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HomeMy WebLinkAbout05-0785 Zimmerman's Auto Service Inc. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA VS. PENNDOT : CIVIL ACTION LAW : Civil Term OS - 1RS CI",L<-r'iA.~ NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: You have been sued in Court. If yoa wish to defend against the claims set forth in the following pages, you must take action within twenty days after this Petition 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 Petition or for any other claim or relief requested by the Plaintiffs. 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 CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty A venue Carlisle, PA 17013 (717) 249-3166 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. S 4904 relating to unsworn falsification to authorities. ~~~fwner ) :2. - q- 06- Zimmerman's Automotive 2234 S. Market Street Mechanicsburg, PA 17055 (717) 766-7656 F4)l.. 717 766' '??'l7 Zimmerman's Auto Service Inc. Civil Term VS PENNDOT Petition to Obtain Transfer of Title VIN #lZWFf61LOX5644035 1999 Mercury Cougar We are petitioning for a title for said vehicle. We have had the vehicle since February 2004. The vehicle would not run, and we were asked by thc owner to diagnose it We needed to partially disassemble the engine to discover it needed an engine replacement. We have tried numerous ways to contact the owner, but they have not responded in a positive manner. We are petitioning for title of the vehicle. "',::::JiERMAN'S AUTo~rOTIVE 2234 S. MARKET ST. r\F,ECHAr-."('~D~I?".C, PA 17055 ~/fJ1. :J, - 1- 0 S Zimmerman's Automotive Service Inc. 2234 South Market St. Mechanicsburg, P A. 17055 Phone -717-766-7656 Fax -717-766-7797 INVOICE 35107 Org. Est. # 083735 Old Fashioned Values. 21st Century Technology Part Description Work Completed Date: 01/25/2005 Print Date: 0112512005 1999 Mercury - Cougar 2.5L, V6, VIN (L) Lic #: EXP6755 Odometer In: 136899 Unit #: Silver Vin #: 1ZWFT61LOX5644035 Hat # : pz Ref # : Sale Extended Labor Description Extended INVOICE Crans, Danielle PO Box 9254 New Castle. PA 16107 Home 724-652-2431 ---- Office 724-931-9434 Cust ID: 7518 Qty Diagnose engine noise including partial disassemble to check lower end of engine. Needs engine replaced. Storage Storage for vehicle. $50.00 per month for 12 months. 244.55 600.00 [Technicians: Goodling, Jason; Please, Select 1 Or9. Estimate $895.22 Revisions $0.00 Current Estimate $ 895.22 Additional Cost Revised Estimate labor: Parts: Sublet: Sub: $844.55 $0.00 $0.00 $844.55 [ Payments - ] Tax: Total: 581 Due: $14.67 $859.22 $859.22 I hereby authorize the above repair work to be done along with the necessary material and hereby grant you and/or your employees permission to operate the car or truck herein described on street, highways or elsewhere for the purpose to testing and/or inspection. An express mechanic's lien is hereby acknowledged on above car or truck to secure the amount of repairs thereto. Warranty on parts and labor is one years or 12,000 miles whichever comes first. Warranty work has to be performed in our shop & cannot exceed the original cost of repair. SIGNATURE... Zimmerman Je Paul M. Date...... ................................... Time......................... Page 1 of 1 06.30,04lnvoic1a __ _ ........ "'..,. U~: ;"-111'0 Crans 1-6:~"~5?