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Home My WebLink About00-00480 +, .L, _,~ 0 '-0 "- "~"- '''_'';'''h' :' ,;:~';,~""-,,,,,,",,,",,,;~,.,-, ; -"~-;"'O'"-,~i,:,, ~iliiiIiililili ON FEBRUARY 15, JUDGE GUIDO IN COURT LEFT THE RECORD OPEN IN ORDER TO GIVE MR. MULDERIG 7 DAYS TO FILE SOMETHING FROM DOCTOR LUTTERMOSER. MR. MULDERIG WAS TIMELY IN HIS FILING. IF THE JUDGE IS WILLING TO ACT ON THE SUPERSEDEAS, THE ATTORNEYS BOTH MULDERIG AND KABUSK FROM PENN DOT HAVE AGREED ON: MONDAY. AUGUST 14.2000. AT 9:00 A.M. FEB 22 2000 14:23 122_flIleol_ .~~~.PA 1105S 717195MOO . 117 795~S ""' , . 717 795 6955 P.02/02 MECH. FAM. PRRCT. CENTER 4) PINNAcuHEAlTH 02/1712000 RE: JOY E. GARNER OOS: 12/03/1947 To Whom It May Concern: I have taken care of Joy Gamer for many years with her seizure disorder. However, due to lowering her dose at home recently, the patient had a recurrent seizure. Due to this reculT&nt seizure She has been taking her medications regular1y. Her drug levels have increased, and further follow-up will be done. Due to her past history and to the best of my medical knOwledge, I feel the risk of a recurrent seizure at this time is low to minimal. If you desire any further information on the patient. please consult me. Si;~ ~__ GARY K LUTTERMOSER. M.D. rrh c: File OJ: 613432 AN8'f) FEB 18 aoo TOTAl P. 02 ~, "'kL J I " ,- . , . ,- ~,,' I~ .'-. DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PENNSYLVANIA Appellee :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO 00- q 80 CIVIL TERM JOY GARNER :APPEAL FROM LICENSE SUSPENSION Appellant ORDER AND NOW, this ~ I) ~ day of j~~OO, upon representation and consideration of the within Petition for Appeal from License Suspension, a de novo hearing is set for the ~ay of h.J/C-IAAd.Y ,2000 at8: Jt) ti.M. in Court Room No.5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. Further, the motor vehicle license suspension in this case is stayed pending this appeal hearing. BY THE COURT, J. .e-d/~1Z..iII L &u.hllJ ) Cbpt~ t'1'1~({<Lc.L ,;llrt IclJ I .,,--c.'~' ~_DIilIi\-""="=~~-'o ". ~~ --':'t~_~lIiIiii_~IIllII':;" Vli\iVI\1,\SNN3d , "lrlT',,) ",r;U~,'1,""'" A.U'o .\._\,,_ i.' f'_.:.:':,:,'~i k) ~":21 Hd 0 I a:,iJ DO Ab\.I.!nC);,\--,< ...;. ,~= q ,- '~ ~,,^-,,;, - - ,,'*"", , ..;. --..' . -,".:',~. '-h :'~,:J . . , ~ I. l....~ __ 0, ~ -'" _' 0 < ~_' , '< ,,~, ~. . i~ DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PENNSYLVANIA Appellee :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO 00- 'f rf1) CIVIL TERM JOY GARNER :APPEAL FROM LICENSE SUSPENSION Appellant PETITION FOR APPEAL FROM LICENSE SUSPENSION AND NOW, comes Appellant, Joy Garner, by and through her attorney, Robert J. Mulderig, Esquire, and files the following Petition: 1. Appellant is Joy Garner, an adult individual currently residing at 4 Rusty Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. On December 18,1999, the Appellant suffered a possible seizure disorder. 3. Following this incident, medical reports were submitted to Appellee. 4. By letter of January 7,2000, a copy of which is attached and made part hereto, the Department of Transportation did recall the Appellant's driving privileges for an indefinite period. 