Loading...
HomeMy WebLinkAbout14-6222Bryan W. Shook, Esquire ID # 203250 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone — (717) 975-9446 Fax — (717) 975-2309 BShook(cr�dplglaw.com f 'i_1+u-O F ICE OF THE PROTHONOTARY 2014 OCT 23 PM 2: 36 CUMBERLAND COUNTY PENNSYLVANIA Attorney for Christopher Wherley IN RE: OWNERSHIP OF 1992 TRAILET WESTWIND XLT 2 -HORSE GOOSENECK TRAILER (VIN: 11 UWW252XN1000405) : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No: 2014- 2 2 Z - 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 li57spciis714 030602_ Bryan W. Shook, Esquire ID # 203250 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone — (717) 975-9446 Fax — (717) 975-2309 BShook(dpialaw.com Attorney for Christopher Wherley IN RE: OWNERSHIP OF 1992 TRAILET WESTWIND XLT 2 -HORSE GOOSENECK TRAILER (VIN: 11 UWW252XN1000405) : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No: 2014- - CIVIL TERM PETITION FOR DECLARATION OF OWNERSHIP AND NOW comes Christopher Wherley, by his legal counsel, Bryan W. Shook, Esquire, who petitions this Honorable Court, pursuant to 42 Pa. C.S. § 7531, et seq. for a Declaration of Ownership of a 1992 Trailet Westwind XLT 2 -Horse Gooseneck Trailer (VIN: 11 UWW252XN1000405) sufficient to permit the Commonwealth of Pennsylvania, Department of Transportation, Bureau of Motor Vehicles to issue a Certificate of Title to the aforementioned trailer in the name of Chris Wherley and in support thereof respectfully avers: 1. Your Petitioner is Christopher Wherley, an adult Pennsylvania resident currently residing at 4305 Avon Drive, Harrisburg, Pennsylvania 17112. 2. Christopher Wherley acquired the 1992 Trailet Westwind XLT 2 -Horse Gooseneck Trailer (VIN: 11UWW252XN1000405) (hereinafter simply referred to as the "subject trailer") from DM Performance Horses which has its principal place of business at 920 North Garfield Road, Bernville, Pennsylvania 19506. 3. DM Performance Horses sold the subject trailer to Christopher Wherely on July 10, 2014 for the sum of $2,600.00. (A Bill of Sale from DM Performance Horses to Christopher Wherley is attached hereto, made part hereof and marked as Exhibit "A"). 4. Venue is proper in this county, pursuant to Pa. R.C.P. 1006, as the subject trailer is located at 3357 Spring Road, Carlisle, Cumberland County, Pennsylvania. 5. It is believed that the last registered owner of the subject trailer was a farm in Delaware. 6. The undersigned filed a request with the State of Delaware, Department of Transportation, Division of Motor Vehicles to search their records to find any record of the subject trailer being registered or titled there; the search returned that no such record was found. (A true and correct copy of the reply letter received from State of Delaware, Department of Transportation, Division of Motor Vehicles is attached hereto, made part hereof and marked as Exhibit "B"). 7. The undersigned further filed a request with the Commonwealth of Pennsylvania, Department of Transportation to search their records to find any record of the subject trailer ever being registered or titled here; the search returned that no such record was found. (A true and correct copy of the reply letter received from Penndot is attached hereto, made part hereof and marked as Exhibit "C"). 8. Christopher Wherley, is unable to obtain a title to the subject trailer because he does not possess sufficient documentation so as to permit Penndot to issue a Certificate of Title in the name of the Christopher Wherley. 9. 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. 