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HomeMy WebLinkAbout13-1747 Supreme Co nnsylvania Con fcro)" leas For Prothonotary Use Only: t f Docket No: CU LA li County t3 !7 `7 The information collected on this form is used solely j6r court administration purposes. This frrrrn does not supplement or replace the fling and service ofpleadings or other papers as required by law or rules ofcourt. - Commencement of Action: S 0 Complaint 0 Writ of Summons El Petition [3 Transfer from Another Jurisdiction Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T AACA MUSEUM, INC. I Are money damages requested? 0 Yes lM No Dollar Amount Requested: Swithin arbitration limits (check one) Doutside arbitration limits N Is this a Class Action Suit? 0 Yes ll No Is this an MDJAppeal? 0 Yes El No A Name of Plaintiff/Appellant's Attorney: Bryan W. Shook, Esquire(ID#203250)2132 Market St Camp Full PA 17011 0 Check here if you have no attorney(;are a Self-Represented [Pro Sej Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. if you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include.ludgments) CIVIL APPEALS © Intentional 0 Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection:Credit Card i Board of Assessment Q Motor Vehicle 0 Debt Collection:Other 0 Board of Elections 0 Nuisance Dept.of Transportation 0 Premises Liability Statutory Appeal:Other S © Product Liability (does not include mass tort) 0 Employment Dispute: -- --- ---- [D Slander/Libel/Defamation i Discrimination ------- C 0 Other: 0 Employment Dispute:Other 0 Zoning Board -- -- — -- 0 Other: 0 Other: 0 MASS TORT _ -- 0 Asbestos N 0 Tobacco —�-- --- 0 Toxic Tort-DES 0 Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste 0 Other; 0 Ejectment 0 Common Law/Statutory Arbitration 0 Eminent Domain/Condemnation 0 Declaratory Judgment 0 Ground Rent Mandamus 0 Landlord/Tenant Dispute Non-Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY I 0 Mortgage Foreclosure:Commercial 13 Quo Warranto Q Dental 0 Partition 0 Replevin © Legal 0 Quiet Title n Other: 0 Medical 0 Other: Petition for Declaration of 0 Other Professional: I I wners ip o do donated vehi Updated 11112011 -14 Bryan W.Shook,Esquire L YLVA.`"iA ID#203250 2132 Market Street Camp Hill,Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 BShookO-di)lqlaw.com Attorney for AACA Museum,Inc. IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS 1940 FORD DELUXE CONVERTIBLE : CUMBERLAND COUNTY, PENNSYLVANIA {Identification Number 185864852) : No: 2013- -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 Bryan W.Shook,Esquire ID#203250 2132 Market Street Camp Hill,Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 BShook0_dolplaw.com Attorney for AACA Museum,Inc. IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS 1940 FORD DELUXE CONVERTIBLE : CUMBERLAND COUNTY, PENNSYLVANIA (Identification Number 185854852) No: 2013- - CIVIL TERM PETITION FOR DECLARATION OF OWNERSHIP AND NOW comes the AACA Museum, Inc., who petitions this Honorable Court, pursuant to 42 Pa. C.S. § 7531, et seq. for a Declaration of Ownership of a 1940 Ford Deluxe convertible automobile (Vehicle Identification Number: 185854852) 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 AACA Museum, Inc. and in support thereof respectfully avers: 1. Your Petitioner is the AACA Museum, Inc., a Pennsylvania non-stock, not for profit, corporation with its principal offices and place of business being located at 161 Museum Drive, Hershey, Dauphin County, Pennsylvania 17033. 2. The AACA Museum, Inc. is requesting a Declaration of Ownership relative to a certain 1940 Ford Deluxe Convertible automobile (Vehicle Identification Number: 185854852) (hereinafter sometimes referred to simply as the "automobile") which was so graciously donated to the AACA Museum, Inc. by MBNA America Bank, N.A. in 2002, (A true and correct copy of an August 12, 2002 confirmatory letter from MBNA to the AACA Museum, Inc. is attached hereto, made part hereof and marked as Exhibit "A"). 