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Home My WebLink About03-1822IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Ye IOANIS GEOR KOTSOPOULOS Operator No. 25 662 178 APPEAL OF LICENSE SUSPENSION AND NOW, comes Ioanis Geor Kotsopoulos, by and through counsel, Gerald A. Lord, and files the within appeal of license suspension: 1. Your appellant is Ioanis Geor Kotsopoulos, license number 25662178, whose operating privileges are scheduled to be suspended on March 22, 2004, at 12:01 a.m. (Exhibit "A"). 2. Appellant appeared before District Justice Thomas Placey, Magisterial District Number 09-3-04, on March 24, 2003, and was convicted of speeding and driving under suspension pursuant to Section 1543(a) of the Motor Vehicle Code. 3. The appellant filed an appeal of the summary convictions in the Cumberland County Court of Common Pleas on the same date that this appeal is being filed. (Exhibit "B"). 4. It is the appellant's belief, and therefore the appellant's averment, the Commonwealth of Pennsylvania will not be able to meet its burden of proof at the hearing on the appellant's summary conviction appeal and, therefore, the appellant respectfully requests that the license suspension currently scheduled to begin on March 22, 2004, be rescinded pending disposition of the smnmary conviction appeal. 5. The appellant is attaching a proposed order, to be signed by the court of common pleas judge, scheduling a hearing on the appellant's appeal of the license suspension. WHEREFORE, based on the foregoing, it is respectfully requested that the license suspension be rescinded pending disposition of the summary conviction appeals. Respectfully submitted, Gerald A. Lord Miller, Poole & Lord, LLP 139 East Philadelphia Street York, PA 17403 (717) 845-1524 Sup. Ct. I.D. No. 49539 Attorney for Ioanis Geor Kotsopoulos COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: APRIL 01, 2003 IOANIS GEORGE KOTSOPOULOS 2878 DOVE DR YORK PA 17404 WID ~ 030849283553917 001 PROCESSING DATE 03/25/2003 DRIVER LICENSE ~ 25662178 DATE OF BIRTH 09/24/1980 Dear MR. KOTSOPOULOS: LICENSE IN BUREAU This is an Official Notlce of the Sus~enston of your Driving Privilege as authorized by Section [543 of the Pennsylvania Vehicle Code. As a result of your 03/24/2003 conviction of violating Section [543A of the Vehicle Code DRIVING NHILE SUSP/REVOKE on 02/24/2005: · Your driving privilege is SUSPENDED fo~ a pePiod of 1 YEAR(S) effective 03/22/2004 at 12:01 a.m. This suspension is in addition to any other suspensions already on your record. ~ROVIDING PROOF OF INSURANCF Within the last 30 days of your suspension/revocation, we will send you a letter asking that you provide proof of insurance at that time. This letter will 1/st acceptable documents and what will be needed if you do not own a vehicle registered in Pennsylvania. ZmpoPtant: Please make sure that PennDOT is notified if you move from your current address. You may notify PennDOT of your address change by calling any of the phone numbers listed at the end of this letter. 030849283553917 APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) with/n 30 days of the mail date, APRIL 01, 2003, of this letter. Zf you file an appeal in the County Court, the Court wlll give you a t/me-stamped .cePtlfled copy of the appeal. In order for your appeal to be valid, you must send this time-stamped cert/fied copy of the appeal by certified mail to: Pennsylvania Department of Transportation Office of Chief Counsel Th/rd Floor, Riverfront Office Center Harrisburg, PA 17104-2516 Remember, this is an OFFZCZAL NOTZC£ OF SUSPENSZON. SEND FEE/LICENSE/DL-16LC/TO: Department of Transportation Bureau of Driver Licensing P.O. Box 68693 Harrisburg, PA 17106-8693 Sincerely, Rebecca L. Bickley, Director Bureau of Driver Licensing INFORMATION (7:00 AM TO 9:00 PM) IN STATE 1-800-932-4600 OUT-OF-STATE 717-391-6190 TDD IN STATE 1-BOO-22B-0676 TDD OUT-OF-STATE 717-391-6191 IN THE COURT OF CONI/VlON 'pt~E~,, C6UNTv OF CuM:~~.D' .