10.A search of the United States Department of Justice's National Motor Vehicle Title Information System (NMVTIS) was performed on October 16, 2014 and the search returned that the subject vehicle was not found in the NMVTIS database. (A true and correct copy of the October 16, 2014 NMVTIS search results are attached hereto, made part hereof and marked as Exhibit "D").12 11.A search of the National Insurance Crime Bureau (NICB) VINCheck database was performed on October 16, 2014 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 October 16, 2014 1 The National Motor Vehicle Title Information System ("NMVTIS") has been established pursuant to 49 U.S.C. § 30502 and has the participation of all fifty states. As of 2012, 96% of all U.S. DMV data was represented in the system. The purpose of NMVTIS is to assist in efforts to prevent the introduction or reintroduction of stolen motor vehicles into interstate commerce, protect states and individual and commercial consumers from fraud, reduce the use of stolen vehicles for illicit purposes including fundraising for criminal enterprises, and provide consumer protection from unsafe vehicles. http://www.vehiclehistorv.gov/nmvtis states.html (Last visited 10-16-2014). 2 The U.S. Department of Justice is responsible for oversight of the implementation and operation of NMVTIS, and works in partnership with the American Association of Motor Vehicle Administrators ("AAMVA"). AAMVA has been the operator since 1992. NICB search results are attached hereto, made part hereof and marked as Exhibit "E"). 3 12. There is no indication that there is anyone besides Christopher Wherley who claims ownership of this subject trailer. 13. 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). 14. The primary function of certificates of title to automobiles and in this instance, trailers, 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. 15. The entire action is largely procedural and administrative, as pursuant to 13 Pa. C.S.A. § 2401(2), DM Performance Horses and Christopher Wherley, took the steps necessary to transfer ownership of the trailer as between themselves as outlined more specifically on the attached Bill of Sale. See Semple v. State Farm Mut. Auto. Ins. Co., 215 F.Supp. 645 (E.D. Pa. 1963). 16.The entering of a declaration of ownership in this case would serve to permit Christopher Wherley to lawfully title, register and enjoy this horse trailer and would terminate and end any controversy or uncertainty of ownership which may come from having possession of or otherwise owning an untitled trailer. 3 NICB's VINCheck is a free service provided to the public to assist in determining if a vehicle has been reported as stolen, but not recovered, or has been reported as a salvage vehicle by cooperating NICB members. https://www.nicb.orq/theft and fraud awareness/vincheck (Last visited 10-16-2014). WHEREFORE, Christopher Wherley respectfully requests that this Honorable Court declare that Christopher Wherley is the owner of the 1992 Trailet Westwind XLT 2- Horse Gooseneck Trailer (VIN: 11UWW252XN1000405). Respectfullyll/`� Submitted: Date: O�JoL A 3, 1ofy ai Brya Shook, Esquire ID # 203250 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 975-9446 BShook(a�dplglaw.com Attorney for Christopher Wherley .• FAX 1eWt!'"I,`..',`."k"- ti•'Sd'a+0Wi rtes Edi 7y :24161' Company Name: DM Performance Horses Phone: 484-818-3091 FAX: 610-488-9049 ?Address: Be ville. PA 19506 Tor& i t SYnbo \<-- F 7V71- -q-Ts- a C1 DATE: /b—RE), iLI FROM: FAX*: # OF PAGES& Message: 9 a "-Tra:‘ \A(wse__. Ave_ 361d to 'hr• t, 1,1e.rt C --or X19OC', ©/I9 39Vd uci ,, +v^,.. ..:>'�W410,2�=Lfif..g.34ib-viifS.ni9•''`."r�`�.n+:4o'39'?' EXHIBIT IA 6120688tr0I9 Zb:00 bI©Z/ZZ/69 Division of Motor Vehicles P.O. Box 698 Dover, Delaware 19903 COPY REGISTRATION INFO $ 0 DRIVERS LICENSE INFO 0 COPY DRIVING RECORD VESZHECK L4 -1C". 