5. I to drive. WHEREFORE, for all the above reasons, the Appellant, Joy Garner, by and through her The Appellant was not given an opportunity to show that she is not incompetent i attorney, Robert J. Mulderig, Esquire, requests this Honorable Court to set a lime for hearing in I .,'C , '~ the propriety of Appellant's license recall and further, to stay the imposition of this license recall pending said hearing and, after said hearing, reverse the recall heretofore previously issued. Respectfully Submitted TURO LAW OFFICES ;,h(/c;o <7ff~~-1f Date Robert J. Mulderig, Esquire 32 South Bedford Street Carlisle, PA 17013 (717) 245-9688 Attorney for Appellant , ., , : ~-." --, VERIFICATION I verify that the statements made in the foregoing 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. /-~/- e::<jC1 d Date II recalszr COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: January 7, 2000 JOY GARNER 4 RUSTY DR MECHANICSBURG PA 17055 Dear Ms. JOY GARNER: We have received medical information indicating that you have a Seizure Disorder condition which preventS you from safely operating a motor vehicle. As of 0211112000, you may no longer drive. Your driving privilege is hereby recalled indefinitely as mandated by Section 1519(c) ofthe Vehicle Code. This decision has been made by comparing your medical condition with the standards recommended by our Medical Advisory Board and adopted by this Department. This action will remain in effect until we receive medical information that your condition has improved and you are able to safely operate a motor vehicle. Since you have a seizure disorder, you must remain seizure free for a six month period, with or without medication, before you will be eligible for reinstatement of your driving privilege. Our records indicate that your seizure occurred on 12/18/99. In order to comply with this action, you must return all current Pennsylvania driver's licenses, learner's permits, temporary driver's licenses (camera cards) in your possession, on or before the effective date listed above. If you cannot comply with the requirements stated above, a sworn affidavit stating that you are aware of the sanction against your driving privilege must be submitted. When the Department receives your license or affidavit, we will send you a receipt. YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR IDENTIFICATION PURPOSES. However, you may apply for and obtain a photo identification card at any Driver License Center. You must present two (2) forms of proper identification (e.g., birth certificate, valid U.s. passport, marriage certificate, etc.) in order to obtain your photo identification card. You have the right to appeal to the Court of Common Pleas (Civil Division) within thirty (30) days of the mail date of this notice. If you file an appeal in the County Court, the Court will give you a time-stamped certified copy of the appeal. In order for your appeal to be valid, you must send this time-stamped certified copy of the appeal by certified mail to: "- . . I "'~.""--,,,I'I Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104 You still must send in your license before the effective date of recall unless you appear in person before a judge and receive an order permitting you to continue driving. If you have any questions or need further information, please contact the Medical Unit, P.O. Box 68682, Harrisburg, PA 17106-8682 or call (717) 787-9662 between the hours of 8:00 a.m. and 4:30 p.m. Sincerely, ~~\~ Rebecca L. Bickley, Director Bureau of Driver Licensing Driver License #: 13294934 J ., '.- - "".~- -, -' -. . ''',,",''< . ,. ~ .' CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Petition for Appeal from License Suspension upon Office of the Chief Counsel, Pennsylvania Department of Transportation, by depositing same in the United States Mail, first class, postage pre- paid on the 21st day of Januarv ,2000, from Carlisle, Pennsylvania, addressed as follows: PA Department of Transportation Office of Chief Counsel 3rd Floor, Riverfront Office Harrisburg, PA 17104-2516 TURO LAW OFFICES ~ ----.f J"" /.... j/ :1 II . -,,~~.