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HomeMy WebLinkAbout01-2916 FX ,,....\ 1",... 1""", \.,,-,;' v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 0 f. :L 91(, C;M-( f;.:- CHARLES M, FOGARTY COMMONWEALTH OF PENNSYLVANIA: DEPARTMENT OF TRANSPORTATION : LICENSE SUSPENSION APPEAL AND NOW, comes CHARLES M. FOGARTY, by and through her attorneys, MANCKE, WAGNER, HERSHEY & TULLY, and files the following license suspension appeal: 1. Petitioner, CHARLES M. FOGARTY, is an adult individual and a licensed driver within the Commonwealth of Pennsylvania with a residence address of 617 Gutshall Road, Boiling Springs, Cumberland County, Pennsylvania, 2. Respondent, Pennsylvania Department of Transportation, Bureau of Driver Licensing, has a mailing address at P,O. Box 68693, Harrisburg, Pennsylvania. 3. On or about January 28, 2001, in the Borough of Mechanics burg, Cumberland County, Pennsylvania, the Petitioner herein was charged with allegedly violating 75 Pa.C.S.A. ~3731(a)(1). :2.. !'!''" , ~?- , T ~ ,~ " " .",- """""'~, " --~ o ('1 \..-.-,,;,.-.' 4, Petitioner herein is alleged to have violated ~1547 of the Motor Vehicle Code (75 Pa.C.S.A. ~1547). 5. As a result of the alleged violation of ~ 1547, Petitioner received a notice of license suspension dated Aprilll, 2001, a copy of which is attached hereto, incorporated herein by reference, and marked as Exhibit A, for an alleged violation of Section 1547 ofthe Motor Vehicle Code, refusing to take a chemical test. 4. The suspension of the Petitioner's license is invalid, improper, and illegal for the following reasons: A. Petitioner was not properly advised of the consequences of violating ~1547 of the Motor Vehicle Code; B. Petitioner supplied sufficient samples of breath in order to have activate the equipment being utilized to test his breath; C. The equipment being utilized to test his breath malfunctioned or otherwise did not function properly; D. Petitioner did not refuse, and fully cooperated with the police in providing a sample of breath; -2- ...3 "''"'Ii, 0"-_"",, "". , . I " ",'"~F''' o ('i ~,~~#" E. Petitioner supplied sufficient breath that provided a read out of his breath sample for purposes of use by the Commonwealth; F. Petitioner was not properly instructed on how to provide sufficient breath; and G. The booking center officials did not properly instruct the Petitioner on how to give a sufficient breath sample. 5. As a result of the above, the Petitioner believes that he did not violate ~1547 of the Motor Vehicle Code and requests this Court to grant his appeal. WHEREFORE, Petitioner prays this Court to grant his appeal from the license suspension for allegedly violating ~1547 of the Motor Vehicle Code. Respectfully submitted, Mancke Wagner, Hershey & Tully P ichar agner, Esquire J.D. 23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 Attorney for Petitioner DATE: 5'"/'i/~1 / I -3- Jf 1~~,^"_"o, '<~'" , ,.., , t 1 ..- "-~~ ,......, v ,"""'\ '"",-,.,/ VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. )( DATE: .s' 1-"''''1.". ""~ I ,- . ''''''''''''''''I!f~,'' o (') ""' COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau Df Driver Licensing Harrisburg, PA 17123 APRIL 18, 2001 BOILING SPGS PA 17007 011016112745575 001 04/11/2001 1"1671382 07/05/1"162 CHARLES MATTHEW FOGARTV 617 GUTSHALL RD Dear MDtDrist: As a result Df YDUr viDlatiDn Df SectiDn 1547 Df the Vehicle CDde, CHEMICAL TEST REFUSAL Dn 01/28/2001, YDUr driving privilege is being SUSPENDED fDr a periDd Df 1 YEAR(S). In Drder tD cDmplY with this sanctiDn YDU are required tD return any current driver's license, learner's permit and/Dr tempDrary driver's license (camera card) in YDUr PDssessiDn nD later than the effective date listed. If YDU cannDt cDmp1Y with the requirements stated abDve, YDU are required tD submit a DL16LC FDrm Dr a SWDrn affidavit stating that YDU are aware Df the sanctiDn against YDUr driving privi- lege. Failure tD cDmp1y with this nDtice shall result in this Bureau referring this matter tD the PennsYlvania State PDlice fDr prDsecutiDn under SECTION 1571(a)(4) Df the Ve- hicle CDde. AlthDugh the law mandates that YDUr driving privilege is under suspensiDn even if YDU dD nDt surrender YDUr license, Credit will nDt begin until all current driver's license prDduct(s), the DL16LC FDrm, Dr a letter acknDwledging YDUr sanction is received in t~~s Bureau. 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. The effective date of suspension is OS/23/2001, 12:01 a.m. *********************************************************** I WARNING: If YDU are cDnvicted fDr driving while YDur I license is suspended, the penalties will be: a MINIMUM I Df 90 days imprisDnment AND a 1,000 fine AND YDUr I license will be suspended for 1 year. I *********************************************************** -Il- /r, !""r,~, " -" - '.' 1,';' 'F 1 o 1""'1 \. .-' 011016112745575 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, APRIL 18, 2001, of this letter. 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, ynu must send this time-stamped certified 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 TOD 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 7 1'","''' <" e*_~,~ ',~ ' " " e-,. '1",,# !""'\ I ) '----,;,..<' CERTIFICATE OF SERVICE I, DEBRA K. SPINNER, Secretary in the law firm of MANCKE, WAGNER, HERSHEY & TULLY do hereby certify that I am this day serving a copy of the foregoing document to the following persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of civil Procedure, by depositing the same in the United States Mail, Harrisburg, Pennsylvania, with first class postage, prepaid, and addressed as follows: George Kabusk, Esuqire Office of Chief Counsel Department of Transportation 1101 South Front Street Harrisburg, PA 17104 By Jil,w of. jo~ Debra K. Spinn~r, Secretary MANCKE, WAGNER, HERSHEY & TULLY 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorneys for Charles M. Fogarty DATE: .!flp/Of I ( f ';"'~'.~~ "~-; '_f'-_""'""!'"" " 1 e , , r" ~ I ~ ~_.,.,,,,,,,,,",,,,-- .,,~'fr: ,.0 (" \, ./ CHARLES M. FOGARTY v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. ~ 1- 2'11" ~ -r u- COMMONWEALTH OF PENNSYLVANIA: LICENSE SUSPENSION APPEAL DEPARTl\1ENT OF TRANSPORTATION : ORDER AND NOW, this ~l day of Ma,.<I\ , , 2001, upon Petition of CHARLES M. FOGARTY, a hearing is set on the License Suspension Appeal for the 1"/..., ~ day of ,2001, at 1-00 o'clock, L.m., in Courtroom NO.~, of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Cumberland County, Pennsylvania, all proceedings to stay meanwhile. Pursuant to Section l550(b) of the Pennsylvania Motor Vehicle Code, Petitioner's appeal shall act as an automatic supersedeas, and Petitioner's operating privileges shall not be suspended pending final detennination in this matter. ~ BY THE // ~?-\'O \ ~ \, 1. / J !";.",,,-,,"~(-". - ,.), "'f-"""- ,. , 1 ~ ' , , . "" " ,." -. ;1f'I'li C") ~ ,"- 1111'_. 9 ~ ~~ J< :3 _.~ .:.J:Z ____,.:.2 '..;.1 LLl ~~ Cl- ~ 5 ~ ,:;;;:;: c<. ~~;~ ~ c:.:.1 ,,1 ~~ 'W",,~",.~ o."~__<_n_~"'_ &',~='''~"_~'' ~<~~" '_,_d , ~". -b,~ "_r",.-.."....-C'~'~ -'~~1ifflt~~"'~\!:!!li~~~~!W!~_~.-.'W},'''''':,'~:",k'''"' :",'\1_'" ""f,c"""-. - "--~,~\W~',i,W,:0,'t;ie;,~r;"ti!"F":;;:'Jf-~"",1m-'r~;;;;"f,jPj1;-f,"'~i'!i'i!iiffil'Ji~ o o CHARLES M. FOGERTY, PETITIONER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, RESPONDENT 01-2916 CIVIL TERM ORDER OF COURT AND NOW, this '8 '" day of August, 2001, following a hearing on the merits, the within license suspension appeal, IS DISMISSED. P. Richard Wagner, Esquire For Petitioner Edgar B. Bayley, J. George Kabusk, Esquire For the Department of Transportation :saa (y~~' ;;1 l() OJ-'' - '';'''.,'' ~ ~',.-~-'.,,~- . ""'~ " ",}",. '~-'."., ~"~~ -~ ~~~ "~ -~,- - ~ "-- I " .' ""~ "" <' '~'t. ~\ ~ ~ , --c.;,t<,., ~:J."""':;;" '~-, ,,,,,..lfr~'" -" , -'--' - ..,~ '~""',--, ,~""-"",,,,, ~" - .".." ,", -'1"""'-" -,""~~"~~-~'~".=--- -., .~- -. \fIcNr'4!\~?~tm~V'm8 ;.JNn J)-" ," '20:\"j Hd g-:}\\\j Ie; '~~L\"I-'~--"'~\, \" ~',-- 'uwl\....I',,;' -.. ""\ ' {\o~' ~'J\::\~O-U::\ i, J <_,,,,,,.,,,,,~ ~_1."'~fflU!t'Pfi!'f~,,,,'l';--'llI&'i'_'lWl!H'.,,.<;,,,."':"""'-~'''''''!P'l>'''':t'-~5iU;?ffl>:,,",~~1ll1iilil'I1!"i~~~I~ _,_"M o o CHARLES M. FOGARTY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Petitioner, v. : NO: 01-2916 CI~ TERM : CI~ ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Respondent. ORDER AND NOW, this $0 day Of~, 2001, upon Petition of Charles M. Fogarty, it is hereby ORDERED that a supersedeas be issued against the (~ Respondent, Commonwealth of Pennsylvania, Department of Transportation, \I,( staying the imposition of suspension. of tlte licen~e of the Peti~'Wer hereiA, pending I _. I"l ~ C4Af-,~ ~ 1\?'" ~ ~ (;flM441t'tMJ't;-..I~ o@fl Order of the Commonwealth Court of Pennsylvania. 0.." S~~ - 1. II 'F~_~_", ---'._'<!-""'i'-_"".,~~_" ., 1'- - .,.". -t F'! i t. 'P 'l) . ~ 1':: , ~ ~!I. ,~~ H ~, h ~, ' - ~" ~> -"- 'R'~"" '>" - '~o' - ~'-" '-- " , >,,.; ~-"'-}''',','n'); '"-..,,U,'% '*",', "\''''~' '.;i..,'_j, ,. ~'<ili"",r:':"~w<.' """",:',..,,'," ~Ulrr-- ~ ~,"io'"~",,. ~r ill - "r_'~ --~"~"'-- "':'" - \ . II,'! \(~\'~'~'\::\~,,\I"\"""" \1~t'S,,;\ I{....."_ ,-"",.:,1"1 \'-.J ,-;:~ .,-y--,'>',;' '\.''-'''-' ,-' .l"n, \_' l\~L;.\~\ I',' "\' (' \ :1,) ., .,.1 "1 ~ r, , c ~,\\\! \" I, u '"' _ "!WJil!I),'.l'l.' . ~ ~~..",._Lmi!1,711~,q~H1IMgiji!1!~v.,~'f<1iW;j;-!."':-""'~~;-""IWli~-'N5"':~[t'''fi~:';{1ff'~~~~~,,~!~!~IM;~~ o o CHARLES M, FOGARTY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Petitioner, v, : NO: 01-2916 CIVIL TERM : CI~ACTION -LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Respondent. PETITION FOR SUPERSEDEAS AND NOW, comes your Petitioner, Charles M. Fogarty, by and through his attorneys, Mancke, Wagner, Hershey & Tully, and files the following Petition for Supersedeas: 1. Your Petitioner, Charles M. Fogarty, is an adult individual residing at 617 Gutshall Road, Boiling Springs, Cumberland County, Pennsylvania. 2. The Respondent, Department of Transportation, is a state agency having as an address, 1101 South Front Street, Harrisburg, Pennsylvania, 17104. 3. On or about August 8, 2001, the Court entered an Order dismissing the appeal of the Petitioner herein and reinstating the one (1) year suspension by the Department of Transportation. IJ... 'F~,,~, . I, ~.- ~ ~,~~' o o 4. Petitioner herein desires to file an appeal to the Commonwealth Court of Pennsylvania and believes that his appeal has merit. 5. Petitioner filed a license suspension appeal on the 17th day of May, 2001. 6. A hearing was set for the 23rd day of July, 2001, regarding his license suspension appeal. 7. On August 8, 2001, following a hearing, the Court dismissed the license suspension appeal without opinion. 8. Petitioner desires to file an appeal to the Commonwealth Court of Pennsylvania, however, is unaware of the basis upon which the initial license suspension appeal was dismissed. 9. Petitioner has surrendered his license as a result of ARD entrance on August 10,2001, in Cumberland County and expects not to receive a return of that license for a six (6) month period of time or February 10, 2002. 10. Upon the return of his license on February 10,2002, it is anticipated that this appeal to the above matter will be still pending in the Commonwealth Court. /3 '\'''1_ > _0 ' - , I' '-,,' I f-- ~" o o 11. Petitioner desires to retain his license pending appeal to the Commonwealth Court, particularly since no opinion was provided upon which the dismissal occurred. 12. Petitioner prays this Court to grant relief in granting him a stay of the license suspension that would otherwise take effect as a result of the August 8, 2001. Order. Respectfully submitted, c a Wagner, Esquire . #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner Date: S/,A'i/OI I I 1""..._., ",' " ILl - -.-- ,",' ("""1 \11'1'''/ o VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn DATE: ?rr IS ,'-<1,=",.......,,. "I' ., ., ~ -.