845 RECEIPT k -42,t -Z) 0 CASH - TOTAL DMV EMPLOYEES INITIALS DATE VALIDATION SPACE ONLY Ii S04185 -MV -228 9/09 CUSTOMER DOVER P.O. ROE 098 DOVER, IDE 19903 13021744-2500 GEORGETOWN 22737 DUPONT BLVD, GEORGETOWN, DE 19947 ,.3021 053-1000 SHAILEN F'. BHATT SECRETARY October 6, 2014 5TATE Of DELAWARE DEPARTMENT OF TRANSPORTATION DIVISION OF MOTOR VEHICLES Dethlefs-Pyk.osh Lav Group, L 2132 Market Street. Camp Hill PA 1701.1 RE: VIN: 1 11:WW252XN1 000405 To Whom It May Concern: DELAWARE CITY 2101 MID COUNTY DRIVE NEW CASTLE. DE 19720 13021 226.5000 WILMINGTON 2230 HESSLER BLVD. NEW CASTLE, DE 19720 (302; 434-3200 In reply to the attached letter, we have checked our records and there is no active record on our computer database for the above referenced person or vehicle. If we may be of further assistance please feel free to contact us. Sincerely. Vatanda Wittianto Yulonda Williams M.V. Specialist, II Division of Motor Vehicles Yw De/DOT -7-- Darrell C. Dethlefs* .1. t'ykosh* Bryan W. Shook Heather N. Orisko Charles J. Hartwell Richard D. liollingworth, Jr. Matthew R. Seeley Katherine L. McDonald Hannah R. Suhr Matthew S. Kudrick DETHLEFS-PYKOSH LAW GROUP, LLC 2132 Market Street Camp Hill, PA 17011 Phone: (717) 975-9446 Toll Free: (800) 287- 1202 Fax: (717) 975-2309 E-mail: 1.Shook1iikIntaiaw.com hitn://www.dplglaweom Division of Motor Vehicles ATTN: Correspondence Section P.O. Box 698 Dover, DE 19903 Legal Staff Sherry L. Deckman* Crystal L. Mahoney Melissa C. Foreman Kathryn S. Fogle *Licensed PA Title AReni September 29, 2014 Re: Vehicle Title History — 1992 Trailet Westwind XLT 2 -horse gooseneck trailer — (VIN: 111:1WW252XN1000405) Dear Sir or Madam: Enclosed please find your form # MV703 (Personal Information Release Form) for vehicle title history information concerning the above referenced horse trailer. This information is necessary as I will be petitioning the Court of Common Pleas in and for Cumberland County, Pennsylvania for a Court Order authorizing the Pennsylvania Department of Transportation to issue a Certificate of title, to the above referenced trailer, in the name of my client, Chris Wherley. The last known registered owner of the vehicle will be notified of the Court Action as soon I receive notification as to who that individual is from your office. Please allow this letter to serve as sufficient proof of interest in this matter. Should you have any questions or require additional information please do not hesitate to contact me. Very truly yours, . Shook, Esquire Enclosures: L MV703 2. Identification Cards (Driver's License, Bar ID Card, Business Card for Bryan W. Shook) 3. Dethlefs-Pykosh Law Group Business Check in the amount of $15.00 4. Self -Addressed, Stamped Return Envelope • 138 East Market Street, 3'd Floor 550 Cleveland Avenue, Suite 204 York, PA 17401 A Debt Relief Agency Chambersburg, PA 17201 The Dethiefs-Pykosh Law Group, L1,C — "Your Full Service Law Firm '' COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION DRIVER & VEHICLE SERVICES HARRISBURG, PA 17123 10/15/14 08:45 BRYAN W SHOOK ESQUIRE 2132 MARKET ST CAMP HILL PA 17011-0.000 Dear Customer: 142881167000036 004 The Bureau of Motor Vehicles has received your request for information. We are not able to provide this information because the record you requested, as indicated below, does not exist in our files. VIN : 11UWW252XN1000405 If you have any questions concerning this information, please contact Vehicle Record Services at the address or telephone number listed below. ADDRESS CORRESPONDENCE TO: Department of Transportation Vehicle Record Services PO Box 68691 Harrisburg, PA 17106-8691 Sincerely, Customer Service Team Bureau of Motor Vehicles INFORMATION: IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE (8:00 AM TO 5:00 PM) 1-.800-932-4600 717-412-5300 1-800-228-0676 717-412-5380 www. dot. state. pa. us Auto Data Direct Vehicle History Search (NMVTIS) AutofataDirect, Inc. NMVTIS.. 