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HomeMy WebLinkAbout13-1751 Supreme Co nnsylvania Co U f=C II leas For Prothonotary Use Only: t Docket No: y+ s County /7_ I75/ &tiI The information collected on this_form is used solely t , or cotert administration purposes. Thisforrn does not supplement or replace the filing and service ofpleadings or other-papers as required by law or rules of court. Commencement of Action: —� Complaint D Writ of Summons El Petition Transfer from Another Jurisdiction Q Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: AACA MUSEUM, INC. I Dellar Amount Requested: x❑within arbitration limits T I Are money damages requested? El Yes El No � _ (check one) Dout i de arbitration limits � Is this a Class Action Suit? Q Yes 9 No Is this an MDJAppeul? 13 Yes El No A " Name of Plaintiff/Appellant's Attorney: _Bryan W. ,hook,Esquire (ID#203250)2132 Market St Camp Hill PA 17011 © Check here ifyou have no attorne,, tare a Self-Represented 1Pro Sel Litigant) — Nature of the Case: Place an"X"to the left ofthe 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 Judgments) CIVIL APPEALS © Intentional ® Buyer Plaintiff Administrative Agencies Malicious Prosecution Q Debt Collection:Credit Card D Board of Assessment Motor Vehicle Debt Collection:Other Board of Elections Nuisance _ Dept.of Transportation Premises Liability _ _ _ Statutory Appeal:Other S Product Liability (does not include E ► mass tort) � Employment Dispute: — - Discrimination Slander/Libel/Defamation - -------- C 0 Other: ! Employment Dispute Other Zoning Board T - — --- -- ---- D Other: [� Other: Q I MASS TORT _ — 0 Asbestos N Tobacco ---- --- -- -- Toxic Tort-DES Q Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS © Toxic Waste Other: Ejectment 0 Common Law/Statutory Arbitration Bi [3 Eminent Domain/Condemnation Q Declaratory Judgment — Ground Rent Mandamus — Landlord/Tenant Dispute Non-Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Q Mortgage Foreclosure:Commercial Quo Warranto © Dental © Partition 13 Replevin Legal Quiet Title 0 Other: Medical Other: Petition for Declaration of r] Other Professional: _—_ _ — wnership o donated vehu4 Updated 1/1/2011 „{.,., CUH,9EPxL c'Lswid i PEK,rS YLVI-„ ..r, Bryan W.Shook,Esquire ID#203250 2132 Market Street Camp Hill,Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 BShookadolglaw.com Attorney for AACA Museum,Inc. IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS 1959 LINCOLN CAPRI : CUMBERLAND COUNTY, PENNSYLVANIA FOUR DOOR HARDTOP (Identification Number H9YA420729) : 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 32 S. Bedford St. CARLISLE, PA 17013 (717) 249-3166 Ir”3 6 Bryan W.Shook, Esquire ID#203250 2132 Market Street Camp Hill,Pennsylvania 17011 Telephone—(717)975-9446 Fax—(717)975-2309 BShook(&dr)lalaw.com Attorney for AACA Museum, Inc. IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS 1959 LINCOLN CAPRI : CUMBERLAND COUNTY, PENNSYLVANIA FOUR DOOR HARDTOP (Identification Number H9YA420729) : 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 1959 Lincoln Capri four door hardtop automobile (Vehicle Identification Number: H9YA420729) 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 1959 Lincoln Capri four door hardtop automobile (Vehicle Identification Number: H9YA420729) (hereinafter sometimes referred to simply as the "automobile") which was so graciously donated to the AACA Museum, Inc. by Michael C. Sauta and Donald Richard McGettigan, Jr. by deed of gift dated December 13, 2010. (A true and correct copy of the December 13, 2010 Deed of Gift from Messrs. Sauta and McGettigan 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. At the time the vehicle was donated to the AACA Museum, Inc., it was owned by both Michael C. Sauta and Donald Richard McGettigan, Jr. and was duly registered in the State of New Hampshire. (A true and correct copy of the New Hampshire registration certificate is attached hereto, made part hereof and marked as Exhibit "B"). 