HomeMy WebLinkAbout13-1752 Supreme Co nnsylvania
ds
Con f Cali leas For Prothonotary Use Only:
1 � _t Docket No:
U
LAM, County
13- /"WOW
The information collected can this-form is used solely fin, court administration purposes. This,lorm does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
0 Complaint ll Writ of Summons Petition
Transfer from Another Jurisdiction 0 Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
AAGA MUSEUM, INC.
T Dollar Amount Requested: Elwithin arbitration limits
I Are money damages requested:' 0 Yes S No
0. (check one) Doutside arbitration limits
Is this a Class Action Suit? Yes 191 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 Hill PA 17011
13 Check here if you have no attorney(are a Self-Represented [Pro Sel 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 inelude.ludgments) CIVIL APPEALS
Intentional Buyer Plaintiff Administrative Agencies
0 Malicious Prosecution Debt Collection:Credit Card El Board of Assessment
0 Motor Vehicle Debt Collection:Other E] Board of Elections
Nuisance —�_ Dept.of Transportation
Q Premises Liability — _ _ — _ Statutory Appeal:Other
S 0 Product Liability (does not include ® Employment Dispute: �- ----
Emass tort) --- —--
a Slander/Libel/Defamation Discrimination
C D Other: Q Employment Dispute:Other 0 Zoning Board I
0 Other:
— - 0 Other: -—- -^-
o MASS TORT
Q Asbestos
® Tobacco -- --------^ _—
Toxic Tort-DES
Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste
Other: 1:1 Ejectment [3 Common Law/Statutory Arbitration
l El Eminent Domain/Condemnation ® Declaratory Judgment
------ -- ❑ Ground pent Mandamus
--- -- Landlord/Tenant Dispute Non-Domestic Relations
E3 Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY ga
Mortgage Quo Warranto
e Foreclosure:Commercial
Dental [] Partition 0 Replevin
0 Legal 0 Quiet Title n Other:
[ [3 Medical a Q Other: Petition for Declaration of
l3 Other Professional: Ownership of donate vehi
Updated 11112011
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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
BShook(&-dr)lqlaw.com Attorney for AACA Museum, Inc.
IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1959 PONTIAC STAR CHIEF : CUMBERLAND COUNTY, PENNSYLVANIA
FOUR DOUR HARDTOP
(identification Number 4591-7461)
: 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
Bryan W.Shook, Esquire
ID#203250
2132 Market Street
Camp Hill,Pennsylvania 17011
Telephone—(717)975-9446
Fax—(717)975-2309
BShookOdplalaw.com Attorney for AACA Museum, Inc.
IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1959 PONTIAC STAR CHIEF : CUMBERLAND COUNTY, PENNSYLVANIA
FOUR DOUR HARDTOP
(Identification Number 459L7461)
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
Pontiac Star Chief four door hardtop automobile (Vehicle Identification Number:
4591-7461) 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 Pontiac Star Chief four door hardtop automobile (Vehicle
Identification Number: 4591-7461) (hereinafter sometimes referred to simply as
the "automobile") which was so graciously donated to the AACA Museum, Inc. by
Ms. Marjorie L. Hadlock, Ms. Nancy Elder and Ms. Joan Fontes, by way of deed
of gift dated April 14, 2008. (A true and correct copy of the aforementioned Deed
of Gift is attached hereto, made part hereof and marked as Exhibit "A"). (A copy
of a May 23, 2007 letter from Ms. Marjorie L. Hadlock is attached hereto, made
part hereof and marked as Exhibit "B").
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. The subject 1959 Pontiac was originally purchased on October 26, 1959 in New
Jersey by Willard Vern Hadlock. (A copy of the October 26, 1959 title in the
name of Mr. Hadlock and bearing New Jersey title number 6693037 is attached
hereto, made part hereof and marked as Exhibit "C").
5. In 1969, the Hadlock family moved from New Jersey to Alexandria, Virginia
where Mr. Hadlock retitled the car. (A copy of the July 2, 1969 Commonwealth of
Virginia Certificate of Title bearing number 14425859 is attached hereto, made
part hereof and marked as Exhibit "D").