- o o CHARLES M, FOGARTY, . IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA v. . NO. 01-2916 CIVIL TERM . CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, NOTICE OF APPEAL NOTICE IS HEREBY GIVEN that CHARLES M. FOGARTY, above-named, hereby appeals to the Commonwealth Court of Pennsylvania from Judgement of Suspension enter in this matter on the 8th day of August, 2001, by the Honorable Edgar B. Bayley, Judge of the Court of Common Pleas Court, Cumberland County, Pennsylvania. The Order has been reduced to judgment and entered in the docket as evidenced by the attached docket entry. Respectfully submitted, er, Hershey & Tully agner, Esquire I.D. #23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 Attorneys for Defendant Date. 3/.8tJ/tl! I / 17 'r"*-!~~~., ~" , ~, , I _, ~'_ ,~~, 1 ,;'" F "~~ .. o o , CHARLES M. FOGARTY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 01-2916 CIVIL TERM : CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTJ'vlENT OF TRANSPORTATION, ORDER FOR TRANSCRIPT A NOTICE OF APPEAL, having been filed in this matter, the official court reporter is hereby order to produce, certify and file the transcript in this matter in conformity with Rule 1922 of the Pennsylvania Rules of Appellate Procedure. Respectfully submitted, Mancke, Wagner, Hershey & Tully , . Rich I.D. #23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 By Attorneys for Defendant Date: S/.3~/()1 I I lP ""'"m~_._ ~ r 'I ' , .. o o , CHARLES M. FOGARTY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v, : NO: 01-2916 CIVIL TERM : CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, CERTIFICATE OF SERVICE I, Debra K Spinner, Secretary in the law finn ofMANCKE, WAGNER, HERSHEY, & TULLY, do hereby certifY that I am this day serving a copy of the foregoing document to the following persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Appellate Procedure, by depositing the same in the United States Mail, Harrisburg, Pennsylvania, with first class postage, prepaid, and addressed as follows: George Kabusk, Esquire Office of Chief Counsel Department of Transportation 1101 South Front Street Harrisburg, PA 17104 The Honorable Edgar B. Bayley Court of Common Pleas Cumberland County Courthouse Carlisle, P A 17013 Court Reporter Cumberland County Courthouse Carlisle, PA 17013 DATE: 3/21"'1 By ~u{Jf~~ Debra K Spinner, Secretary MANCKE, WAGNER, HERSHEY & TULLY 2233 North Front Street Harrisburg, PA 17110 p, Richard Wagner, Esquire Attorneys for Appellant 19 """";,,~ ,~> > ",~,' -, " ~. - -,- PYS510 2001-02916 CUmbO.,land County prothonotary'~.. Office , ... Civil Case Inquiry (,_, ~% - FOGARTY CHARLES M (vs) PENNSYLVANIA COMMONWEALTH OF Filed. . . . . . . . : Time........, : Execution Date Jury Trial. . . . Disposed Date. Higher Crt 1.: Higher Crt 2.: Page 1 , 5/15/2001 8:06 0/00/0000 0/00/0000 Reference No. . : Case Type. ....: APPEAL Judgment..... . Judge Assigned: BAYLEY Disposed Desc. : ------------ Case Comments ------------- - LICENSE .00 EDGAR B SUSP ******************************************************************************** General Index Attorney Info FOGARTY CHARLES M 17 GUTSHALL ROAD BOILING SPRINGS PA 17007 PENNSYLVANIA COMMONWEALTH OF DEPARTMENT OF TRANSPORTATION POBOX 68693 HARRISBURG PA 17123 APPELLANT WAGNER PRICHARD APPELLEE ******************************************************************************** * Date Entries * ******************************************************************************** 5/15/2001 5/21/2001 8/08/2001 8/31/2001 - - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - APPEAL FROM SUSPENSION OF DRIVERS LICENSE ------------------------------------------------------------------- ORDER - DATED 5/.21/01 - IN RE LICENSE SUSPENSION APPEAL - A HEARING IS SET FOR 7/23/01 AT 2:00 PM IN CR 2 OF THE CUMBERLAND CO~TY CARLISLE PA - BY THE COURT EDGAR B BAYLEY J COPIES MAILED 5/21/01 ------------------------------------------------------------------- ORDER OF COURT - DATED 8/8/01 - LISCENSE SUSPENSION APPEAL IS DISMISSED - BY EDGAR B BAYLEY J - COPIES MAILED 8/9/01 ------------------------------------------------------------------- ORDER - DATED 8/30/01 - IN RE PETITION OF CHARLES M FOGARTY IT IS HEREBY ORDERED THAT A SUPERSEDEAS BE ISSUED AGAINST AGAINST THE RESPONDENT COMMONWEALTH OF PA DEPT OF TRANSPORTATION STAYING THE IMPOSITION OF SUPENSIONS OF THE LICENSE OF THE PETITION HEREIN PENDINGS PERFECTION AND APPEAL TO THE COMMONWEALTH OF PA AND ANY SUBSEQUENT - BY THE COURT EDGAR B BAYLEY J COPIES MAILED 9/4/01 - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - ******************************************************************************** * Escrow Information * * Fees & Debits BeQ Bal Pvmts/Adi End Bal * ******************************************************************************** APPEAL LIC SUSP TAX ON APPEAL SETTLEMENT JCP FEE 35.00 .50 5.00 5.00 35.00 .50 5.00 5.00 .00 .00 .00 .00 45.50 45.50 .00 ******************************************************************************** * End of Case Information * ******************************************************************************** -.,,,,,- ~D ~I r'~' ,~= ~- o o D(,.Le'. lo-/S-of Commonwealth Court of Pennsylvania September 10, 2001 RE: Fogarty v. DOT No.: 2071 CD 2001 Agency Docket Number: No. 01-2916 Civil Term Filed Date: September 5, 2001 Notice of Docketing Appeal A Notice of Appeal, a copy of which is enclosed, from an order of your court has been docketed in the Commonwealth Court of Pennsylvania. The docket number in the Commonwealth Court is endorsed on this notice. The Commonwealth Court docket number must be on all correspondence and documents filed with the court. Under Chapter 19 of the Pennsylvania Rules of Appellate Procedure, the Notice of Appeal has the effect of directing the Court to transmit the certified record in the matter to the Prothonotary of the Commonwealth Court. The complete record, including the opinion of the trial judge, should be forwarded to the Commonwealth Court within forty (40) days of the date of filing of the Notice of Appeal. Do not transmit a partial record. Pa.R.A.P. 1921 to 1933 provides the standards for preparation, certification and transmission of the record. The address to which the Court is to transmit the record is set forth on Page 2 of this notice. Notice to Counsel A copy of this notice is being sent to all parties or their counsel indicated on the proof of service accompanying the Notice of Appeal. The appearance of all counsel has been entered on the record in the Commonwealth Court. Counsel has thirty (30) days from the date of filing of the Notice of Appeal to file a praecipe to withdraw their appearance pursuant to Pa. RAP. 907 (b). Appellant or Appellant's attorney should review the record of the trial court, in order to insure that it is complete, prior to certification to this Court. (Note: A copy of the Zoning Ordinance must accompany records in Zoning Appeal cases). The addresses to which you are to transmit documents to this Court are set forth on Page 2 of this Notice. If you have special needs, please contact this court in writing as soon as possible. Attorney Name Harold Cramer, Esq. George H. Kabusk, Esq. Paul Richard Wagner, Esq. Party Name Bureau of Driver Licensing Bureau of Driver Licensing Charles M. Fogarty Party Type Appellee Appellee Appellant ""'~ \,"~,Ji!_",~ ,0,,__ ~ - _ '"': ' - \ 'I~'r.' , ," " '" CHARLES M. FOGARTY, c:J6 7 I c...-'t> ;LOb I : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V MiA v. : NO: 01-2916 CIVIL TERM : CIVIL ACTION - LAW C:J ~~;: COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, ,", 1J ~,~ l ~::::: '.-< - " ~,.:: NOTICE OF APPEAL 00 ~,:~~ -':.i .~ ~ el. ~ NOTICE IS HEREBY GIVEN that CHARLES M. FOGARTY, above-named, hereby appeals to the Commonwealth Comt of Pennsylvania from Judgement of Suspension enter in this matter on the 8th day of August, 2001, by the Honorable Edgar R ).. Bayley, Judge of the Court of Common Pleali Court, Cumberland County, Pennsylvania. The Order has been reduced to judgment and entered in the docket as evidenced by the attached docket entry, " Respectfully submitted, TRUE COpy FROM RECORD In TesUmonv wherecf I \ h'?re unto ~f,:t my ht.:nd ~~~str~~ O~~~!d ~o,~~:~:,.":e';;;f CfJ" f} y,., ~~U;o;ot1. er, Hershey & Tully ~ P -Ri.eha:rd agner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Defendant Date: J lad It'} I I I ;oJ . oJ? ~. ~~llll!PilIl!II '" _1,li1Jl o . IJI' :~.TJlIF_~'Iw.i'~?"Ji..~'~~~!~W-ffl;.lm;"""!-;;;-;F"""';-'i'.I-"'t"" -,;"" iI!'.~'" W t) C <- "Uce COr}; ""-.J_' ~~;.- :;;:c::..: ~c >0 c z -l -< .... "... C; r'-.., ~~ Of) P1 v ;;g :"17 ,10 "~~': (~) i'~~:-B ;~fri '-- :r;i ::0 -< ,~' N (,.) , '-, ~; "-";'lh"}FIIDT,_~Jrjl>l!'iFn"4:i ~"",;,~'11: ""'1'.'lYW;;;'~~J1~,"~~Q~ o 0'... .. CHARLES M. FOGARTY, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, RESPONDENT : 01-2916 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of September, 2001, petitioner shall pursuant to Pennsylvania Rule of Appellate Procedure 1925(b), file and serve in the chambers of this judge a concise statement of matters complained of on appeal, with an accompanying brief, within fourteen (14) days of this date. P. Richard Wagner, Esquire For Petitioner ~- George Kabusk, Esquire For Respondent ~~ 9-1.2.-0 , C).-, :saa .;27' F ~,,~ ~" _"___~" """_,. ;,h'-~-;'- <-'I ~ ~ - -~'", -, ",." ,.." " c< >,'___ .,~, AJ.Nt1~'!r~l(\SNN3d '" /'il7H=1p'M"" "~,r .J!'wf i...,; 61 :h u, I '~d II d3S 10 /1.1'<1[,""",'"'' ' '1:;).~;,iS:gnd 11 ,:10 -~ -" "J,I!!'!!f_iil,:"!'K~,."!"lrr,'r W.' .. '~',~~."" ,.,' ".--.",.,,- ,i'" L_' ,;'., ;"'.,,'-~ ;,' '~";",a;,",,, - ,. ~,',.. n j n , ilIIllffT][ 1', . rl ~ ~~*tlIf$~j':,,#'jI:P'~'''''Y'',"H'''''T,.MJ:n;,I'.'<,:;",,<,,;,;,''i''),3i:#im,-r1fiP?lr~~lf<~1fjOfi:;",N"','Nlr"'J>;~~~,~;!~~~ ,0 o .. CHARLES M. fOGARTY, : IN THE COURT Of COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V AN1A Petitioner, v. : NO: 01-2916 CIVIL : CIVIL ACTION - LAW COMMONWEALTH Of PA DEPARTMENT Of TRANSPORTATION Respondent. STATEMENT OF MATTERS COMPLAINED OF ON APPEAL PURSUANT TO PA RULES OF APPELLATE PROCEDURE RULE 1925(b) AND NOW; comes the Petitioner, Charles M. Fogarty, by and through his attorneys, Mancke, Wagner, Hershey & Tully, and files the following concise Statement of Matters Complained of on Appeal: 1. Petitioner (licensee) contends that the officer who administered the breath test failed to adequately instruct the Petitioner on how to complete the test 2. The officer who administered the test did not explain to the licensee that the intoxilyzer required approximately ten (10) seconds of uninterrupted breath, and further, at several points, indicated "o.k." to the licensee while he was attempting to comply with the request for a breath test. Jj -i"'~_ '"-' ,,', , r" .., I ,~-'-- . .. 0.' , ' o 3. The Petitioner believes he made a conscious effort to supply sufficient breath (noting that one sample in fact was sufficiently supplied), that the operator failure in instruction cannot be considered a refusal. WHEREFORE, the above serves as the statement of matters Complained of on Appeal. Respectfully submitted, Mancke, Wagner, Hershey & Tully /,] By i P ~ha.F .D. #23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 Attorneys for Petitioner Date: 9/R10 I J/p !"~9 ,__ _." o '~ I' r! f""J ,,-.I o CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of MANCKE, WAGNER, HERSHEY, & TULLY, do hereby certify that I am this day serving a copy of the foregoing document to the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Appellate Procedure, by depositing the same in the United States Mail, Harrisburg, Pennsylvania, with first class postage, prepaid, and addressed as follows: George Kabusk, Esquire Office of Chief Counsel Department of Transportation 1101 South Front Street Harrisburg, PA 17104 By D~.