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HomeMy WebLinkAbout06-5008 , . o In The Court Of Common Pleas of Cumberland County, Pennsylvania In Re Motorcycle, VIN JYA4M400lBA013099 ; Dkt. # D{. - %tYR {It:'':L~~ Roger Lee Drake, Petitioner 513 Spring Run Drive Mechanicsburg, Pa 17055 Petition for Order to Confirm Ownership Roger Drake by and through counsel move this Court for an Order confirming ownership of a Motorcycle and avers as follows: 1. Roger Drake is the owner ofa 1981 Yamaha 650 Special motorcycle, bearing Vehicle Identification Number JYA4M400lBA013099. 2. The vehicle was purchased by Roger Drake in or about 1984 from Poor Richard's Auto Sales of New Cumberland, Dick Brubacher proprietor. Mr. Drake received a proper title at the time of the purchase. Mr. Brubacher indicated that he retained records for only 10 years and did not have a copy of the title or transaction records due to the passage oftime. 3. The vehicle was licensed and operated for about a year, but was permanently parked when Mr. Drake got married. 4. Registration lapsed, and the vehicle is no longer in the PennDOT records system. 5. Sometime from 1985 to the present date, the title documents were lost because of water in the basement area where they were stored. 6. In June 2006, Mark Lebo, petitioner's brother in law, expressed interest in purchasing and repairing the vehicle for his use. 7. The vehicle has been repaired and is ready to be transferred and licensed to Mr. Lebo upon confirmation of title as required by PennDOT Form MV-217, and MV-38. (Attached). 8. PennDOT has supplied a draft Order on the back of Form MV-217. 9. Form MV-217 includes a Note that "in questionable cases," the Department may require the applicant to execute an indemnification agreement or other forms. 10. Petitioner has no objection to indemnifying both the Department and the purchaser, and language is added to the draft form of Order for that purpose. 1 I. The above statements are confirmed by sworn affidavit of Mr. Drake. Wherefore, Petitioner requests that an Order confirming ownership be issued in the form of the proposed Order attached. , /s/ ew An ew bin Atty. No, 43571 Andrew W. Barbin, P.C. 5020 Ritter Road, Suite 109 Mechanicsburg,Pa17055 717-506-4670 Date: August 23, 2006 MV-,217 (03-03) . , ~ Commonwealth of Pennsylvania Bureau of Motor VehIcles . . P.O. BOX 68672 HARRISBURG, PA 17106-8672 APPLICATION FOR CERTIFICATE OF TITLE AFTER DEFAULT BY OWNER .. FOR DEPARTMENT USE ONLY .. NOTE: When default occurs, the following three options are available for obtaining a certificate of title. Form MV-1 must be properly completed and accompany this application in all cases. CHECK APPROPRIATE BLOCK below indicating which option you are proceeding under: /./ o 1. Judgment and execution 0 2. Non-judicial sale or repossession and retention ~ Court Order (U.C.C.) Title Number 099 FOLLOW THE INSTRUCTIONS BELOW FOR THE APPROPRIATE BLOCK CHECKED ABOVE AND THE APPLICANT LISTED ON FORM MV-1 MUST SIGN THE APPLICATION BELOW. Applicant Name OPTION 1 - JUDGMENT AND EXECUTION -(NOTE: An individual or business listed as a lienholder on a Pennsylvania Certificate of Title that is not licensed with the Department of Banking, must follow this Option). If the vehicle owner has defauited on a loan from a private individuai, then Option 3 may be used for the lienholder to take ownership of the vehicie. (NOTE: A Judgement is used by a private individual that is listed as the lienholder on the Pennsylvania Certificate of Title. This option will allow the individual to be re~paid for the remaining amount of the lien.) The purchaser at the sheriff's.~onstable's sale may obtain certificate of title upon presentation of all the following items: . Certified copy of the judgment and writ of execution, or the court order of sale. . Bill of saie from the sheriff, constabie or other duly authorized executing officer showing the date of sale, name of purchaser, make and V1N of vehicle. . Documentation that any existing lien is satisfied. OPTION 2 - NON-JUDICIAL SALE OR REPOSSESSION & RETENTION (Uniform Commercial Code) Certificate of title will be issued in the name of the purchaser at the sale (who may be the lienholder) upon receipt of the following: .. . . The certificate of title when a lien is recorded on the title OR the original or an acceptable copy of the filed financing statement. . The original or an acceptable copy of the agreement which is the basis of the right to repossess. . The original or an acceptable copy of the notice of intention to sell, mailed