HomeMy WebLinkAbout14-6324Jeffrey R. Boyd, Esquire
BOYD & KARVER
7 East Philadelphia Avenue
Boyertown, PA 19512
610-367-2148
tto`ney tD # 89033
Attorney for Petitioner
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
TO DETERMINE OWNERSHIP
OF A 1974 HILLCREST
/
CIVIL ACTION
)(1 .
NO. � �� t
IN RE: PETITION OF THOMAS E. NICE
: ATTORNEY 1.D. #89033
PETITION TO DETERMINE OWNERSHIP OF A 1974 HILLCREST
Your Petitioner, THOMAS E. NICE, through his attorney, JEFFREY R. BOYD,
ESQUIRE, respectfully represents:
1. Your Petitioner lives at 90 Salem Church Road, Lot 201, Mechanicsburg,
Cumberland County, Pennsylvania 17050.
2. On September 6, 2014, Petitioner purchased the mobile home from Ed Stover,
the manager of the Salem Acres Mobile Home Park for the sum of $1,000.00. A copy of the
Manufactured IIome Bill of Sale is attached as Exhibit A.
3. The home was previously owned by Heather Leigh Henry of 145 Hermon
Avenue, Apt #1, Lemoyne, PA 17043.
4. A copy of a letter from Ms. Henry stating that she has no interest in the home
is attached as Exhibit B.
5. Petitioner has been unable to obtain the Title to the mobile home.
6. Petitioner was unable to locate the VIN # for the mobile home.
7. Petitioner contacted the local police who performed a VIN # Verification,
without success.
8. Petitioner went to a notary who performed a search with PennDOT. A copy of
the search is attached as Exhibit C.
9. Petitioner is the legal owner of said 1974 Hillcrest, having purchased the same
from Salem Acres Mobile Home Park in 2014.
10. Petitioner seeks to have the title registered in his name for the following
ookk s l is.75 Pjff.t,
C 301 -
"��a9 ?
mobile home: 1974 Hillcrest, Serial No. 02V-70144, VIN #Unknown.
WHEREFORE, Petitioner requests this Honorable Court to enter an Order
directing PennDOT to transfer the title for the above-mentioned mobile home in Petitioner's
name.
Respectfully submitted,
A/ r
Jeff f' .': oy s , Esquire
A orney for Petitioner
7 East Philadelphia Avenue
Boyertown, PA 19512
610-367-2148
VERIFICATION
I, THOMAS E. NICE, verify that I am the Petitioner named in the within action, and that
the facts set forth in the foregoing are true and correct to the best of my knowledge, information and
belief. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904
relating to unsworn falsification to authorities.
Dated: I ° 2,6 , 2014
Thomas E. Nice
16/03/2014 17:12 7176919254
SAFETY
PAGE 03/09
MANUFACTURED HOME BILL OF SALE
( Paw 10f2)
M CONSIDERATION of the sum of $ 54/ /Jt00_0'
/ z,41
received by,
whose address Is
from
?lb
`711fr\-,
("BUYER")
whose addrs- is
receipt and sufficiency of which re hereby acknowledged, SELLER(s) grants, sells, conveys,
transfers and delivers to BUYERthe followino Manufactured home:
MANUFACTURER:
P1ODL
WILL ClIA
-----
-.
SERIAL NUMBER:
0
. \ ••••• . ,
2_
S.LZE:
YEAR MANUFACTURED; .
CURRENT LOCATXON OF HOME: '
• P/0-43.4:Lt G____M______gtA,_:_ZG
To have and to hold the same unto BuYERand BUYER'S executors, administrators, and assigns,
forever.
'MantifaCtured NOMA Ifrord-togeth-ervitir an equal interest in all the fixtures., acces..sodeLenci,_
equipment and all other necessaries thereto appertaining and belonging except:
SELLER warrants that Manufactumd Home Is sold free and clear fiorn any lien, security Interest,
mortgage or other encumbrance, except;
a lien by ("IMN HOLDER"),
SELLER warrants to BUYER that SELLER Is the legal and true owner of the Manufactured Home
and tha.t SELLER has the right to sell'the Manufactured Home.
