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HomeMy WebLinkAbout13-6574 Supreme Cotiff" Pennsylvania AID Courf, bf, Commo Pleas For Prothonotary Use Only; dvi1f CoVef "S` V t Docket No: County 1 3l /�- 7 The In /Ol "771atlOn collected on t121s fOrin IS used solely fir cour administration p1/rpOJ'dS. This f)1']YZ does not su pplemen t or replace the filing �endservice ofpleadings or otr'rerpapers crs reguil -ed by Icztiti or rules ofcout•t. Commencement of Action: Complaint 0 Writ of Summons Petition F1 Transfer from Another Jurisdiction Declaration of Taking :E. Lead Plaintiff's Name: Lead Defendant's Name: 1. r T . t C� t [_ iR tiT �-0 5'� Co ven P a t.� DwF 12 D � C��R t C� c Z Dollar Amount Requested: Elwithin arbitration limits I Are money damages requested? Yes No (check one) noutside arbitration limits O. N Is this a Class Action Suit? F� Yes 0 No Is this an MDJAppeal? El Yes R No A Name of Plaintiff /Appellant's Attorney: t - om X �• �So'1 Chick here if yon have no attorney (are a Self -R presented tPl! 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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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania (717) 249 -3166 C 136 ag7j /-3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VIGILANT HOSE COMPANY, CIVIL ACTION Plaintiff CASE No: vs. EDWARD RODRIGUEZ, IN EQUITY Defendant ACTION TO QUIET TITLE AND now comes the Plaintiff, Vigilant Hose Company, a Pennsylvania non - profit corporation, by and through its attorney, Thomas P. Gleason, and requests that it be declared the sole titled owner of a 1963 Seagrave Fire Engine based upon the following: 1. Plaintiff is Vigilant Hose Company ( "Vigilant "), a Pennsylvania non - profit corporation, with principal place of business at 20 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Edward Rodriguez whose last know location of residency was Stafford, Virginia. 3. In March, 1963, Plaintiff, Vigilant Hose Company, purchased a pumper fire engine ( "the engine ") with a serial number of N4965 from the Seagrave Company located in Clintonville, Wisconsin. 4. The engine remained in service with the Vigilant Hose Company for 21 years until it was sold to a private party on August 20, 1984. The engine was then resold and Vigilant lost track of the engine. 5. In April, 2002, the Vigilant Hose Company was contacted by Edward Rodriguez of Stafford, Virginia, who informed that he acquired the dilapidated engine with the hope of using it as a restoration project for the Stafford Junior Firefighters. (See photo attached as Exhibit "A "). 6. Mr. Rodriquez advised that the restoration project never came to fruition and the engine had to be removed from its storage location. 7. Mr. Rodriguez informed that he would donate the engine to the Vigilant Hose Company if it would be willing to pay for transportation back to Shippensburg, Pennsylvania. 8. On June 6, 2002, Vigilant contracted with Gordon's Body Shop of Stewartstown, Pennsylvania to haul the engine from Stafford, Virginia to its original home in Shippensburg, Pennsylvania. 9. Mr. Rodriquez did not forward either title or associated ownership document to Vigilant at the time the engine was picked up in Stafford, Virginia and transported to Shippensburg, Pennsylvania. 10. The engine remained in storage for several years at the Cressler Trucking terminal in Shippensburg until Vigilant decided it would commence a complete restoration of the engine. 11. As Vigilant made progress in restoration of the engine, it contacted Mr. Rodriguez who informed that he would forward his ownership documents to Vigilant. 12. Mr. Rodriguez never forwarded any ownership documents to Vigilant. 13. All future attempts to contact Mr. Rodriguez were unsuccessful as Mr. Rodriguez's telephone number was changed with no forwarding information. 14. Vigilant was unsuccessful in its attempts to locate the title to the engine in both Pennsylvania and Virginia. 15. A controversy as to the legal ownership of the engine exists. 