6. Mr. Hadlock passed away on March 10, 1999 in San Francisco, California
leaving to survive him his wife, Marjorie, and his two daughters Nancy L. Elder
and Joan C. Fontes; Mrs. Elder was named the executrix of his estate by Order
of the San Francisco County Superior Court dated May 24, 1999. (Copies of Mr.
Hadlock's death certificate and San Francisco County Superior Court filing are
attached hereto, made part hereof and marked as Exhibit "E").
7. The subject vehicle was parked in Ms. Hadlock's garage in 1980 and was not
moved again until it was donated to the AACA Museum, Inc. in Hershey,
Pennsylvania in 2008.
8. At the time of donation, the original of the 1969 Virginia Title (Exhibit "D") was
forwarded to the AACA Museum, Inc. however it cannot be assigned to the
AACA Museum, Inc. because it was improperly executed by the donors of the
subject vehicle.
9. Because Mr. Hadlock is deceased and so much time has passed the donation,
the AACA Museum, Inc. is without alternative but to petition this Honorable Court
for a declaration of ownership relative to the subject 1959 Pontiac sufficient to
permit Penndot to issue a certificate of title to the 1959 Pontiac in the name of
the AACA Museum, Inc.
10.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.
11.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 "F).
12.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 "G").
13.There is no indication that there is anyone besides the AACA Museum, Inc. who
claims ownership of this 1959 Pontiac Star Chief automobile.
14.The subject vehicle has been at the AACA Museum in Hershey, Pennsylvania for
nearly five years.
15.During these nearly five years, the vehicle has been publically displayed and
feature in both national and regional publications throughout the collector and
antique vehicle hobby.
16.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).
17.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.
18.The entire action is largely procedural and administrative, as pursuant to 13 Pa.
C.S.A. § 2401(2), AACA Museum, Inc. and Marjorie Hadlock, Nancy Elder and
Joan Fontes, 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 Farm Mut. Auto. Ins. Co., 215 F.Supp. 645 (E.D. Pa. 1963).
19.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 Pontiac Star Chief four door
hardtop automobile (Vehicle Identification Number: 4591-7461).
Respectfully Sub tte
Date: A a:I `I oo
Brya W. 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: 717-566-7100
Museum., Fax: 717-566-7300
mtiseum.org
www.aacamuseum.org
Antique Automobile Club of America Museum
Am&of 40iff-Amu f Release
to the
AACA MUSEUM,Inc.
Be It Known That:
NANCY L.ELDER(7714 Midday Lane,Alexandria,VA 22306)
And
JOAN C.FONTES(201 Legault Drive,Cary,NC 27513)
Hereby grant unto the AACA 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 object(s), 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 Pontiac Star Chief Four-Door Hardtop; VIN.-459L7461 Car is white in color with a
vermillion and white vinyl interior, V8 engine and automatic transmission;options include power steering and
brakes,am radio and an underdash aftermarket air conditioner;one-owner car was purchased new by the
donor's parents(Willard Vern and Marjorie Hadlock);now has 84,888 miles on odometer,car was parked in its
current location in 1980 by the donors' mother;the battery was disconnected and the car has sat in the same
location up to the point of donation,car is complete and in good overall condition;paint is original and body
shows some wear/dents;interior is very good with period seat covers still in place.
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 MUSEUM, Inc. /
IN WITNESS WHEREOF I have hereunto set my hand and seal this day of 2008.
Nancy L.Elder GCt c
Subscribed to and sworn to before me this day of 200 M--'URENMA L.WILLIAMS
ARY PUBLIC DISTRICT OF COLUMBIA
MY
My Commission expires
-- Notary Public
_ a . - - - -- - - - - - -- --- -- - - --- -- - --- - -- -- -- - - -- - - - - - - - - - - - --- - - - -
.. .�.- .w.�. ..
