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Home My WebLink About02-0646John's Mobile Repair Service, Inc. 1511 East Commerce Avenue Carlisle PA 17013 VS. Brian Watts 432 Creighton Run Road Creighton PA 15030 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : ACTION IN EQUITY ; :NO. 0 : NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after 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 or relief requested by the Plaintiffs. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717)249-3166 Le han demandado a usted enla corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tine viente (20) dias de palzo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma eschita sus defenses o sus objectones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notification y por cualquier queja o alivio que es pedido en la pentcion de demanda. Usted puede perder dinero o sus propiedades o ostros derechos importantes para usted. John's Mobile Repair Service, Inc 1511 East Commerce Avenue Carlisle PA 17013 VS. Brian Watts 432 Creighton Run Road Creighton PA 15030 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : ACTION IN EQUITY :NO. Petition to Obtain Title of an Abandon Vehicle Vehicle Owner: Brian Watts Vehicle: 1988 Ford F350 VIN # 2FTIW35G9JCA59083 This truck was towed into our shop from the Carlisle Campground located on Route 11 in Carlisle Pa on June 2001. The mack had an engine noise and the customer wanted it checked out. We performed diagnostic lch0'ecks and found the engine to be bad and needed replaced. We then called the Carlisle Campground, where the owner was camping at that time, in an effort to contact the owner to inform him of our findings. We never heard from him again. We did trace telephone records which were found in his truck and was able to contact his mother. She claimed she has not heard from her son in three years. We sent two letters to the address we found in the truck to be registered to and have never received any response. To this date, the customer has never returned a call nor has he responded to any of the letters sent to the only address we had. Therefore, we are seeking a court order from the Commonwealth of Pennsylvania to assign ownership of this vehicle to John's Mobile Repair Service, Inc. The total outstanding at this time is as follows: Towing Charges Shop Charges Storage charges from June 15, 2001 thru January 25, 2002 224 days ~ $15 per day Administrative Fees TOTAL $ 75.00 110.00 3,360.00 250.00 $ 3,795.00 I verify that the statements made in this Petition are true and correct. I understand that false statements Herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities. laintiff l c9- 6-oa. JOHN'S MOBILE REPAIR SERVICE 1511 East Commerce Avenue CARLISLE, PA 17013 (717) 245-0076 ;USTOMER'S ORDER NO PHONE DATE SOLD BY ZCOZ 7s ioo / / 0!oo s ,oo Nat 30 days. A finance charge of 11/2% per month will be charged on all unpaid balances. Collection faal will be assesled if necessary. RECEIVED BY T 13359 Thank You ! JOHN'S MOBILE REPAIR SERVICE, INC., Plaintiff V. LENDERS TRUST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-646 CIVIL TERM ORDER OF COURT AND NOW, this 14th day of February, 2002, upon consideration of the "Petition To Obtain Title of an Abandon Vehicle" in the above-captioned case, and the record containing no indication that Defendant was served, either conventionally or by substituted service authorized by the court, with original process in the case, Petitioner's request for a hearing at this time is denied without prejudice. BY THE COURT, //J~s Mobile Repair Service, Inc. 1511 East Commerce Avenue Carlisle, PA 17013 Plaintiff, Pro Se penders Trust .O. Box 5564 Gainesville, FL 32627 Defendant, Pro Se ;rc ¥1N~,,'X!.ASNN~d ,',J,.NNO0 ' ....... ~ JOHN'S MOBILE REPAIR SERVICE, INC., Plaintiff BRIAN WATTS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-646 CIVIL TERM ORDER OF COURT AND NOW, this 14th day of February, 2002, upon consideration of the "Petition To Obtain Title of an Abandon Vehicle" in the above-captioned case, and the record containing no indication that Defendant was served, either conventionally or by substituted service authorized by the court, with original process in the case, Petitioner's request for a hearing at this time is denied without prejudice. BY THE COURT, :J'~hn's Mobile Repair Service, Inc. 1511 East Commerce Avenue Carlisle, PA 17013 413~intiff, Pro Se ~ an Watts Creighton Run Road Creighton, PA 15030 Defendant, Pro Se irc