HomeMy WebLinkAbout97-01773
DEPARTMENT OF TRANSPORTATION
COMMONWEALHI OF PENNSYLVANIA
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97- 1?7.3 Ct'v'J Ti_
JAMIE R. VALENTINE,
Appellant
PETITION FOR APPEAL OF LICENSE SUSPENSION
AND NOW, comes Appellant,Jamie R. Valentine. by and through her attorney, Gregory Barton Abeln, Esquire.
who files the following petition:
I. Jamie R. Valentine is an adult individual currently residing at 4340 Brush Lane. Felton, PA 17322.
2. On March 8. 1997, Pennsylvania Depanment of Transponation sent to Appellant a notice of License
Suspension. a copy of which is allached hereto and incorporated herein by reference as Exhibit "A".
3. Appellant has a valid pennsylvania operator's license in her possession.
4. The defendant was arrested and charged with Underage Drinking on September 28, 1996.
5. The Appellant has appealed her conviction for underage drinking and is pending a hearing in the Coun of
Common Pleas.
6. The Appellant believes that she will prevail in the criminal appeal because the evidence was suppressed by the
Cumberland County Coun in a companion case. See ('1I1II1I"lIIlI'eolllr \', Steplre" E, Fllml')', 46 Cumbo 51 (1997).
7. If the criminal appeal is sustained. this civil appeal becomes moot.
WHEREFORE, Appellant requests this Honorable Coun to set a time for a hearing on the priority of Appellant's
license suspension and immediately Slay the imposition of her license suspension pending the result of said hearing.
Date
'-I ('-C (s1
Respectfully submitted.
ABELN L~~ O~FfES II
,~ !ti~'^"-
Gregory Banon Abeln. Esquire
ID # 35.960
Attorney for Appellant
37 East Pomfret St.
Carlisle. PA 17013
7 I 7/245,285 I
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Harrisburg, PA 17123
MARCH 08, 1997
JAMIE R VALENTINE
47 COLLEGE PARK APTS
97042843b0009b5 001
03/01/1997
2422512b
05/09/1977
SHIPPENSBURG PA
17257
Dear MS. VALENTINE:
As a result of \lour violation on 09/28/1996
Section 6308 (offenses related to alcohol),
privilege is being SUSPENDED for a period of
mandated by section 1532D of the vehicle code.
of violating
your driving
90 DAyeS) as
In order to comply with this sanction yOU are required to
return any current driver's license, learner's permit and/or
temporary driver's license (camera card) in your possession
no later than the effective date listed. If \IOU cannot com-
ply with the requirements stated above, yOU are required to
submit a DL16LC Form or a sworn affidavit stating that yOU
are aware of the sanction against your driving privilege.
Failure to comply with this notice shall result in this Bu-
reau referring this matter to the PennsYlvania State Police
for prosecution under SECTION 1571(a)(4) of the Vehicle Code.
Although the law mandates that your driving privilege is un-
der sUspension even if YOU do not surrl!nder your license,
Credit will not begin until all current driver's license
Productes), the DL16LC Form, or a letter aCknowledging your
sanction is received in this Bureau.
WHEN THE DEPARTMENT RECEIVES YOUR LICENSE OR ACKNOWLEDGEMENT,
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.
The effective date of SUspension is 04/12/1997, 12:01 a.m.
Please see the enclosed application for restoration fee in-
formation.
r:: ". :>-
" c;
i;:: ., ".
uJ: -- ),":}
(y
., .
h: .....: .~
( ,:. <I
2.. . r-' .....
I ,
\-1"'. "
,
(;-.\ p'~ .-
:.1
i I, .-
...
,. .- J
,: .:r :J
~
r ::;
~ .1..':"
,,") \~"
'" ~
~ ~ ~
(::; ....
~ to-
~ ~ ~
0<. "-"')
- ~
~~
DEPARTMENT OF TRANSPORT A T[ON
COMMONWEALTH OF PA
[N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
KELLY L. HELFRICH,
CHRISTINE D. SW ANKOSK[,
JEFFREY T. WENZEL,
KENNETH R. BROWN,
DAVID STEINOUR,
MA TIHEW GOSSAGE,
EDWARD A. HORSTMANN, and
JA[ME VALENTINE,
Appellants
NO. 97-1776 Civil
NO. 97-1780 Civil
NO, 97-[781 Civil
NO. 97-1774 Civil
NO. 97-1778 Civil
NO. 97-[775 Civil
NO. 97-1777 Civil
NO. 97-1773 Civil V
ORDER OF COURT
AND NOW, this J3 day of ~ \).Vl ,[997, upon Motion of counsel for the
defendants, and upon the express concurrence by the Commonwealth. the hearings scheduled for
June 23, [997, are continued generally. The hearings are to be rclisted at the call of the
Commonwealth.
ey
J.
cc: Gregory Barton Abeln, Esquire
Pennsylvania Department of Transportation, Office of Chief Counsel
~ ~ 6/19/?1
P-
.... C'J ~
!:'l r:-:
1- .. ::- J . _:~
l.uQ .:t 1._) ~ ..
0" )'..
fE~.: u.. . -
~r .? ~:':J
c ,-
'- en ',:n
UJll. .l... .'
; . . '.~ .
-' 'Ij.j
a:k.. -.. I
:.:' ,~~ ~..
f~' -, ....
IL r- .--}
0 0'1 ()
JAMIE R. VALENTINE,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNA.
v.
CIVIL ACTION - LAW
COMMONWEALTH OF PENNA.
DEPARTMENT OF TRANSPORTATION
BUREAU OF DRIVER LICENSING,
Respondent
NO. 97-1773 CIVIL
PRAECIPE TO WITHDRAW APPEAL
TO THE PROTHONOTARY, CUMBERLAND COUNTY COURTHOUSE.
Please mark this license suspension appeal as withdrawn.
Respectfully submilled,
ABELN LAW OFFICES
'\ ('
... ,.1
, -', '-.
Jbl..~q /\.
Gregory Barton Abeln, Esquire
ID #35,960
Allomey for Petitioner
37 East Pomfret Street
Carlisle, P A 17013-3313
717/245-2851