3. Venue is proper in this county as Petitioner, AACA Museum, Inc. consistently does business in Cumberland County through its participation with Auctions America by RM and Carlisle Events' productions at the Carlisle Fairgrounds and the vehicle in question may be deaccessioned in Cumberland County. 4. Upon information and belief, in 2005, MBNA America Bank, N.A. was acquired by Bank of America. 5. Not much is known of the history of the subject 1940 Ford Deluxe convertible prior to the vehicle being obtained by the AACA Museum, Inc. in 2002. 6. Although the letter from MBNA (Exhibit "A") references that Mr. Neil Criscuolo would forward the necessary documents to transfer the ownership of the subject vehicle, it appears, through a search of the records of the AACA Museum, Inc., that this did not happen. 7. Because MBNA has been acquired by Bank of America and further because so much time has passed since the time of donation, the AACA Museum, Inc. is without alternative but to petition this Honorable Court for a declaration of ownership relative to the subject 1940 Ford Deluxe Convertible sufficient to permit Penndot to issue a certificate of title to the 1940 Ford Deluxe Convertible in the name of the AACA Museum, Inc. 8. 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. 9. A search of the United States Department of Justice's National Motor Vehicle Title Information System (NMVTIS) was performed on March 1, 2013 and the search returned that the subject vehicle was not found in the NMVTIS database. (A true and correct copy of the March 1, 2013 NMVTIS search results are attached hereto, made part hereof and marked as Exhibit "B"). 10.A search of the National Insurance Crime Bureau (NICB) VINCheck database was performed on March 1, 2013 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 the March 1, 2013 NICB search results are attached hereto, made part hereof and marked as Exhibit "C"). 11.The undersigned caused a search of the records to be conducted by the Commonwealth of Pennsylvania, Department of Transportation, Bureau of Motor Vehicles on March 1, 2013 in which the Bureau returned a finding that no record of the aforementioned vehicle exists in their files. (A certified original of the March 1, 2013 Certificate and Attestation is attached hereto, made part hereof and marked as Exhibit I'D"). 12.There is no indication that there is anyone besides the AACA Museum, Inc. who claims ownership of this 1940 Ford Deluxe Convertible automobile. 13.The subject vehicle has been at the AACA Museum in Hershey, Pennsylvania for over ten years. 14,During the past ten years, the vehicle has been publically displayed and featured in both national and regional publications throughout the collector and antique vehicle hobby, 15.The failure to be able forward a Certificate of Title to Penndot for processing does not operate to prevent the transfer of ownership of the vehicle herein. Dept. 16.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. Steinard-Hannon Motor Co., 97 Pa. Super. 19, 23 (1929) See also Dept of Transp. v. Walker at 1082. 17.The entire action is largely procedural and administrative, as pursuant to 13 Pa. C.S.A. § 2401(2), AACA Museum, Inc. and MBNA America Bank, N.A., took the steps necessary to transfer ownership of the automobile as between themselves as outlined more specifically on the attached confirmatory letter. See Semple v. 18.The entering of a declaration of ownership in this case would serve to permit AACA Museum, Inc. 