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Home My WebLink About02-3048Central Penn Recovery P.O. Box 2420 Mechanicsburg, PA 17055 VS. Robert P. Jones 2467 Joppa Road York, PA 17403 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : ACTION IN EQUITY NOTICE TO DEFEND TO THE RESPONDENTS NAMED HEREIN: You have been sued in Court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) 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 T.(~ 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 GE LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717)249-3166 Le hah demandado a usted enla corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partie de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objectones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, las corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. Central Penn Recovery P.O. Box 2420 Mechanicsburg, PA 17055 VS. Robert P. Jones 2467 Joppa Road York, PA 17403 : IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : ACTION IN EQUITY Petition to Obtain Title of an Abandon Vehicle 1. July 13, 2001: Central Penn Recovery Service (CPRS) received a repossession assignment for one personal water craft and one trailer· 2. July 13, 2001: CPRS repossessed the above mentioned water craft and trailer. The trailer was a two boat model. On the same trailer was a 1996 Yamaha Wave Blaster and some other personal property. 3. August 1, 2001: The auction company picked up from our location the assigned personal water craft and trailer, leaving behind the personal property and the 1996 Yamaha Wave Blaster. 4. For the following several months after the repossession, CPRS had contacted the debtor, Robert Jones, about picking up his personal property and Yamaha boat. The debtor refused to make arraignments and pick up his property. 5. November 28, 2001: In an effort to dispose of the abandoned Yamaha boat, CPRS contacted the lien holder of the boat about this situation. Household Automotive, the lien holder, had no interest in recovering their collateral due to the fact that the storage had already surpassed the value of the boat. 6. February 25, 2002: CPRS contacted the Pa Fish Commission to start the steps to apply for an abandoned boat title. The Fish Commission gave CPRS a guideline list of steps to take in order to obtain title of an abandoned boat. 7. February 27, 2002: CPRS placed an advertisement in 'q'he Guide" to meet the requirements of the abandon boat procedures· 8. April 28, 2002: The required waiting period expires. 9. May 1, 2002: CPRS wont to the Pa Fish Commission with all necessary paperwork and attempted to apply for an abandoned boat title. At this time, we were informed that this situation did not fall under their abandoned boat scenario and the only way we could obtain title was to get a court order. 10. June 25, 2002: Submitted paperwork for court order at Cumberland County Courthouse. 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.~ 4904 relating to unsworn falsification to authorities. Plaintiff 2 5" Ju'"¢- o ~- Central Penn Recovery P.O. Box 2420 Mechanicsburg, PA 17055 VS. Robert P. Jones 2467 Joppa Road York, PA 17403 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ACTION IN EQUITY ORDER OF COURT AND NOW, this --~r~day of--~'~z-~ 2002, the foregoing petition is ordered filed and a ~ hearing thereon is fixed for ~ ~' , 2O02, at <~:q, 5 t3./~, in Courtroom No. ~ of the Courthouse" v. ^in Carlisle, Pennsylvania· Central Penn Recovery P.O. Box 2420 Mechanicsburg, PA 17055 VS. Robert P. Jones 2467 Joppa Road York, PA 17403 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : · ACTION IN EQUITY · ORDER OF COURT AND NOW, this _~ day of 2002, after reasonable notice and an opportunity for headng having been provided to all interested parties, the Court hereby awards ownership of one 1996, Yamaha, Wave Blaster 700 bearing vehicle identification number YAML8271 K596 to Central Penn Recovery 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. Ca. ~-~ co P3