HomeMy WebLinkAbout13-1488 FILED—Oi:.i=ICS _ . .
Cif TUE PROTHONOT�aR OF �
2013 MAR 20 PM 1: 24 2013 MAP, 20 r i
CUMBERLAND CtOUtiTY CUMBERLAND COUt�T'Y
Dry#203250 ook,Esquire PENNSYLVANIA PENNSYLVANIA
2132 Market Street
Camp Hill,Pennsylvania 17011
Telephone—(717)975-9446
Fax—(717)975-2309
BSh99KQdvkzl&w.com Attorney for Harry J.Tucci
IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1923 ROLLS ROYCE 20HP : CUMBERLAND COUNTY, PENNSYLVANIA
(Identification Number 611-16)
: No: 2013- I`{$g - CIVIL TERM
NOTICE
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 Complaint
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 Complaint or for any other claim or relief requested by the Plaintiff. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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Bryan W.Shook,Esquire
ID#203250
2132 Market Street
Camp Hill,Pennsylvania 17011
Telephone—(717)975-9446
Fax—(717)975-2309
Qft"§plalft.com Attorney for Harry J.Tucci
IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1923 ROLLS ROYCE 20HP : CUMBERLAND COUNTY, PENNSYLVANIA
(Identification Number 61116)
No: 2013- - CIVIL TERM
PETITION FOR DECLARATION OF OWNERSHIP
AND NOW comes Harry J. Tucci, who petitions this Honorable Court, pursuant to
42 Pa. C.S. § 7531, et seq. for a Declaration of Ownership of a 1923 Rolls Royce 20HP
automobile (Vehicle Identification Number: 61 H6) sufficient to permit the
Commonwealth of Pennsylvania, Department of Transportation, Bureau of Motor
Vehicles to issue a Certificate of Title to the aforementioned motor vehicle in the name
of Harry J. Tucci and in support thereof respectfully avers:
1. Your Petitioner is Harry J. Tucci, an adult individual currently residing at 220
Snonaker Road, Spring City, Chester County, Pennsylvania.
2. Your respondent is Victoria Campbell at adult individual who, upon information
and belief is currently residing at 24 Silver Spur Lane, Bel Canyon, California
91307.
3. The Rolls-Royce Foundation is a non-profit, non-stock corporation organized
under Pennsylvania law with its principal place of business located at 191 Hempt
Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. (Sometimes
hereinafter simply referred to as the "Foundation").
4. Harry J. Tucci is requesting a Declaration of Ownership relative to a certain 1923
Rolls Royce 20HP automobile (Vehicle Identification Number: 611-16) (hereinafter
sometimes referred to simply as the "automobile") which was so graciously
donated to The Rolls-Royce Foundation by Dr. Elisha Wright Burr Nyberg on
February 26, 2001. (A true and correct copy of the Commonwealth of Virginia
Certificate of Title issued March 13, 2000 and numbered 84213508 evidencing
the gift from Dr. Nyberg to The Rolls-Royce Foundation is attached hereto, made
part hereof and marked as Exhibit "A").
5. At the time the vehicle was donated to The Rolls-Royce Foundation, it was
owned by Dr. Elisha Wright Burr Nyberg and was duly registered in the
Commonwealth of Virginia. (A true and correct copy of the Commonwealth of
Virginia, Department of Finance, Vehicle License Registration is attached hereto,
made part hereof and marked as Exhibit "B").
6. Upon information and belief, the subject 1923 Rolls Royce was sold to
Respondent, Victoria Campbell on August 26, 2001 for the sum of$1,000.00.
7. It appears as though Ms. Campbell immediately had the $1,000.00 purchase
price sent to the Foundation however did not communicate further with the
Foundation until April16, 2003.
8. On April 16, 2003 the Foundation sent Dr. Nyberg's title to the subject vehicle
and a bill of sale from the Foundation to Ms. Campbell with a notation that the
Foundation would like the subject vehicle and its related parts removed as soon
as possible.