IN WITNESS WHEREOF I have hereunto set my hand and seal this /'f day of �p
t Joan C.Fontes
Subscribed to and sworn to before me this 14 day of_ AT>t'► i 2008. °
C%IISt�A�adL�. , � {�Q IS-7-0
e.. My Commission expires 11 ti
Notary Public
Smithsonian Institution
Affiliations Program
' A
DEED OF GIFT PROVISIONS
Acceptance of gifts by the AACA MUSEUM, Inc. is subject to the following:
I. 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.
2. Title to all objects acquired for the collections must be obtained free and clear, without restrictions
or conditions as to use or future disposition. Donor shall assume all risk of loss or damage to the
property up to the time of its 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 gift at the time of receipt of the donation; however, the Museum will not
guarantee that the gift wiii 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 COLLECTION: Worn or duplicate items of significant historical value
used for teaching,study,or loan,and falling within the Museum's purposes.
B. NON-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 twenty-four(24) 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.
5. 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 Page Date
3903 Picardy Court
Alexandria, Va. 22309
May 23, 2007
Curator,
Antique Automobile Club of
America Museum,
P. 0. Box 234,
161 Museum Dr. ,
Hershey, Pa. 17833 .
Recently I read with interest an article on your
museum, and, that in 2008 you are planning a "FINS" exhibit .
I have in my garage a 1959 Pontiac Starchief 4-door
hardtop white with burnt orange interior. I have for
sometime thought of donating this car to a venue where it
might be seen and enjoyed in today' s time .
It has not been restored, but on the whole, it is in
pretty good condition. It does not run because it has been
garaged only for a time .
Might you be interested in including this model in
your exhibit? I do have pictures , and, would be happy to
share other details with you. Just either send me a note,
or telephone, and I would be happy to talk with you about it .
Sincerely,
Marjor' e L. Hadlock
( 703) 780-7488
fi
PURCHASED NEW IN 1959 BY
SOLE AND ONLY OWNER
WILLARD VERN HADLOCK
GIVEN TO MUSEUM BY
MARJORIE HADLOCK AND DAUGHTERS
NANCY ELDER AND JOAN FONTES
ABSTRACT OF CONTRACT COPY
DIVISION OF :MOTOR VEHICLES
DEPARTMENT OF LAW AND PtiBLIC SAFETY
OCT* 26j,1959 -
X093037
DATE CERTIFICATE NO.
WILLARD V• HADLOCK
N A M E
SULLIVAN WAYS EAST BRUNMOK. N*J*
ADDRESS IN FULL
PONTIAC 1959 ST*CH*V1$TA16kW.$
MAKE YEAR BO TY E
454L 7 ki 459 3
SERIAL NO. MODEL C.
CONTRACT OR ENCUMBRANCE H B�
EASTERN ACCEPTANCE CA4
N A M
208 GAVETT PLAC$�'l,,AP 1NFtELDs N*J* ,
A RE FULL
ACCT-6.NU. 72930 3 7 F 8C $ 2-25 NEW 13RU M W. K
AGENCY
I, the Director of the ivilion of Motor Vehicles, Department of Law
and Public Safethe State of New Jersey,do hereby certify that evidence
of purchase or whip,in compliance with the provisions of R.S.Title 39,
Chapter 1Mumied,am ded, of she above described motor vehicle, has been re-
corded an with me,and I do hereby issue this Certificate of Ownership
to the subject to contractor encumbrance,if any,as stated above,
TI I nim,,5 4.,mof, I have set my hand and official
real on the date shown above.
