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Home My WebLink About13-6623 JEFFREY HAGEN, : IN THE COURT OF COMMON PLEAS Plaintiff, pro se : OF CUMBELAND COUNTY, : PENNSYLVANIA V. r , C-) r-q 'L7 3 :L-r KELLY TRIVELY, CIVIL ACTION zrn Defendant C -tom` No. 13 — 4 G d 3 awl-f tfk 5� _ _< _-' PETITION FOR VEHICLE TITLE 1. The plaintiff is a resident of Pennsylvania, residing at 153 Blue Jay Way Hummelstown, PA 17053. 2. The defendant is a resident of Pennsylvania residing at 201 Columbia Ave. Camp Hill, PA 17011. 3. The plaintiff owns a rental property in Cumberland County, located at 101 E. Main Street Shiremanstown, PA 17011. The property consists of two apartments and separate five-stall garage. 4. The defendant was a tenant of 101 E. Main Street Shiremanstown, PA 17011 from approximately 1997 though 2000. 5. While a tenant of plaintiff's property, the defendant owned and operated a 1984 Ford Mustang bearing vehicle identification number IFABP28M5EF179184 and PA license plate number KELL 33. 6. While a tenant, the defendant entered into an agreement with plaintiff to rent a garage stall for$25 per month to park said vehicle. 7. In 1999 the subject 1984 Ford Mustang ceased operating, the defendant parked the subject vehicle in the rented shall. 8. The defendant vacated the apartment she had been renting from plaintiff in 2000 and failed to remove the 1984 Ford Mustang from the garage stall. 9. The defendant has not paid rent, interest or penalties for the garage stall since vacating the premises. 3 75- o� xt- ,L-?6Ti 10. The defendant has not attempted to reclaim the vehicle since vacating the premises 11. The subject vehicle has not had a current Pennsylvania inspection since 1999. 12. The subject vehicle has not been registered with the Commonwealth of Pennsylvania since June 2001. 13. By failing to pay rent, interest and penalties and make any attempt to reclaim the vehicle for over 12 years, it is plaintiff's position the defendant has forfeited ownership of the subject vehicle. 14. In lieu of seeking recovery for unpaid rent, interest and penalties, the plaintiff seeks to gain ownership of the subject vehicle. The plaintiff requests the court execute the Court Order extinguishing defendant's right, title and interest in the subject vehicle and awarding all right, title and interest of the 1984 Ford Mustang to plaintiff. effrey Hagen, plaintiff, pro se COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION SAFETY ADMINISTRATION HARRISBURG, PA 17123 7/03/13 14:16 HAGEN,JEFFREY 131841391000040 001 153 BLUE JAY WAY HUMMELSTOWN PA 17036-0000 Dear Customer: Enclosed is the Vehicle Information you requested. If you have any questions concerning this information, please contact Vehicle Record Services at the address or telephone number listed below. Sincerely, Customer Service Team Bureau of Motor Vehicles ADDRESS CORRESPONDENCE TO: INFORMATION: (8:00 AM TO 5:00 PM) Department of Transportation IN STATE 1-800-932-4600 Vehicle Record Services OUT-OF-STATE 717-412-5300 PO Box 68691 TDD IN STATE 1-800-228-0676 Harrisburg, PA 17106-8691 TDD OUT-OF-STATE 717-412-5380 www.dot.state.pa.us PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 7/03/13 14:16 PAGE 1 131841391000040 002 OWNER KELLY A TRIVELY LESSEE NONE 101 EAST MAIN STREET SHIREMANSTOWN PA 17011 TITLE NUMBER 36150176 TAG NUMBER KELL33 TITLE DATE 05/08/84 VIN 1FABP28M5EF179184 REGISTRATION EXPIRY