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, AACA Museum, Inc. respectfully requests that this Honorable Court declare that AACA Museum is the owner of the 1940 Ford Deluxe convertible automobile (Vehicle Identification Number: 185854852). Respectfully Submitted: Date: 2; 9,o)013 Bryan . Shook, Esquire I D # 203250 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 975-9446 BShook -dplglaw.com Attorney for AACA Museum, Inc. FIF Neil A.Criscuoto �a director of Fleet Services A M E R C A® MBNA America Bank,N.At9 Wilmington, Delaware 19884-2212616 1302)457-4810 August 12, 2002 William H. Smith Executive Director Antique Automobile Club of America Museum, Inc. 501 West Governor Road Hershey, PA 17033 Dear Mr.Smith: I am pleased to inform you that MBNA is donating the following vehicles to the Antique Automobile Club of America Museum as stated in the previous memo dated July 1, from Basil Maas: * 1941 Chevrolet Deluxe Convertible * 1940 Ford Deluxe Convertible Mr. Neil Criscuolo from MBNA Fleet will be forwarding the necessary documents to transfer ownership of this vehicle. For further questions please contact Chip Romano r~7a,(302) 457-3128. 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In Order io—Imue with our in err dl' Y 4 vas to whether a VIN is in the data teas¢, "�. you most agree to and accept these Terms and Conditions of Use., t= pups:liwy-w.nicb.org,/the ft—and_fraud aw are ness/vincheck 3!1 i2 013 VinCheck Page 4 of? e I',".R :—is ma W °.he p,- ,dr i:_„?error hf_ 1?rY'C7d lilJtes ,.�`tip .�mCEri r%?52 r;l("ha-. https./.'www.nicb.orgttheft_and__fraud-awareness/` ,incheek 3/1/2013 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION SAFETY ADMINISTRATION HARRISBURG, PA 17123 3/01/13 15:07 BRYAN W SHOOK ESQUIRE 130601132000110 002 2132 MARKET STREET CAMP HILL PA 17011-0000 VIN : 185854852 NO RECORD FOUND CERTIFICATE 8 ATTESTATION I hereby certify that Anita M. Wasko, Director of the Bureau of Motor Vehicles of the Department of Transportation, is the legal custodian of the Motor Vehicle Records of the Pennsylvania Department of Transportation. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL OF THIS DEPARTMENT ON THE ABOVE DATE IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA. Consolidated Statutes. /JAMy ,• . BARRY J. SCHOCH, P.E. SECRETARY OF TRANSPORTATION I hereby attest that the Bureau of Motor Vehicles has received your request for information. We are not able to provide this information because the record you requested, as indicated below, does not exist in our files. In compliance with your request, I certify that I have caused a search to be made of the files of the Department of Transportation. VIN : 185854852 CERTIFIED IN ACCORDANCE WITH SECTION 6103 OF THE JUDICIAL CODE, TITLE 42, PA. Consolidated Statutes. ANITA M. WASKO, DIRECTOR BUREAU OF MOTOR VEHICLES VERIFICATION I hereby verify that the statements of fact made in the foregoing documents are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Date: r Title: C H h AACA Museum, Inc. IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS 1940 FORD DELUXE CONVERTIBLE : CUMBERLAND COUNTY, PENNSYLVANIA (Identification Number 185854852) 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, Certified, First Class, postage prepaid, return receipt requested, addressed as follows: Bank of America 100 North Tryon Street Charlotte, North Carolina 28255 Certified Mail # 7012 1640 0002 1546 8858 Respectfully Submitted: Date: 2izJ �! 013 Bryan VVShook, Esquire ID # 203250 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 975-9446 BShook _dglglaw.com IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS 1940 FORD DELUXE CONVERTIBLE : CUMBERLAND COUNTY, PENNSYLVANIA (identification Number 185864852) : No: 2013- 1"7q-7 - CIVIL TERM ORDER AND NOW, this the 1 day of fln 4" 2013, upon consideration of the Petition of the AACA Museum, Inc. for a declaration of ownership of a certain 1940 Ford Deluxe Convertible which was donated to the AACA Museum, Inc, by MBNA America Bank, N.A. on August 12, 2002, the Court hereby awards exclusive ownership of one 1940 Ford Deluxe Convertible (Vehicle Identification Number:- 185854852) to AACA Museum, Inc. 