~~retarY MANCKE, WAGNER, HERSHEY & TULLY 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorneys for Appellant DATE: September 01 , 2001 d7 ,-","""lilI!I'~, , >'~', I - ",~ ,j [,^,. I -,- ~ .,_.,; "~ i'~ ,- -~ iim,'~lL~.",,,...,,_,,o ~ ~, _ _ rn nrt l I -",,,,-,, -~ -~~- . ,_ ,,~, -,"'w _ __~~ ,~ ""~:, ~ !M?:\JlW~~l~Jll!'I~.$W:""'''-}'i-~1--'''-'C''~''-''~;-''''''~''','': v"," '{:,'-""!:'i' - 0 a C ~il 5: 01) -0 [" IT1 ~. r., rTl --0 Z :J::) Zc f'-) ~~~7; c , r;:::C) , , ::-P:,- :r=:" Z>-C; >c: co '....; ""'- :::> )?: =< .~- ~:;; -"ll~IITi1 r !" 0, o CHARLES M. FOGARTY, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, Respondent 01-2916 CIVIL TERM IN RE: TRANSCRIPT OF PROCEEDINGS Proceedings held before the HONORABLE EDGAR B. BAYLEY, J., Cumberland County Courthouse, Carlisle, Pennsylvania, on July 23, 2001, at 2:20 p.m. in Courtroom Number Two. APPEARANCES: GEORGE KABUSK, Esquire For the Department of Transportation P. RICHARD WAGNER, Esquire For the Petitioner ).J . " ~f ~ ;":<?,'1'::F,~ '~e"" ",' , __ ""~I ,'~~." > .."~'--"~'~-' ,,.-. ,~, ~ ",--, o o FOR THE DEPARTMENT INDEX TO WITNESSES DIRECT CROSS REDIRECT RECROSS 1. William R. Meneses 2. Brandon D. Mitchem 4 12 9 16 19 22 FOR THE DEPARTMENT INDEX TO EXHIBITS IDENTIFIED 1. DL-26 Form 2. Breath test ticket 3 . Videotape 21 21 14 ADMITTED 22 21 21 2 30 ~,"'~~ - ~ ---",~'-~p,t.v'" ~"T'_'_ ".,,,'~ - ,~_ _I" .."", ~_, ,_ ", .,~. ~- , . . " o o 1 July 23, 2001, 2:20 p.m. 2 Carlisle, Pennsylvania 3 (Whereupon, the following proceedings 4 were held:) 5 THE COURT: This one is the 2:00 one? 6 MR. KABUSK: Yes, Your Honor. 7 THE COURT: We will take it. Do you need an 8 order on the 1:30 one? 9 MR. KABUSK: Yes, Your Honor. Maybe we want 10 to take care of that after this one. 11 THE COURT: I will take care of it. Remind 12 me after we finish this one. Are we ready to go on this? 13 MR. WAGNER: We are. 14 THE COURT: Proceed. 15 MR. KABUSK: Your Honor, this is the case of 16 Charles M. Fogarty versus Commonwealth of Pennsylvania, 17 Department of Transportation, case number 2001-2916. This 18 is an appeal from a one year suspension as a result of the 19 motorist's failure -- or excuse me, a violation of Section 20 1547 of the Vehicle Code, a chemical test refusal on 1/28 21 of 2001. The Department now calls Officer Meneses. 22 Whereupon, 23 WILLIAM ROBERT MENESES, 24 having been duly sworn, testified as follows: 25 MR. WAGNER: Judge, if it helps, we are 3 ~l "~"~",""-",,,,,-,~-{, ',,""-" '-'\f "17'" '"-'~'I'<::' ';:, ",--~~"",, .'," To' -'f""1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ,'~ o o prepared to stipulate to a lot of things. THE COURT: Well, whatever. MR. KABUSK: Your Honor, if I may please put on the case because it goes to certain things that I believe Mr. Wagner is contesting. I will be brief. THE COURT: If you wish to present your case, go ahead. MR. WAGNER: That's fine. THE COURT: Not all stipulations are accepted. Okay. Proceed. DIRECT EXAMINATION BY MR. KABUSK: Q Officer Meneses, please state your name. A My name is William Robert Meneses, M-as in Michael-e-n-e-s-e-s. I'm a police officer with the borough of Mechanicsburg Police Department. Q During the course of your official duties, have you had occasion to investigate an alleged incident of DUI on or about January 28th of 2001? A Yes. Q Would you please tell the Court about that incident. A Yes. On that date, I was assigned to a uniformed patrol, and I was working from 10:00 at night until 6:00 in the morning. At about 0230 or so, I was in 4 o~ '--<],-, ' ,"' ',~. ",- "1_ '"',~'", ',~", ". ,_, H '_" , " ':""':" " " o o 1 full uniform and patroling in a marked vehicle. I was on 2 West Main Street when I took notice that there was a parked 3 white jeep occupied by the driver on the first block of 4 that street. Although this is common, it caught my 5 attention. 6 As I proceeded past the vehicle, I saw a 7 white male running from between parked -- or from between 8 buildings which occupy businesses and quickly enter the 9 passenger's side of that vehicle. That caused suspicion to 10 me, and I continued to watch this vehicle from my rear-view 11 mirror. At this time I'm driving westbound on Main Street. 12 Suddenly and without any required turn 13 signal usage, the white jeep pulled away from the curb very 14 quickly onto West Main Street heading westbound. Its 15 headlights were turned off. The vehicle then made a very 16 quick left-hand turn onto Lamont, it's Lamont Avenue. This 17 caused concern to me. 18 I viewed this activity as being extremely 19 suspicious, and my initial concern was that a burglary may 20 have occurred at one of these businesses where I saw the 21 white male coming out of. I also had two traffic 22 violations as well. 23 I circled the block, and I met the vehicle 24 at the intersection of Lamont and West Simpson Street. 25 When I saw the vehicle, the headlights were turned on, and 5 33 ,,,., ',--:,,", -", ,_,~_N; _" "_'I - , - '--I " - ',I ", "." " '<"',<,-,~ = ,'_' '1'-" ,,- - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 "" --',-7" -..."", .<,,_.__. "..",.__"_,"",_~, o o I immediately put the emergency lighting on my police car in order to stop this vehicle. It failed to stop. The driver made a left-hand turn onto West Simpson Street, and then made a right-hand turn onto South Market Street, and another right-hand turn leading me to an area behind a church in a parking lot. The total distance was approximately one-tenth of a mile from when I initially attempted to stop the vehicle. I notified other officers of what I had and awaited for their arrival before I approached the vehicle. When I did approach the vehicle I spoke to the driver, whom I recognized as Mr. Fogarty, sitting to the left of counsel wearing a white shirt and a tie. I asked the driver why he had pulled away from the curb or, I'm sorry, I asked the driver what had occurred when I saw the male entering the vehicle. He denied this. I could smell a very strong odor of alcoholic beverage. I asked him if he had had very much to drink, and he stated, no, not too much. I then asked him if he was very intoxicated, and his response was, no, not very. I'm sorry, it was, no, not too much, which he then changed to, no, I'm not. I asked him for his driver's license, registration and insurance cards. Mr. Fogarty seemed very 6 34- ,= _ -~,"" >- - o o 1 confused in presenting the cards. In fact, he told me he 2 had presented the vehicle registration card to me, which he 3 never did. 4 The strong odor of alcoholic beverage, his 5 confusion and his -- and he admitting that he was -- he had 6 been drinking and was possibly intoxicated caused concern 7 to me that I was now investigating an active misdemeanor 8 level crime of DUI. 9 I asked Mr. Fogarty to step out of his 10 vehicle, and when he did so, I noticed his balance was very 11 poor. I asked Mr. Fogarty to submit to field sobriety 12 testing which is comprised of three tests. He completed 13 the first test, however, would not complete any other test. 14 He told me that there was no need for this, 15 that he was a businessman, that he had spent a considerable 16 amount of money that evening at a turkey dinner, that the 17 only beverage available to drink at this dinner was beer 18 and that he had consumed that, and if I felt that he was 19 intoxicated that I should then place him into custody, 20 which I did. 21 I advised Mr. Fogarty that he was under 22 arrest for suspicion of driving under the influence of 23 alcohol. When I handcuffed Mr. Fogarty as a standard 24 procedure, he protested that, again telling me that he was 25 a businessman, he shouldn't be treated as a common 7 ~6 "'~'>'__~';""""~' I,,, ,r_' ','I ,,-> _' ~ p.J' , -, ~ ,~ ~o "- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ~-- , ~""' ''''''T-!'''~-'~' ," ' o o criminal, that he knew several police officers, and that he had a good attorney that would get him out of all of this. I transported Mr. Fogarty to the West Shore Booking Center. At the booking center under video and audio recording I explained to Mr. Fogarty that he had rights under Pennsylvania's Implied Consent Law. I explained to him that he was under arrest for the violation indicated and that the waiver sheet was read to him, I recall that I had to repeatedly read this instructional sheet to Mr. Fogarty, specifically Section 4(b). Mr. Fogarty seemed confused, somewhat argumentative and didn't fully understand the simple instructions and rights that apply to this case. Mr. Fogarty agreed to take -- or provide a sample of breath for a breath test. After the first sample was obtained which showed that it was above 10, Mr. Fogarty then refused to take any other testing regarding his arrest. Q Were you there the entire time the booking agent was performing the breath test? A Yes, I was. MR. KABUSK: That is all the questions for right now, Your Honor. THE COURT: Okay. Cross. 8 ~~ _, _, .- ,,,~I,=_,,__,,, , '0 -0' ~-~ o o 1 CROSS EXAMINATION 2 BY MR. WAGNER: 3 Q Officer, do you have a log sheet to show 4 when you arrived at the booking center with Mr. Fogarty? 5 A I have it on my written report, if I may -- 6 MR. WAGNER: May he be permitted to do that? 7 THE COURT: Sure. 8 9 10 11 12 13 14 your question, this isn't a log sheet per se. However, on 15 my written report, which would be the second page, I have a 16 listing of times. These are approximate times. At 0307, 17 or about, I arrived at the booking center and Booking Agent 18 Mitchem's 20 minute observation period of Fogarty began. 19 BY MR. WAGNER: 20 Q Did you remain there with Mr. Fogarty during 21 22 23 24 25 MR. WAGNER: Thank you. THE COURT: You may refresh your recollection. You may get it. THE WITNESS: Thank you. THE COURT: Just take it up with you. THE WITNESS: Mr. Wagner, in reference to the entire 20 minute wait period? A Yes. Yes, I did. Q He was in your presence? A Yes. Q And was the booking officer, Mr. Mitchem, 9 37 I~--'~, - -!;"j , _ _",'_" -I,"," ; ~,~,,~ ,~ .,,", '. 1'- " -- <,." , - 'i',~, ,~_,,;, ~,-"'_'" " >0'" ~, i I"',! .,. ,- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 -, , ''''-,'"'' ,""1",,'~, ,^, _ 0 o o also in your presence? A I can't testify to that. Q Do you recall approximately what time the film began running at the booking center on Mr. Fogarty? A I can't state with a high degree of certainty. However, I indicated that at 0349 a.m., or about, I read Mr. Fogarty his implied consent which would indicate to me that the recording began at that time or just shortly before that. Q Up until the time you read the implied consent, was there ever a period of time that the booking officer and Mr. Fogarty were alone and you were not there? A Not that I recall. Q Was whatever the booking officer said to Mr. Fogarty during Mr. Fogarty's time at the booking center on film? A That I don't know. Q Did you ever hear the booking officer give Mr. Fogarty instructions on how to take the test when the camera was not running? A I don't recall. Q At any rate, if there would have been instructions given by the booking officer off of the tape, would you have noted that as being something important? A No. 10 3$ ,,' "<~< -.--., - -~ , , ~ '1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 o o Q Were the instructions to Mr. Fogarty given after you read the Implied Consent Law to him? A I'm sorry, the instructions? Q The instructions on how to actually take the test, were they given to him after you read the Implied Consent Law? A They generally are. I can't -- my recollection just Q In this case, is it your recollection that they followed the general practice that they usually do, and that is after you read the implied consent then they tell them how to take the test? A Yes. I noted nothing unusual in this processing that I observed. Q Now, just to be clear, you've indicated you got one sufficient sample, is that correct? A That's correct. Q And when you used the phrase he refused to do any other testing, he actually tried to give samples on many occasions, did he not? A Going solely by what the report says -- like I said, this was January. My recollection isn't very good with details. After the first breath test, my recollection is that he refused any other testing. However, the videotape should show. 11 31 i-',"'" ,'~""'- ,~,",--"',"~' ,,",, -'",-', ", -- , , ,"" ~~ ~~,~ "",P, ~" "_ ~" ",0" ,~ ~~ o Q 1 Q Finally, Officer, did you instruct Mr. 2 Fogarty on how to take the intoxilyzer breath test or was 3 that strictly Mr. Mitchem? 