g7;it!:TgeGavw:,.'';p,t1::ft?',,'..,;:::„,t,, iir., 1 , ,...61.ci.iiiiAii6s DATE PA TITLED : --' 1. ,, , "T7TIT,, ,:-. " ' ,-- IA -el:"!",,'' "..,'", •T:' ::' •AZ..,' i.,,, -„, „1,,,,...„•,,t. ,.. , ,,,,,,,,, : .114 .4.!.i,..-c.',:•,-. .,:-.-.'••_,,::,.:--4.,,,, .'•.,‘“,izt .:r, „4,, •,:••,-:• ....,,,--•,. --4„,, • .,, ,--s, ' • , x T•q.11r i„.)I7..!,ff-:,',::l:-,,.,:--;•,i'-',-=.'• m•----...---• ••?-.:--•---' '".', -' -.1•-''-' 'R-'-" ,.:,.., , ..,.:,:, LAW $4 4.ONMPT '• ODOMETER ir...:i..-:-",1 . k..,:ii.;,.:,:,....'._:;. . ,.... oi sci_ns UR E-Ewfpkt _re,'',1± _f_ .E.11..ER,A,L. L A exh,,,.,2,, ODOMETER -7„----„,„,, li„. ....j.. ';...,... ".:,...- 41.k.4., ..•' , :.7!. -f,.,41.'..t.0`"!",...'"M.,..- ','.' ,..tC,.'",; ' "!.,.,' ' '. •'''.-.1 L.,1 , -.,.- ReD• ;.,,,,J•-'t.',,,, ,, ' ,,;'•11.•.'',,.'.111F1,i-: :;.;.';.,. .4,.-i-.1.;". .,- ' '..,..." -",. - •%- D:.*:t`M;"4"''T N''.",''''. t!''''.' :n 1 .I.,:ri", .1r. :',,,',:4;.,,,,',....'..:,.. ,%,.„,-,,„?,, ...,:";4.(;.!1.'I'l-• iitp,,,,.,4„.-4-„ofkiiiigriPt40".• ,,. `,;=- • ;.(,.‘ ,,,,,',.•, i.,;.,:I bp,.•'. r.,,,,r .1'....: ',.:;•-1.!, ,-, -,:, ;'--,:. ' ''."■■■,' .-,. ;'! ,' , ., .1 . ''...'''," .t."%., . '';..-.. '-'.,.- ',.-.. - . .. '. ...,..,. , " "— c.'"',....:•,.. '';,. 'T " ''''.1,..r.;.,':' ----I : '7,;'''illit7'"""''' '4''''." 4-,-4!," '':' 4''''''- -:'"7"'. '2i• i!'"-;1,ri, ''1,- 17::,''''c: 1!L::r:d i4'*'..''''. 21.,,:; ' 1 ,44er ,,aot,„ , _ . C i =Load wool :," : :L. ' ' 2 ''',-, f =NAVAS A POLICE VEHICLE A .RECONSTRUCTED' ' 1 ' ft CtIA . e4.:: .;U::;,' . RA-"f. ,17 CI tf 4.? .41.4c,,,,,', :'.''' .•,,,,,4to,,,:- ' T.RECOVERD-THEFT'MI V ,..44.'14-*;,., ;.:',-4 ';,fi ...:''. ' V ,....A.", .:. ......,.4 7:, o VI FWD 10012,, .: •..:,.,.,-. 1 -:;. X.r MAMAS A TAXI '-' -"'', -'',, ,-,•,' ' : '''- EORGE , A Z!IltR 1--:',4?.- _--,:f-.- .4,-,.-1,:,,-, ,.--."•.,.-. .6-,:: :. . - .. .- , •,.- 4_ ____ It a!ward lienboIdet Is listed N. 'irrl . , .. :,ii, lt-N, ' 4; ' r' AanhOlder must forwale this T '."--:T f.-' I-.--II -.' ,, =,.6 1 "V",",•,:::, 4, 0„..1 140, appropriate font and fee I.,..•S).!:',1 F.,41ti'iiEl_ :.' '.:,,•- '!1'`-.. ';.;,.•'-' ';.:.' . ....:%.: DATE -!. ' ,..:-_CZ-44m FlEpEIEEEt 4:cr;:riv ,.../. ,4' -7---- SECOND LIEN RELEASED el >; ::* I-: . MAILING ADDRESS I SC' :, AUTHORIZED REPRESENTATIVE ' .,:::•-• M I t'i , ,. _ ,, , y, , 0 r ; , ,y,'„;7,:',7, ,,L ,'..`,.., i- ,:'ia'At, :,,,-,,,:* :z.,,--,-,4,74..,:- :t.,.-;.,-,`,.;.;,,s* ' ',4 lir ••= -.• .'''', ''•' 7(1 illi::4 ' ' ' '. $'-''''' t': '-''', '.--",'• , .,.. ii'.:: ,l'A .c :, .' G-•.11,- ,.-ia -,'-.--,-u3_54 ,-,. - - ; ._ is!-. c -, .. .i.. ft-,.,,i f if. a .77fAilit ik14 vi 4 !: #,,,,,„ 104,,,,?,. ::',-,, iiii4,4,,,,,,,: ,,,,,,,,,,,,4 4.,,44,,,, w,,45: , ,.•:,,,,. ,, .. , , ..0: ...., .,..„. ....,:-..‘,,,, .... •,,,,,,-z,k,,. ii.t. !,,,,,, .:,,,,,,,,:.,„ • ,,,..i., ,,,,,,,, 14 )4 —..,' 4 'r Fr4.4., t. .,:.' 'i.i.,.:•.c. . ...I, .0ii, '' , i ,,,,,,' " m,,, A 1.;.1* ir ' , .;7 MIt P.,-,.,0,0,' ..,.,',..,:, -,•?-kAis, '••, '',1:0",!- ''',c.;',' •••9`' a = •.1--•=. o?; official mores a the Peensfleania DePenment ',BRADLEY: L 'MAttORT 11:1•_:.,.:.: 0 011°R,...ponihontiV as°I Inswiectdniethat°1 ihkur p44.40,x'the to 04 company named herein a;the wow comer secretary of'rrempeetetkes . :.- '' ot the said vehicle. • ..-,:. D. APPLICATION FOR TITLE AND LIEN INFORMATION if - SUESCRIBED AND SWORN - C.,,t,IF LCTL:, Is moo and you want the title to beatistedco-Purchaas"ser.;:ntothT:alhr:Fizo .$yoursP°7:of tp,...,:ra hid death ? one "1•,.,... .;.•/: ..,';'4"... ..,Jr; ',..•1.•-.-...71ritkilik ,:t.' „..:" ..---.:," %4:..,:...-.'." ',. .:''): -.-.,..;to .'. -',:.°T ''''")* ':'.." .Eimm.2- i'''':...m...,:. ,.,:"f",' 'r...,: ,-.„ 1.,,:::.11,4.? :.,,,,t,,.:: •,,,,,,,,,,. ,,,,nmig: t3±, ---' ,---- -----,':., , --z, ,,,, ,,,,",.. „,:+.0- '.,•,.. z-r!.71!,-,•,- .;.--.•:. V. ...A•'-k- -.:„-44,P- .;.::,,i,,■.1,.4.44'4-: ''Z''''.4i 14'4'il'''fr,5;;;. '.4..4'•; ''t-.1“.' -,'44".4 ;Iii '. 1ST utroloi.D.R 4,42' -,.V, ''' .'' .• ' •Ii';r '44k;7"flit r2r4:414'ii!' •: '','. ':. 