5. The reverse of the New Hampshire registration certificate is endorsed with the following statement: Transfer ownership of one 1959 Lincoln VIN # H9YA420729 to the AACA Museum, Inc on December 13, 2010. /s/ Michael C. Sauta /s/ Donald R McGettigan Jr 6. The AACA Museum, Inc., is unable to obtain a title to the subject vehicle because they do not possess sufficient documentation from the State of New Hampshire so as to permit Penndot to issue a Certificate of Title in the name of the AACA Museum, Inc. 7. 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 1959 Lincoln Capri sufficient to permit Penndot to issue a certificate of title to the 1959 Lincoln Capri 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 found in the NMVTIS database and that it was last registered in the State of New Hampshire in 2009. (A true and correct copy of the March 1, 2013 NMVTIS search results are attached hereto, made part hereof and marked as Exhibit "C"), 10.A search of the National Insurance Crime Bureau (NICB) VINCheck database was performed on March 3, 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 3, 2013 NICB search results are attached hereto, made part hereof and marked as Exhibit "D"). 11.There is no indication that there is anyone besides the AACA Museum, Inc. who claims ownership of this 1959 Lincoln Capri four door hardtop automobile. 12.The subject vehicle has been at the AACA Museum in Hershey, Pennsylvania for over two years. 13.During the past two years, the vehicle has been publically displayed at the Museum. 14.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. of Transp. v. Walker, 584 A.2d 1080 (Pa. Commw. Ct. 1990). 15.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, 16.The entire action is largely procedural and administrative, as pursuant to 13 Pa. C.S.A. § 2401(2), AACA Museum, Inc. and Messrs. Sauta and McGettigan, Jr., took the steps necessary to transfer ownership of the automobile as between themselves as outlined more specifically on the attached Deed of Gift. See Semple v. State Fan-n Mut. Auto. Ins. Co., 215 F.Supp. 645 (E.D. Pa. 1963). 17.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 1959 Lincoln Capri four door hardtop automobile (Vehicle Identification Number: H9YA420729). Respectfully/Sub1mitte Date: 02013 Bryan 4l. Shook, Esquire ID # 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. 161 Museum Dr. Hershey,PA 17033 Phone: 717-566-7 100 Fax: 717-566-7300 �er�,��v.aacamuseum.or� to the AA CA WSEUM,Inc. Be it Known That: Michael C. Sauta 31 Foster Road,Milford,.NH 03055 Hereby grant unto the.4.4C.4 MUSEUM Inc., hereafter"Museum," all my right, title an interest in and to the object(s)described herein,and hereby unconditionally waive all of my present or future rights in,to or over the described object(s), its use or disposition. I expressly warrant that I have sole free, clear and unencumbered title in and to said objects), and that I have authority to make this gift. I understand that the Museum,a non-profit Pennsylvania corporation,accepts this gift without any obligation or condition that the object be exhibited,either temporarily or permanently, or that the Museum keep it permanently. The Museum may restore, reconstruct, refurbish or repair any part of this gift. I further grant to the Museum all rights of reproduction,publication,copyright, or such other intellectual property rights that I may have in said property. -The property that is subject to this Deed of Gift is described as follows:- Antique Vehicle. 1959 Capra Four-Door Hardtop; VIN. H9Y420729 Car is black in color with a two-tone interior; 430 cad V8 engine, automatic transmission; odometer reads 5.I,546; car is in restored and in good overall condition. Car is owned by the donor, but he has a second name (Donald Richard McGettigan, Jr.) listed on the registration. By signing below, Mr. McGettigan acknowledges that he is aware of and in agreement with this ve "le being donated to the Museum. ' ,� W J Donald Richard McGe ,Jr. .Date I have read and fully understand the Deed of Gift Provisions attached hereto,and I agree that my gift shall be subject to said provisions in all respects. This gift is being made pursuant to my historical interest in and appreciation for the work of the AACA 11LISELiM, Inc.. IN WITNESS WHEREOF I have hereunto set my hand and seal this _day of 2010 Donor