9. By email dated July 24, 2003, Cal West, on behalf of the Foundation, informed
Ms. Campbell of the problems with vehicle transporters declining to accept the
vehicle for transport.
10.At this point Mr. West reminded Ms. Campbell that the vehicle was essentially a
collection of loose parts and a chassis that is tied and wired together and
suggested to Ms. Campbell that she may be better off flying to Pennsylvania,
renting a truck and hauling the car to California herself.
11.By letter dated June 16, 2004, Mr. R.D. Shaffner, then Executive Vice President
of the Foundation, expressed to Ms. Campbell that the Foundation would no
longer store the subject vehicle without payment of storage expenses by Ms.
Campbell.
12.4n June 21, 2004, the Foundation received, from Ms. Campbell, a check in the
amount of$665.60 for storage of the subject vehicle at Rt. 15 Self Storage.
13.Further by correspondence dated June 21, 2004, the Foundation made it clear
that all future obligations with respect to storage of the subject vehicle were the
responsibility of Ms. Campbell and accordingly had the storage lease assigned to
Ms. Campbell and mailed her a key to the self-storage unit (Unit E18) located at
Rt. 15 Self Storage in Dillsburg, Pennsylvania.
14.In May 2006, after Ms. Campbell failed to pay past due storage fees for March,
April and May 2006, Rt. 15 Self Storage began to take steps to sell the contents
of Ms. Campbell's storage unit.
15.The Foundation was contacted by Rt. 15 Self Storage, in May 2006, and
apprised of the situation with Ms. Campbell's failure to pay.
16.The Foundation contacted your Petitioner and others about the vehicle, Ms.
Campbell's nonpayment of storage fees and Rt. 15 Self Storage's upcoming sale
of the vehicle.
17.Your Petitioner, on May 30, 2006, by paying the back storage fees and late fees
was conveyed the contents of storage unit E18 by Rt. 15 Self Storage, to wit the
subject vehicle.
18.The law in Pennsylvania is clear that the owner of a self-storage facility has a lien
upon any and all property stored in the facility and that the lien is superior to any
other lien against the property. 73 P.S. § 1904.
19.Further the law is such that in Pennsylvania if a customer does not pay their bill
to the self-storage facility and are in default for a continuous period of more than
thirty (30) days the owner of the self-storage facility can begin taking steps to
deny the customer access to the unit and force the sale or disposition of the
property to satisfy the self-storage facility's lien on the stored property. 73 P.S. §
1905.
20.The law goes on to state that a purchaser in good faith of the personal property
sold to satisfy the self-storage facility lien takes the property free of any rights of
persons against whom the lien was valid, despite any noncompliance by the self-
storage facility with the requirements of the Act. 73 P.S. § 1911.
21.Your Petitioner was a good faith purchaser.
22.Respondent abandoned the vehicle.
23.Harry J. Tucci, is unable to obtain a title to the subject vehicle because he does
not possess sufficient documentation so as to permit Penndot to issue a
Certificate of Title in his name.
24.Mr. Tucci wrote a letter to Ms. Campbell requesting that Ms. Campbell send Mr.
Tucci the Certificate of Title to the vehicle that was given to Ms. Campbell by the
Foundation in 2003. (A true and correct copy of the January 6, 2013 letter from
Mr. Tucci to Ms. Campbell is attached hereto, made part hereof and marked as
Exhibit "C").
25.Mr. Tucci emailed the aforementioned letter to campbellsgarage @aol.com and
also sent the letter via Certified U.S. Mail to Ms. Campbell.
26.The email was not returned as undeliverable, however the letter was returned as
unclaimed on March 9, 2013.
27.Ms. Campbell did not respond to Mr. Tucci's request for the Certificate of Title.