-FORM AUTO 3 REV 2/67 COMMONWEALTH OF VIRGINIA
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I, C. H. LAMB, COMMISSIONER, DIVISION OF MOTOR VEHICLES OF THE
COMMONWEALTH OF VIRGINIA, DO HEREBY CERTIFY, PURSUANT TO THE
PROVISIONS OF CHAPTER 342 OF THE ACTS OF THE GENERAL ASSEMBLY OF
VIRGINIA, PASSED AT THE SESSION OF 1932,AND ACTS AMENDATORY THEREOF,
THAT AN APPLICATION HAS BEEN MADE TO ME AS BY SAID ACT PRESCRIBED,
FOR A CERTIFICATE OF TITLE OF A MOTOR VEHICLE AND THE RECORDING OF
THE LIENS THEREON IF ANY. I DO FURTHER CERTIFY,THAT UPON THE STATE-
MENT OF FACTS MADE UNDER OATH, CONTAINED IN SAID APPLICATION, I AM
SATISFIED THAT THE APPL!CANT IS THE LAWFUL OWNER OF THE HERE-IN-
DESCRIBED MOTOR VEHICLE, OR IS OTHERWISE ENTITLED TO HAVE SAME
REGISTERED IN HIS NAME;
NOW, THEREFORE, I DO HEREBY CERTIFY THAT THE BELOW NAMED AP-
PLICANT HAS BEEN DULY REGISTERED IN MY OFFICE AS THE LAWFUL OWNER
OF THE HERE-IN-DESCRIBED MOTOR VEHICLE, OR IS OTHERWISE ENTITLED
TO HAVE THE SAME REGISTERED IN HIS NAME, AND THAT IT APPEARS UPON
THE OFFICIAL RECORDS OF MY OFFICE THAT AT THE DATE OF THE ISSUANCE
OF THIS CERTIFICATE, SAID MOTOR VEHICLE IS SUBJECT TO THE LIENS HERE-
INAFTER ENUMERATED, IF ANY, AND NONE OTHER.
REGISTERED OWNER DESCRIPTION OF MOTOR VEHICLE
MAKE BODY STYLE (DENT-NUMBER
WILL A?-0 VER,'41 HAPjLt,C1" PON t IAA SLDN 459L7461
200,7' 1�y U-NT}Y 7NGTCN AVE TITLE NUMBER WEIGHT YR. MFR'D/YR. MODEL
AL' XIr`T�fiDR,1,4 VA 22303 14425859 3450 3
SALES TAX PAID
RECORDED LIENS
AMOUNT KIND DATE OR
;I I
NOTICE OF RELEASE OR SATISFACTION OF A LIEN MUST BE MADE BEFORE A NOTARY PUBLIC
AS WITNESS, MY HAND AND THE SEAL OF MY OFFICE THE DAY AND YEAR SET OPPOSITE
THE NAME OF THE APPLICANT IN THE AFOREGOING CERTIFICATE.
NOTE: TO TRANSFER OWNERSHIP THE _ +' v5 c� 7
ASSIGNMENT OF TITLE ON THE BACK
HEREOF MUST BE PROPERLY FILLED
v AND ACKNOWLEDGED BEFORE A NOTARY
PUBLIC OR OTHER OFFICER AUTHORIZED
TO ADMINISTER AN OATH.
COMMISSIONER.OIVISION OF MOTOR VEHICLES
J ASSIGNMENT OF TITLE BY REGISTERED OWNER
FOR VALUE RECEIVED, THE UNDERSIGNED HEREBY SELLS, ASSIGNS OR TRANSFERS THE MOTOR VEHICLE DE. -i
CRIBED ON THE FACE OF THIS CERTIFICATE UNTO THE PURCHASER WHOSE NAME APPEARS BELOW IN THIS SECTION AND
THE UNDERSIGNED HEREBY WARRANTS THE TITLE TO SAID MOTOR VEHICLE AND CERTIFIES THAT AT THE TIME OF DE- --I
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' CERTIFICATE OF DEATH 3 1999 38 001534
STATE OF CALIFORNIA -
USE!LACK INK ONLYM0 ERASURES,WHITEOUTS OR ALTERATIONS
STATE FILE NUMBER LOCAL REGISTRATION HUMMER
Vf•/1(REV.TNIT)
! I.I/Aw[O,DK[D6Nr-FIwK fGrvtwl 2.MIOOIt •!.WT(PUwLY)
iy WILLARD VERN HADLOCK. _
- 4.DATL OF SIRTH M M/D D/C-C T Y 8.AGL TRf. v Vw I YEAR 1 Houw[w>a weuu 6.S[x r03/10/1999 E OP OEATN M M/D OTC C Y Y 6.HOUR {
y 12/15/1918 80 i w�N.wf i iwwNT M 1816 I
DECEDENT 6.STATE OI BIRTH 10.SOCIAL SECURITY NO. 11.0"TART SERVICE 12.MARITAL STATUS 16.[�UCAT10N-TWIs COMPLETED l
'PCR60NAL - - -
DATA UT 528-18-2520 D
Yca No LINK MARRIED - 16
14.RAC[ 1L.HISPANIC-arCC1IY 16.USUAL[MROYER E
WHITE ❑Yis No EXXON CORP:
.17.OCCUPATION. - 10.KIND 0/SYi1N[Sf - 10.YEARS IN OCCUPATION i
HUMAN RESOURCES OIL AMENDED 25
20. AND NUM6[R ON LOCATION) _ •r^�.
usuAL 828 TAYLOR STREET # 35- ! VI 1 i
RESIDENCE 21.CRY 22.COUNTY.. - - 26.DIP '24.YRa'IN COUNTY 2S.STATE OR fORENGN COUNTRY.
i.! SAN FRANCISCO SAN FRANCISCO 94108' : 10 CALIFORNIA
f - 26.NAM[,R[LATIOMSNIF 27.MYLINO ADDRESS lirwtST Awe NuwS[w Ow wuwAL wWrX.NUwStR O*'/Ow TOwlr.:eiATE,SIP)'
1 INFORMANT
JOAN FONTES- N.
(DAUGHTER) 1347 WATERFORD GREEN ,MARIETTA, 'GA 3006.8
28.NAM[OF SURVIVIN8,6POUf19--►MST 28.MIDDLE 30.LAST(MAIDEN NAME)
MARJORIE ELTON LEE
fPOUEE 81.NAM[Of FATHER.-ARST 82.MIDDLE : 73.LAST _ aa.wlwnl HAGS .
AND .{-•'
rAR[NT ' - ORLANDO D. HADLOCK UT
INFORMATION MwnI STAR
25.NAME DI MOTI![R-FIRST 20.MIODL! 37.LAST(MAIDEN)
+ MELISSA •3B.JANET BINGHAM UT
89.DATE.M Ht D D/G O T FLAC[Of FlNAL DISPOSt[ION _ -
olsroslnal(s) 03/15/1999 r. I OGDEN CITY' CEMETERY; OGDEN, UTAH
- 4/.TYPE or DISPOSITION(fl TURE OF LM R _ AS.UCENS[NO.
FUNERAL -
DIRECTOR TR/BU[ '. .. - 7891
A
�£k
R5 MAN9 OF FUNERAL DIRECTOR 48.LICENSE NO. 4[.SIGMA I TRA 47.OAT[M M/D D I C C Y Y
AH ITOtRI CI AN RVIc S CE
FD 1532 03/15/199 9
101.TwJICL OF DGTN 102.IF Has or 1111"It."ONie 1Oi.:FAC'U"I f"11%THAN H~ALI. 104:COUNTY
►LAec CPMC - PACIFIC 'CAMP.US', ®rP' CROP.❑DOA D"NOS►. CNIe D oTNEe SAN FRANCISCO
DEATH 108.STREET AODREfi-fSTR[[T AND MVMa[R opt LOCATION). 106.CCTV -
2333 BUCHANNAN $ ". AN FRANCISCO
107.OEATH-:WAS CAUSED BY,(LNT[R ONLY ONE CAUSE TER LINK FOR I4 Sr C.AND'DI TINS IRRMnL' 106.MAW REPORTED M CORONE[
: AND D[ATN -
IMMEDIATE Rn[RRAL NYMf[R
�ya
CAUSE (A) CARDIOPULMONARY ARREST' 5 MIN.'
IOU.D/OPSY PERFORMED
DUE To (a)-PULMONARY EMBOLISM 1 HOUR D'YCS D No
110.AUTOPSY Pirit"AM[D
CAUSE
�# OF DUE TO (C) ILIO FEMORAL VENOUS THROMBUS 3 DAYS YAS No
IX(' DEATH I _ 11 I.USED IN DET[eMINiMG CAusE
t Duero (o) ADENO CARCINOMA ESOPHAGUS (DIGITAL THIRD), 9 MONTH D ref ❑No
1 I2.OTHER SIONWICANT CONDITIONS CONTRISU INO TO DEATH OUT NOT N[LA"O TO CAUSE GIVE.IN I-
ARTERIOSCLEROSIS,DYSPHAGIA,.WEIGHT LOSS-.UPPER GASTRO INTESTINAL BLEEDING j
3 - 113.WAS OPERATION PERFORMED FOR ANY CONDITION IN ITEM 107 OR 110 W YES,UST YYFE DF om*AT10N AND DATL
ESOPHAGO-GASTROSTOMY 03/01/1999
114.1 CERTIFY THAT TO THE`BEST Of MY KNOWL. 118.WGNATUR[.AND [OF C[R I Ia.LICENSE NO. 117..DATE M M/D D/C C YY .h
-PHYGI- [DOE DEATH OCCURRED AT 7M['HOYIL DATE - .