DATE: 06/01 BODY TYPE CP MAKE FORD ODOMETER READING 10,230* MODEL *ACTUAL MILEAGE RENEWAL WID 001950310000440 001 DUPLICATE TITLE COUNT 0 PREVIOUS TAG 20YEAR VEHICLE YEAR 1984 LIENS NO STOLEN DATE STOPS NO TITLE BRAND INFORMATION NO TITLE BRANDS EXIST FOR THIS TITLE ADDRESS CORRESPONDENCE TO: INFORMATION: (8:00 AM TO 5:00 PM) DEPARTMENT OF TRANSPORTATION IN STATE 1-800-932-4600 VEHICLE RECORD SERVICES OUT-OF-STATE 717-412-5300 PO BOX 68691 TDD IN STATE 1-800-228-0676 HARRISBURG, PA 17106-8691 TDD OUT-OF-STATE 717-412-5380 WWW.DOT.STATE.PA.US JEFFREY HAGEN, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : e ' rn m �.. KELLY TRIVELY, ° r DEFENDANT NO. 13-6623 CIVIL Cnr- .Q ORDER OF COURT ^^�3 -- AND NOW, this 13th day of November, 2013, upon consideration of thdiPl&tift Petition for Vehicle Title, IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule is issued upon the Defendant, Kelly Trively, to show cause why the relief requested should not be granted; 2. Defendant will file an answer on or before December 20, 2013; 3. The Plaintiff shall serve this Order on the Defendant by certified and regular mail to the Defendant's last known address at 2010 Columbia Avenue, ,Camp Hill, PA 17011 and 201 Columbia Avenue, Camp Hill, PA 17011; 4. The Prothonotary is directed to forward said Answer to this Court; 5. Argument on the matter will be held on Thursday, January 9, 2014, at 8:30 a.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, M. L. Ebert, Jr., J. ZJeffrey Ha en g , Pro Se Plaintiff . ,,I/Kelly Trively, Pro Se Defendant bas it lit l (") e..a SHERIFF'S OFFICE OF CUMBERLAND COUNTY a - -- Ronny R Anderson m `.'F Sheriff coy-- i �x4xt3,at' "arNwG�,?4 -< " o't t Jody S Smith r r— —,_�� Chief Deputy 0<c-.) =-,-, Richard W Stewart 3 `" ,c~; oc: c`'P�F Solicitor oFr E OF T "Erw,'i=` '-x Jeffrey Hagen vs. Case Number Kelly A Trively 2013-6623 SHERIFF'S RETURN OF SERVICE 12/02/2013 07:49 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Order& Petition by"personally" handing a true copy to a person representing themselves to be the Defendant,to wit: Kelly A Trively at 2010 Columbia Avenue, Camp Hill Borough, Came `P, PA 17011. `. - •i/J/ BRIAN GRZYB o SKI, D UTY SHERIFF COST: $49.41 SO ANSWERS, 6 :72 ‘7":' December 03, 2013 RON�R ANDERSON, SHERIFF • (c)CounrySuite Sh•rif`:Tcleoscf;.Inc. JEFFREY HAGEN, • IN THE COURT OF COMMON PLEAS OF PLAINTIFF • CUMBERLAND COUNTY, PENNSYLVANIA • V. rr � r KELLY TRIVELY, • DEFENDANT •. NO. 13-6623 CIVIL >T <' ORDER OF COURT :; 3," AND NOW, this 9th day of January, 2014, upon consideration of the FvI thtiff' Petition for Vehicle Title and after hearing, IT IS HEREBY ORDERED AND DIRECTED that the Petition is GRANTED. This Court hereby awards ownership of one 1984 Ford Mustang, bearing vehicle identification number 1FABP28M5EF179184, to Jeffrey Hagen. The right, title and interest of Kelly Trively or any other person to said vehicle is hereby extinguished. The Pennsylvania Department of Transportation may accept this order as evidence of ownership in lieu of a certificate of title. The Petitioner shall submit the appropriate forms, taxes and fees and comply with any other procedures of the Pennsylvania Department of Transportation in order to receive the appropriate certificate of title for said vehicle. By the Court, 1\\* 1 M. L. Ebert, Jr., J. Jeffrey Hagen, Pro Se Plaintiff e l— bas S S 11 rr; 4� &Ard4t1—ien fj //9/1/$0