~ 1I_Al."' . ~ ,,-'Co.' ~ >- 0::; ~ " W~'::- C) :"'..::~ t- ~"- :',-" ~JE iI ~-~_.! ~-- (L a f z :5< (-)--- C)~ .,:>- '=~ ;;;J "'-0 57 '"I-Z mill t:f)["l- " ~ <".:) ::) o . () .- ~ 0... \~O N :;;:. < '. ~H!ffl!hih!!l~tlil.~-- o l- ~ f'- :J\ 0.... Q~ ~ V) ~ "iI: V) ~ . ~. "'~ ~ -.J. ~ <CL 01.. ~ (V) q, CO .'"," ".. ----'.,,-'", u.u - .. - ",,- ,. " MECHANICSBURG FAMILY PRACTICE CENTER GARNER, JOY E DOB: 12/03/1947 SS#: 202-36-5536 00200588853 01/21/2000 S: Patient comes in for completion of her pelvic exam. ROS: GYN, she is gravida 2, para 2002 with last menstrual period 1/13/00 which was regular and without problems. She has ~o boyfriends whom she is sexually active with and has been for a long time but plans to wean that down to one in the near future. Her last Pap was in 12/97. She is status post tubal ligation. She does breast ~elf-exams semiregularly. She denies DES exposure, abnormal Pap smears, STD, dyspareunia, vaginaFC!lischarge changes, breast lumps or biopsies. She had her first child when she was 23. Family history is negative for cervical, breast or colon cancer. Personal, no smoking or alcohol use or drug use. She does not like her job as a waitress and is looking for another one. Health maintenance, she will get a mammogr~l11 today but refused in the past. She refuses to get flex, sig. but will get Hemoccults. Cholesterol was 207 in 11/95. She exercises regularly and watches her weight. HEENT, symptom check. Extremities/Newr!ologic, symptom check. She is taking her Dilantin, 100 mg. 2-3 x a day regularly. She has not lost her licel1se and has not had any seizure disorder or problems since I last saw her. Her lawyer says she will probably not lose her license totally by delaying the follow-ups"," ~ ~f' ~ t: - ~.... .6.- -- .. . 0: Vital Signs: Per flow sheet; overall checked. General: Check. Neck/Carolids/Heart/Lungs/ Axillary/Breasts/ Abdomen/Back/I nguinal: Checked. Pelvic: Vulva, vaginal vault and cervix all normal. Pap smear done. One nabbthian-type cyst on the cervix seen. Bimanual and rectovaginal checked. Rectal: Some extemal hemorrhoids without palpable masses. Stool guaiac negative. A: Seizure disorder, now controlled. 2. Pelvic exam. P: Pap smear. 2. Scr.e,ening mammogram. 3. Dilantin level. 4. May take Dilctntil], 100 mg. in the a.m. and 200 mg. h.s. 5. Stoolguaiacs x three. 6. Call if any particular problems. 7. Patient education on regular breast exams and the other tests that we do. 8. Return to office in six months unless increased problems before that time. DO: 01/21/2000 OT: 01/24/200010:46 A/rrh 0#: 600924 GARY K. LUTTERMOSER, ~ DEFENDANT'S EXHIBIT J./lS!O<J ~ 41 -. I,~.~,^ , . .......'I4Ol~,.,~~_ -~. , MECHANICSBURG FAMILY PRACTICE CENTER GARNER, JOY E DOB: 12/03/1947 SS#: 202-36-5536 00200559086 12/20/1999 S: Patient states she stopped her Dilantin several months ago and had a grand mal seizure while at work. She was taken to the ER on 12/18/99 where she was examined and discharged. Supposedly a driver's suspension .form was completed on the patient. Yesterday while at work again she had a sensation that she might have a seizure and almost completely passed out without any obvious clonic tonic movements and woke up status post feeling lightheaded and dizzy. However, she did not remember the events that occurred either time. Therefore, she started taking Dilantin that she had at home, 100 mg. pills twice yesterday and today. She has been off her Dilantin before and has had seizures; but she thought since she had not had one for over a year that she could do without it. Her seizures generally start with a weird sensation in her feet and