Subsc�l °to and swor to before me this day*of a/ &O 2 0 f�. `rotary Public KATHY L PAEiM My commission expires PWA°-NOW"W 4,2015 Smithsonian Institution AkfAiations Program DEED OF GIFT PROVISIONS Acceptance of gifts by the ACA AJUSEUM,Inc. Board of Directors is subject to the following: L The value of the gift may be deductible from taxable income in accordance with and limited by the provisions of the Federal Income Tax laws. The Museum assumes no responsibility for the valuation of a donation received or for obtaining any required appraisals, each of which are the sole responsibility of the donor. it e uo mst b d ee d h2. an w restrictions or ty�+ conditions as t e ispost io . s or damage to the property up ta,t t e Z ts delivery to the Museum or designated Museum storage site. -- � 3. The Museum maintains three types of collections.The Museum will attempt to designate the disposition of the °iji at the irnc of receipt, of the doratEor, hCis=a rdr the Miis-i m will not auarantee`hat the gift will always retain a particular designation or that the categories of designated gifts will not be changed. A. ACCESSIONED: I. EXHIBIT COLLECTION: Relation directly to the Museum's purpose and of the finest quality available;used for exhibit and research. 2. STUDY COLLECTIOIti:Worn or duplicate items of significant historical value used for teaching,study,or loan,and falling within the Museum's purposes. B_ NOM-ACCESSIONED: 1. MATERIAL COLLECTION:Of a documentary nature with little intrinsic value,used for references purposes,or items of an expendable nature,subject to modification,for operational use or for use as exhibit support material. 4. Objects in the accessioned collections will be retained permanently if they continue to be relevant and useful to the purposes and programs of the Museum,and if they can be properly stored,preserved and used. In no event,shall objects donated to the AACA Museum subject to the provisions of Section 501.c.3 of the U.S. Internal Revenue Services Code be disposed of sooner than a thirty-six(36)month period after receipt unless otherwise provided for in the provisions of Section 501.c.3 of the U.S. Internal Revenue Services Code. The Collections Management Committee will determine, with the approval of the Board of Directors,which objects are to be de-accessioned.Disposal may be through exchange,donation or sale. S. Because of limited gallery space and the policy of changing;exhibits,the Museum cannot promise the permanent display of any object. Donor Must Initial After Reading This PaguA01 Date ° 1 1 . State of New Hampshire RETAIN FOR TAX PURPOSES P REGISTRATION CERTIFICATE STATE FEES j patios ce ific to not walid for title oy;goses:_Ai;rg;CQnt tazes_for whle�i„dm L EIe hay@`•e., en osaic 0642AO029891 PLATE 59LINC TYPE IANTI CD 6 VSNO837510 Gvw 5750 E REGISTRATION SS0,00 X 0$!r 31/G0�1 SURCHARGE 50.00 MAKE LINO MODEL CAPRI BOY STL 4DSED CLR BLK P TITLE $0.00 YEAR 1959 F G AXLES 2 LP NEW 5100 VIN H9YA420729 TOTAL DUE $46.00 '. PPIf PP TYPE SPir SP TYPE MUNICIPAL FEES 00&1D _LASTNAJwfE SUFFIX_FIRSTNA.ME M MCSrMILLS 12 3 515100 '- w 08/2811962 SALIi'A MICHAEL C MOS!MILtS O O KOO N 07/1911963 MCGET71GAN JR DONALD RICHAR 'ai PERMIT FEE $0.00 R �� i' 1t ;`••Lf f AGENT 53°00 S a xi is a3`s� CLERK $;.00 RENEW REGISTRATION � LOCALTITLE $000 - NOT VALID WITHOUT DIRECTOR'S SEAL TRANSFER $0.00 ATTENTION: TRANSFER CREDIT 50,00 OBSEP2010 5003.0001 0642 9983 1$46.00 WASTE $0.00 RSA 266:1 IV Provides that neMY TRANSPORTATION $0 A0 j registered vehicles and vaNdes PARKING TRUST $0.00 i4 of which the ownership has been LEGALADDRESS MICHAEL C SAUTA transferred must bs inspec ed j 31 FOSTER ROAD within 10 consecutive days of IN TOTAL DUE $19A0 MILFORD NH 03055 31 FOSTER ROAD registrabon date stamped on the MUNICIPAL COMMENT: I MILFORD NH 03055 registration rcraseda �a new vehicle is purchased at retai from ': Receipt:119231 € --- 7 a licensed 1wier the vehicle 'i € CHANGE ADDRESS IN SPACE ABOVE must be inspected np later than PUrsuan`,to RSA 261'55, the Director' 30 days after tie date o'transfer. must be notifad In writing within 10 days ;a+s WR-ICA ON is slaN-D A V Avv AooictoL e f wnen moving from the address printed X dRIXtWlT:QV 5 OffEAFD -1N!3EA �iNKTY O% +� : Rila+vsaa;usvirttas; o�nmraa•scocv on the•egisiralioncertificate. 