44?'''''.;4.-ri' -:'''. , 4.,.4 , STATE Zip . ." . ,-.*:;r-'' l'iti •‘.7:;.: 1.4•P -H, • ,,7;1;1 '4'4:6; ...''4FITtt" ',..A'''..'.- '' ''''' , ,, 3,,,,,--T,2Y;.:'. ''-k..'..-.: ', ''';''' i" ••• 4P* ,.,,er,ril,„44.Liono,NUMBER ' '...,-,..,..-- . -.:,....,..4v: A- sil . 2ND LIEN DATE: IF NO LIEN CHECK r„„... , t. 7-*7.i.." ;- 6,L1-,,-,a ;', ' ' -"- _ x 4 iip.. 2nDLEN-9.0 Ea 4 '-,,,N:,,,---,I NV„P..-..T,HA-M,,,'.l.lUi-f-,n,-,I',I•_: i! ',171.11KM1111111111 i' =1111111111111Milk . , , . . CD ...- "' STATE' crry CO - 1 FINANCIAL INSTITUTION NUANIER ,.. ..,, ,,..w.,.....,............ _ ERASURE,.. folly;THI, ...IT, .TSTORE.INA S.A.''''PLACE.-IF LOSTA,PPLY FOR A DUPLICATE ANY ALTERATION OR 1. __. ,.. 1,X41-1 14 i T 8 • LEASE OF MOBILE ROME SPACE TREOO,jR MOBILE ROME PARK was MIXTURE,made this_1_day ofd,BY AND BETWEEN Tabor Mobile Rome Park,party of the first part,Lessor,and Steven Wert ., party of the second part,Lessee. WPl'EES8ET8,that the said party of the first part,for and in consideration of the covenants and agreements hereinafter mentioned and to be kept and performed by the said party of the second part,their executors and administrators,does hereby demise and lease,to the said party of the second part,the premises in the Township of Monroe,County of Cumberland,and State of Pennsylvania,known and described as lot or street number Lot#27 in Trcborr,a mobile home park,to be occupied solely as a private dwelling place. TO SAVE AID TO ROLE the same for a tenancy from month-to-month commencing on the_llday of oetaber 4000 Either party may terminate this lease by providing in writing to the other written notice,which notice is delivered to the other party at least thirty(30)days prior to the end of the month at which termination is to take place. In all events,if notice of to nination is provided by either Lessor or lessee,Lessee shall remove his or her mobile home from the leased premises no later than the termination date. If such removal does not occur,Lessee hereby grants to Lessor the absolute right and power to remove said mobile home,and hereby releases Lessor from any and all claims,damages or liability incident to said removal. 1. Lessee shall pay to the Lessor at the office of the latter,tent as follows: A. Lessee shall pay to Lessor upon execution of this document the sum of$258.00 representing rental for the first month of occupancy which begins on the first day of a month;Lessee shall also pay to Lessor the sum of$ which represents the proportionate amount of one month's rent if the lease is executed on a day other than the first of the month. B. S 258,00 on the first day of this instrument thereafter in advance during the remainder of the lease. C. Said rental shall be paid promptly on the let of each month,it being agreed by the parties hereto that the time of each and all payments is of the essence of this agteemeht. A late charge of$1.50 per day shall be due and payable with respect to any amount of rent that is not received by the seventh day of the month,said charge to be computed beginning with the first day of month,until the balance is paid. However,the imposition or payment of this late charge shall not be taken to prevent Lessor from ternmaatung this lease or otherwise proceeding against Lessee on account of failure to pay the rent on the 1st of the month,and no waiver shaft occur by accepting rent and late payment after the fast of each month. 2. The leased space shall be used only for the parking of a mobile home. It is mutually understood for the purpose of this agreement,that said mobile home is personal property and not realty. 3. As additional rent hereunder,Lessee agrees to pay the following,which is due at the same time the basic rental is due as set forth in Paragraph 1 above: (a) $10.00 per month per pet which is maintained by Lessee for any part of the month; (b) $10.00 per month for each automobile or motor vehicle,including campers,trucks, trailers and other similar vehicles,in excess of two(2),which are owned,used or possessed by any occupant of the premises during part(f each month. 