then spread throughout her body making her not remember them. Supposedly, by history through others, the seizure was tonic clonic in nature. Personal, no new medications; no smoking, alcohol use or other drug use. She is working as a waitress which is not completely stressful, but her income has decreased. She does have some financial worries because her income decreased from $400 or more per week when she gave up her baby-sitting job to $200 per week. She is dating two males which puts her under increased stress because she feels that she must get married to one of them but has not made that decision. ROS: Heart/Lungs/Abdomen/Extremities/ Neuro/ Vaginal, all symptom check. She denies weakness, numbness, tingling, visual changes or problems except with the above mentioned episodes. 0: Vital Signs: See flow sheet; weight stable; BP 130/80. General: Check. HEENT: Checked. Funduscopic checked. Neck/Carotids/Heart while sitting/Lungs/Extremities/Neuro with pinprick/Pulses: All checked. Gait is within normal limits. Sensory to soft touch and pinprick within normal limits. A: Seizure disorder with recent seizure secondary to discontinuation of her Dilantin. P: Patient understands the importance of taking her medications. I indicated she may be seizure-free on the medication for a period of time until she stops taking them. She states she still take them regularly. She has Dilantin, 100 mg. at home which has found taking 3 x a day helps. She has #80. I gave her a new script for Dilantin, 100 mg., #90, 12 refills, 1 !.i.d. 2. Retum to office in 1-2 months. Supposedly she has an appointment 1/20/2000. 3. Obtain comprehensive medical panel and Dilantin level after being on the medication for at least one month, hopefully prior to seeing me. 4. I indicated to her she will probably get her driver's license taken away and should not drive due to possibility of seizures. 5. Patient education, see flow sheet. DO: 12/20/1999 DT: 12/21/1999 9:46 A/rrh 0#: 584735 GARY K. LUTTERMOSER~ ij&/ /~ ~.~. .- . -~ - y, D~.-326 (PIgS) CERTIFICATION DATE: February 11, 2000 I hereby certify that Rebecca L. Bickley, Director of the Bureau of Driver Licensing of the Pennsylvania Department of Transportation, is the legal custodian of the Driver License records of the Pennsylvania Department of Transportation. As the Director of the aforesaid Bureau, she has legal custody of the original or microfilm records which are reproduced in the attached certification. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL OF THIS DEPARTMENT THE DAY AND YEAR AFORESAID. ~ BRADLEY L. MALLORY, SECRETARY OF TRANSPORTATION I HEREBY CERTIFY THAT THE FOREGOING AND ANNEXED IS A FULL, TRUE AND CORRECT CERTIFIED PHOTOSTATIC COPY OF: 1) Official Notice of Recall dated & mailed 01/07/2000, effective 02/11/2000; 2) Initial Reporting Form, date of examination 12/18/99, and 3) Driving Record, which appears in the file of the defendant Joy Elizabeth Garner, operator's no. 13294934, date of birth 12/03/47, in the Bureau of Driver Licensing, Harrisburg, Pennsylvania. CERTIFIED TO as prescribed by Sections 6103 and 6109 of the Judicial Code, Act of July 9, 1976, P.L. 586, as amended, 42 Pa.C.S. 996103 and 6109. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL THE DAY AND YEAR AFORESAID. <:&~~. SEAL _. .R!'O.BECCA L. BICKLEY, DIRE J" R BUREAU OF DRIVER L1CENS G COMMONWEALTH'S EXHIBIT I ~11~lllb rnvJI --,'~ - , ,,,,"""-_''''';_V --~ -,. ,<, ""''''-'~'~'''^~'''','''''''''=~~_' ___,_ ',d',_' >iT'="..";' . . ",,,,.'''j " recalszr COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: January 7, 2000 JOY GARNER 4 RUSTY DR MECHANICSBURG PA 17055 Dear Ms. JOY GARNER: We have received medical information indicating that you have a Seizure Disorder condition which prevents you from safely operating a motor vehicle. As of 02/1112000, you may no longer drive. Your driving privilege is hereby recalled indefinitely as mandated by Section 1519(c) of the Vehicle Code. This decision has been made by comparing your medical condition with the standards recommended by our Medical Advisory Board and adopted by this Department. This action will remain in effect until we receive medical information that your condition has improved and you are able to safely operate a motor vehicle. Since you have a seizure disorder, you must remain seizure free for a six month period, with or without medication, before you will be eligible for reinstatement of your driving privilege. Our records indicate that your seizure occurred on 12/18/99. In order to comply with this action, you must return all current Pennsylvania driver's licenses, leamer's permits, temporary driver's licenses (camera cards) in your possession, on or before the effective date listed above. If you cannot comply with the requirements stated above, a sworn affidavit stating that you are aware of the sanction against your driving privilege must be submitted. When the Department receives your license or affidavit, we will send you a receipt. YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR IDENTIFICATION PURPOSES. However, you may apply for and obtain a photo identification card at any Driver License Center. You must present two (2) forms of proper identification (e.g., birth certificate, valid U.S. passport, marriage certificate, etc.) in order to obtain your photo identification card. You have the right to appeal to the Court of Common Pleas (Civil Division) within thirty (30) days of the mail date of this notice. If you file an appeal in the County Court, the Court will give you a time- stamped certified copy of the appeal. In order for your appeal to be valid, you must send this time- stamped certified copy of the appeal by certified mail to: ;t-l .~"..~ ,~.' ~ - __~."~_ ,v"., ..~r.,=>. ~"__. "'"';~">"'I " Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104 You still must send in your license before the effective date of recall unless you appear in person before a judge and receive an order permitting you to continue driving. If you have any questions or need further information, please contact the Medical Unit, P.O. Box 68682, Harrisburg, P A 17106-8682 or call (717) 787-9662 between the hours of 8:00 a.m. and 4:30 p.m. Sincerely, ~~\~ Rebecca L. Bickley, Director Bureau of Driver Licensing Driver License #: 13294934 ~. .. , > ~, ~. .- ~<<= -~~ I~ v:I DEPARTMENT OF TRANSPORTATION BUR::",U OF DRIVER LICENSING INITIAL REPORTING FORM (Prlnl or TY1>> Requested InformsUon) FOR BUREAU USE ONLY DL.'3(4.!l3) Date Received , . Oli_' Reference DEAR PROVIDER: Although the Department seeks youl judgement about your patient's medical fitness to safely opelate a motor vehicle, the decision about your patient's dlivet's license is a responsibility 01 the. Department's Bureau of Driver Licensing which .must also take into account other considerationi.' Please complete Sections A,B,C,andD. ~ L~ ~C\3~ DATE OF EXAMINATION: t 'l.- . I f 'C; i . I I I ~ ! I H I ,I ! I SECTION A: PATIENT INFORMATION DATE OF BIRTH LAST NAME FIRST NAME MIDDlE NAue MONTH . DAY YWI 6""4"\1\-<..1 ..-.-. 13 /1.- u> 1{1 -..I. ~ V' ADORESS . , L{ (\...",1-(!. v ,fl.-,v.e DIAGNOSIS OF DISORDER OR DISABILITY: Please Check (I") appropriale items . ~' Q Loss 01 Impairment of a Foot, Leg, Finger, Thumbs, or Hand. . Condition:l\. Q Unstable Diabetes Q Celebral Vascular Disease . Q Cardiovasculal Disease Iliil' Loss of Consciousness. Cause: .