7 �� �1� ✓,i,° rt i!/j0 C”! C?N 1 G` rrY t -,v' �!'11 tl f '/Al �o�t���� r 70 ML 5 F-om 7x/c, 001 DECeM,94�, acs 10. 1. II��, Page 1 of 5 NMVTIS MULTI-STATE VEHICLE HISTORY REPORT VIN H9YA420729 This data was originally accessed on 2013-03-03 13:22:04.665 EST at which time it was current with the National Motor Vehicle Title Information System(NMVTIS) wi.n,..w.jW�l Yh�ill�fi��ii6'-"ul�i�iVtl�Ii�VIifW4511� 'i'IYif1f lfW�4�i�i i ,,u A"Brand"defines the status of a vehicle, such as Theft, Flood, Salvage or Rebuilt.A brand is carried with the title as the vehicle travels from state to state.There are over 250 brands recognized by NMVTIS that can be categorized by type. BRAND CATEGORY NMVTIS SEARCH RESULT Total Loss No Brand Reported Salvage 9 No Brand Reported Disclosed Damage No Brand Reported Bond No Brand Reported Flood No Brand Reported CARS/Cash for Clunkers No Brand Reported Gray Market No Brand Reported Junk No Brand Reported Manufacturer Brand No Brand Reported New/Re-Issued VIN No Brand Reported Odometer No Brand Reported Rebuilt/Re aired/Reconstructed P No Brand Reported Dismantled No Brand Reported https:Happs.add 123.com/NmvtisPpiWeb/nmviisppiweb/NmvtisPrint?sessionId=29VOEUHC... 3/3/2013 Page 2 of 5 Rental/Taxi/Police No Brand Reported Agricultural/Logging Vehicle No Brand Reported Title Copy No Brand Reported Antique/Classic No Brand Reported Undisclosed Lien No Brand Reported https:Happs.add l 23.com/NmvtisPpiWeb/nmvtisppiweb/NmvtisPrint?sessionld=29V OEUHC... 3/3/2013 Page 3 of 5 Current Title Information State VIN Issue Date Odometer New Hampshire H9YA420729 09/04/2009 EXEMPT Historical Title Information State VIN Issue Date Odometer New Hampshire H9YA420729 07/20/2004 EXEMPT If you need more information, please contact the State of New Hampshire by visiting http//ww�v.nh.gov/safety.fdivisions/dmvlforms/dsmv505.pdf. Reporting Reporting Entity Date Vehicle intended for Vehicle Occurrence Information Obtained Export? Disposition No Junk/Salvage Reportings Found 1Mi Reporting Occurrence Reporting Entity Information Date of Total Loss Declaration or Date Total Loss Claim Paid No Total Loss Reportings Found https:Happs.add 123.com/NmvtisPpi Web/nmvtisppiweb/NmvtisPrint?sessionId=29V OEtJHC... 3/3/2013 . Page 4of5 Lien Count There are no liens reported for this vehicle. Lien data does not include information on all motor vehicles in the United States because not all lien holders provide lien information nuADD's data provider KJM\/T|S Consumer Access pMDdU[t 08C|aiDle[ The National Motor Vehicle Title Information System (NMVTIS)is an electronic system low that contains information on certain automobiles titled in the United States. NMVTIS is intended to serve as a reliable source of title and brand history for automobiles, but it does not contain detailed information regarding a vehicle's repair history. All states. insurance companies, and junk and salvage yards are required by federal law to regularly report information to NMVTIS. However, NMVTIS does not contain information on all motor vehicles in the United States because some states are not yet providing their vehicle data to the system. Currently,the data provided to NMVTIS by states is provided in a variety of time frames;while some states report and update NMVTIS data in"real-time"(as title transactions occur), other states send updates less frequently, such as once every 24 hours or within a period of days. Information on previous, significant vehicle damage may not be included in the system if the vehicle was never determined by an insurance company(or other appropriate entity)to be a"total loss"or branded by a state titling agency. Conversely, an insurance carrier may be required to report a"total loss"even if the vehicle's titling-state has not determined the vehicle tobe''ee|vage^or')unk''� Before making a decision to purchase a vehicle, consumers may wish to obtain an independent vehicle inspection, a Nk0VT|S Vehicle History Report(from an approved NMVT|S data provider look for the NMVT|S|ogo) and consult other available