4. Lessee shall not sublet the demised premises,or any part thereof,or assign this agreement,or any rights pursuant to this agreement. In the event a termination of this lease agreement occurs,the Lessee shall have absolutely no right whatsoever to sell or otherwise transfer his rights in the lot demised herein to any person,and shall have the obligation to remove his mobile home at this own expense by the terimnation date,unless express written approval is granted by Lessor pursuant to tams and conditions to be set forth in such document. Lessee hereby signifies his understanding that the leasing of the space in the mobile home park from Lessor,and his right to place a mobile home on said lot,does not give hint any rights to retain said mobile home on the lot in the event of termination of this lease, excepting only in strict accordance with the earlier provisions of this paragraph. 5. Lessee shall pay for all gas,heat,light,water,power,telephone and any other public utility services that may be obtained or supplied to the demised premises. 6. No storage shall be allowed outside the mobile home unless the space is attractively enclosed in a manner specifically approved by the Lessor. 7. Lessee agrees to maintain the demised premises,and all parts thereof,in good condition and repair. Trees, shrubs and flowers may be planted,posts may be installed,driveways and cabanas added,but only with the prior written consent of the Lessor. Lessee agrees to properly cultivate and care for the lawn,shrubbery,trees and grounds. In addition,Lessee agrees to properly maintain in good condition and repair the mobile horn and storage enclosures, which might be placed upon the premises. Lessee specifically authorizes Lessor to come upon the premises at all reasonable times for the purpose of inspecting the exterior of the mobile home and enclosures,and herewith agrees to comply with an directives of the lessor with respect to maintenance and repair of said facilities. Lessee recognizes that failure to abide by these obligations with respect to maintenance and repair will be an additional basis upon which Lessor may terminate this lease. 8. lessee agrees not to erect or display either on the lot or within the mobile home,any business sign unless written authority is previously obtained from Lessor. 9. Lessor expressly releases and quit claims to Lessee any and all right,title and interest in or to the mobile home as realty which may,during the term of this lease,become attached to the real property. 10. Inasmuch as Lessor's mobile home park is maintained as a private enterprise,its streets and lanes are private and not public thoroughfares. Lessor may,therefore,at his discretion,and in the interest of safety and traffic control as well as for the well-being of tenants therein,restrict the delivery of certain products and services to designated suppliers. These controls may or may not include such goods and services are the furnishing of daisy products,fuel,bakery goods,laundry and dry cleaning, Where such limitations exist,the information shall be posed in the office of the park and such posting made part of this lease. 11. It is expressly understood between the parties hereto that the posted rules and regulations,to be found in the office of the mobile home park,are a part of this lease at the time of execution. Lessor may alter,add or amend said rules and regulations from time to time but said rules shall not take effect until a written notice to this effect has been given to the Lessee. Lessee acknowledges receipt,at the time of execution hereof,of a copy of the applicable rules and regulations dated as ofpe-a-00 acknowledges also that he/she has read and understands same,and agrees to abide by the terms and conditions thereof in the same manner as the written provisions of this lease. 