HomeMy WebLinkAbout12-6628ESTATE OF JAMES E. JOHNSTON,:
ANGELA MILLHOUSE and
FAME MILLHOUSE,
Plaintiffs
V.
CAThIERINE N. SMITH,
DECEASED AND UNKNOWN
HEIRS, SUCCESSORS, ASSIGNS
AND ALL PERSONS, FIRMS OR
ASSOCIATIONS CLAIMING
RIGHT, TI~~LE OR INTEREST.
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2012- ~6~~ CIVIL TERM
CIVIL ACTION-INVOLUNTARY" TRANSFER
OF MOTOR VEHICLE 'TITLE
PLAINTIFF'S PETITION FOR INVOLUNTARY TRANSFER
OF OWNERSHIP OF VEHICLE BY COURT ORDER
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AND NOW, comes the Plaintiffs, the Estate of James E..lohnston, Angela Hillhouse and
Faye Hillhouse, by and through their attorney, David A. ]Bark, Esquire and respectfully
represents as follows:
1. James E. Johnson who last resided at 152 Neil Road, Shippensburg, (~umberland
County, Pennsylvania 17257 died on November 7, 2011.
2. Jean Bartley as duly appointed Executrix of the Estate of James E. Johnston joins
in this Petition.
2. The Defendant is Catherine N. Smith, a deceased individual who's iast known
address was 152 Neil Road, Shippensburg, Cumberland County, Pennsylvania 17257.
3. The Plaintiffs, Angela Hillhouse and Faye Hillhouse purchased the pa-operty
located at 152 Neil Road, Shippensburg, Cumberland County, Pennsylvania 17257 on September
l 4, 2012 from the Estate of James E. Johnston.
~~. When the Plaintiffs purchased 152 Neil Rcrad, Shippensburg, Cumber and County,
Pennsylvania 17257, a 1974 Redman mobile home, title number A25667936, VIN number
12206204 which is legally titled to James E. Johnston anal Catherine N. Smith. ~ da ~ • ~~~ ~ ~~_0
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Plaintiffs desire to obtain new title in their names to the above-described mobile
home.
6. In order to obtain title to the above-described mobile home, Plaintiffs are required
to commence the instant action, obtain a hearing date, attempt to comnnunicate the hearing date
to the Defendants by certified and/or public notice and obtain an order of court follo~.~in~ the
hearing, all in accordance with the rules and regulations promulgated by the Department of
Transportation.
WHEREFORE, Plaintiffs respectfully requests that this Honorable Court:
Schedule a hearing date at least sixty (60) days after the receipt of the instant
action so as to allow the Plaintiffs to promptly complete all of the regc.zired notice
provisions for advertisement to the Defendants; and,
2. After such hearing, enter an order directing that the Connmonwealth o
Pennsylvania, Department of Transportation may accept the order of court as
evidence of ownership in lieu of a certificate of title, provided Plaintiffs submit all
forms, taxes and fees in order to receive the appropriate certificate of title for said
mobile home.
Respectfully submitted,
BARK SCHEREIEZ LLC
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David ~ . Baric, Esquire
I.D. # 44853
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
VERIFICATIOIyT
We. verify that the statements made in the foregoing Plaintiffs Petition For [nvoluntary
Transfer Of Ownership Of Vehicle By Court Order are true and correct. We und~,rstand that
false statements herein are made subject to the penalties of l8 Pa. C.S. § 4904, relating to
unsworn falsification t:o authorities.
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t._-~~'~' -._.--
Angela Millhouse~
-~,l' Faye Millhouse ~ ~ --
j state of James E. Joh torrS~
by Jean 13~artley, Executrix
DATED: /~~_~~ JOl
ESTATE OF JAMES E. JOHNSTON,:
ANGELA MILLHOUSE and
FAYE MILLHOUSE,
Plaintiffs
V.
CATHERINE N. SMITH,
DECEASED AND UNKNOWN
HEIRS, SUCCESSORS, ASSIGNS
AND ALL PERSONS, FIRMS OR
ASSOCIATIONS CLAIMING
RIGHT, TITLE OR INTEREST.
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.2012- p~~ CIVIL TERM
CIVIL ACTION-INVOLUNTARY TRAN~'E~;
OF MOTOR VEHICLE TITLE ~ N
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ORDER OF COURT
AND NOW, this ~~ay of ~~~~'v~'4~' , 2012, upon consideration of the
attached Petition For Involuntary Transfer Of Ownership Of A Vehicle By Court Order, it is
ordered and decreed that a hearing on this matter is set for the ~ day of ,
20~ at " 7_ :J~ =~ .m. in Courtroom No. ~ of the Cumberland County Courthouse,
Carlisle, Pennsylvania.
Counsel for Plaintiffs is directed to provide notice of this hearing to the Defendants at
their last known address by certified mail, return receipt requested and by regular mail and, if
such notice is unclaimed, advertise notice of such hearing once per week for three consecutive
weeks, in accordance with the requirements of the Pennsylvania Department of Transportation.
BY THE COURT,
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