SELLER will defend Manufactured Home against any claims or demands, except any previously
mentioned lien (if any).
7 The Manufactured Home is s
warranties or representations ha n made by Seller to Buyer.
OR
? The Manufactured Home Is sold with the following warranty:
•
h no express orimplled
SUYER"S IP11TIALS
EXHIBIT "A"
10/08/2014 04:48 Carlisle Carrier
11
T47176918559 P.0011002
i5101() .1±) co; th the_
8-31 9b Q/ Y)
13,,oL,4 002- 1Bt-t-6cn
eksc Ohok
EXHIBIT "B"
'10703/2014 17:12 7176919254
`n•
•'
SAFETY PAGE 09/09
Lice0.e 13x0 .els Mecharfcsbu g
•y
PA"Aii'to' L1censc •Prokers.Mech a nicsburg
: 6.483 C ij'Hs1e; ike Suite 104
•
'.Mechanitsburg,'A 17050
(717) 691-6720- -
For:
THOMAS ERIC•NICE •. . •
• 90 SALEM CHURCH RD LOT 201
MECNANICSBIIR9,1?A 17050 .
t
•
•' Record #:'36467.
1'
Date: 09/03/2014
;Time: 10:37 AM
•
Clerks.Initials: djrri
Title Number
VIN
Year
Mat e
Odometer'
Tag Number
Con lents:
MVI6A •
•
4 4y
•
Offline Transaction
UNKNOWN '
b2V70144
1974_
• litLL• CREST
.,
I/We swear that I/we have applied for the above'jtem(s).-
t• ., y
Sworn and subscribed to before me on 03 -Sep -2014.
Notar
99/03
01.4 10:37AM
Agency Fees
Conruuotiwealth of PA - Disc •50.00'
•
Agency amount paid
Cbeck,to.state•O ---•
Su�`cb�ai•ge' ' . .
Total Agency -Fees
•
50610 •-
• r',• •i . , •,. •Q.0'o ,••
50.06
Service Fees
Messenger Fee ' • •
Nofary/Clerical Fee •
Copy/Fax Fee •
Other Fee -•
Payment Type'
Total Fee'
Surcharge
Total' Surcharge.. •
Total Amount Due
Amount Tendered
Change Due
50.Q0_•
0:00,
0100
0.00
'DEDIT
50.00-
' 0.00
0.00
'100.00
100,00
0.00
No J efurads, on Service or Notary fees. We are xaot '
'responsible for 'the work the State fails to process,
Welcome to PA Auto License BrokergMeclsaniesburg
Your Direct Coxzoection with PENNDOT, "Online", State & Service Fees Apply
•
EXHIBIT "C"
•
i
LU -Or- F ICE
THE PROTHONOTARY
2014 NOV -6 AM 8:142
CUMBERLAND COUNTY.
PENNSYLVANIA
IN RE: PETITION OF THOMAS E. NICE
TO DETERMINE OWNERSHIP OF A
1974 HILLCREST
Countp of itumber1anb
IN THE COURT OF COMMON PLEAS
OF THE NINTH JUDICIAL DISTRICT
2014-6324 CIVIL ACTION
IN RE: PLAINTIFF'S PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 5th day of November 2014, upon consideration of the Petition to
Determine Ownership of a 1974 Hillcrest, a RULE is issued upon Respondents to show
cause the requested relief to title ownership in Petitioner should not be granted.
PETITIONER shall effectuate service of this Order of Court upon Respondents and
shall file proof of service. Response by Respondents shall contain a proposed order.
RULE RETURNABLE twenty (20) days from the date of service.
BY TH
tribution:
grey R. Boyd, Esq.
toyer
eather Leigh Henry
/I//i/y
Thomas fl 11acey C.P.J.