.AND PLACE STATED IRROM rNS CALnif.STATED. , A 17683- 03/15/1999
.CIAN'6 OCCEOLNT ATfO1DED MNC[l DECEDENT{AST SEEM AL1YE
CERTIFICM M:Y/DO f C C T Y M M/D D/C C Y Y )16.TYP ATT DING►NYtICIAN'S NA II,MAIUNG ADDRESS.MP
rILiN 03/01/1999 i 03/10/1999.' DOUGLA PINTO MD.,2100 WEBSTER,SAN FRANCISCO,, CA 9
-- 1 CERYIFY TNAT,IN MY OPINIO,I MUYH 120.DUURY AT WORK IXI.IMASIY DATL M M I D D/C C Y Y 122. HOUR 129.PLACE OP I Wu h,;
i - - OCCURRED AT THi'HOUR,DATE AND PLACE Q I-I '
STATED FROM THE CAUSES STATED. IL JF
1.19.MANNER OF DEATH 124.DESCRIBE NOW IWURY OCCURRED(EVENTS WHICH RESULTED IN IWURV)
- ❑NATURAL D SUICIDE L�'❑''1F'HOMICIDE.
CORONER'S D. DM EITAT10MD 0eCOin)NITRD .,.�,,,,^'M"• N.�1 .-
USE. .ACCIDENT - -
k
ONLY t28.LOCATION.ISTREST AND NUMBER,OR LOCATION AND CITY,EI►)
126..SIGNATURE OF CORONER OR DEPUTY CORONER 127.DATE MMMMCCYY 128.TYPED NAM[,TITLE OF CORONER OR DEPUTY CORONER
:STATE A S. C D- E - F r H I.ALITH. S -CENSUS-TRACT
o
-REGISTRAR
J t)„
tt\+\)/4 3 p 0 2 2 3 3 9 5 1 STATE OF CALIFORNIA,CITY AND COUNTY OF SAN FRANCISCO )r
R This is to certify that the image reproduced hereupon is a true copy of the record on file
in the SAN FRANCISCO DEPARTMENT OF PUBLIC HEALTH as of the date issued.
s Mitchell Katz,M.D. T )
~ " DATE ISSUED Health Officer and Local Registrar
r, ; �� 1� This copy is not valid unless prepared on an engraved border,displaying the date,seal and signature Of the City and County Health Officer.
"', (/PORN
V W0 a 014N 04 i1�1311 :
e
{n c CITY AND COUNTY OF
;` � SAN FRANCISCO
AFFIDAVIT TO AMEND A RECORD 3 1999 38 001534 ''
pc non.ns.at oc, DEATHS AFTER 1-1994 ►oeu amourm?m caerwiaT A,o Cvm Tz wwa
bb
q ND BUINA-WHITMM Oft ALTExATTata .�
REGO
G11STRLACAL
a
ONLY
USE
ONLY , r
PART 1 INFORMATION TO LOCATE RECORD—TYPE OR PRINT IN BLACK INK ONLY
NAME AS IT t.NAMS—FI1RS, Mm M - 2 WOOLS 3.LAST(RAM•.Y)
APPEAM i Vern _ Hadlock
WORD' a Sax 3.DATE OF'EVENT—MM/OO/CCYY 6.CRY OF OCCURRwcE 7.COUNTY of occtlRRENCE. ..