28.Because of the unique circumstances of this matter, Harry J. Tucci is without
alternative but to petition this Honorable Court for a declaration of ownership
relative to the subject 1923 Rolls Royce sufficient to permit Penndot to issue a
certificate of title to the 1923 Rolls Royce in his name.
29.With respect to these types of actions, the undersigned, on December 22, 2010,
contacted Matthew Haeckler, Esquire, Assistant Counsel for Commonwealth of
Pennsylvania, Department of Transportation, Bureau of Motor Vehicles, who
stated that Penn Dot has no interest in these matters other than the
determination of who the owner of the vehicle is.
30.A search of the United States Department of Justice's National Motor Vehicle
Title Information System (NMVTIS) was performed on December 14, 2012 and
the search returned that the subject vehicle was not found in the NMVTIS
database. (A true and correct copy of the December 14, 2012 NMVTIS search
results are attached hereto, made part hereof and marked as Exhibit "D").
31.Based upon the records of the U.S. Department of Justice, it does not appear as
though Ms. Campbell ever titled this vehicle in her name.
32.A search of the National Insurance Crime Bureau (NICB) VINCheck database
was performed on December 14, 2012 and returned that the subject vehicle has
not been identified as a vehicle listed in the VINCheck Theft Records or the
VINCheck Total Loss Records. (A true and correct copy of December 14, 2012
NICB search results are attached hereto, made part hereof and marked as
Exhibit "E").
33.There is no indication that there is anyone besides the Harry J. Tucci who claims
ownership of this 1923 Rolls Royce 20HP automobile.
34.Marquee registries have shown Harry J. Tucci as the owner of the subject vehicle
since 2006.
35.The failure to be able to forward a Certificate of Title to Penndot for processing
does not operate to prevent the transfer of ownership of the vehicle herein. Dept.
of Transp. v. Walker, 584 A.2d 1080 (Pa. Commw. Ct. 1990).
36.The primary function of certificates of title to automobiles have always been, and
are still, to register the name and address of the person having the present right
of possession, and to furnish persons dealing with one in possession of a car a
means of determining whether such possession was prima facie lawful. Braham
& Co. v. Steinarol-Hannon Motor Co., 97 Pa. Super. 19, 23 (1929) See also Dept.
of Transp. v. Walker at 1082.
37.The entire action is largely procedural and administrative, as pursuant to 73 P.S.
§§ 1901, et seq., Harry J. Tucci acquired good marketable title to the vehicle
from Rt. 15 Self Storage.
38.The entering of a declaration of ownership in this case would serve to permit
Harry J. Tucci to lawfully title, register and enjoy this antique automobile and
would terminate and end any controversy or uncertainty of ownership which may
come from having possession of or otherwise owning an untitled automobile.
WHEREFORE, Harry J. Tucci respectfully requests that this Honorable Court
declare that Harry J. Tucci is the owner of the 1923 Rolls Royce 20HP automobile
(Vehicle Identification Number: 611-16).
Respectfully Submi e
Date: 3-v ( - 13
Brya . Shook, Esquire
ID # 203250
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, Pennsylvania 17011
Telephone: (717) 975-9446
BShookA-d0gIaw.com
Attorney for Harry J. Tucci
"
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NYBERG,ELI HA WRIGHT BURR
1716 UNION MILLS ROAD
TROY ETA 22974--2100
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Harry J.Tucci
Harmaleah Farm
220 Slonaker Rd.
Spring City, PA 19475
6 Jamuary 2013
Victoria Campbell
24 Silver Spur Lane
Bel Canyon, CA 91307
camgbellsaaraRetDaol.com
Dear Victoria,
A few years ago, I was asked by Bob Shaffner to"rescue"a Rolls Royce that was scheduled to
be auctioned off by a storage locker concern.
The car was a 1923 20HP;chassis number 61116 that was being stored at"Rt. 15 Self Storage",
845 Rt. 15 North, Dillsburg, PA 17019. 1 did as he asked and purchased the car.
Recently, I learned from a document search at the Rolls-Royce Foundation,that Bob had sent
you the title to the car.