16. Vigilant desires to clear the clouded title to the engine in hopes of using it in ceremonial parades and promotional events. WHEREFORE, Plaintiff prays for a judgment declaring that it is the owner of the 1963 Seagrave Fire Engine model #900 with a Serial Number of N4965. Respectfully submitted, R mas P. Gleason, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717) -532 -3270 PA Attorney ID No. 82259 Dated: i ?.o(°j VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Barry W. Sfoltry, Restora 'o hairman VIGILANT HOSE COMPANY t ` . , � � v' J " - ✓� )�_ y fi � � � �' Aid T C Oda �. f - 5 y ✓ �� Kr t�. � ��i �- ,.:.- �r�✓"" "" 't .. a (� - a � --."'. - -� �„ WW Air rj� f ir""'- 'i y .� ��% .. ✓ � ^ Wi o t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VIGILANT HOSE COMPANY, CIVIL ACTION Plaintiff CASE No: VS. EDWARD RODRIGUEZ, IN EQUITY Defendant ORDER OF COURT AND NOW, this day of November, 2013, upon consideration of Plaintiff's Action to Quiet Title, said Petition is Granted declaring that the Vigilant Hose Company is the owner of the 1963 Seagrave Fire Engine model #900 with a Serial Number of N4965. BY THE COURT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VIGILANT HOSE COMPANY, : CIVIL ACTION • Plaintiff • vs. No: 13-6574 ``. rrt • r_ EDWARD RODRIGUEZ, - r- Y c _ •• Defendant r ' F PETITION FOR SERVICE BY PUBLICATION AND now comes the Plaintiff, Vigilant Hose Company, a Pennsylvania non-profit corporation, by and through its attorney, Thomas P. Gleason, and sets forth the following: 1. Plaintiff is Vigilant Hose Company("Vigilant"), a Pennsylvania non-profit corporation, with principal place of business at 20 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Edward Rodriguez whose last know location of residency was Stafford, Virginia. 3. In April, 2002, the Vigilant Hose Company was contacted by Edward Rodriguez of Stafford, Virginia, who informed that he acquired the dilapidated fire engine (the"Engine") formerly owned by the Vigilant Hose Company with the hope of using it as a restoration project for the Stafford Junior Firefighters. 4. Mr. Rodriquez advised that the restoration project never came to fruition and the dilapidated engine had to be removed from its storage location. 5. Mr. Rodriguez informed that he would donate the engine to the Vigilant Hose Company if it would be willing to pay for transportation back to Shippensburg, Pennsylvania. 6. On June 6, 2002, Vigilant contracted with Gordon's Body Shop of Stewartstown, Pennsylvania to haul the engine from Stafford, Virginia to its original home in Shippensburg, Pennsylvania. 7. Mr. Rodriquez did not forward either title or any associated ownership documents to Vigilant at the time the engine was picked up in Stafford, Virginia and transported to Shippensburg, Pennsylvania. 8. The engine remained in storage for several years at the Cressler Trucking terminal in Shippensburg until Vigilant decided it would commence a complete restoration of the engine. 9. As Vigilant made progress in restoration of the engine, it contacted Mr. Rodriguez who informed that he would forward his ownership documents to Vigilant. 10. Mr. Rodriguez never forwarded any ownership documents to Vigilant. 11. All future attempts to contact Mr. Rodriguez were unsuccessful as Mr. Rodriguez's telephone number was changed with no forwarding information. 12. Vigilant contacted the Stafford Volunteer Fire Department and was advised that Mr. Rodriguez was no longer affiliated with the department. 13. The Stafford Volunteer Fire Department also informed that it had no knowledge or information whatsoever about the Engine. 14. Vigilant was unsuccessful in its attempts to locate the title to the engine in both Pennsylvania and Virginia. 