4 A Primarily it would have been Mr. Mitchem. I 5 may have assisted. However, again, I don't recall. 6 MR. WAGNER: Thank you. I have no further 7 questions. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I , 1" ^ ,=~, _,~-" MR. KABUSK: Your Honor, we do have the tape here. May I reserve the right to recall Officer Meneses? THE COURT: You may. You may step down. MR. KABUSK: The Department calls Booking Agent Brandon Mitchem. Whereupon, BRANDON D. MITCHEM, having been duly sworn, testified as follows: DIRECT EXAMINATION BY MR. KABUSK: Q Agent Mitchem, please state your name and spell your last name for the record. A Brandon D. Mitchem, M-i-t-c-h-e-m. Q Where are you employed? A Cumberland County District Attorney's Office, Central Processing Department. Q And what are your duties? A My primary duties are to process any 12 fro 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 , ,~" o o criminals that are brought in for criminal and/or DUI processing. Q During the course of your official duties, have you had occasion to be involved in the alleged -- involved in the investigation of an alleged incident of DUI on or about January 28th, 2001? A Yes, I had. Q With Mr. Charles M. Fogarty? A That's correct. Q In regard to that, are you a certified breath test operator? A Yes, I am. Q Do you have the certification with you? A My actual certification -- MR. WAGNER: We will stipulate that he is certified. THE COURT: So stipulated. BY MR. KABUSK: Q What breath test instrument were you using to administer the chemical test? A The Intoxilyzer 5000. Q Do you have the breath test instrument certificate of accuracy for that instrument? MR. WAGNER: We'll stipulate they have a certificate of accuracy as well as calibration. 13 Lr-1 ~ ".. ;~ >1-' ~"-",""I, " ,~- .r I,"~ , o o 1 THE COURT: So stipulated. 2 BY MR. KABUSK: 3 At the time of the incident was the breath Q 4 test instrument that was in service for use in this 5 incident functioning properly? 6 Yes, it was. A 7 And did you run the instrument through a Q 8 self check? 9 A Yes. 10 Did the petitioner inform you of any Q 11 physical or medical conditions that may have prevented him 12 from properly performing the test? 13 Not that I recall, no. A 14 Did the petitioner exhibit any symptoms Q 15 which would indicate the presence of a physical or medical 16 condition that would have affected his ability to perform 17 the test? 18 A No. 19 Q Was a videotape made contemporaneously with 20 the requested breath test? 21 A I'm sorry, I don't understand. 22 Q Was a videotape made of the breath test? 23 A Yes. 24 Q And did you bring a copy of that along? 25 A Yes. 14 ~~ ,. q~,-""",<,~.,~.,>,--,--, "',~'-" " '.. _I, ,_.,', ' ""- " _~, l " "-', '" p 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 "H , , "-^-C'"' o o 1 MR. KABUSK: Your Honor, I request that you 2 view the videotape, please. THE COURT: All right. Do you want me to do it now? MR. KABUSK: The tape is approximately 40 minutes long. However, the first portion of it consists of Officer Meneses reading to Mr. Fogarty the DL-26, and this happens four times. Then the last approximately 15 minutes is the actual breath test. So I would request that you we could go over the very first part, fast forward over the first part, and just view the breath test itself. THE COURT: Are you challenging the I see here in the petition, the petitioner was not properly advised of the consequences of violating 1547. MR. WAGNER: There's some -- I've had a chance to see the tape. There's some confusion at some point concerning what he can and cannot do if he does or does not take the test. I think that's important. THE COURT: Okay. Hold on a second. MR. WAGNER: Can we approach? THE COURT: Yes, come on up. (Whereupon, a brief discussion was held off the record at sidebar.) MR. WAGNER: Your Honor, if it please the Court, as a result of the sidebar, petitioner's prepared to 15 ~; ,-'- ,i_,~~I"", ,___~b' < ,-'r,~,'~', r ,,--"-, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 !"i'~~ o o be allowed to cross-examine Mr. Mitchem, and at the conclusion we have no objection to the Court, when the Court deems the time available, to see the tape in the Court's chambers. THE COURT: MR. WAGNER: THE COURT: MR. KABUSK: And you have seen it? I have seen it. Have you seen it, counselor? Yes, Your Honor. THE COURT: Fine. That is excellent, and I will watch the tape in its entirety. MR. WAGNER: And I would note that Mr. Fogarty was present with me when we both watched the tape. Correct, sir? MR. FOGARTY: Yes, sir. THE COURT: That is an excellent way to do it. You may proceed. CROSS EXAMINATION BY MR. WAGNER: Q Officer, when the tape first begins, did you prior to the beginning of the tape have any conversation with my client? A Not that I recall. Q To the best of your knowledge, whatever instructions were given to my client in taking the test would be on this tape? 16 44- '., _r. ",~,"'_"'~"..F", "" ,'__,' "r>,~ ~ ~ -~ - " ~ '--"~"- - , - '._", - ~. ,,' ''l,.. _'_,'-' _, ,~ , ~~ ~ ~ = 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 : ~' :: ,. , >, '~. . ^.,,,- -,~-',I-. o o A That's correct. Q And specifically are there a set of instructions that you give to a subject in order to have that subject be able to take the test? A There is a set of instructions that I normally give with every test I do, yes. Q Do you have any indication that you did it in this case? A No, I don't have any indication, but I do the same instructions every time I process. Q Those instructions include that a person is supposed to give approximately ten seconds of uninterrupted breath? A The specific instructions I give? Q Yes. A No. Q Tell us what they are. What are your instructions? A My instructions are take one good normal breath, make a tight seal around the top part of the mouthpiece, blow one steady, strong breath into the mouthpiece until I tell you to stop blowing. Q And you don't tell the person when they hear the machine activate that they are supposed to sustain a breath for any period of time? 17 ~ --^, , '''' ~,,~. ",' ,~, ,,- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 o o A Yeah. Whenever I -- I will tell them whenever the instrument starts to make a tone you have to keep that tone going until I tell you to stop. Q You tell them that as they are blowing and as you hear the tone, you don't tell them ahead of time, here's what I want you to do, I want you to make a tight seal, I want you to blow, and I'm going to require you to have that tone activated five to ten seconds? You don't tell them that ahead of time, do you? A No. Q You tell them that as they are blowing and you say things like okay, stop, no, while they are attempting to blow, don't you? A That's correct. Q So you don't tell somebody ahead of time that they should blow in the machine until you hear a beep, that the machines require approximately ten seconds of uninterrupted breath, and that the person should take a deep breath and continue to blow for that time period, do you? A No. My only instructions are to blow one steady breath until I tell you to stop. MR. WAGNER: No further questions. Thank you. THE COURT: Anything else? 18 ~ '" - --",", ~-., F'"flP:"",>, _,'~ ~__'o ,',', ,~. r",- ',_ ,-"-,,^- ,." ., = " - <, '--" ,,~. ,", ",-0- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I o o MR. KABUSK: Yes, Your Honor, if I may proceed. THE COURT: You may, sure, REDIRECT EXAMINATION BY MR. KABUSK: Q Mr. Mitchem, as you understand the Judge is going to view the videotape in his chambers. Did the petitioner ever provide two consecutive adequate breath samples without the required waiting period? A No, he didn't. Q Did he provide one adequate breath sample? A Yes, he did. Q Now, could you just very briefly characterize Mr. Fogarty's breath test. Just very briefly describe what happened in this matter. A The first test he did provide a good sample, but the second test he would not blow properly by not supplying any air through the mouthpiece into the tube for it to even register any kind of breath. Q Now, if he was not blowing properly, what do you recall telling him? A I don't recall without -- it will be on the tape. Q What do you generally do? If someone is not blowing properly, what do you generally do? 19 ~7 ",~~...".I!J' ,"C' """ -c~,;" 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 o o A I would have them take the mouthpiece out of their mouth, re-explain to them what they are supposed to do, tell them not to put their tongue in front of the mouthpiece because a lot of people do that, that will stop the air from going into the mouthpiece. I will then give the tube back to them, have them try again, and give them the instructions over, make a tight seal, blow one steady strong breath until I tell you to stop. Q If someone is not blowing, can you tell that? A Yes. Q If you tell them you are not blowing, are they not blowing? A Yes. Q Do they oftentimes puff their cheeks out and not blow? A Sometimes. Q Do they oftentimes let the air out the side of their mouth? A Sometimes. Q Do they oftentimes put their tongue over the tip? A Sometimes. MR. KABUSK: May I approach the witness, Your Honor? 20 4-~ .,- , ,-- '- ,~-, - ~ ~ ~ - ~ ,,, " , ""r""nnlfilti'" "'''" """""1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 o o THE COURT: Sure. BY MR. KABUSK: Q Does the machine print out a ticket indicating the breath samples? A Q Yes. Would you identify what I just handed to you? A This is the breath test ticket from the time in question. Q And what does that indicate? Was there one adequate breath test? A Yes, the first one there at 4:01 hours. Q What would that reading be? A Point 181. Q Was there ever a second adequate breath test? A No, there was not. MR. KABUSK: I move for the admission of -- MR. WAGNER: No objection. THE COURT: All of the exhibits are admitted, including the tape. MR. KABUSK: Additionally, I do have another exhibit that's been marked Commonwealth's Exhibit No.1. MR. WAGNER: That's the DL-26 form. We have no objection to the entry of that form. 21 !f1 ",< " "^ 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 j,<~, c" -_." '."'~ "'" ." o o THE COURT: That is admitted too. MR. KABUSK: So if I could have that DL-26 as number one, the breath test ticket as number two. THE COURT: And the tape is? MR. KABUSK: And the tape is number three. THE COURT: They are all admitted. MR. KABUSK: Now, oftentimes the District Attorney will request that I provide the Court with a copy of the tape so that they could use that original tape in the criminal matter. I would just ask leave from the Court that I may do so if the District Attorney requests that. THE COURT: If the D.A. requests it, fine. We won't lose it. MR. WAGNER: There is no -- this is an ARD case. THE COURT: Okay. MR. WAGNER: It's not going to be necessary for criminal prosecution. RECROSS EXAMINATION BY MR. WAGNER: Q One question, if I could, Officer, on what you just said. If a person supplied sufficient breath, the machine is activated and you hear a tone, do you not? A Correct. Q If that tone is not sustained for a period 22 50 'h "m_.,. 