-5805 .Zimmerman's Auto ATTN. PAUL July 2, 2004 De-ar Paul. I am sending you this fux hi regards to :ny sister's car, Dan[elk Crans, 1999 mercury cougar. I apologize for the delay in getti:'\g back to you. 1 n.:..er got the first message you left in June ar,d I just got the sccond Ol:'~. We are stilla",aiting the title to come from the financing OOlnIYdllY, I mailed in the pape[,\I\'ork, they then sene Danie~le a letter stating there was a fee that had to be paid in order to process the title. J then sent Hul' in and they S3id it would take 30 - 60 days to receive the title. We will send it directly to YO\1 when it e.omes. Again, [ apologize fur the delay. My work schedule is lang in the summer alKt I am not aHowed to make personal calh from work, SI,) that is why I am sending you this fax. If you have any questions, please leave a message at 724-652-2431. 'Thanks. Sincerely. ..!r-vxorJ,t..- Tracv Clark (sister) 1'.1 Danielle Crans P.O. Box 9254 New Castle, PA 16107 Dear Danielle: November 16, 2004 We would appreciate hearing from you in reference to your 1999 Mercury Cougar. Would you please call or fax me and let me know your wishes on this vehicle. Can you not find or acquire the title? Are you planning to repair the vehicle? Do you want to come and tow the vehicle away? My parking spaces are valuable, especially coming into the winter. If I turn it over to the police, they will take the vehicle away and I will not receive anything toward my costs. I would very much like to hear from you in the next few days. SENDER: COMPLETE THIS SECTiON . Complete items 1. 2, and 3. Also complete item 4 if Restricted Delivety is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailplece. or on the front if space permits. 1. Article Addressed to: D411,'f!, /Je- C ran .s po. 80><. 9;)... 51 New &.5 fie f.-.r, , /6/t:>? Sincerely, Paul Zimmerman's Co-Owner Zimmerman's Automotive COMPLETE THIS SECTION ON DELIVERY 3. Service Type .fiL Certifled Mail 0 Exp.... Mall o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 0s{J9 ,. ArticleNumber rv 0/\ '\ 1 <:"51 J (Transfer from service label) 7(J.:iJ . V\.OOO. VOl I . <,.). '-I. ~S Form 3811, August 2001 Domestic Retum Receipt 1 02595.Q:j~.M-1540 '-HUC OJ. .......,.".,....., ~,.,......'....... ,....,........... r-7%3 ',0011001 F-rt' ~"",""."'VlU tu:'4i' -- fROHA 'lii~' A~to Blr Alice T1T-zm8ro 1t PEHHSYUJRHIR IHDEPEKDEHT aUTOMOBilE BERLEHS RSSOrlRTlOH E~EC,{80NIC LIEN VEB!FICA TION qOUESUOl\M Please type 01' print nearly Requesting Dealer Name 2/~I1JIJ?t:"l"'m~.s A./b ~.s 4"em~on-member (arcleone) DIN R~-/..?tt<97>2..z: Dealer PbollC Number 7/7- 766'- ?6S',6' Fax 7/7 - ?~/-7?97' , Customer Name ---'11"1 k.{\ e. C ,-~ ~ ."' Year, Make, Model 99' d?erc.<<ry r.ot-l9Qr I t/ Vehicle ID Number(VIN) /2. (L)PT6/,t.. oX..r61/~.I) PA Title Number (Required) Complete above information and fiIx to PIADA at 711.238-3870 Cost fur report is $8.00 for members and $11>.00 for nou-members. " NOH-memb/l1'S mU$t enclo1e credit card number/expi1'r1lion date forpaymUJI: Name on card Type of c;ard (circle one) Visa MasterCard Amcx Discover Card N~ Exp.Date. IS01 N. '.OIlT STIli'! . J{AaaISllllG, p'Klln~vAMu. 11102 111.238.8002 · j,.x: 111.288-8810 JAN-04-2005 16:22 FAX: 7177667797 ro: PAGE: 001 R=l00~ Hft\MfJiiCR~QIT JAN 18 2005 To: ZIMMERMAN AUTOMOTIVE 2234 S M~T UPPER ALLEN PA 17055 RE: 404547911 1999MERCURY COUGAR lZWFT61LOX5644035 To Whom It May Concern: This letter is to inform you that AmeriCredit has no intention to enforce its security interest in the vehicle described as a 1999 MERCURY COUGAR. We will not oppose any action. You ZIMMERMAN AUTOMOTNE, may take pursuant to a legally imposed mechanic's lien or salvage title; however, we do not waive any rights to pursue our customer, the registered owner, DANIELLE M CRANS for the deficient balance remaining. Should there be any questions concerning this account, please contact AmeriCredit Financial Services, Inc., at 877-817-1329. Thank you, ... ~ &~.?