I would be most thankful if you would send me the title so that I may subsequently register
the car here in Pennsylvania.
Your help in this regard would be most appreciated.
Sincerely,
Harry J.Tucci
Multi-State Vehicle Repair(NMVT1S) Page 1 of t
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IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1923 ROLLS ROYCE 20HP : CUMBERLAND COUNTY, PENNSYLVANIA
(Identification Number 611116)
: No: 2013- - CIVIL TERM
Certificate of Service
I hereby certify that a copy of the foregoing Petition, was hereby served by
depositing the same within the custody of the United States Postal Service, First Class
and Certified Mail, postage prepaid, addressed as follows:
Victoria Campbell
24 Silver Spur Lane
Bel Canyon, California 91307
Certified Mail# 7012 1640 0002 1546 8827
The Rolls-Royce Foundation
191 Hempt Road
Mechanicsburg, Pennsylvania 17050
Certified Mail# 7012 1640 0002 1546 8834
Respectfully Submitt d'
Date: 3-90-20/3 O�F�'
Brya . Shook, Esquire
ID # 203250
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, Pennsylvania 17011
Telephone: (717) 975-9446
BShook _dplglaw.com
IN RE: OWNERSHIP OF 1923 ROLLS
ROYCE 20HP (Identification Number
611-16)
IN THE COURT OF COMMON PLEAS
OF THE NINTH JUDICIAL DISTRICT
2013-01488 CIVIL TERM
IN RE: PETITION FOR DECLARATION OF OWNERSHIP
ORDER OF COURT
AND NOW, this 27th day of March 2013, upon consideration of Plaintiffs
Petition for Declaration of Ownership, a HEARING on the issue of ownership of the
vehicle in question is scheduled for 2 May 2013 at 1:30 p.m. in Courtroom Number
Six of the Cumberland County Courthouse, Carlisle, Pennsylvania.
Petitioner is directed to serve the petition upon Respondent, any lienholder, and
any other interested person in accordance with the Pennsylvania Rules of Civil
Procedure and to serve notice of the hearing upon Respondent, any lienholders and all
other interested persons by certified mail, addressee only, returns receipt requested. If
said notice is unclaimed, Plaintiff shall advertise such notice in accordance with
Pennsylvania Department of Transportation rules and regulations. The notice of
hearing must include the following: (1) a specific description of the vehicle; (2) the name
of the court where this action has been filed; and (3) the time, date, and place of the
above scheduled court proceeding. If Petitioner is unaware of the identity of such
interested persons, Petitioner may fill out a Request for Vehicle Information available
through the Pennsylvania Department of Transportation to obtain the information.
In the event that Petitioner is unable to serve Respondent, lienholders, and any
other interested persons, Petitioner must provide notice upon Respondent,lienholders,
and other interested persons by publication, once in the Cumberland Law Journal and
once per week for three consecutive weeks in a newspaper of general circulation where
any person known to claim an interest in the trailer may be located. The notice of
hearing by publication must include the following: (1) a specific description of the
vehicle; (2) the name of the court where this action has been filed; and (3) the time,
date, and place of the above scheduled court proceeding.
Proof of service must be filed with the Cumberland County Prothonotary prior to
the above-scheduled hearing.
BY THE COURT,
Distribution: Thomas A. Placey C.P.J.
✓ Bryan W. Shook, Esq.
V' Victoria Campbell
The Rolls-Royce Foundation C
Cep;�s Ma,le,4 3�a-z 3
usr' ry 73
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IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1923 ROLLS ROYCE 20hp : CUMBERLAND COUNTY, PENNSYLVANIA
(Identification Number 61 H6)
No: 2013-1488 — CIVIL TERM c•'
Affidavit of Service
N N . r:
Commonwealth of Pennsylvania
County of Cumberland : ss.