12. The Lessee will in every respect comply with the ordinances of Monroe Township,with the rules and orders of the Board of Health thereof,with the orders and requirements of the police department,with the requirements of the Underwriters'Association so as not to cause any raise in the rate of insurance upon the building and contents thereof,and with the rules and orders of the fire department in respect to any matters coining within their jurisdiction. 13. At the termination of the l ease,by lapse of time or otherwise,the party of the second part shall yield up immediate possession to the party of the first part and failing to do so shall pay as liquidated damages for the whole time such possession is withheld,in addition to all of the monies due pursuant to this lease,the sum of$10.00 per day, plus any and all expenses,including attorney's fees and costs before a justice of the peace or a court,incurred by Lessor because of such failure on the part of Les see. 14. References to the masculine shall include the feminine as well,and the singular shall include the plural if there are more than one party who executes this Lease. IT IS EXPRSOSLY AQRfBD,between the parties hereto,that if default be made in the payment of the rent herein agreed or any part thereof,or in any of the covenants and agreements herein contained,to be kept by the party of the second part,it shall be lawful for the party of the first part,or the legal representatives of said party,at any time thereafter,at the election of said first party of the legal representatives thereof,without notice,to declare said term ended,and to re-enter said demised premises,or any part thereof,either with or without process of law,and the said party of the second part of any person or persona occupying the mobile home,to expel,remove and haul said mobile home from the premises,using such force as may be necessary so to do,and the said premises again to repossess and enjoy,as before this demise,without prejudice to any remedies which might otherwise be used for arrears of rent or preceding breach of covenants said party of the second part hereby expressly waiving all right to any notice or demand under any statute of this state,relating to forcible entry and detainer,and said party of the second part further covenants and agrees that said party of the first part,or the representatives or assigns of said party,shall vela ,at all times,the right to distrain for rent due,and shall have a valid and first lien upon all property of said party(tithe second part,whether exempt by law or not,as security for the payment of the rent herein reserved. iT IS PURTRER AGRRI D,by the parties hereto,that after the service of notice,or the commencement of a suit,or alter final judgment for possession of said premises,the first party may receive and collect any rent due,and the payment of said rent shall not waive or affect such notice,said suit,or said judgment. The party of the second part further covenants and agrees to pay and discharge all reasonable costa,attorney's fees and expenses that shall be made and incurred by the party of the first part in enforcing the covenants and agreements of this lease;and all the parties to this lease agree that the covenants and agreements herein contained shall be binding upon,apply and inure to their respective heirs,executors,administrators and assigns. Witness the hands and seals of the parties hereto,the day and year first above written. eeiv.et&.. ) •:a' a' .MEPARK LESSOR _ PEAL) icEE (SEAL) LESSEE a _ TREBOR MOBILE HOME PARK RULES AND REGULATIONS PURPOSE: PARKING A MOBILE HOME FOR RESIDENTIAL USE ONLY. BUSINESS HOURS: Business will be transacted at the Park Office at 1000 N. Front St. Wormleyaburg. The office telephone number is 731- 0700. In case of an emergency after hours, the number will • be answered by our service. ADDITIONAL PERSONS: Any persons in excess of three who will occupy a mobile home shall be reported in writing to the Lessor, and the full name and relationship, if any, of said party or parties to the Lessee shall be disclosed. PETS: NO PETS shall be allowed to run loose