15. The Petitioner, after making diligent search and inquiry, has been unable to ascertain the existence and present location of the Defendant. WHEREFORE,the Petitioner respectfully asks leave of court to obtain service of the Complaint in the instant matter upon the Respondents by publication pursuant to Cumberland County Rule 1009-1 and Rules 1066-1 through 4. Respectfully submitted, Dated: I Z-/D/2 U 13 Thomas P. Gleason, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 PA Attorney ID No. 82259 VERIFICATION I verify that the statements made in this petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: D-CsC.- . 30 10/3 //' -C O Barry W.rltry, R, tor. '; Chairman VIGILANT HOSE COMPANY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VIGILANT HOSE COMPANY, CIVIL ACTION Plaintiff • CASE No: v. . EDWARD RODRIGUEZ, . : IN EQUITY Defendant . AFFIDAVIT AND NOW comes Thomas P. Gleason, Esquire, Affiant, who being duly deposed, does state the following: 1. On behalf of the Plaintiff, the undersigned attempted to contact Defendant at his last know telephone number without success. 2. On behalf of the Plaintiff,the undersigned contacted the Stafford Volunteer Fire Department and was notified that the Defendant was no longer affiliated with the Department and that it had no forwarding contact information for him. 3. The undersigned was unable to locate the Defendant through a computer telephone record search for Stafford, Virginia, and for Stafford County, Virginia. 4. Both the Plaintiff and the undersigned have exhausted all reasonable methods of locating the Defendant without success. Date: 12 - 3a--- 7 1 ,..—m s--,___ Thomas P. Gleason, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA VIGILANT HOSE COMPANY, CIVIL ACTION Plaintiff : CASE No: 3 ✓ 5 7� V. EDWARD RODRIGUEZ, : IN EQUITY Defendant 7% ORDER OF COURT AND NOW, this / day ofl.i� , 2014, upon consideration of the foregoing Petition, it is hereby Ordered that service of the Complaint in this Action to Quiet Title be permitted upon the Defendant by publication pursuant to Cumberland County Rule 1009-1, Rule 1066-1, Rule 1066-2, Rule 1066-3, and Rule 1066-4. Said publications shall b made by public notice with one publication in a newspaper of general circulation and one publication in the Cumberland Law Journal. If no answer is filed or appearance is made, a judgment by default may be taken against the aforesaid Defendant, his heirs, personal representatives or assigns. BY THE COURT: y G Le.,�Pwo J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VIGILANT HOSE COMPANY, CIVIL ACTION Plaintiff VS. No: 13 -6574 EDWARD RODRIGUEZ, ACTION TO QUIET TITLE Defendant PETITION FOR FINAL DECREE OF COURT 03 f 3 TO: THE HONORABLE JUDGES OF SAID COURT NOW, this 27th day of March, 2014, comes Thomas P. Gleason, attorney for the above - named Plaintiff and respectfully represents that an Affidavit has been executed and is attached hereto deposing and saying that a Complaint in the above- captioned Action to Quiet Title, endorsed with Notice to Plead, has been served on the Defendant by publication pursuant to Order dated January 14, 2014 of this Honorable Court, and said Defendant has not answered said Complaint, entered an appearance, and/or initiated any action or contact whatsoever and that the time to do so has expired. WHEREFORE, the Plaintiff moves this Honorable Court to enter judgment in its favor and against the Defendant and to grant the Plaintiff the relief prayed for in its Complaint in accordance with Pa.R.C.P. 1066(a) and (b)(1). By: Respectfully submitted, (P„,,,94ea..„ Thomas P. Gleason 49 W. Orange Street, Shippensburg, PA 17257 (717) 532 -3270 Supreme Court ID # 82259 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VIGILANT HOSE COMPANY, CIVIL ACTION Plaintiff vs. No: 13 -6574 EDWARD RODRIGUEZ, ACTION TO QUIET TITLE Defendant AFFIDAVIT AND NOW comes Thomas P. Gleason, Esquire, who being duly deposed, does state the following: 1. In accordance with Order of Court dated January 14, 2014, I did cause a Notice to be placed for publication as to the above - captioned Action to Quiet Title 2. Attached hereto and incorporated as Exhibits A, B and C, respectively, are copies of the Proofs of Publication from the Cumberland Law Journal, The News Chronicle and the Stafford County Sun along with the Notices as published. 