vehicle information resources. The information inNMVT|SINCLUDES: ' Information from participating state motor vehicle titling agencies. ~ Information on outomnbi|oo, buoeo,hucks, motoo9dau, recreational vehicles, motor homes, and tractors. NMVTIS may not currently include commercial vehicles if those vehicles are not included in a state's primary database for title records(in some states,those vehicles are managed by a separate state agency), although these records may be added atu later time. ~ |nfonnadonon''bnundy''app|iedtnvohio|aypmvidndbyparticipatingotytemotorvehide1iUinAagonoies. Brand types and definitions vary by state, but may provide useful information about the condition or prior use of the vehicle. ' Most recent odometer reading m the state's title record. ' Information from insurance companies, and auto recyclers, including junk and salvage yards,that is required by law to be reported to the system, beginning March 31, 2009, This information will include if the vehicle was determined tobea"total loss"byan insurance carrier. ~ Information from junk and salvage yards receiving a"cash for clunker"vehicle traded-in under the Consumer Assistance tn Recycle and Save Act ofJO0S(CARS) Program. Consumers are advised to visit www.vehic|ehistory.gov for details on how to interpret the information in the system and understand the meaning of various labels applied to vehicles by the participating state motor vehicle titling agencies. ' ADD CODsU0MB[ Access Disclaimer Auto Data Direct, Inc. is a"read-only portal"of data stored in the NMVTIS databases, Data is passed directly from AAMVA to the client through the ADD interface,which has been tested and approved by AAMVA.ADD does not enter the information found on a NMVTIS record, nor is it responsible for the accuracy or verification of the information found therein. The motor vehicle records accessed by ADD clients are recorded by participating states and are current with those entities at the time uf access through the ADD portal. hthpo:H»nna.sddl23.0000/NmuvtioPpiWeb/nmvtioppiwebNmvtiaPdmd?oesoionId=24V0Bl]}lC... 3/3/2013 Page 5 of 5 Name on Card Bryan Shook Address 11 - City olo r State PA Zip . Card # 1114MOMMONNOW. Expiration Date Amount $2.50 This charge will appear on your statement as a charge from NMVTIS -- ADD https://apps.add 123.com/NmvtisPpiWeb/nmvtisppiweb/NmvtisPrint?sessionld=29VOEUHC... 3/3/2013 VinCheck Page 1 of 2 USE2 ID. PASSWOP.D *ATIONAkA."XNCr CrkrIAL OUR fraud SOlttt'1t19t5 s�",- -*o to can e remember me :nembeis-only usar Forgof your:D or pe-iswo;a' ari.•:.fr,a:, Pi.'ar-ne,s= i NC.hY k VINCheckSM RiMiultl Ill,VIN:HBYA420720 Print this Page __ _____ _. .. _.._. About VINChecks" VINCheck="Theft Record H9YA420729 has not been identified as a vehicle listed in the VINCheck-Theft Records. VINCheck`i"is updated regularly as additional '.. information is reported. VINCheck$-Total loss H9YA420729 has not been identified as a vehicle Record listed in the VINCheck—Total loss Records. VINChecksM is updated regularly as additional NICB's VINChecl,is a service provided to the public to assist information is reported. in determining if a vehicle has been reported as stolen,but AgMC *Ck not recovered,or has been reported as a salvage vehicle by Furiter rfarrnnlon;z av+,uame cooperating NICB members.To perform a search,a Vehicle tb,ough AutoCheck. Identification Number('VIN)is required.A maximum of five VINCheck searches can be conducted within a 24-hour period '.. per IP address. An additional source for vehicle history data can be found on the National Motor Vehicle Titling Information System(NMVTIS)Web site Have a VINCheck success story?Tell us about it! by clicking here. '.. Special Thanks If you are searching a motorcycle,click here for additional The NICB VINCheck database is made possible;through the �w•v+a�+�f cooperation of participating NICB members,'v'e•.:a list of ' information from CycIeVIN.An additional charge will apply. C i Mrir ', those members. The National Insurance Crime Bureau(NICB)has access to a database of vehicles which '.. were reported as stolen within the past five years and remain unrecovered or declared as '.. salvage.This