HomeMy WebLinkAbout03-2136CHRISTINE M. ALLEN
Petitioner
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Respondent
AND NOW, this
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
LICENSE SUSPENSION APPEAL.
· day of May, 2003, comes Christine M. Allen, through her attorneys, Mancke,
Wagner, Tully & Spreha, who respectfully represent:
1. Your Peffioner is an adult individual residing at 2109 Cedar Run Drive, Apartment 302, Camp Hill,
Cumberland County, Pennsylvania and is a licensed operator of motor vehicles in the Commonwealth of
Pennsylvania.
2. Your PeflJoner had a conviction date of April 24, 2003 for an alleged violation of §3362.
3. Your Pe~oner has been advised that Penn Dot has mailed an official notice of license suspension
as a result of her conviction of §3362, carrying a violation date of June 25, 2002.
4. Your Petitioner believes the suspension is illegal, unjust and improper for reasons which include,
but are not limited to, the following:
(a) Your Petitioner believes that she is not guilty of the violation; and
(b) Your Petitioner has filed an underlying summary appeal from the
alleged conviclion which is pending before Cumberland County Court.
WHEREFORE, Your Petitioner prays Your Honorable Court to hold a heating to determine the validity
of the suspension outlined in this PelJ~on.
Resp.e. cffully submitted,
John ke, Esq., ID No. 07212
Manc~,e, Wagner, Tully & Spreha
2233 N. Front Street, Harrisburg, PA 17110
717-234-7051, Attorney for PelJtJoner
Dated:
JOHN B. MANCKE
~ RICHARD WAGNER
WILLIAM T. TULLY
EDWARD ~ SPREHA
LAW OFFICES
MANCKE, WAGNER, TULLY & SPREHA
2233 NORTH FRONT ~TREET
PHONE (717) 234.-705t
FAX (717) :Z3zl'-?OSO
VERIFICATION
I hereby vedfy thatthe statements made in this document are true and correct. I understand
that false statemen~ herein are made subject to the penalties of 18 Pa.C.S. Sec'don 4904, relating to unswom
falsification to authorities.
Date
CHRISTINE M. ALLEN
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
· NO. (~)~- ~'/'~' c,;,,~
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Respondent
ORDER
_~,day of ti~ ~ -~ ,2003, upon consideration of the within Petition,
AND
NOW,
this
it is hereby ordered and decreed that a hearing be held on the 3~) ;~f-'day of ~_.~- ,
2003,
at/~ ~/..) o'clock in Courtroom ! , Cumberland County Courthouse, Carlisle, Pennsylvania.
Notice of said hearing shall be sent by cerflied mail to the Department of Transportation by Petitioner's
attorney at least sixty days prior to the date of the hearing.
By the Court,
CHISTINE M. ALLEN,
VS.
Petitioner
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION,
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
No.: 03-2136
PRAECIPE TO DISCONTINUF
TO THE PROTHONOTARY:
Please withdraw the license suspension appeal filed in the above-captioned matter.
Respectfully submitted,
John I~ Mancke, Esquire., ID No. 07212
Manck~ Wagner & Spreha
2233 N. ~mnt Street, Harrisburg, PA 17110
717-234-7051, Attorney for Petitioner
Distribution: George Kabusk, Esquire, Office of Chief Counsel, Pennsylvania Department of Transportation
1101 S. Front Street, Harrisburg, PA 17104
CHRISTINE M. ALLEN,
Petitioner
Vo
COMMONWEALTH OF
PENNSYLVANIA,
DEPARTMENT OF
TRANSPORTATION,
Respondent
AND NOW,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, pENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-2136 CIVIL TERM
ORDER OF COURT
this 286 day of July, 2003, upon consideration of the Praecipe To
Discontinue filed in the above matter, the hearing previously scheduled for July 30, 2003,
is cancelled.
o3/ohn B. Mancke, Esq.
2233 N. Front Street
Harrisburg, PA 17 ! 10
Attorney for Petitioner
~orge Kabusk, Esq.
Office of Chief Counsel
Pa. Department of Transportation
Riverfront Office Center
1101 S. Front Street
Harrisburg, PA 17104-2516
Attorney for Respondent
BY THE COURT,
0 -3o'
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