3. More than thirty (30) days has elapsed since publication of the Notices in the Cumberland Law Journal, The News Chronicle and the Stafford County Sun. 4. No responsive pleading has been filed by any party to the Complaint, no appearances have been entered and no action has been initiated against Plaintiff. A true and correct copy of the docketing statement for this matter procured from the Prothonotary of Cumberland County is attached hereto and incorporated herein as Exhibit D. Sworn to and Subscribed before me Thomas P. Gleason, Esquire This rl day of March, 2014. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Kelly S. Baker, Notary Public C.arlIsle Boro, Cumberland County MyCommlssian 4 Mb. 7,2016 ON OF NOTA 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 February 14, 2014 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. sa Marie Coyne, Ed for SWORN TO AND SUBSCRIBED before me this 14 day of February, 2014 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 EXHIBIT A CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania No. 13 -6574 VIGILANT HOSE COMPANY, Plaintiff vs. EDWARD RODRIGUEZ, Defendant ACTION TO QUIET TITLE You are notified that the Plaintiff, Vigilant Hose Company, has com- menced an Action to Quiet Title against you at Docket No. 13 -6574 CIVIL in the Court of Common Pleas of Cumberland County, Pennsylva- nia, against which you are required to defend. This action concerns the fire en- gine described below: A 1963 Seagrave Fire Engine, Model # 900B, Serial # N 4965. If you wish to defend against the claims set forth in the following pag- es, you must take action by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objection 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 by the court against you 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 OR CAN- NOT AFFORD ONE, GO TO OR TELE- PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY 7 BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. Cumberland County. Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249 -3166 THOMAS P. GLEASON, ESQUIRE Attorney for Plaintiff 49 West Orange Street Suite 3 Shippensburg, PA 17257 (717) 532 -3270 Feb. 14 Proof of Publication of Notice in The News - Chronicle COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA THOMAS GLEASON -- NOTICE BY PUBLICATION FOR A QUIET TITLE ACTION John Zimmerman, being duly sworn according to law, deposes and says that he is the General Manager of "The News - Chronicle," which is a bi- weekly newspaper of general circulation published in Shippensburg Township, Cumberland County, Pennsylvania, by Latrobe Printing and Publishing Company, a corporation duly organized and existing under the laws of the Commonwealth of Pennsylvania having its principal place of business at 22 East King Street (P.O. Box 100), Shippensburg, Pennsylvania; that he is authorized to and does make this affidavit on its behalf; that the printed notice, advertisement of publication attached hereto is the same as was printed in the regular editions and issues of "The News - Chronicle" on the following date(s) February 7, 2014 Affiant further deposes that neither he nor "The News - Chronicle" and The Latrobe Printing and Publishing Company have any interest in the subject matters of the aforesaid notice or advertisement, and that the facts set forth in the foregoing affidavit is true a d correct. A' dor Sworn . . subscri 6 Day of ed before me this , 2014 PENNSYLVANIA Notarial Seal Rebecca Smith, Notary Public Napier Twp., Bedford County My Commission Expires June 11, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES To: "The News - Chronicle" Shippensburg, PA 17257 For publishing the notice attached hereto: On the stated date(s) . $ 104.75 Affidavit $ 5.00 $109.75 EXHIBIT B Nee Ri'C &a aii NOTICE IN THE Court-of Common Pleas of Cumberland County, Pennsylvania No.. 13.6574 - VIGILANT HOSE COMPANY, Plaintiff vs. EDWARD RODRIGUEZ, Defendant ACTION TO QUIET TITLE You are notified, that the Plaintiff, Vigilant Hose Company, has commenced an Action to Quiet • Title against you at Docket No, 13 -6574 CIVIL Court of Common pleas of Cumberland County, . Pennsyl- vania against which you are required to defend. • This action concerns the fire engine descri- bed below: • A 1963 Seagrave Fire Engine, Model.