information is being made available,free of charge,as a public service to '.. consumers. This database contains a"salvage"file and an"insurance theft"file which is the information VINCheck searches during queries.The terms"total loss"and"salvage"are '.. not synonymous in the insurance industry and that is important to understand when using VINCheck.Not all vehicles identified as a total loss will become salvage.A salvage !. determination is made by individual insurance companies based on individual company '.. policies and applicable state law. '.. • The NICB has not independently verified the information in the database and cannot, '.. therefore,vouch for the accuracy of this information. There are many other vehicles which have been reported as stolen which are not '.. included in this database. There are also many other vehicles which are total losses or salvage which are not '.. o�ciuded in this database. • It is possible that a vehicle was incorrectly reported as having been stolen,or was stolen and recovered,but has not removed from this database. • it is possible that a vehicle was incorrectly reported as salvage and has not been removed from this database. • it is also possible that there are vehicles with duplicate VINs and/or VINS incorrectly entered. • If a vehicle is reported in this database as having been stolen,but not recovered, you should verify with the NICB or your local law enforcement agency that a stolen vehicle report is active before taking any action regarding the vehicle. By checking a VIN against this database,you agree to not hold the NICB,its '.. employees,Board of Governors,Members,agents or any other entity which '.. provided this information to NICB,liable for any reason as a result of your use of this information including,but not limited to,if the information proves to be '.. inaccurate. In order to continue with your inquiry as to whether a VIN is in the database, you must agree to and accept these Terms and Conditions of Use. E:z:l https://www.nicb.org/theft_and_fraud_awareness/vincheck 3/3/2013 VipCheck Page 2 of 2 The NICE VINCheck database is made possible through the cooperation of participating NICE members.To view a list of those members,please click here. '.. <Back to Search https://www.nicb.org/theft_and—fraud—awareness/vincheck 3/3/2013 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: 3 d duo/3 U Y:l��G e L 9 ' ✓k/'b Title: C y Oh AACA Museu , IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS 1959 LINCOLN CAPRI : CUMBERLAND COUNTY, PENNSYLVANIA FOUR DOOR HARDTOP (Identification Number H9YA420729) : : 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, Certified, postage prepaid, return receipt requested addressed as follows: Michael C. Sauta 31 Foster Road Milford, New Hampshire 03055 (Certified Mail Receipt# 7012 1640 0002 1546 8896) Donald Richard McGettigan, Jr. 31 Foster Road Milford, New Hampshire 03055 (Certified Mail Receipt# 7012 1640 0002 1546 8902) Respectfully Submitted: Date: iq z Brya . Shook, Esquire ID # 203250 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 975-9446 BShooko_dplglaw.com � 1 IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS 1959 LINCOLN CAPRI : CUMBERLAND COUNTY, PENNSYLVANIA FOUR DOOR HARDTOP (Identification Number H9YA420729) : _ : No: 2013- / 75 / - CIVIL TERM ORDER AND NOW, this the 1 P day of Ma.r , 2013, upon consideration of the Petition of the AACA Museum, Inc.. for a declaration of ownership of a certain 1959 Lincoln Capri four door hardtop, which was donated to the AACA Museum, Inc., on December 13, 2010 by Donald Richard McGettigan, Jr. and Michael C. Sauta, the Court hereby awards exclusive ownership of one 1959 Lincoln Capri four door hardtop (Vehicle Identification Number: H9YA420729) 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. -0 3 (...., --i ma) a - x rn a• rn 2r " -< -7). to 1 xt, BY THE COURT: •�c� - // , • zr. -i /� --- 7 DISTRIBUTION LEGEND: cyan W. Shook, Esquirechael C. Sauta 2132 Market Street 31 Foster Road Camp Hill, Pennsylvania 17011 1 Milford, New Hampshire 03055,;),)ri(717) 975-9446 II nald Richard McGettigan, Jr. 0 31 Foster Road 'k• Milford, New Hampshire 03055 \ cP 1