to the debtor. ( i) If a public saie, the notice must set forth the time and place of the'sale. ( Ii) If a private sale, the notice must set forth the time after which the sale is to be made. . Bill of saie showing the date of sale, name of purchaser, make and VIN of vehicle, if the purchaser is not the lienholder OPTION 3 . COURT ORDER - (NOTE: A sample court order is printed on the back) This option is used by a lienholder, who is not recorded on the Certificate of Title or who is not licensed by the Department of Banking, when the lienholder wls.hes to obtain ownership of the vehicle. C'tiiicate of title will be issued upon receipt of the foilowing items: / . A certified copy of an order of a Court of Common Pleas listing the make and VIN of the vehicie and naming the person l to whom the court awarded ownership of the vehicle and proof that notice of the Court of Common Pleas proceeding was given to the prior owner and any other person who had an interest in the vehicle. . " If the originai certificate of title is available, it must be attached to your application and court order. If the title is not aVailable, documentation must be inciuded explaining why the title is not attached. -_...,-"'"" . NOTE: In questionable cases, the Department may require the applicant for certificate of title to execute an indemnification agreement, or other forms as necessary. I/We hereby make application for a certificate of title and certify under penaity of law that I/we have complied with )( the appropriate instructions listed on this application and have acted in accordance with the law. f3 01- tJlP Dale . NOTE: THIS IS ONLY A SAMPLE. A certified copy of the original is required under Option 3 on the front of this application. SAMPLE COURT ORDER AND NOW, this day of , 20 , after reasonable notice and an opportunity for hearing having been provided to all interested parties, the Court hereby awards ownership of one [year], [make], [model], b ring vehicle identification number [name of applicant], and the right, title and interest of any other~ Icle Is hereby extinguished. The Department of Transportati s order as evidence of ownership in lieu of a certificate of title. The pet,S hail 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: , Judge . MV-38 0 (09.02) . lPLICATION FuR DUPLICATE CERTIFICATE OF TITLE BY OWNER ... For Depllrtmenl Uoe Only ... , Depor1mont or Transportation au..... or Molar VellicIn Horrillburg, PA 17104-2518 See Instructions on Reverse FEE: $22.50 VEHICLE INFORMATION "l1IloN_ Nu_ M4BO I BPr 0/3 OC{ "'" --- , '5 \3> E l"ii'I Lostl 0 Stolen 0 Defaced (Der.ced - must 0 Never (Provide "",r correct I Deslroyed be ._heeIl __ .ddress .-1 EHICLE OWNER'S NOTARIZATION E A L OTARlZE UNLESS LVANIA PRE~~,~PubIc Sout'I Oem-e T"".. CoI,,"bia Cotrily ~nltUre c:A Co-Owner or 1'ItIII AuthclrIr:ed SIgner TMIphone Nurnbltr (VIIIII only be uud if there.. pmbIem with your .ppIication,) (7/1> 7ft, t,.;Lcf to . " Member, ;"..,n;l&jri.;~'niil _....;;~:.'i;latt:m Of NobIrItts NOTE: COMPLETE THE INFORMA110N LISTED BELOW ONLY IF A LIEN WAS RECORDED AGAINST THE VEHICLE AND THE LIEN HAS BEEN SA11SFIED AND THE 11TLE IS NOT ATTACHED. U ER F1n1lnd8llrlltllutlon Number MO. DAY YEAR I_WI h.... .- and oIlplod thIo oppIca1IDn _11& .....-,._ I __ '" aftInn W the atementa nwcte herein 81'8 true and ClOIT8CI, lInd that any ......nt n8de on or pul'8U8nt to lb. opplicatIon . subject to the po-. or 18 PA C.s. _ 01803(0)(2) <_9 to - ~). _ _ _ ~ or 0 fine not exooedlng $6,000, or to . tonn . Impn.onment of not more than two ye&r8, or both. SIGNATURE OF PERSON ADtwtNlSTERING OATH S E A L S1gnatul1l 01 Uenhok* Mphone Number ( > DO NOT NOTARIZE UNLESS SIGNED BY LIENHOLDER IN PRESENCE OF NOTARY 11tIe of AuIhoriEed SIgner Messenger No. THIS APPLICATION MAY BE PHOTOCOPIED . . In The Court Of Common Pleas of Cumberland County, Pennsylvania In Re Motorcycle, VIN JYA4M400lBA013099 : Dkt. # Roger Lee Drake, Petitioner 513 Spring Run Drive Mechanicsburg, Pa 17055 ORDER ANn Now, this , 2006, upon consideration of the day of Petition and Affidavit of Roger Drake and for good cause shown the Court hereby awards ownership of a 1981 Yamaha 650 Special motorcycle, bearing Vehicle Identification Number JY A4M400lBA013099 to Roger Lee Drake and the right, title and interest of any other person of said vehicle is hereby extinguished. The original title was lost as a result of water being in Mr. Drake's residence. The Department of Transportation (PennDOT) may accept this order as evidence of ownership in lieu of a certificate of title. 