I, Bryan W. Shook, Esquire, being duly sworn according to law, deposes and say that
on April 5, 2013, 1 sent Respondents, The Rolls-Royce Foundation and Victoria
Campbell, Notice of Hearing pursuant to the March 27, 2013 Order of this Honorable
Court. Proof of mailing of said notice, via U.S. Postal Service Certified Mail, Return
Receipt Requested is attached. Notice to The Rolls-Royce Foundation was signed for
and accepted (Mailing Receipt # 7012 1640 0002 1546 8964). Notice to 'Victoria
Campbell was expected to be delivered on April 8, 2013, but it has remained unclaimed
at the West Hills, California Post Office since that date. (Mailing Receipt # 7012 1640
0002 1546 8957).
Accordingly, pursuant to the March 27, 2013 Order of this Honorable Court, I caused
the Notice of Hearing to be published once in the Cumberland Law Journal and once a
week for three consecutive weeks in the Los Angeles Times, a Newspaper of general
circulation in Bel Canyon/West Hills and Los Angeles County, California. Original
proofs of Publication are attached. Notice was also published on the internet by the Los.
Angeles Times starting April 2, 2013.
Further, the Affiant sayeth not.
DATE: /� a.' r! ��, aoi 3 BY:
B an W. Shook, Esquire
Sworn an� Slubscribeq before me, this 22nd day of April, 2013.
ai4- f L.�,
C^ T
Nota f-ri
My commission expires:
COMMONWEALTH OF PENNSYLVANIA -{> CAD
Notarial Seal
=
Crystal L.Mahoney,Notary Public v `0 O��-
Camp Hill Boro,Cumberland County O - �-
My Commission Expires March 20,2014 —Cr CJ r,•.
Member,Pennsylvanla Association of Notaries C?
;' C', ^!
i
COMPLETE • COMPLETE
■ Complete items 1,2,and 3.Also Complete A. Si
Item 4 if Restricted Delivery is desired. X El Agent
■ Print your name and address on the reverse ❑Addressee
so t that we can return the card to you. B.R�cP,,� ted N me) C. Date of Delivery
■ Attach this card to the back of the mailpiece, I(�T•� L Q,r( Jig
or on the front if space permits. X
1. Article Addressed to: D. Is delivery a ss different from Item 1? ❑Yes
If YES,enter delivery address below: ❑No
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❑Insured Mall ❑C.O.D.
4. Restricted Delivery?(Extra Fee)
2. Article Number 7'01;2 1640 0002 15-4- 6 8- 964 -
(transfer from serv/ce label)
PS Form 3811,February 2004 Domestic Return Receipt 102595-o2-lut_t5ao•
Postal U.S. Postal
CERTIFIED!ti • .. Only; Provided)No Insurance Coverage Provided) i _n
Ln
Er Er
r-1 Postage $ 471A'i 0011 a � ;Ln Postage $ $0.46 S
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fu Certified Fee $3, f) Ir a Certified Fee $3 0 1f1
'0 nj Postma 0 Return Receipt Fee I e` r PAC r
C3 Return Receipt Fee Here n C3 (Endorsement Required) Here
C3 (Endorsement Required) #�,. ��, �
C3 Restricted Delivery Fee a
Restricted Delivery Fee (Endorsement Required) v
C3 (Endorsement Required) f$0;00 I60L� p #0.01} 9\ d
...D Total Postage s Fees $ #6.11 04/05/2013 Total Postage&Fees $ $6,11 04/05/2013
ru Sent To 7ne-1
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`or ----�L�' d--SL .-°°Crry ware, +4 ------------o^Co Ca 9 t307 o�� L. PA �?Prg PS Form :rr ,r
PS Form 3800,August 2006 See Reverse tar Instructions - See Reverse for Instructions
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
April 5, 2013
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.