ADDITIONAL
N 03/10/1999 San Francisco San Francisco
TO RECORD S.FATmrs NAME AS.STATED ON ORIGINAL a MOTHER'S NAME As STATED ON ORIGINAL. it
Orlando D. Hadlock Melissa Janet Bingham
PART I! STATEMENT OF CORRECTION
$--NO ERASURES, WHITEOUTS, OR ALTERATIONS
10.CX1trV=ATN ti:INFORMATION AS IT APPEARS ON ORIGINAL RECORD la INFORMATION AS IT SHOULD APPEAR
1TH1 NIIYYII
No
LIFT ONE AMENnFn
ITEW PER--
LINE -
h
:
ik
REASON FOR Ia To Correct original- Certificate.
CORRECTION
AM
AFFIDAV :We,the undersigned;hereby certify under penalty of perjury that we have personal.knowledge of the above facts
SONATUPY-i a t.the_jdformililtion given above is true and correct. -
14.SIGINATFIRE OF-P1 SON ISr TITLE/11RELATION3HIP TO PERSON IN PART 1 iS.DATE SIGNED—MWOO/CCYY
► ' .Funeral Director I 03/15/1999
MUST MGM 17..A I I&:ADDRESS(STRIM.CRY.STATIL spy
THIS FORM -
LecrAl Acre ' 3434 17th Street San Francisco. a
/8. ATURE OR SECOND PERSON 20.TI1lE/RELATIONSHiP TO PERSON IN PART I 1'21.DXTE SIGNED—MM/DO/CCYY
USE
SLACX INK 1 - ' Funeral Director ' 03/15/1999
1999.
ONLY AGE I.28.ADORESS 11ST11llT.CRY.•TAM sl►1 - -
Legal Acre ' U3/44 17th Street, San Francisco, Ca 94110
TATZTRAR 26.31GNATURE OF 5�7y �^ ,--y_6111, 25,DATE ACCEPTED.FOR REGISTRATION-MM/DD CCYY :?<
Q
USE ONLY 03/16/1999
y,) j tat sTAIE a CMAU M DUSI AW or HIuTil SOMM OM OF sTME i RUM K:•a>n...ux�.
3802233968
STATE OF CALIFORNIA,CRY AND COUNTY OF SAN FRANCISCO -
a This is to certify that the Image reproduced hereupon is a true copy of the record on file
in the SAN FRANCISCO DEPARTMENT OF,RUBLIC HEALTH as of the date issued.
= Mitchell Katz,M.D.
DATE ISSUED Hearth officer and Local Registrar
— This copy is not valid unless prepared on an engraved border,displaying the date,seal and signature of the City and County Health Officer. -
DE-150
ATTORNEY OR PARTY WITHOUT ATTORNEY(Name,sta& umber,and ad&essr TELEPHONE AND FAX NOS.. FOR COURT USE ONLY
ROBERT L. MOON, ESQ. 415-392-5718
State Ear No. 020005 415-981-2684 (FAX)
155 Montgomery St., #307 �µ
San Francisco, CA 94104 gK
ATTORNEY FOR(Names NANCY L. ELDER, EXECUTOR - -
Sa„ _ .
SUPERIOR COURT OF CALIFORNIA,COUNTY OF SAN FRANCISCO "'ip Superior Cau-t(�(�
STREET ADDRESS: M 4 1999
MAILING ADDRESS: 400 Mdalister Street
CITY AM ZIP CODE: San Francisco, CA 94102 Clerk
BRANCH NAME: A 1.e`',:`� ,'3';.. ;s'.,+e's
ESTATE OF(Name): WILLARD V. HADLOCK, AKA WjIj-ARD VERN HADLOCK 6Y: _
Deputy Clerk
DECEDENT
LETTERS CASE NUMBER:
® TESTAMENTARY OF ADMINISTRATION 271790
OF ADMINISTRATION WITH WILL ANNEXED SPECIAL ADMINISTRATION
LETTERS AFFIRMATION
1. ® The last will of the decedent named above having 1.0 PUBLIC ADMINISTRATOR:No affirmation required
been proved,the court appoints(name): (Prot.Code,§7621(x)).
NANCY L. ELDER
a. Q executor. 2. ® INDIVIDUAL I solemnly affirm that I will perform the
b. administrator with will annexed. duties of personal representative according to law.
