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Home My WebLink About00-02132 < DEPARTMENT OF TRANSPORTATION: COMMONWEALTH OF PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA VS. /\10. d.-~~ ;;)/3(} CW-f) TerrY) JOHN LUTHER SHULL ORDER OF COURT AND NOW, this /3 -d day of /1 /l/c./L ,2000 upon presentation and consideration of the within Petition For Appeal From License Suspension, a hearing is set for the / ..;-tA day of U.u,iI L , 2000, at /: 00 o'clock? m.InCourtroomNo. 5" oftheCumberlandCounty Courthouse. FURTHERMORE, the motor vehicle license suspension in this case is stayed pending the disposition of this appeal hearing. ~ _'# 1\,00 l<<~ ~,\ ~ i':J alA/ALe! 1:-: {}w'.do J. ./ cc: Gregory Barton Abeln, Esquire Pennsylvania Department of Transportation, Office of Chief Counsel q- (?;- 00 w;I/f t& Ct'J j); (1) 'i..,L ;-,,~""'r'_,. -I" ,.<" 'I tJ , 'v':IWAlJ8NN3d A1Nr:cn 1'i,':;:3i'J/ljnJ 90 :'1 kd S I lid'J 00 )~,iL,1In\':'-::. \.....\1..1.,-";,,.. .!,. :lG - - "~ . "~ ." ~ 'W'17_li!\W!'~'1~_"""";r~","",,,,'"1l"F"""'1Ol"f_ " -,"- . ,,,,,,,,,,,lli'R;IIf<!IIIll~"~,......m\J!'I!ijIl!!Ql'!!~! DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA vs. NO. ..un;u - :i. ;S.2. ~ -r ~ JOHN LUTHER SHULL PETITION FOR APPEAL OF LICENSE SUSPENSION AND NOW, comes Appellant, John Luther Shull, by and through his attorney Gregory Barton Abeln, Esquire, who files the following Petition: 1. John Luther Shull is an adult individual currently residing at 507 Sleepy Hollow Road, Shermansdale, P A 17090. 2. On March 10, 2000, the Pennsylvania Department of Transportation sent to Appellant a notice of License Suspension, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A". 3. The Appellant's license was suspended for an accident that occurred on March 17, 1998 when Appellant did not have proper insurance coverage and, henceforth, his driving privilege was suspended as authorized by 75 PS S 1772 until he satisfies the judgement. 4. Appellant is negotiating a payment plan with the attorney for the accident victim, and expects that the victim will have no objection to a stay of proceedings pending his compliance. .. , ~ "" ~ WHEREFORE, Appellant requests this Honorable Court to set a time for a hearing on the priority of Appellant's license suspension and immediately stay the imposition of his license suspension pending the result of said hearing. Date '-\ p-( ()O Respectfully submitted, ABELN LAW OFFICES ..~~ Gregory arton Abeln, EsqUire ID# 35 960 Attorney for Appellant 37 East Pomfret Street Carlisle, P A 17013 717/245-2851 "- - ~~ ~=I - -, .~'" . ~- COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau Df Driver Licensing Harrisburg, PA 17123 MARCH 10, 2000 SHERMANS DALE PA 17090 000636117004687 001 03/03/2000 16539577 12/10/1954 JOHN LUTHER SHULL 507 SLEEPY HOLLOW RD Dear MDtDrist: The CDurt Df CUMBERLAND CTY-' has indicated YDU have failed tD satisfy a judgement resulting frDm a mDtDr vehicle accident Dn 03/17/1998. YDur driving privilege is hereby suspended as authDrized by SectiDn 1772 Df the Vehicle CDde until YDU satisfy the judgement. CDurt II: 000021 Term: 1299 YDur driving privilege will nDt be restDred until YDU prDvide prDDf tD the Department that all mDtDr vehicles registered in YDur name are cDvered by a mDtDr vehicle li- ability insurance pDlicy Dr by a prDgram Df self-insurance apprDved by the Department and an Dfficial certificate Df satisfactiDn frDm the PrDthDnDtarYDf CUMBERLAND CTY . This insurance infDrmatiDn will nDt be accepted mDre than Dne (1) mDnth before the eligibility date of the res- toratiDn Df your driving privilege. In order tD comply with this sanction you are