on the premises or to be staked or tied outside. Animals being exercised on leash shall not be allowed on other tenants' premises. No pets shall be housed outside the mobile home. All waste products of pets must be picked up and properly disposed of by the Lessee. There is a $10.00 charge per per per month. REGISTRATIONS: All tenants must register at the office and check out before moving. RENTS: All checks are to be made payable to Trebor Mobile Home Park. Checks are due AT THE OFFICE by the seventh (7th) of each month. After that date a late fee of $1.50 per day ' will be charged retroactive to the first of the month. PARKING: Parking spaces for two (2) cars (for Lessee and guests) in front of the lot will be provided at no charge. Lessees having more than two cars shall be charged $10.00 per month; per car. No repairing or overhauling of cars on premises shall be permitted. Washing of guests' autos is absolutely prohibited. Vehicles with oil leaks shall be moved from the premises immediately. Noisy motorcycles and vehicles shall . be banned from the mobile home park. No trail bikes, three wheelers, snowmobiles or other type of all terrain vehicles are permitted in the park at any time. SPEED LIMIT: A' five (5) mile per hour speed limit and all STOP signs must ' be observed at all times. MAINTENANCE: Lawns must be kept mowed, trimhed and raked, if necessary, at all times. • The Lessor reserves the right to mow any lawn that is neglected. Such mowing shall be'subject to service charges. Shrubbery and plants permanently attached to the premises by tenants shall become the property of Lessor and cannot be removed after planting without the permission of management. It is required that painting shall be done by Lessee to • steps, hitches, roofs, utility buildings and any other • unpainted surfaces which appear to the Lessor to be unsightly. Steps shall be approved type. ' No cinder blocks shall be permitted. Any electrical hook-ups in excess of 50 amps will be charged at cost. MAINTENANCE DIFFICULTIES: When a maintenance problem is encountered, for instance a . light out, leaky outside faucet, broken water or sewer pipe, tree limbs rubbing the trailer or lines,. etc., REPORT IT TO THE PARK OFFICE. The orders for correction of maintenance difficulties are disbursed from the office only. . SKIRTING: Removal of mobile home hitches is mandatory. All skirting shall be installed at the direction of the park owner. This will include the type, the color, the installer, the workmanship; etc. The park owner reserves the right to remove or have removed or reject any color or workmanship which does not conform to specifications. Any coach without. skirting at the end of thirty (30) days shall pay a fee of $10.00 per day until skirting is installed. gee Lessor , before purchasing or installation to avoid problems. • AWNINGS: Awnings, cabana rooms, 'carports, etc. must be discussed with the park owner to make sure construction meets with park standards. , UTILITY BUILD/NOS: Must be approved by park owner. All sheds (new,or being replaced) must be wood. CLOTHESLINES: Will not be permitted outside on premises. Drying of clothes on premises will be permitted with an umbrella-type pole. FENCING: Is prohibited on the lot. GARBAGE CANS: No garbage cans will be permitted outside the mobile home. • ALL garbage must, WITHOUT FAIL, be placed in plastic bags and deposited in the central containers provided by the park owner. There are to be no grass, leaves or tree trimmings placed in the.dumpsters unless they can be cut up in small pieces and tied in bundles or placed in bags and then put in dumpstersb. • No household appliances are to be placed in trash building. You may contact the office and we will make arrangements with you for their disposal free of charge. RESPONSIBILITIES: Parents,ehall be held responsible for the conduct of, and any damage caused by, their children and guests. The Lessor reserves the right to take any corrective measures necessary in such instances. The