{l~'" r>e.. a Neulological Disoldel Q Mental Deficiency 01 Malked Mental Retaldation Q Mental or Emotional Disolder Q Alcohol Abuse Q Drug 01 Controlled Substance Abuse Q Vision Deficiency Q Other Medical Condition which would interfere with the patient's ability to dlive. . Explain: , RE~- llEC221999 OR\V~ORS~vW_G . BUR. V'- , , - .6', t jiif.. Comments: %&e, c..-+ uJ.,....e.. .(je u ~ ,-1-,,..., , .["e-z......,..c. Do these conditions affect the patient's ability, from a medical standpoint only, to safely operate a motol vehicle? ~YES Q NO Seizore Oisordel: .QtYES Q NO Date of Last Seizule: J~ '/~' 115 Does the patient meet any of the Department's waiver lequilements? Q YES 'fNO If yes, please explain · ALL INFORMATION IS CONFIDENTIAL AS PROVIDED IN THE PA VEHICLE CODE, SECTION 1518(3) PROVIDEA'S NAME n r -""--VI r-r... '" I:. <- PLEASe PRINT SIGNATURE OF PROVIOER Cl.ASSI~IC:AT'ON OR SPECIALITY [., jL"'.o.... 2. PROV1t!EA'S ADDRESS G......ft, /~ ,-I-- ( ( 717 ) 2,.<(.)'- ~f'~ Mll 0 '>0 '7 l) - l- Rerum l/lis form 10: BUREAU OF DRIVER UCENSING ' DRIVER QUALIFICATIONS SECTION, P.O. BOX 68682 ' HAIiRISBURG. PA 17106-8682 -tI-~ PENNSYLVANIA DEPARTMENT OF rRANSPORTATION BUREAU OF DRIVER LICENSING CERTIFIED DRIVING HISTORY . FEB' 10 2000 DRIVER: JOY ELIZABETH GARNER 4 RUSTY DR MECHANICSBURG, PA 17055 DRIVER LICENSE (DL) LICENSE CLASS , LICENSE ISSUE DATE: LICENSE EXPIRES : DRIVER LICENSE NO DATE OF BIRTH SEX RECORD TYPE """""""'': PAGE 1 ,-; " ~i Ii "I if] ) i',j k , I:' " : 13294934 : DEC 03 1947 : FEMALE : REG LICENSE r:': 1:,1 COMMERCIAL DRIVER LICENSE (CDL) --------------------------------- C OCT 08 1997 DEC 31 2001 CDL LICENSE CLASS CDL LICENSE ISSUED COLLICENSE EXPIRES CDLEN~gSEMENTS CDL gEST~~~~IONS COt. 1iElAR~E~li'ERMITS COL LICENSE "STATUS ,',,'" , MED RESTRICTIONS : NONE LEARNER PERMITS LICENSE STATUS PEND RECALL SB ENoq~S_Nr PROBATIONARY LI~ENSE (PL) . . . . NONE . NONE . . . : PEND RECALL . . :i :.11 . [r' I' :)i , 1::; I~:j <'I 'I :1 l'i " '::I "',, ',' ------------~-------------------- PL LICENSEC~~SS ,PL LICENSE~~~is. ISS : PI, LICENSE~SS'W~D ~L LICENSE~~~P~RES PL,LICENS~.SijATUS . . . . , ;:: Iii 1,1 [:,i ;i! 1',1 I" I,! " !~ i I"~ '" :.'j fi Ii (,I t! I: " , , il . [I !i " Ii .' Ii : Ol3b.tii'ATIO~AL,LIMI'1'ED LICENSE (OLL) , , , , , '," OLL I;IC,EJ,ySE,>CLAS'S OLL LICE~SEJ;SStJED OLL LIC~NSE!XPIRES : OLL LIl3ENSESTATUS *** CONTINUED *** ~3 . . . . " ~ , .' ~ ...... L ~ <^ . , ;:]1 PAGE 2 CERTIFIED DRIVING HISTORY - FEB 10 2000 - LICENSE NUMBER 13294934 CONTINUED "; i:' I:; , -------------------------------------------------------------------------------- REPORT OF VIOLATIONS AND DEPARTMENTAL ACTIONS I' r ~: -------------------------------------------------------------------------------- VIOLATION DATE: VIOLATION: DESCRIPTION: CONVICTION DATE: ACTION: MAR 02 1990 VEHICLE CODE: 3112A3I RED LIGHT VIOLATION MAR 05 1990 ASSIGNED POINTS j; 'j! f<l :.Ji -':! ili , : -'; )i1 ,. ", I' I:i lrl Ii! I~ Ii: (i [ii iI! I. Ii Ii, l~! ~!! --------------------------~-~-----~---~~-~~~~~~-~-~----------------------------- -----------------------------~-------------------------------------------------- ACTION: ACTION: MEDICAL EXAM ORDERED. RECA~~-\;~lENL MEDICAL~FFEe:WIVE FEB 11 2.000 GEN M~I)'RECALL . . ... .......... OFFICiAir:,iNOTICE MArr,.~D..JiW 07 2000 Iii p. rjl Iii ~i Iii !~ NO ACCIDENTS DURING THIS REPORTING PERIOD *** END OF RECORD *** .