1. YTN 11U V W2.52XR1000405 NOT round Cater V.lfik ..M. I IIIWIrti rrNtpiX1405 Search 2. Terms of Use 3 SnGno Information Record Not Found No Record was laud. If you w:str to matinee, please over a net" Sara a,uvn and diSa 'Search". Exit AvciCatie No Record Found Unfortunately, no matching record was found in the NMVI"!S database. Page 1 of 1 Please check the VIN you entered for possible errors. If the VIN is correct, this vehicle may be tilled in a stale not reporting to NMVTIS. View a map of participating slates. If a state, salvage yard or insurer does not report a vehicle to the federal database, no report will be available. Even though this VIN is not In the National Motor Vehicle Title Information System (NMV11S), it does not mean that this vehicle is tree of damage, title brands or other problems. NMVTIS dale comes from multiple sources, but the absence of 0 report is not an assurance of a vehicle's condition. Before purchasing a vehicle, check all available sources for inforrnetlon. Remember. even a "dean" vehicle history report does not guarantee that a vehicle is problem -free. It's always a good idea to take a vehicle to an independent mechanic to have it checked for evidence of accidents or damage. We apologize that we are unable to provide you with a vehicle report for this VIN. V EXHIBIT i D https: //apps.add 123.com/Nm.vtisPpi Web/Ninvt isPpiWeb.html?vin=11 UWW252XN 1.000... 10/16/2014 VinCheck italt/sAt.MURIACE.e!YmEStatrAt1 FraudSc`u(:ions• ',,;;'';,;';.. Theft x.11 f sad I' ,.rims VI ` Ct Ck VINCheck`M anions for VIT. •VtrWV :ZNIOmIuSO _ Print this Page { VTNChecktm Theft Record IIUWIN2S2XNId00405 has not been identified as a vehicle listed in the VINChecksi' Theft Records. } } } VlNChecks^ Total Loss 1 tUWW 252XNt 00d4OS has not teen Ide.ntifie3 as Record a vehicle listed in the VINCheck"' Total toss Records. VINChecksn's updated regularly as additional ,sibrmat_rcn is rept)rted ,yi uta epic' Funlrrr 6tf',nnalrn is ave l.nik ar51, Aut'. iWit ViNCheck"' is updated reguiarly as etl.itiotal infomiatdon in reported An additional source for vehicle hi'stery data can he found on the National Motor Volide Trirng Information System (hf'IVTI5) Web site by clicking here. NMVTt5 i if you are searching a motcrcyde, click here for additional } lniorrrtation from CycieviN. An additional charge will apply. CYCLEtCa IIsi The Notional Insurance Crime Bureau (NICB) has access to a database of vehicles which I Were reporced as stolen within the past five years and , swain unrecovere.d or declared as salvage. This .information is being made available, free of Charge, as a public senate to consumers. This database contains 3 "salvage" file and an "insurance thee" the which is the i information ,'INCheck searches during queries. The terms "ro;al loss" and "salvage" are not synonymous in the insurance industry and that is important to understand when using vlNChert.. Not all vehicles identified as a zeta! ioss wilt become salvage. A salvage dete-rr.inar:on is made tw .ndividual insurance companies based on indiv:duai ixmpany 1 policies and applicable State law. { • The NICB has not independently verified the information ,n the. database and : annot, therefor, vouch Tor the accuracy of this !ntormetion. • There are many other vehicles wh-dh have been reported as stolen which are not included in this Database. • Theft are also many other vehicles which are total losses or salvage which ere not intlusted in this database. • It is possible that a vehicle was incorrectly reported as having been stolen, Cr was stolen and recovered, but has not removed from tres database. • it is possible that a vch'cie was incorrectly reported as salvage and has not tr_er, removed from this Catabase. • it .5 also possible that there are vehicles with duplicate Vifis and/or VINs incorrectly entered. • If a vehicle