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 'of' o o of seconds, the machine says deficient sample, does it not? A No. Q Was there a test given to Mr. Fogarty that's on the tape where you hear the machine activated -- the tone activated and you say, okay, stop? A It would be on the tape, whatever. Q And that was approximately 4:04? A No, 4:04 would have been the deficient sample, the second test. Q Now, when we look at the tape, we're also going to see the tape stops at 4:06 and picks up again at 4:37. Can you tell me what happened during that 31 minute break that's not on the tape? A Not offhand. Q Nothing from your recollection material to the Court's determination of this case, correct? A No, nothing happened in reference to the breath test, no. MR. WAGNER: Thank you. No further questions. THE COURT: You may step down. Anything further? MR. KABUSK: Just I move that the documents be admitted, and I understand they were. THE COURT: I have. Do you wish to present 23 af ,_-",-< '"", ~~,l""_"___ ,,_->,~ ,~'~~'__'J_""'" ,~ -~ "" -" " ~-, , ' '. , ~>r - o o 1 any testimony? 2 MR. WAGNER: We wish to present no 3 testimony. We would ask the Court to respectfully in 4 considering the decision to review, if the Court would, 5 please, 19(d) and (c) (4), page 523, a 1993 case, Barner 6 versus PennDOT, a decision written by President Judge 7 Kleinfelter in Dauphin County, noting that the appeal of 8 the Commonwealth Court was withdrawn by PennDOT, and this 9 has to do with exactly the nature of the instructions 10 given. 11 THE COURT: All right. I will figure it 12 out. I will watch the tape and have something down 13 shortly. 14 MR. WAGNER: Thank you, Judge, very much. 15 (Whereupon, the hearing was concluded 16 at 2:47 p.m.) 17 18 19 20 21 22 23 24 25 24 5J , ';~, ~" ", ^"~_ ~. "1'0 .~'__"""""__",c ~""- "r'. --" o 0 1 CERTIFICATION 2 I hereby certify that the proceedings are 3 contained fully and accurately in the notes taken by me on 4 the above cause and that this is a correct transcript of 5 same. 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ';"""'~'"- 0' -"~,,,-_,,__,""''l'I_;_ -". r- \~o- If Pamela R. Sheaffer Official Court Reporter The foregoing record of the proceedings on the hearing of the within matter is hereby approved and directed to be filed. ~~, J(DI Date Edgar Ninth , 25 53 I ",-~'-' ~ '" " r I' ~ '" lfilT -', ~- ~r~ "" 0'" v, _..,~ ~iI"ilr:r.~ FfIi '&'~ ",-,'" "v~ ,-ioJ_".~ "-,"'h' -""u~,;. :~,' ff'-rC-'rrF,~w""!l'rr~)1'""f"t'"--r:""'-rw""~--~' '''"1 "'JW~l;fT"''ij~''it~-''':-fi''"8 ('J' 11 -0 ,{: I ).') ;> -..Q i? \ IJ ~ > " -r 0 -r-> ..,.., X ~, ,~,~,""II\!lll'l~~.;';":""iI'1i'f'P$.,,'?J;,",;"'I."'_W";"'''''''i;'''~'P---'f,'W-"""'~~~N!~i'Ji~~'P~'4J~\"'"":iffl~H.'!ll!lm~~,r_ ~ . o o CHARLES M. FOGARTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. COMMONWEALTH OF PENNSL YVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING 01-2916 CIVIL TERM IN RE: OPINION PURSUANT TO PENNSYLVANIA RULE OF APPELLATE PROCEDURE 1925 Bayley, J., October 3, 2001:-- Petitioner, Charles Matthew Fogarty, filed this appeal from an order of Respondent, Commonwealth of Pennsylvania, Department of Transportation, suspending his operator's license for one year for failure to complete a test of his breath following his arrest for operating a motor vehicle while under the influence of alcohol. Following a hearing, an order was entered on August 8, 2001, dismissing the appeal. Petitioner filed a direct appeal from that order to the Superior Court of Pennsylvania. In a concise statement of matters complained of on appeal, petitioner avers: 1. Petitioner (licensee) contends that the officer who administered the breath test failed to adequately instruct the Petitioner on how to complete the test. 2. The officer who administered the test did not explain to the licensee that the intoxilyzer required approximately ten (10) seconds of uninterrupted breath, and further, at several points, indicated "O.k." to the licensee while he was attempting to comply with the request for a breath test. 3. The Petitioner believes he made a conscious effort to supply oft- . "'~-+-- -,",-,,- o o 01-2916 CIVIL TERM sufficient breath (noting that one sample in fact was sufficiently supplied), that the operator failure in instruction cannot be considered a refusal. We find the following facts. On January 28, 2001, at approximately 2:30 a.m., Officer William Meneses of the Mechanicsburg Police stopped petitioner in the Borough of Mechanicsburg for summary violations. Following an investigation at the scene, Officer Meneses arrested petitioner for operating a motor vehicle while under the influence of alcohol. Petitioner was taken to a booking center. He was advised of his rights under the Implied Consent law. After considerable hesitation, the visibly, acutely intoxicated petitioner agreed to undertake a test of his breath on an Intoxilyzer 5000. A booking agent told petitioner to make a tight seal around the mouthpiece and blow one steady, strong breath into it until he was told to stop. Petitioner hardly put any breath into the machine. The Agent repeatedly told him to blow, blow, blow, blow, and that he is not blowing enough air into the machine. The constantly argumentative petitioner maintained that he was blowing air into the machine. It is obvious he is hardly blowing any.' The Agent told petitioner that it was a constant beep of the machine that he was looking for, and to keep blowing air into the machine until he was told to stop. Petitioner was told several times to take a deep breath and make a tight seal around the mouthpiece. As petitioner continued to blow insufficient amounts of air into the machine, the Agent took another mouthpiece and blew into it to show petitioner how to blow enough air into the machine. The Agent told petitioner to take a deep breath, "like , All of this is memorialized on a videotape that was admitted into evidence. -2- 5J o 0,.' ., 01-2916 CIVIL TERM you are forcing up a balloon." On the seventh try, petitioner finally blew enough air into the machine to register a valid test. The Agent then told him to do it one more time. He gave petitioner six separate opportunities to do what he had already done. Petitioner blew virtually no air into the machine on any of those occasions. The Agent then deemed that petitioner refused to perform a valid second test. The Intoxilyzer was properly calibrated, certified as accurate, and working properly. Section 1547(b)(1) of the Vehicle Code, provides: If any person placed under arrest for a violation of section 3731 (relating to driving under influence of alcohol or controlled substance) is requested to submit to chemical testing and refuses to do so, the testing shall not be conducted but upon notice by the police officer, the department shall suspend the operating privilege of the person for a period of 12 months. (Emphasis added.) The regulations of the Department ofTransportation at 67 Pa. Code 9 77.24(b) include: The procedures for alcohol breath testing shall include, at a minimum: (1) Two consecutive actual breath tests, without required waiting periOd between the two tests. The failure to perform two tests as required by this regulation warrants the suspension of an operator's driving privilege under Section 1547(b)(1) ofthe Vehicle Code. Commonwealth, Department of Transportation v. SChraf, 135 Pa. Commw. 246 (1990). In Pappas v. Commonwealth Department of Transportation, 669 A.2d 504 (Pa. Commw. 1996), the Commonwealth Court of Pennsylvania stated: -3- ~ o o 01-2916 CIVIL TERM In order to establish a prima facie case in support of a Section 1547(b) license suspension, DOT must prove inter alia, that the licensee refused to submit to chemical testing. DOT need not establish that the licensee objected to taking the test. Yi v. Department of Transportation, Bureau of Driver Licensing, 164 Pa.Cmwlth. 275, 642 A2d 625 (1995). 'It is well established law that where a defendant, when taking a breathalyzer test, does not exert a total conscious effort, and thereby fails to supply a sufficient breath sample, such is tantamount to a refusal to take the test.' Appeal of Budd, 65 Pa.Cmwlth. 314, 442 A.2d 404,406 (1982). Even a licensee's good faith attempt to comply with the test constitutes a refusal where the licensee fails to supply a sufficient breath sample. Vi. A refusal is supported by substantial evidence where the breathalyzer administrator testifies that the licensee did not provide sufficient breath. See Mueller v. Department of Transportation, Bureau of Driver Licensing, 657 A2d 90 (Pa.Cmwlth.), petition for allowance of appeal denied, 542 Pa. 637, 665 A2d 471 (1995) (officer's testimony that licensee did not make a 'proper effort' was sufficient to meet DOT's burden regarding refusal); Books v. Department of Transportation, Bureau of Driver Licensing, 109 Pa.Cmwlth. 25, 530 A.2d 972 (1987) (officer's testimony that licensee did not provide sufficient breath and stopped blowing as soon as he saw the machine register was sufficient to meet DOT's burden); Budd (officer's testimony that licensee failed to tighten his lips around the mouthpiece of the breathalyzer was sufficient to prove refusal). If DOT establishes refusal by utilizing the testimony of the administering officer, it need not prove that the machine was in proper working condition at the time of the test. Books; Budd. That is, once DOT establishes refusal, the operability or suitability of the breathalyzer is not at issue. Books; Budd. Alternatively, DOT may establish refusal under these circumstances by presenting a printout form from a properly calibrated breathalyzer indicating a 'deficient sample.' Department of Transportation, Bureau of Driver Licensing v. Lohner, 155 Pa.Cmwlth. 185, 624 A2d 792 (1993); Pestock. In this situation, proper calibration may be proven by either documentary or testimonial evidence. See Lohner (calibration established by stipUlation); Pestock (calibration established by testimony of administering officer); see also 67 Pa.Code 9 77.25(c) ('The certificate of accuracy shall be the presumptive evidence of accuracy referred to in 75 Pa.C.S. 9 1547 (relating to chemical testing to determine amount of alcohol or controlled substance).'). Once DOT has presented evidence that the licensee failed to -4- 67 o o 01-2916 CIVIL TERM provide sufficient breath samples, refusal is presumed and the burden of proof then shifts to the licensee to establish by competent medical evidence that he or she was physically unable to perform the test. Pestock. (Emphasis added.) In a brief, petitioner cites Barner v. Commonwealth of Pennsylvania, Department ofTransportation, 19 D. & C.4th 523 (Dauph. 1993), in support of his contention that he made a conscious effort to perform a valid second breath test, and due to operator error his license cannot be suspended. In Barner, the Dauphin County trial court stated: In a studied review of the videotape, counsel and the court attempted to record the results of five attempted tests. The number of seconds during which the tone was activated in each test is as follows: Test 1, three seconds; test 2, nine seconds; test 3, four seconds; test 4, three seconds; test 5, six seconds. During one of these tests the machine provided a momentary reading of .215. Benner also explained that the machine emits a beep when a sufficient sample has been received. In this case, Mr. Benner conceded that he did not instruct the defendant to blow into the machine until she heard a beep. He did not explain to her that the machine required approximately ten seconds of uninterrupted breath or that she would have to take a deep breath before beginning to blow. At one point, the defendant stopped blowing after the operator said "okay" even before the beep had sounded. We find that the lack of clarity in Mr. Benner's instructions was a primary cause of the failure to obtain a valid test. If the licensee makes a conscious effort to comply but is unsuccessful because of operator failure, there can be no refusal. See e.g., PennDot v. Marion, 109 Pa. Commw. 