� isa Marie Coy e,Editor
SWORN TO AND SUBSCRIBED before me this
5 day of April, 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
r
CUMBERLAND LAW JOURNAL
NOTICE OF HEARING Camp Hill,PA 17011
In Re: Ownership of 1923 Rolls (717) 975-9446
Royce 20HP(Identification No.61116) Apr. 5
To Victoria Campbell
YOU ARE HEREBY NOTIFIED
that a civil action was brought
against you in the Court of Common
Pleas of the Ninth Judicial District of
the Commonwealth of Pennsylvania,
at Docket No. 2013-01488 by Harry
J. Tucci for a declaration of owner-
ship to and to quiet title to a 1923
Rolls Royce 20HP(ID#61 H6)in the
name of Harry J. Tucci. YOU HAVE
BEEN SUED IN COURT. If you wish
to defend against the claims of Harry
J. Tucci,you must,pursuant to the
March 27,2013 Order of the Honor-
able Thomas A. Placey,Judge of the
Court of Common Pleas of the Ninth
Judicial District of the Common-
wealth of Pennsylvania, appear at a
hearing to be held on the Petition of
Harry J.Tucci on May 2,2013 at 1:30
P.M.in Courtroom Number Six of the
Cumberland County Courthouse,
One Courthouse Square, Carlisle,
Pennsylvania. You are warned that
if you fail to appear the case may
proceed without you and a judgment
may be entered against you by the
court without further notice for the
relief sought in the Petition or for
any other claim or relief requested by
Harry J.Tucci.You may lose money
or property or other rights important
to you. You should take this notice
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
Lawyer Referral Service
32 S.Bedford St.
Carlisle,PA 17013
(717)249-3166
BRYAN W. SHOOK, ESQUIRE
Attorney for Harry J.Tucci
2132 Market Street
12
n e:F VWner-s up o
Royce 20HP(Identification No.61116)-TO`ictoria Camp-
RECORDING/FILING REQUESTED BY AND MAIL TO: bell.YOU ARE HEREBY NOTIFIED that a civil action was
brought against you in the Court of Common Pleas of the
Bryan W. Shook Ninth Judicial District of the Commonwealth of Pennsylva-
nia, at Docket No. 2013-01488 by Harry J. Tucci for a
2132 Market St. declaration of ownership to and to quiet title to a 1923 Rolls
Rogce 20HP(ID @ 61H6) in the name of Harry J.Tucci.
Camp Hill, PA 17011 YOU HAVE BEEN SUED IN COURT.If you wish to defend
against the claims of Harry J.Tum,you must,pursuant to
the March 27,2013 Order of the Honorable Thomas A.Placey
Judge of the Court of Common Pleas of the Ninth Judicial
PROOF OF PUBLICATION District of the Commonwealth of Pennsylvania appear at a
(California Code of Civil Procedure 2010,2015.5) hearing to be held on the Petition of Harry J.hued on May
2,2013 at 1:30pm in Courtroom Number Six of the Cumber-
land County,Courthouse,One Courthouse Square,Carlisle,
Pennsylvania.You are warned that if you fail to appear the
case may proceed without you and a judgment may be
STATE OF CALIFORNIA entered against you by the court without further notice for
County of Los Angeles the relief sought in the Petition or for any other claim or
relief requested by Harry J.Tucci.You may lose money or
property or other rights important to y ou.You should take
this notice to your law er at once.If you do not have a
lawyer or cannot afford one,go to or telephone the office
I am a citizen of the United States and a resident of the set forth below to find out where you can get legal help.