~ Notice of Appeal frOm Se '-'" Signature .~. ~.= ,,=;7-: .: .~ -. ' .,"; Zip /' ] ~:: :~.,,~ Magisterial Distri~ No. ; ~ ~. - ,J~ If sentence includes fine and $ .2 ,:' r :';i' Name and mailing,: address, of officer as shown on citation "' " ' ' · ' ' ~ : -'-:. jj or complmnt~ - ~,,' -. :', .::. '.~,. ~... ~,: ,; .:..-.j.~.4, . ;,:,J',. ::~.: :?,,,:: ~.":' ::. '-'~.-..:.-/:'.' ;.: i" ".:';: ..... ~.:..d?'.'.: ..~ ..... -" -'" ' i ' ' -,'" .'' -" ..... ~ :::: ':: ;'~",i" ~;.:: .! :.' ,.:.'i. i..: : :':',",:.: :.-~-: i!:; J District Justice Docket No. ?';¢- I _ Name and Address o~Attorney:? (signature) ~:,~ ' _ , ,'~:'!/';u-,. ~',~: '/'.' :- (print name) (,~-- ¢' ~ "~ Z, ;¢? /,¢~ "¢-,c~<'" ¢;~ (address) lo, ne: NOTICE TO DEFENDANT: You will be notified.of court hearing date by the DiStrict Attorney. ~.- ' If your appeal is from a-motor vehicle conviction that will result in your driver's 'in. that, sus~r~sion. ~' the .Bureau?. of Driver Licensing. , , copy, of the appeal..,..., ':f(~r... WHITE - Clerk of Courts Affiant s Co[~v',, YE!;LOW - District lustice J';Defenda nt :,:',: !.;i IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION IOANIS GEOR KOTSOPOULOS No. Operator No. 25 662 178 CERTIFICATE OF SERVICE AND NOW, this 6~7~gt4°Iday of /~^\ ,2003, I, Gerald A. Lord, Esquire hereby certify that I have, this date, served a copy of the License Suspension Appeal by certified mail, return receipt requested, addressed as follows: Francis P. Bach, Esquire Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 Gerald A. Lord. MILLER, POOLE & LORD, LLP 139 East Philadelphia Street York, PA 17403 (717) 845-1524 Sup. Ct. I.D. No. 49539 IN THE CUMBERLAND COUNTY COURT OF COMMON PLEAS COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION V$ IOANIS GEOR KOTSOPOULOS Operator No. 25 662 178 AND NOW, to wit, this ORDER , 2003, the license suspension currently scheduled to take place effective March 22, 2004, is hereby ~}~day of [..~dl.~,~' rescinded. A hearing is scheduled for the in courtroo~.~ ,2003 at , at which time the court will hear testimony and/or argument pertinent to the appeal of license suspension. Copies of this order are to be served on the Cmberland County District Attorney's Office, the Office of Chief Counsel at the Pennsylvania Department of Transportation, the attorney for the appellant, Gerald A. Lord, and the appellant, Ioanis Geor Kotsopoulos. Date: J COMI~0NWEALTH OF PENNSYLVANIA : DEPARTMENT OF TRANSPORTATION : IOANIS GEOR KOTSOPOULOS : IN THE COURT OF COM~ON PLEAS OF CUMBERLAND COUNTY, pENNSYLVANIA 03-1822 CIVIL TERM OPERATOR NO. 25 662 178 IN RE: CONTINUANCE AND NOW, request of the parties, 2003, at 2:30 p.m. this 9th day of June, 2003, at the this matter is continued to June 16, /A rge Kabusk, Esquire orney for PennDOT · /_~erald A. Lord, Esquire Miller, Poole & Lord, LLP 139 East Philadelphia Street York, PA 17403 Attorney for Ioanis Geor Kotsopoulos 0 srs VlNVA~IASNNaa IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA V. IOANIS GEORGE KOTSOPOULOS : No. 03-1822 ._ Civil Term .. .. PRAECIPE TO WITHDRAW APPEAL TO THE PROTHONOTARY: Please withdraw the appeal by the defendant in the above captioned matter in light of the decision of DOT to correct its records and remove the suspension under 75 Pa.C.S.A. §1543(a) as a result of the order of court entered May 27, 2003. Date: Respectfully submitted, Sup. Ct. I.D. No. 49539 Miller, Poole & Lord, LLP 139 East Philadelphia Street York, PA 17403 (717) 845-1524 COMMONWEAL TH V. IOANIS GEORGE KOTSOPOULOS IN RE: L0090461-0 AND NOW, this 2?th day of May, IN THE COURT OF COMMON PLEAS OF C~ERLAND COUNTy, PENNSYLVANIA 03-0842 CRIMINAL TERM CHARGES: APPEAL FROM SUMMARY (2) MAXIMUM SPEED LIMITS (SMRy) AFFIANT: TPR. KENT KAYLOR 2003, the