Will Car Title hold up again a Complaint of Replevin

[PAgurl]

This seems sort of ironic to me...but...

I split up with a boyfriend about 2 years ago. He took THREE of my vehicles (all titled solely to me). The state police didn't want to get involved saying it was a civil matter. I disagree, but it's history, so-
I found one vehicle. Had a key cut at the dealer with the title, drove it home.

The other two he took to his place of residence, which was completely unknown. He was "off the grid" as the PI's said that I hired to find him. I FINALLY found him and hired a repo company to get them on my behalf.

They worked with the local police and got the 2 remaining cars for me.

HERE'S The irony! He filed a civil suit against me about 10 days later under a Complaint of Replevin saying that he wants the cars back! He never filed a bond or writ of seizure. In the suit he even admitted that the cars were titled to me, however he's claiming that he paid for them and since the consideration for the vehicles came from him, he has rights to the cars. (Not true, but hard to prove since I made cash withdrawals, from my own account-my name only!- for both vehicles.)

I am working on a Motion to Dismiss, but was wondering if anyone's had any experience with this sort of thing? I was going to simply provide the titles to the judge and make it cut and dry that he has no RIGHT of possession as I am the legal owner of the vehicles....

Thanks in advance for any input!

 

[army judge]

This seems sort of ironic to me...but...

I split up with a boyfriend about 2 years ago. He took THREE of my vehicles (all titled solely to me). The state police didn't want to get involved saying it was a civil matter. I disagree, but it's history, so-
I found one vehicle. Had a key cut at the dealer with the title, drove it home.

The other two he took to his place of residence, which was completely unknown. He was "off the grid" as the PI's said that I hired to find him. I FINALLY found him and hired a repo company to get them on my behalf.

They worked with the local police and got the 2 remaining cars for me.

HERE'S The irony! He filed a civil suit against me about 10 days later under a Complaint of Replevin saying that he wants the cars back! He never filed a bond or writ of seizure. In the suit he even admitted that the cars were titled to me, however he's claiming that he paid for them and since the consideration for the vehicles came from him, he has rights to the cars. (Not true, but hard to prove since I made cash withdrawals, from my own account-my name only!- for both vehicles.)

I am working on a Motion to Dismiss, but was wondering if anyone's had any experience with this sort of thing? I was going to simply provide the titles to the judge and make it cut and dry that he has no RIGHT of possession as I am the legal owner of the vehicles....

Thanks in advance for any input!

You DO have proof, of some sort.

You withdrew CASH, on or about, the time of your purchase.

You should secure records from your bank PROVING you made those cash withdrawals.

Bring that PROOF with you to court.

Get a letter from bank officials attesting to teh fact they provided you with copies of the withdrawal information.

That letter should also be notarized.

It would be even BETTER if you subpoenaed the bank manager (or custodian of their business records) to testify in court as to the authenticity of the withdrawals!

I doubt that his replevin action will allow him to recover the vehicles without PROOF of ownership.

Fortunately, for you, he has none!

 

[PAgurl]

Thanks for the input! I am requesting bank records...

ONE QUESTION though...lol...
Isn't the title enough? I'm not sure if you were implying that I should have proof of payment to enhance my case, which I completely understand- but isn't the title (which shows me as the sole owner with no leins, co-owners, etc) enough in a court of law? Would replevin really allow him/grant him posession even IF he had paid for it? His name is nowhere on the title and never was?

Thanks for any insight you have. This whole thing just has me antsy. I know he has no right to the car, but it amazes me that this was filed by an attorney!