Cumberland County Lawyer Referral Service, 2 Liberty
Ave.,Carlisle,Pennsylvama 17013-(717)249-3166-Bryan
aforesaid County. I am over the age of eighteen years (18) W.Shook,Esquire,2132 Market Street,Camp Hill,Penn-
sylvania 17011 - (717) 975-9446 Attorney for Harry J.
years, and not a party to or interested in the above-entitled eei.
matter. I am the Principal Clerk of the printer of the
LOS ANGELES TIMES, a newspaper of general
circulation,printed and published DAILY in the City
of Los Angeles, County of Los Angeles and which
newspaper was adjudged a newspaper of general circulation by
the Superior Court of the County of Los Angeles, State of California,
under the date of April 28, 1952, Case Number 598599.
The notice, a true and correct copy of which is annexed, has been
published in each regular and entire issue of said newspaper on the
following dates, to wit:
TUESDAY; APRIL 2, 2013
TUESDAY; APRIL 9, 2013
TUESDAY; APRIL 16, 2013
I certify(or declare)under penalty of perjury under the laws of the State of California
that the foregoing is true and correct.
Dated at Los Angeles, California,
This 16th day of April, 2013
S nature
Jessica Winn
Los Angeles Times Page 1 of 2
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For Sale NOTICE OF HEARING-In Re:Ownership of 1923 Rolls Royce 2oHP(Identification No.61H6)-To Victoria Campbell.YOU ARE
Antiques HEREBY NOTIFIED that a civil action was brought against you in the Court of Common Pleas of the Ninth Judicial District of the
Commonwealth of Pennsylvania,at Docket No.2013-01488 by Harry J.Tucci for a declaration of ownership to and to quiet title to a
Arts&Crafts 1923 Rolls Royce 2oHP(ID#61H6)in the name of Harry J.Tucci,YOU HAVE BEEN SUED IN COURT.If you wish to defend
Auto Parts against the claims of Harry J.Tucci,you must,pursuant to the March 27,2013 Order of the Honorable Thomas A.Placey,Judge of
the Court of Common Pleas of the Ninth Judicial District of the Commonwealth of Pennsylvania,appear at a hearing to be held on
Baby&Kid Stuff the Petition of Harry J.Tucci on May 2,2013 at 1:30pm in Courtroom Number Six of the Cumberland County,Courthouse,One
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judgment may be entered against you by the court without further notice for the relief sought in the Petition or for any other claim
Boats or relief requested by Harry J.Tucci.You may lose money or property or other rights important to you.You should take this notice
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
Books&Magazines where you can get legal help.Cumberland County Lawyer Referral Service,2 Liberty Ave.,Carlisle,Pennsyvlania 17013-(717)249-
Building Supplies& 3166-Bryan W.Shook,Esquire,2132 Market Street,Camp Hill,Pennsylvania 17011-(717)975-9446-Attorney for Harry J.Tucci,
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IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1923 ROLLS ROYCE 20HP CUMBERLAND COUNTY, PENNSYLVANIA
(Identification Number 61 H6)
No: 2013-_j��� - CIVIL TERM
ORDER
AND NOW, this the 2 day of 2013, upon
consideration of the Petition of the Harry J. Tucci for a declaration of ownership of a
certain 1923 Rolls Royce 20HP, the Court hereby awards exclusive ownership of one
1923 Rolls Royce 20HP automobile (Vehicle Identification Number: 61H6) to Harry J.
Tucci and the right, title, and interest of any other person to said vehicle is hereby
extinguished. The Commonwealth of Pennsylvania, Department of Transportation shall
accept this Order as evidence of ownership in lieu of a Certificate of Title. Harry J.
Tucci 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.
BY THE CO R
J.
PL_A6(-_-11
DISTRIBUTION LEGEND:
Bryan W. Shook, Esquire ,
2132 Market Street
Camp Hill, Pennsylvania 17011 �C=
(717) 975-9446 r*t °
1
Victoria Campbell r�n�
24 Silver Spur Lane N
Bel Canyon, California 91307
Z}e-) y -"
CD
The Rolls-Royce Foundation 401 C_ • `;
191 Hempt Road l '` x
Mechanicsburg, Pennsylvania 17050 D�1/L4c�L