Defendant, Ioani Geroge Kotsopoulos, now appearing in court on an Appeal from Summary at No. 05~0842 Criminal Term with his privately retained counsel, Gerald A. Lord, Esquire, and having tendered a plea of guilty at Count 2 ~o Speeding in violation of Section 3362(a) (1.1) of the Vehicle Code at the rate of 104 miles per hour in a 65 mile pst hOur zone at Citation No. L0090461-0, in full satisfaction of all charges at the said citation, the Defendant.s plea of guilty is accepted. The sentence of the Court is that the Defendant pay the costs of prosecution, a fine of $110.50, a $50 CAT Fund surcharge, and a $150 Emergency Medical SerVices Fund assessment. · The Defendant is notified of his right to appeal to the Pennsylvania Superior Court from the Judgment of sentence herein within 30 days of today,s date. · Pursuant to an a~reement of Counsel, the charge of Driving under Suspension is deemed dismissed. By the Court, Jaime M. Keating, Esquire Chief Deputy Diatrict Attorney Gerald A. Lord, Esquire 139 East Philade~phia Street York, PA 17403 For the Defendant Sheriff DJ Placey pcb j,.. ~-Z093 08:06 From..OFFIC; OF CHIEF COUNSEL ?I?-TOS-11ZZ T-OZ9 P.OOZ F-IZ5 COMMONWEALTH OF pENNSYLVANIA DEPARTMENT OF TRANSPORTATION OFIqCI~ OF CHIEF COUNSEL VEHICLE & ~.AFFIC LAW nlVlSION HIVERFRONT OFFICE CF. NTEII- TllJRD FLOOR 1101 SOUTH FRONT STRg, ET HARRISBURG, pENNSYLVANiA 17104-1S16 TELtCFllON~,: ('tiT) 71%2S30 FACSIMILE~ ('fi";) TOS-1122 Gerald A. Lord, ~ Miller, Ponle & Lord 139 East Philadelphia Street York, PA 17403 April 29, 2003 l/e: loanls C~orge Kotsopoulos v. Commw. of PL, DOT, BDL, Cumberland County, 03-1822, Civil Term, License SuspeMion Appeal Dear ARoraey Lord: The D~partmeut is in receipt an Order dated Jone 9, 2003, that indicat~ that upon appeal of the convictiol~ on March 24, 2003, of a violation of Section 1543 of the Vehicle code. violation date February 24. 2003, the appeal of the defendant was sustained nad the charge dismissed, Pleas~ be advised that the Department correctad its records and rescinded ami del~tad the 1543 and the associated one year suspension. Sec attached pfint-ou~s com~irmi~g the same. Your client's operating privilege r~neins suspendad for other smpensions. See attached restoration r~luirem~ms lett~. Additionally, wi~h tho addition of~e 3362, viohtion date February 24, 2003, yOUr client should expect notification r~arding a high sp~d hearing. You will note that you~ client has an indefinite SUSlgnsion as a ras~t of his fifilure to attend a Departmental hearing. He must clear up that indefmit~ suspension by attending the D~-p~ta~tal Hearing, Sec restoration ~equirements letter. Based upon the ~mcord as it now stands, your clinat should be eligible for an Occupational Limited License. I have attached an application for the same. A h~aring is schadul~ for June 16, :2003, at 2:30 p.m. in Courtroom No. 5, Cumberland County Courthouse, Carlisle. AS a gsult of the motorists record being corrected, a hearing is not necessary. The mattar could be disposed o£by you withdrawing the appeal, Kindly provide me a copy of the praecipe so thaz t may ¢lose-ou~ my file. If'you have any questions, please feel flee m call me. Sincarely, Enc.:l Assistant Couns~l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA Vo IOANIS GEORGE KOTSOPOULOS : No. 03-1822 : Civil Term _. .. CERTIFICATE OF SERVICE AND NOW, this 13th day of June, 2003, I, Gerald A. Lord, Esquire hereby certify that I have, this date, served a copy of the Praecipe To Withdraw Appeal by first class mail, addressed as follows: George H. Kabusk, Esquire Depm hnent of Transportation Office of Chief Counsel Vehicle & Traffic Law Division Riverfront Office Center - Third Floor 1101 South Front Street Harrisburg, PA 17104-2516 Gerald A. Lord. MILLER, POOLE & LORD, LLP 139 East Philadelphia Street York, PA 17403 (717) 845-1524 Sup. Ct. I.D. No. 49539