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, and/or for the transfer of title to said vehicle to Mr. Lebo. Petitioner shall indemnify PennDOT and Mr. Mark Lebo as to any and all claims of any third party asserting right, title and/or interest in the vehicle predating this Order. BY THE COURT: J. ~ 0 ~ t; 1( ~ (") ~ <;? "\. c g; ~~ -:-'~ ".. V't -0(: c:: "-' no';' (i.") CY ........ -o~ - -j' N ~n ~ W if u:> (:.J :\ -J ~- :.:..{~;;;'~. ~:'::. t -0 -:::!:~~n C)~ f- ,:.r:'".'-'-', :;I: '~?f" '/ ':- S' - ~i..,,' e. ).-"r.:",: <? J z ;P.; ':2 N }l 0' ,Q . . In The Court Of Common Pleas of Cumberland County, Pennsylvania In Re Motorcycle, VIN JYA4M400 lBAO 13099 Roger Lee Drake, Petitioner 513 Spring Run Drive Mechanicsburg, Pa 17055 : Dkt. # ~ -~cd G'v~tT~ Affidavit of Roger Drake Roger Drake, an adult male citizen of Cumberland County, makes the following sworn statement in support of a Petition confinning ownership of a motorcycle and avers as follows: 1. Roger Drake is the owner of a 1981 Yamaha 650 Special motorcycle, bearing Vehicle Identification Number JY A4 M400 lBAO 13099. 2. I purchased the motorcycle in or about 1984 from Poor Richard's Auto Sales of New Cumberland, Dick Brubacher proprietor. I received a proper title at the time of the purchase. I contacted Mr. Brubacher, who indicated that he retained records for only 10 years, and he did not have a copy of the title or transaction records due to the passage oftime. 3, The vehicle was licensed and operated for about a year, but was pennanently parked when I got married. Registration lapsed, and the vehicle is no longer in the PennDOT records system when I went to apply for a duplicate title. Sometime from 1985 to the present date, the original title documents were lost because of water in the basement area where they were stored. ... , ' ' ~ '- 6. In June 2006, Mark Lebo, my brother in law, expressed interest in purchasing and repairing the vehicle for his use. The vehicle has been repaired and is ready to be transferred and licensed to Mr. Lebo upon confirmation of title as required by PennDOT Form MV-217, and MV-38. (Attached). 8. PennDOT has supplied a draft Order on the back of Form MV-217. Form MV-217 includes a Note that "in questionable cases," the Department may require the applicant to execute an indemnification agreement or other forms. 10. I have no objection to indemnifying both the Department and the purchaser against any claim of right title or interest by any third party, and language is added to the draft form of Order for that purpose. 11. I verify that the above affidavit and the statements contained therein are true and correct to the best of my knowledge, information and belief and that I understand that this Affidavit and any false statements herein are made subject to the penalties of 18 Pa.C.S.A. ~ 4904, relating to unsworn falsification to authorities. .~OA~ ~er Drake . August 23, 2006 Notary: ~ /' ;;;4~r , '-- Notarial Seal Maxine E. Goodman. Notary Public .................. BOJO, Cumberland County My CommIllion Explle. Nov. 10. 2006 (") r.::, <.'" \}{j'; r'nl"~' ~fj UI r"::',' ~~ :'"';1" ;,.~C.-, "J.'"C Z .:(! ......, = = "" :> c:: C;") N \0 o " ~::!l r- -am :1]6 o ~-:f r'j.....d 6FM ?ii -< -0 :;;: ~ 1'0 CT\ RECEIVED L AUG 3 1 2006 0: BY: In The Court Of Common Pleas of Cumberland County, Pennsylvania In Re Motorcycle, VIN JYA4M4001BA013099 Roger Lee Drake, Petitioner 513 Spring Run Drive Mechanicsburg, Pa 17055 ~ D1ct. # Dl. -S~ Ci.CJ~L'-y-~ ,~ AND Now, this 5 day of ORDER S~~h._~t( , 2006, upon consideration of the Petition and Affidavit of Roger Drake and for good cause shown the Court hereby awards ownership of a 1981 Yamaha 650 Special motorcycle, bearing Vehicle Identification Number JY A4M4001BA013099 to Roger Lee Drake and the right, title and interest of any other person of said vehicle is hereby extinguished. The original title was lost as a result of water being in Mr. Drake's residence. The Department of Transportation (PennDOT) may accept this order as evidence of ownership in lieu of a certificate of title. 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, and/or for the transfer of title to said vehicle to Mr. Lebo. Petitioner shall indemnify PennDOT and Mr. Mark Lebo as to any and all claims of any third party asserting right, title and/or interest in the vehicle predating this Order. BY THE COURT: J. 1-/111-, . Alflh'-';i~'r7:'1'1' '-i..1\,; ,n,.., "4.,g"!~,..::; "J, J^""".,'.:-_,';/:~'d Ie :11 IItt/<jA~70 S, elJ. ,{b'kiOt:r" , S gOO! ..., Ivll' ". , .;iQI.I./.;l!''Jd ::J/.h '~. Lr-OJ7!; q, ::/0