required to r~turn any current driver's licens.e# learner's permit and/or temporary driver's license (cam,era card) in YDur possession nD later than the effective date listed. If yOU cannot comply with the requirements stated abDve, you are required to submit a DL16LC Form or a sworn affidavit stating that you are aware of the sanction against your driving privi- lege. Failure to comply with this nDtice shall result in this Bureau referring this matter tD the Pennsylvania State PDlice for prosecution under SECTION 1571(a)(4) Df the Ve- hicle CDde. WHEN THE DEPARTMENT RECEIVES YOUR LICENSE OR ACKNOWLEDGE- MENT, WE WILL SEND YOU A RECEIPT. IF YOU DO NOT RECEIVE THIS RECEIPT WITHIN 15 DAYS CONTACT THE DEPARTMENT IMMEDIATELY. OTHERWISE, YOU WILL NOT BE GIVEN CREDIT TOWARD SERVING THIS SANCTION. ~A- ;.' , ~ c "'. 000636117004687 The effective date of suspension is 04/14/2000, 12:01 a.m. Please see the enclosed application for restoration fee in- formation. APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date of this letter, MARCH 10,';2000. .. If you file an appeal in the County Court, the court will give yOU a time-stamped certified copy of the appeal. Send this time-stamped cer- tified copy of the appeal by certified mail to: PENNSYLVANIA DEPARTMENT OF TRANSPORTATION OFFICE OF CHIEF COUNSEL THIRD FLOOR, RIVERFRONT OFFICE CENTER HARRISBURG, PA. 17104-2516 Sincerely, ~~,~ Rebecca l. Bickley, Director Bureau of Driver licensing SEND FEE/lICENSE/Dl-16lC/TO: Department of Transportation Bureau of Driver licensing P.O. Box 68693 Harrisburg, PA 17106-8693 INFORMATION (7:00 IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE AM TO 9:00 PM) 1-800-932-4600 717-391-6190 1-800-228-0676 717-391-6191 \ ~, ""1 ','j DEPARTMENT OF TRANSPORTATION : COMMONWEALTH OF PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA VS. JOHN LUTHER SHULL CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing PETITION FOR APPEAL OF LICENSE SUSPENSION by mailing a true and exact copy addressed to the following: Department of Transportation Office of Chief Counsel 3rd Floor, River Front Office Center Harrisburg, PA 17104-2516 Respectfully submitted, Date ABELN LAW OFFICES ~~ Johanna L. Bla Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 I ' --, - E~ .' ""~ , << . "<" ~. "< , _~ ~H ",.""",,,0,,'__ "'" "h "'."< j:> I:\:.. ~ ..j:. o CI o f: !\o ~.) ()l ..:J .-'.~~~'" "~. ~~'. .t. 'rt'''Tr~t-' fft ~ UI C51 o -6 0- o C <.:: -orjj n"1 1 y~ ~~-:'1 ~"-~". Q~~:.-", ~~'~ ~g Z :2 (-, 6 -:';?'" -:1 :::~..J I ~._J C) -T"l :'} - l~~l. , :;T~ (':~;'{J If} i'..,"ll . ~--):~ ::_~~ ~"J. -<.. "'7Jii!D!k~lJ:1-W1:'l'~-'~f'-m$tf~~ll)!!Iijflijt!l!l'lq~mt~~!f.'!lfflt . ' DEPARTMENT OF TRANSPORTATION : COMMONWEALTH OF PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA VS. NO. 2000-2132 JOHN LUTHER SHULL TO THE PROTHONOTARY: Please mark the above case as discontinued. Abeln Law Offices ,Q(e&W~ Gregory Barton Abeln, Esquire 37 East Pomfret Street Carlisle, P A 17013 717/245-2851 cc: George Kabusk, Esquire !~ i :j ,! I <, , , 'I :! 'I i , il ;1 ':1; . . DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA VS. JOHN LUTHER SHULL CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing PETITION FOR APPEAL OF LICENSE SUSPENSION by mailing a true and exact copy addressed to the following: Department of Transportation Office of Chief Counsel 3rd Floor, River Front Office Center Harrisburg, PA 17104-2516 Respectfully submitted, Date ~ /14 /00 ABELN LAW OFFICES ~.I!,~ Dana Heberlig , Legal Assistant 37 East Pomfret Street Carlisle, PA 17013-3313 717/245-2851 ~ 1'l!l1, ~ ~P' " "-. -~ -." 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