2. The court appoints(name):
3. INSTITUTIONAL FIDUCIARY(name):
a. Q administrator of the decedenrs estate.
b. special administrator of decedent's estate I solemnly affirm that the institution will perform the
(1) Q with the special powers specified duties of personal representative according to law.
in the Of for Probate. I make this affirmation for myself as an individual and
(2) with the powers of a general on behalf of the institution as an officer.
administrator. (Name and tide):
(3)Q letters will expire on(date):
3.® The personal representative is authorized to administer
the estate under the Independent Administration of
Estates Act ® with full authority
0 with limited authority(no authority,without 4. Executed on(date): May--2-4, 1999,
count supervision,to(1)sell or exchange real property at(place): San Francisco ,California.
or(2)grant an option to purchase real property or(3)
borrow money with the loan secured by an
encumbrance upon real property). '
4.0 The personal representative is not authorized to take MMATURE>
possession of money or any other property without a CERTIFICATION
specific court order.
I certify that this document is a correct copy of the original on
file in my office and the letters issued the personal representa-
tive appointed above have not been revoked,annulled,or set
WITNESS,dark of the court,with seal of the court affixed. aside,and are still in full force and effect.
(sraa h f—` Date: MAY 2 4 999 (BEAD ou R T pc Date: F�' »'i' 2 51999
GC r! ALAN M.CARLSON Q�� Cq ALAN CARLSON
Clerk,by
^. O Clerk,by
CO
O BER
Form
JudicM c«nd,Of C40M i. LETTERS Probe.coat,§g 100+.84M
0E-150 iRw. ��•8541:
�WKMy 1,ISM (Probate) Code or Cif PRoctdnt.§2015.6
P-4
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VERIFICATION
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: D ,�
Y: G Oum,Title:AA A M
IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1959 PONTIAC STAR CHIEF : CUMBERLAND COUNTY, PENNSYLVANIA
FOUR DOUR HARDTOP
(Identification Number 459L7461) :
: 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,
postage prepaid, addressed as follows:
Nancy Elder
7714 Midday Lane
Alexandria, Virginia 22306
(Certified Mail Receipt # 7012 1640 0002 1546 8919)
Joan C. Fontes
201 Legault Drive
Cary, North Carolina 27513
(Certified Mail Receipt# 7012 1640 0002 1546 8926)
Marjorie L. Hadlock
3903 Picardy Court
Alexandria, Virginia 22309
(Certified Mail Receipt# 7012 1640 0002 1546 8933)
Respectfully Submitte
Date: _2013
Bryan VQ. Shook, tsquire
ID # 203250
Dethlefs-Pykosh Law Group, LLC
2132 Market Street
Camp Hill, Pennsylvania 17011
Telephone: (717) 975-9446
BShook ,�dplglaw.com
it
IN RE: OWNERSHIP OF : IN THE COURT OF COMMON PLEAS
1959 PONTIAC STAR CHIEF : CUMBERLAND COUNTY, PENNSYLVANIA
FOUR DOUR HARDTOP
(Identification Number 459L7461)
: No: 2013- I. - CIVIL TERM
ORDER
AND NOW, this the I a day of , 2013, upon
consideration of the Petition of the AACA Museum, Inc. for a declaration of ownership of
a certain 1959 Pontiac Star Chief four door hardtop automobile, which was donated to
the AACA Museum, Inc. by Marjorie L. Hadlock, Nancy Elder and Joan C. Fontes, the
Court hereby awards exclusive ownership of one 1959 Pontiac Star Chief (Vehicle
Identification Number: 459L7461) 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 THE COURT: r='
G r;
Jz.x' -c -0rn
us s
°00,0111•
DISTRIBUTION LEGEND: �'`'
ryan W. Shook, Esquire o,blaRcy Elder y.�,
2132 Market Street 7714 Midday Lane
Camp Hill, Pennsylvania 17011 Alexandria, Virginia 22306 —
975-9446
•
oan C. Fontes • I/6;rjorie L. Hadlock
201 Legault Drive 3903 Picardy Court
Cary, North Carolina 27513 Alexandria, Virginia 22309
r