299, 530 A.2d 1053 (1987). (Emphasis added.) The regulations ofthe Department of Transportation at 67 Pa. Code 9 77.24(b), include: Procedures ... Alcohol and breath tests ... shall be performed in accordance with accepted standard procedures for operation specified by the manufacturer of the equipment or comparable -5- S~ o o 01-2916 CIVIL TERM procedures. (Emphasis added.) In Lackman v. Commonwealth of Pennsylvania, Department of Transportation, Bureau of Driver Licensing, _ Cumberland L.J. _ (opinion filed September 27,2001), the same claim was made that is being made in the present case. We stated: The Operator's Manual of the manufacturer of the Intoxilyzer 5000, Federal Signal Corporation of Minturn, Colorado, sets forth an operating procedure for the administration of a breath test. The manual includes the following: Request subject to blow into the mouthpiece until the tone stops; the subject has three minutes to provide an adequate breath sample. To insure a delivery of a sufficient sample, the display command requests the subject to blow into the mouthpiece until the tone stops. The tone, however, does not actually stop until the subject stops blowing. . .. If the subject stops blowing before providing a sufficient sample, then 'PLEASE BLOW flashes on the display and beep sounds every five seconds. If this occurs, request the subject to blow into the mouthpiece until the tone stops. * * * [Algent Mitchem never told petitioner to blow into the mouthpiece until the tone on the machine stopped. However, he did tell petitioner to make a tight seal around the mouthpiece, to blow harder, and to blow in one sustained breath. He repeatedly told petitioner to make one steady, strong breath until he was told to stop. In Barner, the Dauphin County court reversed a license suspension because, on the facts of that case, the court concluded that "the licensee did make a conscious effort to comply with the testing but was unsuccessful because of operator failure." Here, in contrast, we know, despite petitioner's testimony to the contrary, that he knew how to perform a valid test because he blew a valid .202% on his third try. On his next sixteen efforts, he failed to do the same thing that he had just done. When Agent Mitchem repeatedly told him to make one steady, strong breath, with a tight seal on the mouthpiece until he was told to stop, something he did -6- \51 !,!iiI~]'Ir_ o o 01-2916 CIVIL TERM not do, the procedure was comparable to that set forth in the operator's manual. The procedure used by the Agent complied with 67 Pa. Code i 77 .24(b). As long as petitioner was informed on how to successfully complete the test, which he was, there are no magic words that must be imparted to him. Our review of the videotape satisfies us that the Agent was correct in that petitioner did not exert a total conscious effort to complete a second valid breath test, which he was told how to perform, and which he knew how to perform. There was no operator error. (Emphasis added.) In the case sub judice, the booking agent told petitioner to make a tight seal around the mouthpiece of the Intoxilyzer 5000, and blow one steady, strong breath into it until he was told to stop. The Agent repeatedly told petitioner that he was not blowing enough air into the machine. The Agent blew air into another mouthpiece to show petitioner exactly how to perform the test. 2 He explained to petitioner that he should take a deep breath, "like you are forcing up a balloon." The Agent explained to petitioner that it was a constant beep of the machine that he was looking for, and to keep blowing air into the machine until he was told to stop.' When petitioner finally blew a valid test on his seventh try, the Agent told him to do it one more time. Despite six separate opportunities, petitioner blew virtually no air into the machine. Our review of the videotape satisfies us that the Agent was correct in his conclusion that petitioner did not exert a conscious effort to complete a second valid breath test, which he was 2 A factor not present in Lackman. 3 A factor not present in Lackman. -7- {po '-,-.. . .,.~ . o o 01-2916 CIVIL TERM told how to perform, and which he knew how to perform having just blown a valid test. There was no operator error. The order of August 8, 2001, dismissing petitioner's appeal from the suspension of his operator's license for one year pursuant to Section 1547(b)(1) of the Vehicle Code, was properly entered. ~1,.zvo, (Date) Edgar B. Bayley, J. George Kabusk, Esquire For the Department of Transportation P. Richard Wagner, Esquire For Petitioner ~ ~ 10-3-01 ~, :saa -8- (PI "".".. __"_,~.."c,,,,,,__.,.;,,._~,,,.~",,_ ~,"~".1 ,~".' ^,. ,_,~,,,, ,-c,_ !C',' " "".V.. n~ 1&.l - ~ ,,-=, ..,'"., , ',^ ~- ,. .,,,^ ",- '""i,,"""" ,:",.;,~, -';;"( :,' Z~'titr'''r'(! ' """!'1"'~'w- "'l *lir"'~'":"N","^' ,~,; ~:'<~tf;~t-I iy '1'-" Itl; f':-' \~ '~:,,,.: \1'1\'!~'j \ Il\vl '~I ',.-,,-, .' '. I ;"'C::~,lrv"", )\E'-\:" : . ~:' ':';' j~ '\.,J j :1 " " o -" ,:~:jU i\C ;' -r-. -- r?:' :;.;~ c~ c~ <;;. c-:; ~. "--:::l C~ -"'-', C~} ( -,"~j ':it,: 7~ =2. t7\ ,-", ~ '~- ,,~,~- ~ , . fljj,.~~'iIl'/',~li. ,".'!lI"J!;ml!m~f'!m:~~if~")"""!","")'~"''''5>'1*'''''''1",,;.,,'''F''''/'!''A!IHW<--':~li1I1!niilljF(-'1{"W'1'-W:r'~'1~"*'''lti.~",i1'll-!;fIiji!j~~~: o u, ~ CETIFICATE AND TRANSMITTAL OF RECORDS UNDER PENNSYLVANIA RULE OF APPELLATE PROCEDURE 1931 (C) To the Prothonotary of the Apellate Court to which the within matter has been appealed: COMMONWEALTH COURT OF PENNSYLVANIA The undersigned, Prothonotary of the Court of Common Pleas of Cumberland County, the said court being a court of record, do hereby certify that annexed hereto is a true and correct copy of the whole and entire record, including an opinion of the court as required by PA RAP. 1925, the original papers and exhibits, if any on file, the transcript of the proceedings, if any, and the docket entries in the following matter: ......, ell) , . if: Cll), N c.." - f- 00: W"" .",so < G: -(.) -,~ C:=r: ~ :z.~ > 'Oli~4--l o-tiJQ~ ~J.,l~ Z ~z % kJO UJ uX "- l.uX 0::0 .. CHARLES M. FOGARTY v. COMMONWEALTH OF PENNSYLVANIA DEPARTM,ENT OF TRANSPIORTATION en ... ~ 01-2916 CIVIL TERM 2O.H- CD 2001 7/ The documents comprising the record have been numbered from No. 1 to 62 , and attached hereto as Exhibit A is a list of the documents correspondingly numbered and identified with reasonable definiteness, including with respect to each document, the number of pages comprising the document. The date on which the record has been transmitted to the Appellate Court is 10-4-01 . An additional copy of this certificate is enclosed. Please sign and date copy, thereby acknowledging receipt of this record. Date Signature & Title "'r,~~ ~.."' .'_ -.' . " " . '"""! _e ~. " 0 0 , i! Among the Records and Proceedings enrolled in the court of Common Pleas in and for the county of CUMBERLAND in the Commonwealth of Pennsylvania 2071 CD 2001 to No. 01-2916 Civil Ter!OTerm, 19 is contained the following: COPY OF COMPLETE DOCKET ENTRY CHARLES M. FOGARTY v. COMMONWEWALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION SEE ATTACHED CERTIFIED DOCKET ENTRIES. , ," , ,..,:",;,,, ",-^",.'. .' , ; ""~ 1 I I 1 11 f,] I' I", I' ! 10 PAGE ]'((). 2 - 9 1 , I I. I 11 - 16 22 - 23 24 '. 25 - 28 1:29-53 1154-61 l! 1129-53 ,( 62 - 63 " II :1 " ~ I " ! 'J~, ~~, PYS510 2001-02916 o o FOGARTY Cumberland County Prot~onotary's Office Civil Case Inqu~ry CHARLES M (vs) PENNSYLVANIA COMMONWEALTH OF Filed. . . . . . . . : Time......... : Execution Date Jury Trial. . . . Disposed Date. Higher Crt 1.: Higher Crt 2.: 5/15/2001 8'06 0/00/0000 0/00/0000 2071 cb 2001 Page 1 Reference No. . : Case Type.....: APPEAL - LICENSE SUSP Judgment...... .00 Judge Assigned: BAYLEY EDGAR B Disposed Desc. : ------------ Case Comments ------------- ******************************************************************************** General Index Attorney Info FOGARTY CHARLES M 17 GUTSHALL ROAD BOILING SPRINGS PA 17007 PENNSYLVANIA COMMONWEALTH OF DEPARTMENT OF TRANSPORTATION POBOX 68693 HARRISBURG PA 17123 APPELLANT WAGNER PRICHARD APPELLEE ******************************************************************************** * Date Entries * ******************************************************************************** 5/15/2001 5/21/2001 8/08/2001 8/31/2001 9/05/2001 9/11/2001 9/11/2001 - - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - APPEAL FROM SUSPENSION OF DRIVERS LICENSE ------------------------------------------------------------------- ORDER - DATED 5/.21/01 - IN RE LICENSE SUSPENSION APPEAL - A HEARING IS SET FOR 7/23/01 AT 2:00 PM IN CR 2 OF THE CUMBERLAND CO~TY CARLISLE PA - BY THE COURT EDGAR B BAYLEY J COPIES MAILED 5/21/01 ------------------------------------------------------------------- ORDER OF COURT - DATED 8/8/01 - LISCENSE SUSPENSION APPEAL IS DISMISSED - BY EDGAR B BAyLEY J - COPIES MAILED 8/9/01 ------------------------------------------------------------------- ORDER - DATED 8/30/01 - IN RE PETITION OF CHARLES M FOGARTY IT IS HEREBY ORDERED THAT A SUPERSEDEAS BE ISSUED AGAINST AGAINST THE RESPONDENT COMMONWEALTH OF PA DEPT OF TRANSPORTATION STAYING THE IMPOSITION OF SUPENSIONS OF THE LICENSE OF THE PETITION HEREIN PENDINGS PERFECTION AND APPEAL TO THE COMMONWEALTH OF PA AND ANY SUBSEQUENT - BY THE COURT EDGAR B BAYLEY J COPIES MAILED 9/4/01 ------------------------------------------------------------------- NOTICE OF APPEAL TO COMMONWEALTH COURT OF PA FROM JUDMENT OF SUSPENSION ENTER IN THIS MATTER ON 8/8/01 BY EDGAR B BAYLEY J - BY P RICHARD WAGNER ESQ FOR DEFT ------------------------------------------------------------------- COMMONWEALTH COURT OF PA NOTICE OF APPEAL DOCKETING # 2071 CD 2001 ------------------------------------------------------------------- ORDER OF COURT - DATED 9/11/01 - PETITIONER SHALL PURSUANT TO PA RULE OF APPELLTE PROCEDuRE 1925 B FILE AND SERVE IN THE CHAMBERS OF THIS JUDGE A CONCISE STATEMENT OF MATTERS COMPLAINED OF ON APPEAL WITH AN ACCOMPANYING BRIEF WITHIN 14 DAYS OF THIS DATE - BY THE COURT EDGAR B BAYLEY J COPIES 9/25/2001 STATEMENT OF MATTERS COMPLAINTED OF ON APPEAL PURSUANT TO PA RULES OF APPELLATE PROCEDURE RULE 1925(B) BY P RICHARD WAGNER ESQ ------------------------------------------------------------------- TRANSCRIPT LODGED ------------------------------------------------------------------- OPINION PURSUANT TO PA RULE OF APPELLATE PROCEDURE 1925 - EDGAR B BAYLEY J - COPIES MAILED 10-3-01 ------------------------------------------------------------------- 10/03/2001 TRANSCRIPT FILED - - - - - - - - - - - - - - LAST ENTRY ~TH'S EXHIBITS ******************************************************************************** * Escrow Information * * Fees & Debits Beo Bal Pvmts/Adl End Bal * ********************************~********~******~******************************* 9/28/2001 10/03/2001 APPEAL LIC SUSP TAX ON APPEAL SETTLEMENT JCP FEE APPEAL ~~ 01 ,. - _, ~ 35.00 .50 5.00 5.00 30.00 35.00 .50 5.00 5.00 30.00 .00 .00 .00 .00 .00 , o o ( Cumberland County Prot~onotary's Office Civil Case Inqulry 2001-02916 FOGARTY CHARLES M (vs) PENNSYLVANIA COMMONWEALTH OF PYS510 Reference No. . : Case Type.....: APPEAL - LICENSE SUSP Judgment...... .00 Judge Assigned: BAYLEY EDGAR B Disposed Desc. : ------------ Case Comments ------------- Filed. . . . . . . . : Time......... : Execution Date Jury Trial. . . . Disposed Date. Higher Crt 1.: Higher Crt 2.: ------------ .00 ------------------------ 75.50 75.50 Page 2 5/15/2001 8:06 0/00/0000 0/00/0000 2071 cb 2001 ******************************************************************************** * End of Case Information * ******************************************************************************** TRue U)PY FROM ReCORD In Testimony whereof, I hereunto set my hand ~~m. _~~ rh ~. ~ DO/ . ~rhO o o Commonwealth of Pennsylvania County of Cumberland 1 ss: I, Curtis R. Long , Prothonotary of the Court of Common Pleas in and for said County, do