UNITED STATES BANKRUPTCY COURT

EASTERN DISTRICT OF PENNSYLVANIA

In Re )
)
CITY LINE BEHAVIORAL ) Case No: 19-12493-MDC
HEALTHCARE, LLC, ) Chapter 7
)
)
Debtor. )

TRUSTEE’S NOTICE OF INTENT TO ABANDON INTEREST IN VEHICLES

TO PARTIES IN INTEREST:

NOTICE IS HEREBY GIVEN that Gary F. Seitz, the duly appointed and acting Chapter
7 Trustee (“Trustee”) herein, provides Notice pursuant to Rule 6007(a) of the Bankruptcy Rules
and 11 U.S.C. § 554 of his intention to abandon any interest of City Line Behavioral Healthcare,
LLC (“Debtor”), in specific vehicles. In support, Trustee states as follows:

1. This case was filed on April 17, 2019.

2. The Trustee took possession of certain vehicles believed to belong to the Debtor
which are currently stored with Quaker City Auctioneers, Inc., 409 Easton Road,
Suite 101, Willow Grove, PA 19090 identified as:

2015 Ford Escape VIN # 1FMCU9GX2FUA97921

2016 Ford Escape VIN # 1FMCU0G75GUB64640
2014 Ford Econoline VIN # 1FBSS3BL8EDA21419
2014 Ford Econoline VIN # 1FBSS3BL6EDA21404
2014 Ford Econoline VIN # 1FBSS3BL2EDA64783
2014 Ford Econoline VIN # 1FBSS3BL0EDA64782
2014 Ford Econoline VIN # 1FBSS3BL7EDA03672
2017 Ford Escape VIN # 1FMCU0F72HUA09515
2016 Ford Transit VIN # 1FBAX2CGXGKA00627
2013 Mercedes Sprinter VIN # WDZPE7CC1D5812981
2014 Mercedes Sprinter VIN # WDZPE7CC6E5866021
2013 Toyota Highlander VIN # 5TDZA3EH6DS035939

3. No vehicles were identified on the debtors’ schedules.

4. While keys to the vehicles were found among the debtor’s offices, no titles were
found among the debtor’s records. No proof of payment for vehicles was found in the
debtor’s books and records. Further investigation was obstructed by the federal
Driver’s Privacy Protection Act (DPPA) which limits the disclosure of “personal
information” obtained from state departments of motor vehicles.

5. The lot that secures the vehicles assesses storage charges for the safekeeping of the
vehicles.
 6. After extensive investigation by the Trustee, the estate is unable to sell the vehicles
due to problems in the chain of title to these vehicles.

7. The Trustee provides notice that he intends to abandon the Debtor’s interest in these
vehicles.

8. During the pendency of this case, the bankruptcy estate has incurred storage expenses
but the storage facility is willing to waive any administrative claim and look only to
the vehicles for payment pursuant the state law storage lien process.

9. If any party wishes to oppose this action they must file a written objection and request
for hearing on or before fourteen days from the date set forth below, and serve a copy
on the undersigned trustee.

10. Objections and requests for a hearing shall clearly specify the grounds upon which
they are based, including citation of supporting legal authority, if any. General
objections may not be considered by the court.

11. In the absence of a timely filed and substantiated objection and request for hearing by
an interested party, the Court may approve or grant the aforementioned application
without any further notice to creditors or other interested parties.

WHEREFORE, the Trustee respectfully requests that in the event that no responses to the
Notice are filed or no hearing scheduled, that the court enter an order authorizing the Trustee to
abandon the vehicles.
/s/ Gary F. Seitz
Dated: October 12, 2022
Gary F. Seitz
Chapter 7 Trustee
Gellert Scali Busenkell & Brown, LLC
1628 JFK BLVD, STE 1901
Philadelphia, PA 19103
Telephone: (215) 238-0011
gseitz@gsbblaw.com