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. AACA Museum, Inc. 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 T COURT: rn UM 7= rn— CZ QC'. PSTRIBUTION LEGEND: Aryan W. Shook, Esquire eank of America 2132 Market Street 100 North Tryon Street Camp Hill, Pennsylvania 17011 Charlotte, North Carolina 28255 (717) 975-9446 `r� OTtiO'�OA `t' O13 °� 22 AM 55 Timothy M. O'Connor, Esquire ������SYLVAR� A�� Bank of America,N.A. Mail Code:TX1-792-15-03 901 Main Street Dallas,Texas 75202 Telephone: (214)209-2771 Facsimile: (212)548-3561 Timothy.M.O'Coruior @bankofamerica.com Attorney for Bank of America,N.A. IN RE: OWNERSHIP OF, : IN THE COURT OF COMMON PLEAS 1940 FORD DELUXE CONVERTIBLE : CUMBERLAND COUNTY,PENNSYLVANIA (Identification Number 185854852), : CAUSE NO. 2013-1747- CIVIL TERM ORIGINAL ANSWER AND DISCLAIMER OF INTEREST Defendant Bank of America, N.A. answers the Petition for Declaration of Ownership of AACA Museum, Inc., as follows: I. GENERAL DENIAL Bank of America generally denies the material allegations of Petitioner's Petition for Declaration of Ownership. This general denial shall be deemed to apply to all amended and supplemental petitions filed by AACA Museum,Inc., if any. H. DISCLAIMER OF INTEREST Defendant Bank of America,N.A. answers the Petition for Declaration of Ownership, as follows: Bank of America, N.A., a defendant in rem herein, by its undersigned representative and for the limited purpose of plaintiffs allegations only, disclaims any right, title or interest that Bank of America, N.A. has in and to the property as more specifically described in petitioner AACA Museum, Inc.'s Petition for Declaration of Ownership filed with the Court on April 4, 2013. Bank of America, N.A. prays that said plaintiff take nothing against it, and that the action be dismissed as to this answering Defendant in rem, and that this Defendant in rem be dismissed from further appearances or obligations in this matter. Res ' e Dated: May 14,2013 of Conn r, of America,N.A. 01 Main Street Dallas, Texas 75202 Telephone: (214)209-2771 Timothy.M.O'Connor@bankofamerica.com Authorized Representative for BANK OF AMERICA,N.A. CERFICICATE OF SERVICE c ,a non-attorney, states that he/she has caused a copy of the foregoing to be sent by First Class U.S.Mail to Bryan W. Shook,Dethlefs-Pykosh Law Group, LLC,2132 Market Street, Camp Hill,Pennsylvania 17011,Attorneys for AACA Museum,Inc., on this A day of May, 2013. l ORIGINAL ANSWER AND DISCLAIMER OF INTEREST Page 2 t' t T SENDER: COMPLETE SECTION COMPLETE SECTION ON DELIVERY ■ Complete items 1,2,and 3.Also complete A. Received by(Please Print Clearly) B. Date of Delivery j item 4 if Restricted Delivery is desired. ■ Print your name and address on the reverse So that we can return the card to you. C. Signature ■ Attach this card to the back of the mailpiece, X 0 Agent j' or on the front if space permits. ❑Addressee 1. Article Addressed to:. D. Is delivery address different from item 1? 0 Yes If YES,enter delivery address below: O No 71-' Bryan W.Shook,Esq. r, Dethlefs-Pykosh Law Group,LLC 2132 Market Street 3. S�er�eeTType Camp Hill,Pennsylvania 17011 I Cerfied Mail ❑ Ex s Mail I ` _r. ❑ Registered eturn Receipt for Merchandise I ❑ Insured Mail 0 C.O.D. 4. Restricted Delivery?(Extra Fee) ❑Yes 2. Article Number 7011 0110 3030 3293 4793 =5 I PS Form 3811,tJuly 1999 Domestic Return Receipt 102595-00W 0952 110LT e!ueAlASUuad'II!H dweD ;aaalS jaNjeN ZSTZ ------------ Iv xoa Od Jo -J —J Jll'dnolg nnel ys0N1,d-s}aly1aa dy'laa jyc p C3 � x -bs3 jooyS'Mue%g E, L d CD of JUGS � � $, S88=1 g a6elsod lelol � � COD L-j (pejlnbed 1uaw9si0pu3) O O rA O ead tiaAllaO P813111s8H o -! rn O e�eH (peilnbad 1u9we9J0pu3) C3 C wewiso 99=1 Id wn18a d 889=1 P8!P90 O c O $ e6e4s0d rU C3 C3 ru -D —0 w w 0 Z O• Ut CD w W