-" - -~' > -,;:, " {~ [,:1 IN COMPLIANCE WITH YOUR REQUEST, I HEREBY CERTIFY THAT I HAVE CAUSED A SEARCH TO BE MADE OF THE FILES OF THE DEPART- MENT OF TRANSPORTATION, AND HAVE SET FORTH ABOVE AN ACCURATE SUMMARY OF ALL RECORDS IN THE NAME OF THE PERSON INDICATED. " " ~ i " [1 [:1 I:i f:j ,:~ n ~:1 H H II. k ii, n f ~ :1 ~:~ ~," H /1 , . PAGE 3 CERTIFIED DRIVING HISTORY - FEB 10 2000 - LICENSE NUMBER 13294934 CONTINUED SINCERELY, !,j ('ii i ~ ~~\~ ~!j i'; ;:~ I, SEAL DI~EC~OR,BUREAU OF DRIVER LICENSING FOR SECRE'1'ARY OF TRANS,PORTATION \:~ !,~ '1 COMMONWEALTH OF PENNSYLVANIASS: DATE:FEB 10 2000 i'1 f"i , n H u 'ii :,i Iii: " Iii !i, i;~ II H II I n i ~ ; :::1 j:1 '''I ;L~ ;j II 1 ,I 1 I I HEREBY CER:TfiFYTHAT REBEG:CA.L...BICKLEY, DIRECTOR OF THE BUREAU OF DRI~:&a.LICENSING ,QFTHEPENNSYLVANIA',\DEPARTMENT OF TRANSPORT"",IS THELEG".M..G\:l:sYii0DIAN OF TIi~''DltIVER . LICENSING REG' "'OF THE]jE13~IDiilNTrOF TRANSP~T.K'l'tON. AS THE DIRECTOR~nE AFORE'S~~R:~tmd!iAYi,SHE HA~:'.~. CpSTODY OF THE ORIG[l~A[,eR,J.1ICROrtltiMR'l!lCtmPS'WHICHAAETltl!l SU~JECT OF THE ABOV..E, c. ER.if~'F:tCA'1':E'ON.</ . . . . . , - , , IN TESTIMONY MrER:EPll', I HAVE HEREUNTO SET,M'YaAND AND SEAL OF THIS DEPARTMEN'Jj>'J.IH,EDAY AND YEAR AFORESAID. SINCERELY, -j... SECRETARY OF TRANSPORTATION SEAL ~. ", -'I' _ __', , ,-. . = >"~'- '''' ~-~'- '" "'d_~, ,,-, """" -, '--! 11 11 II I :1 ! >i ['I ! " 'I 11 [I I Ii !I II II l'! H 'Ii [I 1'1 I! [I I II II ,I , ,1 1 I I 'I ,I I ii 1 COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. JOY GARNER : NO. 2000-0480 CNIL TERM APPEAL FROM LICENSE SUSPENSION ORDER OF COURT AND NOW, this 1ST day of MARCH, 2000, upon receipt ofa letter from Dr. Luttermoser, and by agTeement of the parties, the suspension of appellant's operating privileges is stayed pending a determination on the merits of this appeal. A de novo hearing on the appeal is scheduled for August 14,2000, at 9:00 a.m. in Courtroom # 5 of the Cumberland County Courthouse, Carlisle, Pal 17103. By the Court, George Kabusk, Esquire For the Dept. of Transportation Edward E. GUl,(fiJ'dO' 1. ~ . 3-3-0 AK.3 Robert J. Mulderig, Esquire For the Appellant :sld ~liIIill~Wliil'4__llwaIH~ilI~"~i\il!ll!i!i!i...~_4jlll'ili~'lililliI!J~~" (, '/ .... i:}l/j,j nl' uU AJ'})~:C :../0 ~~ ~ ~ ............ ".- ~ " _....... J_= '-', , J. I - .i .[1 :1 i1 [,1 DEPARTMENT OF TRANSPORTATION :IN THE COURT OF COMMON PLEAS COMMONWEALTH OF PENNSYLVANIA :CUMBERLAND COUNTY, PENNSYLVANIA Appellee v. :NO 2000-0480 CIVIL TERM JOY GARNER :APPEAL FROM LICENSE SUSPENSION 11 " '1 'j Ii i ~ l~ j~ t ~ '. :~ ;1 l~ Appellant PRAECIPE !~ , ~ " iJ . TO THE PROTHONOTARY:' Please settle, withdraw and discontinue the above-captioned matter on behalf of the Appellant. Respectfully Submitted TURO LAW OFFICES oft;P; flfI)J:!.!AfJ^ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Appellant cc: Judge Edward E. Guido cc: George Kabusk, Esq. II _~f .-,' ___~lijj_filllll'!1~~~"'!M!l~~""~". .,;..'., . ,.,c,,' ~ ",_, _ 0'_ -~ ' ,- , 'C., . ,. " 0 c:> ~ 0 c: .-\ ~ ~ ~,:r.-n -oCJ ~ rnF mr1" G) .-rJ~-n Z:.::D I .~ m;E; C1:> {~)'C. 0::.::-<', :'_::1....-; 1;20 -0 .-1---rl ::J: Qo ~g - arn J:>C: .- -'"\ ~ - ~ tJ'1 " ~ J?/rs // 0S'c ~/z. . ^ '~- DEPARTMENT OF TRANSPORTATION :IN THE COURT OF COMMON PLEAS COMMONWEALTH OF PENNSYLVANIA :CUMBERLAND COUNTY, PENNSYLVANIA Appellee v. :NO 2000-0480 CIVIL TERM JOY GARNER :APPEAL FROM LICENSE SUSPENSION Appellant o c ~ c Q. :"U:s.. Xa 't PRAECIPE mR? 5;; :;::1 ~~:Jj ~ J nj f1J '-F-I' '~orJ1 ~6 eX> 6? TO THE PROTHONOTARY:. Is :It ~N ~ ; ~m Please settle, withdraw and discontinue the above-captioned matter on B'ehalf of the Appellant. Respectfully Submitted TURO LAW OFFICES ~J>> 1fj/.J.t{!~- 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Appellant cc: Judge Edward E. Guido cc: George Kabusk, Esq.