hereby certify that the foregoing is a full, true and correct copy of the whole record of the case therein stated, wherein Michael M. Foqartv In TESTIMONY WHEREOF, I this 4 th Plaintiff, and Comm. of Pennsvlvania Dent. of Transnortation Defendant _, as the same remains of record before the said Court at No.O 1- 2 916 of Civil Term, A.D. 19__ have hereunto set my hand and affixed the seal of said Court day of r A. D., I~OOl . Prothonotary I, George E. Hoffer President Judge of the Ninth Judicial District, compQsed of the County of Cumberland, do certify that CurtJ.s R. Long , by whom the annexed record, certificate and attestation were made and given, and who, in his own proper handwriting, thereunto subscribed his name and affixed the seal of the Court of Common Pleas of said County, was, at the time of so doing, and now is Prothonotary in and for said County of Cumberland in the Commonwealth of Pennsylvania, duly commissioned and qualified to all of whose acts as such full faith and credit are and ought to be given as well in Courts of judicature as elsewhere, and that the said record, certificate and attestation are in due form of law and made by t IC . Commonwealth of Pennsylvania County of Cumberland } ss: sident Judge t, Curtis R. Lona , Prothonotary of the Court of Common Pleas in and for the said County, do certify that the Honorable Georae E. Hoffer. P. J . by whom the foregoing attestation was made, and who has thereunto subscribed his name, was, at the time of making thereof, and still is President Judge of the Court of Common Pleas, Orphan' Court and Court of Quarter Sessions of the Peace in and for said County, duly Commissioned and qualified; to all whose acts as such full faith and credit are and ought to be given, as well in Courts of judicature as elsewhere. IN TESTIMONY WHEREOF, t have hereunto s'if tW hand and affixedd~1:~tJ of said CO~bOTs of A.D. 19__ Prothonotary "~>-'--'-'>- "".. ~ -"I _~_"~u- ( ! ....2.U....' l~ CHEMICAL TESTING WARNINGS AND REPORT OF ItEI'llSAl. TO SUBMIT TO CHEMICAl. TiaSTIHO AS AU1l\Ol'\1ZEtl 8'1 OF THE VEHICLE COllE I)-a SEcC1'[Otl is.t7 NAME \1": fl~J t-- In AD u~ '-f t-- YlllIllE ~c'- 1-'\ UST Ifez ~Cl("A.\:<-\'1 H """ ., _ <=:,\> P STAlE <'. ..,,<: SOCIAL SECIlTlIlY II1JDIft J:",'l .".. .... ...0 .. Fle1lso be odUod fla. yeu.... now under """..10. I!rivlng undo. lIMo Inllutl_ '" alcohol 0'. __ ...bs'...... _no __ 91:11 oJ . .... Vollida Codo. .... 2..';' "",uo.linQ d1aI y=" .ubmllI0. dlomtoa'le" a' p.,a..~,., Tl-I ;lQ_ or WIne. QIlIca. __ "" chamIcaI lint) o 3. .rr. my cluty... aJ',.lfca am.... 10 !nlarm you t1m11l you ../u.. 10 submit., .... ~"_' _tlng pMlflge...lla.uspondod Io.. ~ pried of onG rea. _ . .... 4. al Tho """.lIutionri rights JOu ha... as a erlmlnal dorondanl CQmmonly knawnu1llo M1r::,~1S. irldud.g lIMo righ'''' _""wllltalawyer and C 111. right..,."""" _t """If onlJ 10 criminal P'O"OctJti""" and do _am 10'" l8dng..- unclar "-Msy_slmpllscl Cons,", Uw. whJch Is . eMf. nol a criminal proeuodnQ. bl You how,"" ""hIla .p.....la s (0"10.. 0' any.... _lIot.""!anI IaIdnl/ lIMo _1caI.... requo'lIld by 1IIa pollco 0_ _cia you....... right '" ramal.ol....Whm ..lAIdbylf1opollcao/flcorla..-It'" Clte_...t UnIo.. you_b_'IOlIMo "",,_l8dby".polIco 0_ your "~Otll:i"Qt wll be deemttd 10 b8 refusal and JOur operating privlege wll M suspanded for OM par. el y"", "".", '" ,ubmll '" dIemIcaIllISllng _ lIMo ImpllIocl Conurll La.. mal biJllll1Oclucecllnlo.-lno -_-Ior_lng whlkJ under ItUI' itnuenc. of ak::01'tcI or. ccnlJalhtd SUB,*">>. . PA q , " SECTION i547 - CHEMIChJlL TESTING WARNINGS " , , , t coerIlly !hall_ ""Ill lha all.....wamInll '" lho matWol "'!larding Ihe ouspsnslon oIl1>1l~ _ling ~ _p...... _""__ nlty 10 wubmR tochsmlcaf toatlnO. ' SIgna.... 01 01_:. ' ~. t;:>. 'lfy-.~ Dole: '" I.~?l - ClI c,~ ~ '(q I h aV1t been ad.,;"Gd ct lhe abow. Signature 01 Molorlal; Dallf: Motori,. ,elus" to $l;n. ahar bQing .dvllod. S~natunt of 0fflCGf': '--S-.~ ~ i,:?, \f'r\ -J..-J -\ &> " Do..: (") \- ':l.~- 0\ O~;z;:,?, APFIDAVlT ,. ihB abovo r/llltonGI was ptaeed under &lrMt lor driving uncS9r tho lnltuontO cll atcoh04 Of . controUed lubstan6J in Ylotalfon 0' gecdon 3731 of the Vohict-e Coch.lInd Ihgf1l we,. roDlonabhJ orounds to bertOVa that the ahoYII' mclorfsl had been ddvklg~ operallng tit In actual phJ&k:aI control oJ th, movemGd 0'. mofOf vehk;fo whBe undM lhelnfluunc:e of alcohol cr<< confrow.d lubsttnClf or bolh. or Thai the qbm1J nanted molOri.ct waslnvolvod' In an ~nr 'It triIlc:h ,. operamr cr PlUJB1lfl6f 0' any wtNcI8ln\'olwd or. pedeo.1I'fan ntqu1md t:rsalmonl all medc::al fad6ty or wu Idtred. 2. The abav8' tllI)loffsJ wa. mquested to submJt to cbemh:aJ I9slJnQ as aulborfzed b7 SectIon tS., oJ lb. VRhJehI Code. 3_ The UbOV9 rtIOtorist was tarorrnad by II pcb officer of It1G dNimfc::gJ m!' wamtngs c::cntainad In paragraph 3 and ... .bow. .t. Th9 .bow n&mtJd motortst ratYsvd to SUbmit: lD chem5caJ t:Qstfng. 01=FlC~R NOlE: lb_ nl".aI to -'gn 1Is1. form .. not a r.fuAJ '0 aubmlt 10 lb. clJemlcal 'hI. You ftluat .1111 gIv_ the _010"''' ell CPPD1'1b- nllf ra ufe_lb, eII""caJ .... .n., reviewing Ihta Ionn. II tit. IndlvlduaJ WAa op....lInO _ ~m rrtrJal motor y~ whh hawJqJ an,. .1 echol or a cmtroltwd eub.bnce In thlllr aphm.-JQu ow.. .tao ClJftlpJ... tlI. r.~oI1bh fDnft; ~ ~ suasCRtBEttAm):n'IcRN . . OfncerStgnatuht: ~-". \ ",~..,(~~....,g.", ~ Z TO BUORElIIE: 110. CAY YEAR C 1= ~ a: i!! C) ::z Officer Name: '-A~\\l\,:-,(""\ ~~. M:,\-....:r"", (t:rptl_Vmt) - Badgo Number: Pho",,: L:llJl --> ') K Ju1lsdloIJcn:~. 1-1E(,}-\. ~q\-?J~ 10-.... l~<-"T ~'l t<'\ \ ~T. f'o.-vn.1 I p~ \--iQl'",S Malllng Address I I I I i I FOf'Nard to: Departmenl of Transportation SUTS-aU of f)"V9T UCGnsfng P.O. Box 2253 Hanfsbu rg, P A 17r 05 THiS FORMlolAY BE DUPLICATED Note: Any pertlnorlllaCIS oot Ctt\I8re-d by-tho nffldovll shoutd be IUbmaUso on a separate ~h99t and aUaeb9rl oomto. That sheat should lncluda tho nam'G$ oi addiUcoo.1 witnesses n8ceUtsry to proys lho atomOflts to whleh you havG alta;ted. ADDITIONAL SUPPlieS OF nus FOAM MAY BE SECUREO BY COMPlEllNG fOR.MOS.S11A - \ . :1l1.~l~L_--- r.B.S .'C,," ~--~ ------ crt~,,!ojlC _ ' IHT,OX(LYZER: - COHN- AHAL YZER PA MODEL 5080 SN 6~-082689 81/28/08 , e,' TEST ,;, -" DIAGNOSTIC OK A I R BLA~jK SUBJECT TEST A I R B,LANK lIlSlIBJECT TEST AIR BLANK CAL. CHECK AIR BLANK \,* DEFl C I Ern PR INTED WAS NO RFI DETECTED " , , , i I I ~~BAC TmE 03:58 03:58 01.\:01 84:01 Q ::ra4: 81.\ ,"04:04 '04:",5 ""0'4: 05 '-'} 1 I I ! I Gr<~~ I I I. i I .000 .181 .800 .888 .080 .139,6 .0'313 , I I i i J I 1 I S!iit1?LE - I,IALlIE ~~GHEST OBTAINED. /' ' -"c, .lira"" I nON I , I I i I i i Y ! I k OPE OR AODlTIONAlINFORMATrON AND/OR REMARKS \ ~- CUMBERLAND COUNTY DUI DEPT, ._~--- ----------_._-..-------- --~-._.) " Commonwealth's eXHII!.IT 21~3iC>J';;' ~2' " . ...... t CETIFICATE AND TRANSMITTAL OF RECORDS UNDER PENNSYLVANIA RULE OF APPE~LA TE PROCEDURE 1931 (C) To the Prothonotary of the Apellate Court to which the within matter has been appealed: COMMONWEALTH COURT OF PENNSYLVANIA The undersigned, Prothonotary of the Court of Common Pleas of Cumberland County, the said court being a court of record, do hereby certify that annexed hereto is a true and correct copy of the whole and entire record, including an opinion of the court as required by P A RAP. 1925, the original papers and exhibits, if any on file, the transcript of the proceedings, if any, and the docket entries in the following matter: CHARLES M. FOGARTY v. COMMONWEALTH OF PENNSYLVANIA DEPARTM,ENT OF TRANSPIORTATION 01-2916 CIVIL TERM 2017 CD 2001 The documents comprising the record have been numbered from No. 1 to 62 ,and attached hereto as Exhibit A is a list of the documents correspondingly numbered and identified with reasonable definiteness, including with respect to each document, the number of pages comprising the document. The date on which the record has been transmitted to the Appellate Court is 10-4-01 . An additional copy of this certificate is enclosed. Please sign and date copy, thereby acknowledging receipt of this record. Date Signature & Title . I .~~ ~ I' ". .. I Among the Records and Proceedings enrolled In the court of Common Pleas in and for the COPY OF CUMBERLAND 2071 CD 2001 01-2916 Civil Termrerm,19 COMPLETE in the Commonwealth of Pennsylvania county of to No. is contained the following: DOCKET ENTRY MICHAEL M. FOGARTY v. COMMONWEWALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION SEE ATTACHED CERTIFIED DOCKET ENTRIES. '-'~1m~ , " -r -I' , , , . ,"Ill ~ ... t Commonwealth of Pennsylvania County of Cumberland } ss: I Curtis R. Long , Prothonotary of the Court of Common Pleas in and for said County, do hereby certify that the foregoing is a full. true and correct copy ofthe whole record ofthe case therein stated, wherein Michael M. Foqarty In TESTIMONY WHEREOF. I this 4t-h Plaintiff, and Comm. of Pennsvlvania Dent. of Transnortation Defendant _, as the same remains of record before the said Court at No.Ol-2916 of Civil Term, A.D. 19_. have hereunto set my hand and affixed the seal of said Court day of A. D., 14!.ooL. Prothonotary I. George E. Hoffer President Judge of the Ninth Judicial District, compQsed" of the County of Cumberland, do certify that Curt1s R. Long , by whom the annexed -record, certificate and attestation were made and given, and who, in his own proper handwriting, thereunto subscribed his name and affixed the seal of the Court of Common Pleas of said County, was, atthe time of so doing, and now is Prothonotary in and for said County of Cumberland in the Commonwealth of Pennsylvania, duly commissioned and qualified to all of whose acts as such full faith and credit are and ought to be given as well in Courts of judicature as elsewhere, and that the said record, certificate and attestation are in due form of law and made by t 1C . Commonwealth of Pennsylvania County of Cumberland } ss: I, Curtis R. Lona . Prothonotary of the Court of Common Pleas in and for the said County, do certify that the Honorable Georae E. Hoffer. P. J . by whom the foregoing attestation was made. and who has thereunto subscribed his name, was, at the time of making thereof. and still is President Judge ofthe Court of Common Pleas, Orphan' Court and Court of Quarter Sessions of the Peace in and for said County. duly Commissioned and qualified; to all whose acts as such full faith and credit are and ought to be given. as well in Courts of judicature as elsewhere. IN TESTIMONY WHEREOF. I have hereunto s'lit'N hand and affixedd~'t~~ of said Co~Ml.is of A.D. 19_. Prothonotary 'f' ,"">"~.~" I- I': ." ~" .~" '" PYS510 2001-02916 Cumberland County Prothonotary's Office Civil Case Inquiry FOGARTY CHARLES M (vs) PENNSYLVANIA COMMONWEALTH OF 1 Page Reference No..: Case Type.....: APPEAL - LICENSE SUSP Judgment...... .00 Judge Assigned: BAYLEY EDGAR B Disposed Desc. : ------------ Case Comments ------------- Filed. . . . . . . . : Time......... : Execution Date Jury Trial. . . . Disposed Date. Higher Crt 1.: Higher Crt 2.: 5/15/2001 8:06 0/00/0000 0/00/0000 2071 CD 2001 ******************************************************************************** General Index Attorney Info FOGARTY CHARLES M APPELLANT WAGNER PRICHARD 17 GUTSHALL ROAD BOILING SPRINGS PA 17007 APPELLEE PENNSYLVANIA COMMONWEALTH OF DEPARTMENT OF TRANSPORTATION POBOX 68693 HARRISBURG PA 17123 ******************************************************************************** * Date Entries * ******************************************************************************** PAGE 00. 