PETITION FOR CERTIFICATE OF TITLE TO ABANDONED VEHICLE

PETITION FOR CERTIFICATE OF TITLE TO ABANDONED VEHICLE IN THE COURT OF COMMON PLEAS PIKE COUNTY, PENNSYLVANIA IN RE: 2000 BMW Z3 Wayne T. Tigue, Petitioner NO.: 2026-CV-________ Petition for Certificate of Title to Abandoned Vehicle AND NOW COMES Petitioner, WAYNE T. TIGUE, by and through his attorneys, Spall, Rydzewski, Anderson, Lalley & Krajkovich, P.C. by Leatrice Anderson, Esquire, and request that this Court approve the issuance of a Certificate of Title to Petitioner, WAYNE T. TIGUE, for the vehicle described below and in support thereof, represent as follows: 1. Petitioner, Wayne T. Tigue, is a sui juris individual, with a current address of 296 Gumbletown Road, Paupack, PA 18451. 2. Petitioner became the owner of the premises known as 105 Meadow Ridge Acres Road, Milford, PA 18337, identified as Tax Map No. 150.00-01-09, and further evidenced by Deed recorded on January 13, 2026, in the Pike County Recorder of Deeds Office in Record Book 2817, Page 240, following a tax sale conducted by the Pike County Tax Claim Bureau. A true and correct copy of said deed is attached hereto as Exhibit "A". 3. The last known titled owner of said premises was Jacquelyn Gardella, of Pike County, Pennsylvania. 4. At the time Petitioner acquired the property, a motor vehicle was located on the property and appeared to have been abandoned. 5. The vehicle is described as follows: a. Vehicle 1: [2000 BMW Z3, VIN No. 4USCH334XYLF43465] A true and correct copy of the vehicle's expired registration card is attached hereto as Exhibit "B". 6. The vehicle was left on the property by the prior owner and has not been removed or claimed by any person since Petitioner's acquisition. 7. Upon information and belief, Jacquelyn Gardella is deceased and no estate has been opened, or alternatively, no personal representative is available to act on behalf of the estate, and that no known heirs, next of kin, or personal representative of Jacquelyn Gardella existed or could be located to claim or take responsibility for her remains. Despite diligent efforts, no heirs, successors, assigns, or representatives of Jacquelyn Gardella have been identified or located. A search of the records maintained by the Register of Wills of Pike County, Pennsylvania, confirms that no estate has been opened for the Decedent and no personal representative has been appointed. A true and correct copy of the estate search showing no records found is attached hereto as Exhibit "C". 8. A petition was filed in the Court of Common Pleas of Pike County, Pennsylvania, Docket No. 1416-2025, where the Pike County Coroner sought for final disposition of the cremated remains of Jacquelyn Gardella, and said proceeding established an Order authorizing the Coroner to dispose of the remains of Decedent. A true and correct copy of filed Petition and Order is attached hereto as Exhibit "D". 9. Accordingly, there exists no person with legal authority to take possession of or otherwise dispose of the Decedent's personal property, including the abandoned motor vehicle identified herein. 10. Said vehicle remains abandoned, as there is no duly appointed personal representative, heir, or other authorized individual to take possession of title thereto or to arrange for its removal or disposition. 11. The vehicle meets the definition of abandoned vehicles under applicable Pennsylvania law, including but not limited to 75 Pa.C.S. § 7305. 12. Petitioner is unable to obtain a certificate of title for the vehicle through ordinary administrative processes due to the absence of any owner or authorized representative to execute title documents. 13. Without title, Petitioner cannot lawfully dispose of, transfer, or make use of the vehicle. 14. Judicial intervention is necessary to resolve the status of the vehicle and permit issuance of a certificate of title. 15. Petitioner further avers that, to the best of his knowledge, information, and belief, there are no liens or encumbrances on the title to the Decedent's vehicle. 16. Petitioner respectfully requests that this Honorable Court award ownership of said vehicle to the Petitioner in order that the Petitioner may proceed with titling procedures of the Commonwealth of Pennsylvania's Department of Transportation. WHEREFORE Petitioner, Wayne T. Tigue, hereby requests this Honorable Court award ownership of said vehicle to the Petitioner. Respectfully Submitted: Leatrice A. Anderson, Esquire Spall, Rydzewski, Anderson, Lalley & Krajkovich, P.C. 2573 Route 6 Hawley, PA 18428 (570) 226- 6229 June 25 2026 LSOM0542016