#900B, Serial #N4965. If you- wish to defend against the claims set forth in the following pages, you must take action by entering . a written appearance, -Personally or by attor- ney and filing in writing with the court your defenses or objection to the claims set forth against you. You are wamed that if you fail to do so the case may pro- ceed without you and a judgment may be entered by the court against you 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. .3'i't.l-'1t.. '3.71 /� T _ pu ' SHOULD., 4 ,:: ��HIS . PAP R, 'T>Q YOUR : LAWYER . AT ONCE.. IF YOU DO NOT- HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BE- LOW TO FIND OUT WHERE YOU CAN GET LE- GAL HELP, IF YOU CANNOT AFFORD, TO HIRE A LAWYER, THIS OFFICE. MAY BE ABLE TO PRO- VIDE YOU WITH INFORMATION ABOUT AGEN- CIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No (717) 249 -3166 By: Thomas P. Gleason, Esquire Attomey for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717) 532 -3270 Adv: NC - February 7, 2014 Stafford -Cty Sun Advertising Affidavit P.O. Box 431 Manassas, Virginia 20108 (703) 369 -7319 THOMAS P. GLEASON 49 WEST ORANGE STREET SHIPPENSBURG, PA 17257 Account Number_ 3636929 Date February 14, 2014 Online End Date Description Ad Size Total Cost 02/14/2014 1 x 72 L $258.00 NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania No. 13 -6574 VIGILANT HOSE COMPANY, Plaintiff vs. EDWARD RODRIGUEZ, Defendant ACTION TO QUIET TITLE You are notified that the Plaintiff, Vigilant Hose Company, has commenced an Action to Quiet Title against you at Docket No. 13-6574 CIVIL in the Court of Common Pleas of Cumber- land County, Pennsylvania, against which you are required to defend. This action concerns the fire engine described below: A 1963 Seagrave Fire Engine, Model 4 900B, Seri - al 4 N 4965. If you wish to defend against the claims set forth in the following pages, you must take ac- tion by entering a written appearance personal- ly or by attorney and filing in writing with the court your defenses or objection 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 by the court against you 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 im- portant to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAW- YER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELE- PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 PER- SONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone No. (717) 249 -3166 By: Thomas P. Gleason, Esquire Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, PA 17257 (717) 532-3270 Publisher of the Stafford Cty Sun This is to certify that the attached was published by the Stafford Cty Sun in the County of Prince William, in the State of Virginia, on the following dates: 02/14/2014 The First insertion being given ... 02/14/2014 Newspaper reference: 0003219137 Media General Classified Representative: ayowell Sworn to and subscribed before me this Publisher, Supervisor or Tear Sheet CIrk a7 Notary Public n,^t,.gf State of Virginia County of Prince William / a)/_5 My Commission expires 730 Q580 THIS IS NOT A BILL. PLEASE PAY FROM STATEMENT. THANK YOU EXHIBIT C [�3 LE'GALS' - LEGAL NOTICES NOTICE In the Court of Common Pleas of ':Cumberland County, Pennsylvania: •. No. 13-6574 • u VIGILANT HOSE COMPANY: Plaintiff -'EDWARD RODRIGUEZ, Defendant 'ACTION'TO QUIET iTrLE ; • • . You are notified that the Plaintiff; Vigilant Hose Company, has commenced. an Action to Quiet Title" against you at 'Docket No. 13 -6574 CIVIL ir)_the'Court of Common Pleas :of Cumber- land County, Pennsylvania;: against which. you are required to defend. " This action concerns the fire engine. described below: A 1963 Seagrave Fire Engine,: Model # 900B, Seri- al # N 4965. .. • " If you wish to defend against the claims set forth in the following pages, you must take ac- tion by 'entering a written appearance personal- ly ,'or • by attorney -and filing in writing with. the court:your defenses or objection 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 by the court Against you without further, notice for 'any 'money 'claimed in the complaint• or for any other claim. or. relief requested by the .,pplaintiff." You may lose money .or property or other rights im- portant to you.. YOU SHOULD TAKE THIS PAPER.TO YOUR LAW YER.AT•ONCE. IF YOU DO NOT HAVE A:LAWYER OR 'CANNOT •AFFORD ONE,, GO TO OR TELE- PHONE THE OFFICE SET FORTH BELOW TO FIND OUTWHERE YOU CAN GET LEGAL HELP: • 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 PER- SONS AT "A REDUCED FEE OR NO FEE. ' Cumberland County Bar Association' 32 South Bedford Street Carlisle, PA" 17013 • Telephone No. (717) 249 -3166 • Thomas P. Gleason, Esquire . Attorney for Plaintiff 49 West Orange Street, Suite 3 Shippensburg, •PA 17257 " .: • (717)532 -3270 . PYS511 Cumberland County Prothonotary's Office Page 1 Civil Case Print 2013-06574 VIGILANT HOSE COMPANY (vs) RODRIGUEZ EDWARD Reference No..: Case Type REAL PROPERTY - QUIET Judgment .00 Judge Assigned: GUIDO EDWARD E Disposed Desc.: Case Comments ************************************************** General Index VIGILANT HOSE COMPANY 20 WALNUT BOTTOM ROAD SHIPPENSBURG PA 17257 RODRIGUEZ EDWARD STAFFORD VI PLAINTIFF DEFENDANT Filed • 11/07/2013 Time ..... : 1:17 Execution Date 0/00/0000 Jury Trial • Disposed Date0/00/0000 Higher Crt 1.: Higher Crt 2.: ****************************** Attorney Info GLEASON THOMAS P ******************************************************************************** * Date Entries ******************************************************************************** FIRST ENTRY 11/07/2013 COMPLAINT - CIVIL ACTION - EQUITY - BY THOMAS P GLEASON ATTY FOR PLFF 1/10/2014 PETITION FOR SERVICE BY PUBLICATION- BY THOMAS P GLEASON ATTY FOR PLFF 1/14/2014 ORDER OF COURT - 1/14 PUBLICATION - *GRANTE COPIES MAILED 1/14/14 14 - IN RE: PETITIONFOR SERVICE BY * - BY THE COURT EDWARD E GUIDO J LAST ENTRY ******************************************************************************** * Escrow Information * ' * Fees & Debits Beg Bal Pymts/Ad] End Bal * ******************************************************************************** COMPLAINT TAX ON CMPLT SETTLEMENT AUTOMATION JCP FEE 65.25 .50 9.50 5.00 23.50 103.75 65.25 .50 9.50 5.00 23.50 .00 .00 .00 .00 .00 103.75 .00 ******************************************************************************** End of Case Information ******************************************************************************** EXHIBIT D TRUE COPY-FROMRECORD In Testimony whereof, 1 here unto set my hand and the se4bf said C5ift at Ciarlisle, Pa. a This a 7--day onotary `1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VIGILANT HOSE COMPANY, CIVIL ACTION Plaintiff vs. No: 13 -6574 EDWARD RODRIGUEZ, ACTION TO QUIET TITLE Defendant DECREE OF COURT N) NOW, this / ■ day of A j L , 2014, an affidavit of service of the Complaint with Notice to Plead being attached hereto and no answer having been made by the Defendant, and upon consideration of the foregoing Petition and upon motion of Thomas P. Gleason, Esquire, attorney for Plaintiff, It is hereby ORDERED, ADJUDGED AND DECREED that ownership of a 1963 Seagrave fire engine model number 900 with a serial number of N4965 is awarded to Vigilant Hose Company, and the right, title and interest of any other person or entity to said vehicle is hereby extinguished. The Department of Transportation may accept this order as evidence of ownership in lieu of a certificate of title. Vigilant Hose Company shall submit the appropriate forms, taxes and fees and comply with any other procedures of the Department of Transportation in order to receive the appropriate certificate for title for said vehicle. BY THE COURT: Cory oe&cis-1 G-tc,=0,) I/NiY J. 3