2 - 9 5/15/2001 1 5/21/2001 10 8/08/2001 11 - 16 8/31/2001 17 - 21 9/05/2001 22 - 23 24 9/11/2001 9/11/2001 25 - 28 9/25/2001 29 - 53 9/28/2001 54 - 61 10/03/2001 29 - 53 10/03/2001 62 63 - - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - APPEAL FROM SUSPENSION OF DRIVERS LICENSE ------------------------------------------------------------------- ORDER - DATED 5/.21/01 - IN RE LICENSE SUSPENSION APPEAL - A HEARING IS SET FOR 7/23/01 AT 2:00 PM IN CR 2 OF THE CUMBERLAND COUWTY CARLISLE PA - BY THE COURT EDGAR B BAYLEY J COPIES MAILED 5/21/01 ------------------------------------------------------------------- ORDER OF COURT - DATED 8/8/01 - LISCENSE SUSPENSION APPEAL IS DISMISSED - BY EDGAR B BAyLEY J - COPIES MAILED 8/9/01 ------------------------------------------------------------------- ORDER - DATED 8/30/01 - IN RE PETITION OF CHARLES M FOGARTY IT IS HEREBY ORDERED THAT A SUPERSEDEAS BE ISSUED AGAINST AGAINST THE RESPONDENT COMMONWEALTH OF PA DEPT OF TRANSPORTATION STAYING THE IMPOSITION OF SUPENSIONS OF THE LICENSE OF THE PETITION HEREIN PENDINGS PERFECTION AND APPEAL TO THE COMMONWEALTH OF PA AND ANY SUBSEQUENT - BY THE COURT EDGAR B BAYLEY J COPIES MAILED 9/4/01 ------------------------------------------------------------------- NOTICE OF APPEAL TO COMMONWEALTH CO~T OF PA FROM JUDMENT OF SUSPENSION ENTER IN THIS MATTER ON 8/8/01 BY EDGAR B BAYLEY J - BY P RICHARD WAGNER ESQ FOR DEFT ------------------------------------------------------------------- COMMONWEALTH COURT OF PA NOTICE OF APPEAL DOCKETING # 2071 CD 2001 ------------------------------------------------------------------- ORDER OF COURT - DATED 9/11/01 - PETITIONER SHALL PURSUANT TO PA RULE OF APPELLTE PROCEDuRE 1925 B FILE AND SERVE IN THE CHAMBERS OF THIS JUDGE A CONCISE STATEMENT OF MATTERS COMPLAINED OF ON APPEAL WITH AN ACCOMPANYING BRIEF WITHIN 14 DAYS OF THIS DATE - BY THE COURT EDGAR B BAYLEY J COPIES STATEMENT OF MATTERS COMPLAINTED OF ON APPEAL PURSUANT TO PA RULES OF APPELLATE PROCEDURE RULE 1925(B) BY P RICHARD WAGNER ESQ ------------------------------------------------------------------- TRANSCRIPT LODGED ------------------------------------------------------------------- OPINION PURSUANT TO PA RULE OF APPELLATE PROCEDURE 1925 - EDGAR B BAYLEY J - COPIES MAILED 10-3-01 ------------------------------------------------------------------- TRANSCRIPT FILED - - - - - - - - - - - - - - LAST ENTRY ~TH 'S EXHIBITS ******************************************************************************** * Escrow Information * * Fees & Debits Beo Bal Pvmts/Adl End Bal * *****************************************~******~******************************* APPEAL LIC SUSP TAX ON APPEAL SETTLEMENT JCP FEE APPEAL "'~ -,.- T'-' 35.00 .50 5.00 5.00 30.00 35.00 .50 5.00 5.00 30.00 .00 .00 .00 .00 .00 t-'" -~, - Cumberland County Prothonotary's Office Civil Case Inquiry 2001-02916 FOGARTY CHARLES M (vs) PENNSYLVANIA COMMONWEALTH OF keference No..: Filed.. ......: Case Type.....: APPEAL - LICENSE SUSP Time.........: Judgment. . . . . . .00 Execution Date Judge Assigned: BAYLEY EDGAR B Jury Trial.... Disposed Desc.: Disposed Date. ____________ Case Comments ------------- Higher Crt 1.: Higher Crt 2.: _ PY~S510 ------------------------ ------------ 75.50 75.50 .00 Page 2 5/15/2001 8:06 0/00/0000 0/00/0000 2071 CD 2001 ************************************~******************************************* * End of Case Information * ******************************************************************************** .,.. ~'r " ~ " \ . CHARLES M. FOGARTY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 01-2916 CIVIL TERM : CIVIL ACTION - LAW o c < -0 l~;:; n"l!";"i 2::" -./t C7j) -< ~C; -- .J.?C'" ;;;6 )>c:: :z ::<l U") fT1 c" COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, ........-; I c. . :r,,"I cD :::> .-.J '. ~;j NOTICE OF APPEAL o =< NOTICE IS HEREBY GIVEN that CHARLES M. FOGARTY, above-named, hereby appeals to the Commonwealth Court of Pennsylvania from Judgement of Suspension enter in this matter on the 8th day of August, 2001, by the Honorable Edgar B. Bayley, Judge of the Court of Common Pleas Court, Cumberland County, Pennsylvania. The Order has been reduced to judgment and entered in the docket as evidenced by the attached docket entry. Respectfully submitted, er, Hershey & Tully agner, Esquire LD. #23103 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Defendant Date: 3/ge/tJ/ I I ";",!,!"",,!,,~ 1,",--- . . 1"1 I CHARLES M. FOGARTY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 01-2916 CIVIL TERM : CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, ORDER FOR TRANSCRIPT A NOTICE OF APPEAL, having been filed in this matter, the official court reporter is hereby order to produce, certifY and ftle the transcript in this matter in confonnity with Rille 1922 of the Pennsylvania Rules of Appellate Procedure. Respectfully submitted, Mancke, Wagner, Hershey & Tully By , . Rich I.D. #23103 2233 North Front Street Harrisburg, P A 17110 (717) 234-7051 Attorneys for Defendant Date: S!.3o/tJI I I -', ~ -". "_P - '- - ~ , 1'_' CHARLES M. FOGARTY, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO: 01-2916 CIVIL TERM : CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm ofMANCKE, WAGNER, HERSHEY, & TULLY, do hereby certifY that I am this day serving a copy of the foregoing document to the following persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Appellate Procedure, by depositing the same in the United States Mail, Harrisburg, Pennsylvania, with first class postage, prepaid, and addressed as follows: George Kabusk, Esquire Office of Chief Counsel Department of Transportation 1101 South Front Street Harrisburg, P A 17104 The Honorable Edgar B. Bayley Court of Common Pleas Cumberland County Courthouse Carlisle, PA 17013 Court Reporter Cumberland County Courthouse Carlisle, P A 17013 DATE: a/dic/ By ~ '-i. ,.20l/!v,'.vJ Debra K Spinner, Secfetary MANCKE, WAGNER, HERSHEY & TULLY 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorneys for Appellant !.,,> '"~, ~. - ~~ , ~,~ _1"'-: " PYS510 ,'., '. '~"'''1' ",_"-,, '_" CumberlandCo~nty Prothonotary's Office Civil Case Inquiry Page 1. . 2001-02916 FOGARTY CHARLES M (vs) PENNSYLVANIA COMMONWEALTH OF Reference No..: . 'Case Type.....: APPEAL - LICENSE SUSP' Judgment:. . . . . . .00 Judge Assigned: BAYLEY EDGAR B Disposed Desc. : ------------ Case Comments ------------- Filed. . . . . . . . : Time. . . . .: . . . .. Execution Date Jury Trial.... Disposed Date. Higher Crt 1.: Higher Crt 2.: 5/15/2001 8:06 0/00/0000 0/00/0000 ******************************************************************************** General Index Attorney Info FOGARTY CHARLES M APPELLANT WAGNER PRICHARD 17 GUTSHALL ROAD BOILING SPRINGS PA 17007 PENNSYLVANIA COMMONWEALTH OF DEPARTMENT OF TRANSPORTATION POBOX 68693 HARRISBURG PA 17123 APPELLEE ~ ******************************************************************************** * Date Entries * ******************************************************************************** 5/15/2001 5/21/2001 8/08/2001 8/31/2001 - - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - APPEAL FROM SUSPENSION OF DRIVERS LICENSE ------------------------------------------------------------------- ORDER - DATED 5/.21/01 - IN RE LICENSE SUSPENSION APPEAL - A HEARING IS SET FOR 7/23/01 AT 2:00 PM IN CR 2 OF THE CUMBERLAND COUNTY CARLISLE PA - BY THE COURT EDGAR B BAYLEY J COPIES MAILED 5/21/01 ------------------------------------------------------------------- ORDER OF COURT - DATED 8/8/01 - LISCENSE SUSPENSION APPEAL IS DISMISSED '- BY EDGAR B BAYLEY J - COPIES MAILED 8/9/01 ------------------------------------------------------------------- ORDER - DATED 8/30/01 - IN RE PETITION OF CHARLES M FOGARTY IT IS HEREBY ORDERED THAT A SUPERSEDEAS BE ISSUED AGAINST AGAINST THE RESPONDENT COMMONWEALTH OF PA DEPT OF TRANSPORTATION STAYING THE IMPOSITION OF SUPENSIONS OF THE LICENSE OF THE PETITION HEREIN PENDINGS PERFECTION AND APPEAL TO THE COMMONWEALTH OF PA AijD ANY SUBSEQUENT - BY THE COURT EDGAR B BAYLEY J COPIES MAILED 9/4/01 - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - ******************************************************************************** * Escrow Information * * Fees & Debits Beq Bal Pvmts/Adi End Bal * ******************************************************************************** APPEAL LIC SUSP TAX ON APPEAL SETTLEMENT JCP FEE 35.00 .50 5.00 5.00 35.00 .50 5.00 5.00 .00 .00 .00 .00 ------------ .00 45.50 45.50 ******************************************************************************** * End of Case Information * *******************************************************.************************* '-~--;>J,~ ~ ,~,,~- '''..'1'''''-'_'_ :, _ . - ~ I ~ 'i- Commonwealth Court of Pennsylvania Charles R Hostutler Deputy Prothonotary/Chiel aerk November 1, 2001 Notice of Discontinuance of Action RE: Fogarty v. DOT Appeal of: Charles M. Fogarty Type of Action: Notice of Appeal No. 2071 CD 2001 Cumberland County Court of Common Pleas Agency Docket Number: No. 01-291.6 Civil Term P.o. Box 11730 Harrisbur.. PA 17108 717.255.1650 The above-captioned matter has been marked "Discontinued" with this court. Certification is being sent to the lower court. Attorney Name Party Name Harold Cramer, Esq. George H. Kabusk, Esq. Paul Richard Wagner, Esq. Bureau of Driver Licensing Bureau of Driver Licensing Charles M. Fogarty CerIIIied from the FleCOId . NaV - 1 2001 and Older Exit "--~""~ ,~~ ,'")"'-' ,-- I'. Party Type Appellee Appellee Appellant . "I c, "'1"'~, "",,~ > ,"'7' . ~ ~. ',,",,' , T ~ ~,' ~ [":11''f', " "' ,,- ~ '" "..'.", "''''''~''''"''''>R II' IlJiUr 'Ie '\Ii~ljll o c di~; z .' z,e Q:;:- r:: ,.' ~,' "" ~~ ..=.." ..,.. 22- ",'~- :",) ~\ -<. ('1> ,~ c':; -v ..,.::;,. ':.") <tl_D:Il~~~~~;l>;it"l"'--,!<F'l":i!-X1"i?'!~:1'j'}'-"F"'i"".p-",,;,"W_J;;~;;'P,'i\Wiiti!"i~~il1ii!lf,,;R~'fl'-l:~~$f.W"~''''''~~~~'i:~' File Copy ." Commonwealth Court of Pennsylvania Charles R. Hostutler Deputy Prothonotary/Ollef Gerk November 1, 2001 P.O. Box 11730 HarrisbU11!. PA 17108 717.255-1650 Notice of Discontinuance of Action RE: Fogarty v. DOT Appeal of: Charles M. Fogarty Type of Action: Notice of Appeal No. 2071 CD 2001 Cumberland County Court of Common Pleas Agency Docket Number: No. 01-2916 Civil Term The above-captioned matter has been marked "Discontinued" with this court. Certification is being sent to the lower court. Attorney Name Party Name Party Type Harold Cramer, Esq. Bureau of Driver Licensing Appellee George H. Kabusk, Esq. Bureau of Driver Licensing Appellee Paul Richard Wagner, Esq. Charles M. Fogarty Appellant Oenitied froIn the R8COnf , NOv - 1 2001 -Onter_ "~,,..,,..,,.,. .. I': ''''''''- ~ -:.< ~ , ''WI. H ~.Rf:!\ll4f.'i'lll'lillfu1~., _. ~~~,:;;r -'T ~ .~.- "' '~' ''''''h' ,-""",,-,!,,;,,,,,", t;""""~"~""~""''''--~''--;"'"''-'~T"(;' "W~~~' "~r'- ")l(:'rilt'Mf'" 'C<"'-'''''''_!i''''o' C c,::: S; ~:1':: -rj v_ ""~ Q,] ,..,n ..,~ " ~ L~_ CI} .... -.": -( e. r:::: :'~<;-" ~:;: /~ --> S; C~ ;.,.'::; ~~ ~.S .:.~) -< -, TI~~"""",~,...--.,.~_~!'!'o'@ll!'1t~~r'''~1!W'Jli~jjl!:ooi~1:\'"''~'1rnf,fmq'''''';\9",,~7WP:iF-ifql,c'..,,""_""'!;~"'J:'M'1i';_!rl~,~'''k'''it~'~i;q:jo'ij:W~~iT~'t,\1l\i1iWJ;-~~;",'~1V'--';.-;;\! ;'P11iN'!J'01P!1P!~W#~~"- File Copy ~ Commonwealth Court of Pennsylvania Charles R. Hostutler Deputy Prolhonornry /Chief Clerk November 1, 2001 P.O. Box 11730 Hamsburl? PA 17108 717-255-1650 TO: RE: Fogarty v. DOT No.2071 CD 2001 Trial Court/Agency Dkt. Number: No. 01-2916 Civil Term Trial Court/Agency Name~tmflJef1aneFS-6IInty:o@out:l:oL60mrn.Q\l:ELeas= Intermediate Appellate Court Number: Annexed hereto pursuant to Pennsylvania Rules of Appellate Procedure 2571 and 2572 is the entire record for the above matter. Contents of Original Record: Original Record Item Trial Court Record Video Tape Date of Remand of Record: November 26, 2001 Filed Date October 9, 2001 October 9, 2001 Description 1 1 Enclosed is an additional copy of the certificate. Please acknowledge receipt by signing, dating, and returning the enclosed c~... ~' fP... IhQP2tary ?ffice <;f t~e Chief Clerk's office. 4~~",..~~, /~ !!!i \I';~'" ._ Commonwealth Court Filing Office ~Y~a. K. ).j,k i~nature ~; .,a. j/. Le heY led Name '-/70'1).. 7. ,;?co; Date ii.li -I- .~ ~~ ~ II/7/CI. Chr'd- (Y"'A'~ ~ ~