Lessor is NOT RESPONSIBLE for any damage, injury or loss by accident, theft or fire to either the property or person of Lessor or guest, and Lessee will assume all risk in such matters. RESTRICTIONS: No peddling, soliciting or commercial enterprises are allowed on the-park premises. No subletting is permitted, ' The Lessbr reserves the right to remove with or without ' prior notice any property or person(s) who create a disturbance by drunkenness, fighting, immoral conduct or loud parties. Residents are expected to be considerate of their neighbors and keep all sounds (radios, TV, stereos, voices, etc.), at a moderate level. Anyone who becomes a . nuisance shall be evicted immediately by the Lessor. The Lessor will be the sole judge of the need for such action. CHILDREN IN TEE STREETS: No children should be allowed to play or participate in games on any of the streets or drives of the park, without specific advance written permission of the Lessor". All ' persons shall be respectful of the rights and property of • each of the other Lessees, and shall not trespass upon their premises or otherwise disturb their quiet possession thereof. REPORTING: All Lessees shall report to the Manager of the park , immediately concerning changes in the number of their pets, ' occupants and vehicles so that proper rental can be calculated. These rules and regulations herein contained constitute a part of the lease and are hereby binding. Regulations of the Park have been established for your protection and to help make living here happy and pleasant for you and your neighbors. The management reserves the right to add or delete rules and regulations when necessary. RVG Management and Development Co. 1000 N. Front Street, Suite 240 Wormleysburg, PA 17043 Dated: /o/0o0.s, • ( ) �1 VT (( ( ,. AGREEMENT LOT#27 TREBOR MOBILE HOME PARK This agreement made this 9 ` day of July 2005 between Trebor Mobile Home Park and Scott Watson and Jennifer Swisher, The parties have agreed that so long as title is obtained from the State of Pennsylvania for the home located at Lot#27 in Trebor Mobile home park, Trebor Mobile Home park will transfer title of the home to Scott Watson and Jennifer Swisher at no charge. A lease for the lot must be signed and monthly lot rent will be paid to Trebor Mobile Home Park. All back taxes owed on the home (approx. $346.68) will be paid prior to signing this agreement and a lease for the lot. The home must be repaired and maintained at the standards as required of other homes in the park. The home is given to Scott Watson and Jennifer Swisher in as-is,where-is condition. If for any reason we are unable to obtain title to the home, the home will still be given to Scott Watson and Jennifer Swisher and all of the above stated terms apply. Therefore, as of this date,the home now belongs to Scott Watson and Jennifer Swisher. / Date: 7/d 67/e) Ro. V. �,.Ifrr,Jr. Trebor / , Home Park ,, j Date: 7 ."LA Scott Watson Date: J C. )c s fennifer S sher IN RE: PETITION FOR THE : IN THE COURT OF COMMON PLEAS OF INVOLUNTARY TRANSFER : CUMBERLAND COUNTY, PENNSYLVANIA OF VEHICLE TITLE FOR VEHICLE IDENTIFICATION : CIVIL ACTION—LAW NUMBER 002850019003041- : 001-6778 : NO. 12-1542 CIVIL TERM IN RE: PETITION FOR THE INVOLUNTARY TRANSFER OF A VEHICLE'S OWNERSHIP ORDER OF COURT AND NOW, this 3"i day of April, 2012, upon consideration of the Petition for the Involuntary Transfer of a Vehicle's Ownership, the Petitioner and Co-Petitioner are granted leave to amend the petition to set forth the details of the attempts that were made to contact and locate Owner Steven L. Wert. Petitioner is further ordered to submit a proposed order for service by mail to the last known address and by publication of the notice to the Owner of the vehicle. c� 1 c= BY THE COURT, -�, '`' rn '_,a r f 7A3 r i ete?< r-....