reported in this database as having been Staten. bit riot recovered; you should verify with the NICE Cr your !ecar Few anfors'emens agency that a stolen article report is active before taking any action regarding the vehicle. ey checking a VIN against this database, you agree to not hold the NICO, its employees, Roard of Governors, Members, agents or any other entity which provided this information to NICO, 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. USER i0: r3 remember ma https://www.nicb.orgitheft_andiraud_awarenessivineheek Page 1 of 2 PASSWORD: r He, t0 teccnte a rrininbe15-eniy riser forgot year ID or password? • About VINChecks" NIC.C's VINLhec!' is a :rr .. service provided to the public to assist in determining If 3 vehicle has been reported as stolen, but not recovered, or has been reported as a salvage vehicle by cooperating ItICB members. To perform a search, a vehicle identification number (Vii -i) is required. A maximum of r:va VINCheck searches car: be conduced within a 24-hour period per IP address. Have a VINCheck success story? Tell us about it! Participating Companies Trio NICB VINCheck database is made possible through the cooperation of , articip:wing Nice members. EXHIBIT I E 10/16/2014 VinCheck Page 2 of 2 NCB VMCI:eck detabase thr0:41 the c.oeper,,ition partiopi,t.Mg .^41co Tc vow., thrp,;.e maint*.rn, please clIck aese, Search https://www.nich.org/theft_ancLfraud_awareness/vincheck 10/16/2014 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: %D a/4/e7 -hristoph Wherley IN RE: OWNERSHIP OF 1992 TRAILET WESTWIND XLT 2 -HORSE GOOSENECK TRAILER (VIN: 11 UWW252XN1000405) : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No: 2014- - 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, Certified, First Class, postage prepaid, return receipt requested, addressed as follows: DM Performance Horses 920 N. Garfield Rd. Bernville, PA 19506 (Certified Mail Receipt # 7013 2250 0000 5570 6483) Date: Respectfully Submitted: Bryan W. Shook, Esquire ID # 203250 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone: (717) 975-9446 BShookdplqlaw.com Bryan W. Shook, Esquire ID # 203250 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone — (717) 975-9446 Fax — (717) 975-2309 BShookdplqlaw.com tJ(T t! Attorney for Petitioner, Christopher Wherley IN RE: OWNERSHIP OF 1992 TRAILET WESTWIND XLT 2 -HORSE GOOSENECK TRAILER (VIN: 11UWW252XN1000405) • : No: 2014-6222 - CIVIL TERM Petition of Christopher Wherley : : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA AFFIDAVIT OF SERVICE OF ORIGINAL PROCESS Commonwealth of Pennsylvania County of Cumberland : ss. I, Bryan W. Shook, being duly sworn according to law, deposes and say that on October 23, 2014, I sent Respondent, DM Performance Horses, pursuant to pursuant to Pa. R.C.P. 403 as authorized by Pa. R.C.P. 400(b)(3) and 404(2), a true and correct, original time -stamped, copy of the Petition. I mailed the same to the address as follows: DM Performance Horses 920 North Garfield Road Bernville, Pennsylvania 19506 The aforementioned documents were sent postage prepaid via United States Postal Service Certified Mail, Return Receipt Requested, as evidenced by the attached receipts. The aforementioned Certified Mail was delivered to DM Performance Horces by the United States Postal Service on October 27, 2014 as evidenced by the attached United States Postal Service Return Receipt # 7013 2250 0000 5570 6483. Further, the Affiant sayeth not. DATE: / r - oJv ;rni.naf S imir, .t7ln IMF BY: B W. Shook, Esquire re me, this 2Sth day of October, 2014. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Crystal L. Mahoney, Notary Public Cairo Hill Dora, Cumberland County My Commission Expires March 20, 2018 $UUUAI, P•111111.10* A MSOaAnOO Of MOOAAIIS CARLISLE MPO CARLISLE, Pennsylvania 170139998 4134870013 -0096 10/23/2014 (800)275-8777 02:43:34 PM Sales Receipt Product Sale Unit Final Description Oty Price Price BERNVILLE PA 19506-9024 Zone -1 First -Class Mail Large Env 3.40 oz, Expected Delivery: Fri 10/24/14 Return Rcpt (Green Card) ®® Certified USPS Certified Mail is: 70132250000055706483 $1.61 $2.70 $3.30 Issue Postage: $7.61 Total: $7.61 Paid by: Personal Check $7.61 illi For tracking or inquiries go to USPS.com or call 1-800-222-1811. XXX*X*XX*2XX*2X**XXX*XX*X2*X*X*X*X*XXXXX XX**XXX*XXXXX*21K*eXX*XXXXXXXX*X*XXXXX'X*X BRIGHTEN SOMEONE'S MAILBOX. Greeting cards available for purchase at select Post Offices. *X**X**XXT.*X**XX*XXX*XXX**XX*X*XXXXX*X** ******2***X*X******X****70*******X***X2** Order stamps at usps.com/shop or call 1-800-Stamp24. Go to usps.com/clicknship to print shipping labels with postage. For other information call 1 -800 -ASK -USPS. **XX*XXX*X*X*XX**********X**X2*2X*XXX*XX **XXX*X*X*****XX*X**XX**X***X***XX*X**XX Get your mail when and where you want it with a secure Post Office Box. Sign up for a box online at usps.com/poboxes. ***************XX******X***XX*X**X*X***X ******XXX***X**XXXXXXX*XX*X*XXX*XX****XX Bili#: 1000405693721 Clerk: 07 All sales final on stamps and postage Refunds for guaranteed services only Thank you for your business HELP US SERVE YOU BETTER TELL US ABOUT YOUR RECENT POSTAL EXPERIENCE Go to: https://postalexperience.com/Pos Or scan this code with your mobile device. U.S. Postal ServiceTta CERTIFIED MAIL. RECEIPT (Comas* Mall Oniy; No insurance Coverage Provided) 7013 2250 0000 Postage Certified Fee Return Receipt Fee (Endorsement. Required) Reseicled Uoftwry Fee (Endorsement Required) Total Postage E Foes Sent To Q Din r C2cOrtp, S�liee(.{P. No.; or PD Box No. ?o N ��+e f) I? J :SENDER; CO/NJPi tETMiSa`.Ei11QN ;a Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired, al Print your name and address on the reverse so that we can return the card to you. ar Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: i ecit4,etn•encc. Liners `fp..v to Crci rzc; e 1Zcl. ern„ ; I 1 S©,C 'C©MPGE'TETMW SE ctiONFON .DELIVER i ro D. Is delivery address different from temj11 0 es If YES, enter delivery address below: 0 No ❑ Agent ❑ dd : see B. Recely-d by (l 4nted amel 3.. Service Type Certified Mail° O Priority Mail Express" ❑ Registered 0 Return Receipt for Merchandise ❑ Insured Mail 0 Collect on Delivery 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Transfer from service label) 7013 2250 -0000 5570 6483 PS Form 3811, July 2013 Domestic Return Receipt UNITED STATES POSTAL SERVICE First -Class. Mail Postage & Fees Paid USPS Permit No, G-10 • Sender: Please print your name, address, and ZIP+4® in this box• fit A . 5kmDL, Esq iI 3 2. •T a 2 kc 1161'ti=4'tii'i1'1i+1li1111i ii 11. 1111111ili1,l1$11111101iiiiiii IN RE: OWNERSHIP OF 1992 TRAILET WESTWIND XLT 2 -HORSE GOOSENECK TRAILER (VIN: 11 UWW252XN1000405) : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No: 2014- - - CIVIL TERM ORDER AND NOW, this the 51 day of OA -0""' , 2014, upon consideration of the Petition of the Christopher Wherley for a declaration of ownership of a certain 1992 Trailet Westwind XLT 2 -Horse Gooseneck Trailer (VIN: 11 UWW252XN1000405), the Court hereby awards exclusive ownership of one 1992 Trailet Westwind XLT 2 -Horse Gooseneck Trailer (VIN: 11UWW252XN1000405) to Chris Wherley and the right, title, and interest of any other person to said trailer 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. Christopher Wherley 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. gISTRIBUTION LEGEND: ` /Bryan W. Shook, Esquire 2132 Market Street Camp Hill, Pennsylvania 17011 (717) 975-9446 DM Performance Horses 920 North Garfield Road Bernville, Pennsylvania 19506 (484) 818-3091 ConpIES ,'t if:cL lv� t Y l3/77/v c,)