~L Loss Mitigation Dept. 4000 Embarcadero Drive 2"J Floor. Arlington, TX 76014. 877-8l7-1329 -\0,. ~ (':) V) It ~ Vc -- ~ () ~ ~ ~ ~ ~ ~ ~~r ~ "', --\.U- \"-.", .-', '.' -',"1 :---! -, -- ~..'. (,) l." "',, (;J ZIMMERMAN'S AUTO SERVICE INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. 05-785 CIVIL PENNDOT IN RE: PETITION TO OBTAIN TRANSFER OF TITLE ORDER AND NOW, this z Z ~ day of February, 2005, hearing herein is set for Thursday, April 7, 2005, at II :00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. The petitioner shall serve upon the vehicle owner(s) a copy of their petition and a copy of this order setting the hearing by both certified and regular mail not less then ten (10) days prior to the hearing and shall, prior to said hearing, file an affidavit of service. BY THE COURT, Paul M. Zimmerman Petitioner /l.d :rlm ~. rn rne.~lY\QI\' S ~n(\ tJ01- ) tt\.\J'[} >(1 \(lIWV ~l <al:l9JOl -------."--_.."._-.-~- . Commonwealth of Pennsylvania County of Cumberland os: - "1~ CIG;lL '-&~ I, Paul M Zimmennan, sent copies of the below mentioned petition to AmeriCredit and Danie\le Crans on March 7, 2005 via regular mail and certified mail. Court of Common Pleas Cumberland County, Pennsylvania Civil Action - Law 05-785 Civil -i!J/lIf.~~ "7. \0...('\ ed Cf.-' 5 uJotin be\ute, fhQ..-. fYb-rch / ~ { d.Cf)JL-- JJtf-= - Notarial Seal Judith A. Walter. Notary Public Upper Allen Twp.. Cumba~and County My Commission Expires May 12, 2006 Merr.ber, Pennsylvania Association Of Notanes ~ ZIMMERMAN'S AUTO SERVICE INC., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. 05-785 CIVIL PENNDOT IN RE: PETITION TO OBTAIN TRANSFER OF TITLE ORDER AND NOW, this z z ..t day of February, 2005, hearing herein is set for Thursday, April?, 2005, at 11:00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, P A. The petitioner shal! serve upon the vehicle owner(s) a copy of their petition and a copy of this order setting the hearing by both certified and regular mail not less then ten (10) days prior to the hearing and shall, prior to said hearing, file an affidavit of service. BY THE COURT, Paul M. Zimmerman Petitioner /J. ;1. :rlm ,\ - ... . ,. . j'\ fLd 1 " 2005 Zimmerman's Auto Service Inc. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. PENNDOT : CIVIL ACTION LAW : Civil Term DS - -^lIS Civi LlliLYYJ AND NOW, this r day of 4;0"'( ,20, after reasonable notice and an opportunity for hearing having been provided to all interested parties, the Court hereby awards ownership of one 1999 Mercurv Cougar bearing vehicle identification number lZWFf61LOX5644035 to Zimmerman's Automotive Service Inc., and the right, title and interest of any other person 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. The Petitioner 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 of title for said vehicle. ,~ BY THE COURT: L r ~ft . Judge . ~-t t; ~ ~~~~ ~~ 1Yl=;11...~ t.c 3/7(Q..j --P~ J)v 1- r --------/- ;-:. - (..) 2:,~ -..", - - " "-, ~ <.ri h ::P -D 1 ......, 'i? 3'1 nj~ r- :C;'" ~-c.:..Jt;;' '-':1[_:, f?;~~~' 0-1 ,..,;-;. .:0 .""