- Christyle . Peck, J. : . ✓ Jason A. Mitchell, Esq. -_G 3100 Market Street Camp Hill, PA 17011 Attorney for Petitioner :rc t'c,r% ma:lr-d 4_04_ We ,, The Patriot-News Co. Lx 1-1 ,e,iT D , 2020 Technology Pkwy he atnotNews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 J.C. BAR PROPERTIES 5rlr,ro 415 FALLOWFIELD ROAD f -;111 1i ll.. r:',1 i _SUITE 301 `` 1 Tr CAMP HILL PA 17011 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad# 0002210984 ran on the dates shown below: May 21, 2012 May 28, 2012 i June 04, 2012 / ‘ 1 1 / ' Ir. Pi ...,......„ Cumberland County Court of Common � Please Civil Action 2012-1542 has been flied for the ownership of a 1969 Azalea j I ham V 9N 6 0W8.5T01nd90e 3R1 aL7#27 1,o- Sworn to .n c- su,Iscrib:d before me(t . 07 of June, 2012 A.D. Monroe Township,Cumberland County. - Any person with interest in this home should loin the above Civil Suit. -, / I Notary Plic COMMONWEALTH OF PENNSYubLVANrq Sher,* L Notarial Seal Lowar�, rweliS,Notary Public My Cammiss onrwu.`Dauphin County MEMBER,PEN pireS Nov.26,2015 NSYLVgNIq ASSOCIATION OF NOTARIES The Patriot-News Co. 2020 Technology Pkwy e a rlo fix e s Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 J.C. BAR PROPERTIES 415 FALLOWFIELD ROAD SUITE 301 CAMP HILL PA 17011 STATEMENT ALL CHARGES ARE NET ACCT# NAME AD ORDER# DATE EDITION ADDTL. INFO. TYPE OF CHARGE AMOUNT 136393 J.C.BAR PROPERTIES 0002210984 05/21/12 REGULAR BASIC AD CHARGE $39.06 136393 J.C. BAR PROPERTIES 0002210984 05/28/12 REGULAR BASIC AD CHARGE $39.06 136393 J.C.BAR PROPERTIES 0002210984 06/04/12 REGULAR BASIC AD CHARGE $39.06 AFFIDAVIT CHARGE $5.00 TOTAL: $122.18 This is not an invoice. Please do not remit payment from this Statement. An invoice will be generated at the end of the month. --Thank you. NOTE: This Statement replaces the Order Confirmation which we previously sent with Proofs of Publication Cx H e I i .' , ,- D �� coGPs Vfr pf gay ! 11.:_p� ' L1 *kiss "c`o CUMBERLAND LAW JOURNAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 Tele: (717)249-3166 Fax:(717)249-2663 June 1, 2012 Cumberland Law Journal is published every Friday by the Cumberland County Bar Association and is designated by the Court of Common Pleas as the official legal publication for Cumberland County and the legal newspaper for publication of legal notices. TO: Deborah K. Darr—Property Manager J.C. Bar Properties RE: Vehicle Title 1969 Azalea Home Legal advertisements must be received by Friday Noon. All legal advertising must be paid in advance. Make all checks payable to: Cumberland Law Journal. Advertisement inserted on following dates: June 1, 2012 Advertising Cost $ 75 .00 Proof of Publication $ .00 Second Proof Request $ .00 Payment received $ 75.00 Total Amount Due $ .00 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND . Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz June 1, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 1isa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 1 day of June, 2012 C\ l J Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE Cumberland County Court of Com- mon Pleas Civil Action 2012-1542 has been filed for the ownership of a 1969 Azalea home VIN 0028550019003041- 001-6778; located at 967 W. Trindle Road, Lot #27, Monroe Township, Cumberland County. Any person with interest in this home should join the above Civil Suit. June 1 4 Jason A. Mitchell, Esquire Atty ID#85148 J.C. BAR Properties, Inc. 3100 Market Street Camp Hill, PA 17011 (717)761-7801 Attorney for Petitioner In Re: Amended Petition for the Involuntary Transfer of COURT OF COMMON PLEAS Vehicle Title for Vehicle CUMBERLAND COUNTY, PA Identification Number 002850019003041-001-6778 CIVIL ACTION NO. 2012-1542 ORDER OF COURT AND NOW, this ,Welt, day of 0L , after reasonable notice and an opportunity for hearing having been provided to all interested parties, the Court hereby awards ownership of one 1969 Azalea mobile home, bearing vehicle identification number 002850019003041-001-6778, to Jennifer Swisher, 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 Co-Petitioner shall submit 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: 4. cf } ? o ,G /(/ Judge 0.7 (l) y- , Coiy P21.4cLekt) Q�)olI.2