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HomeMy WebLinkAbout01-06610 ...-...;.~ "-< '" "'"." ~ , , ~ liIlf~ '-.-x - j~jli'R' 0"; \i - STEPHEN E. SEYMORE, Appellant v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6610 Civil COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF TRANSPORTATION, : Suspension BUREAU OF DRIVER LICENSING, Appellee ORnER 01< C'OTJRT AND NOW, this ;'.3 ~y of ~llUltttY 2002, upon consideration of Appel!ant's request for a continuance, it is hereby Ordered that this case be continued until Q"j Ilif V ~ 2002 at e : 3d G~ in Courtroom s.... of the Cumberland County Courthouse, Carlisle, Pennsylvania. T, L opW> :l:.JJ o 1- .23 - 0 :z R~S ~tribution: L-I -PA Dept. of Transportation, Office of Chief Counse~ Third Floor, Riverfront Office Center, . Harrisburg, PA 17104 - Georg e. 1<0...'o\..l...5K l-/-PatrickF. Lauer, Jf., Esq., 2108 Market 81., Camp Hill, PA 17011 .'", C'V. -", ~ "0'- ,,',~'.~, '>Co,""V '~""'T 'M' ~~.'~.. r 'II'lmnltnnliLJ'n'sit1F~r;:r,~(J:'tt~~l;1Y' ,< OF FI_t1}{)t=flCF: ',-:~,!n"f'RY .'".r"./It\ 02 Jil';! 2'1 _ "."1.1" ....0,,; f'r'112: 59 CUMBEHU,JU COUfm PENNSYLVANIA 9 0/ - - "l'~~~i!r.,~~:;MWJ.~m>1,~'lE~~!'!1I~illi"f.!jJiB~~~~~~~1"*)~~<")""C':'"";""";~~"<,,,,:,,,,,: ---~-";'(!'~__"'~~i;ii,!j\itf,J~ft-I~-'#,'~;.;,-y-#,*~~~:~~~~.r,~~ - , ,""'~~" - ~=,. "0 ~W~~ ~ rl'"' , I;:;-~"Ylllil - 1 '.d61:" .u ~ ""'"~~litiiiMlJ~"","">$~W-" " , , STEPHEN E. SEYMORE, Appellant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-6610 Civil COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF TRANSPORTATION, : Suspension BUREAU OF DRIVER LICENSING, Appellee A,PP~T.T.4. NT'~ DRQJTF,ST ROD rnNTTNTT.4. N~ AND NOW comes the Appellant, Stephen E. Seymore, by and through his attorney, Patrick F. Lauer, Jr., Esquire, and respectfully avers the following: 1. The Defendant was convicted of3 731 (A)(I), driving under the influence on May 16, 2001. 2. The Defendant was found not guilty of3731(A)( 4). 3. Post-Trial Motions were filed and denied before the trial court. 4. A direct appeal was filed before the Superior Court on August 21, 2001. 5. Briefs have been filed by the Commonwealth and the Defense, and Oral Arguments are in the process of being scheduled before the Superior Court. 6. On October 31,2001, the Appellant was notified by the Commonwealth of Pennsylvania, Department of Transportation that his license were being suspended for one year as a result of his conviction ofDUI. 7. The Defendant submits that the license suspension hearing is premature since the Defendant's conviction is being appealed before the Superior Court. 8. Defense counsel has spoken with Attorney George Kabusk of the Pennsylvania Department of Transportation and he has no objection to the continuance of the license suspension appeal hearing scheduled for Friday, January 25, 2002 at 8:30 a.m. before the Honorable Judge Edward Guido until the case is deposed of by the Superior Court. """" ~,.. --_Ih"""'~"",'''''''~~'''''~., ''''~~'''''' ~'t - ~~" ,........" " I '" ~ ~ ~ ,',j. .:ooillliliiIt__*~~~I-"!Ik'~~%!C,~ WHEREFORE, defense counsel hereby respectfully requests that this hearing be rescheduled/continued for a later date after the Superior Court resolves these issues. Date: I /zz/O v I I ~'7ij Patrick F. Lauer, Jr., Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID#46430 Te1.(717)763-1800 ~ "--.ii\~_~,w,<t """,_,,~ " . '~ , ". " ,,', ~ ~ ~11!"'~~~tillr;JI :iitw..lll~ _h,~it:AA"jfJi~i~i;: STEPHEN E. SEYMORE, Appellant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 01-6610 Civil COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF TRANSPORTATION, : Suspension BUREAU OF DRIVER LICENSING, Appellee A TTORNIi'V VERTmCA nON I, Patrick F. Lauer, Jr., Esquire, undersigned counsel for Appellant, Stephen E. Seymore, hereby verifies and states that: 1. I am the attorney for Appellant, Stephen E. Seymore; 2. I am authorized to make this verification on my client's behalf; 3. The facts set forth in the foregoing Appeal are known to me and not necessarily to my client; 4. The filets set forth in the foregoing Appeal are true and correct to the best of my knowledge, information and belief, and 5. I am aware that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: ~ l{/T/vI PatrickF. Lauer, Jr., Esqwre 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID#46430 Te1.(717)763-1800 i ~- ~ - -- ""'-~>. '~1i>11"~'~' ,. STEPHEN E. SEYMORE, Appellant v. . ^'" - "';I~ji!w,":..k"''';>"'' ~r1lil~:i tl:1<,iiE"."t~*,J_'; '",,"""cdi ... .' : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6610 Civil COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF TRANSPORTATION, : Suspension BUREAU OF DRIVER LICENSING, Appellee rERTmTr A TE OR SERVTrE I hereby certifY that I am this day serving a copy of the foregoing APPELLANT'S REQUEST FOR CONTINUANCE upon opposing counsel by depositing a copy of the same in the United States Mail, Camp Hill, Pennsylvania, through first class mail, certified, return receipt requested, postage paid and addressed as follows: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, P A 17104 Date: , I Respectfully submitted, rJJFJv Patrick F. Lauer, Jr., Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 46430 Tel. (717) 763-1800 jjg S?J !^,'J";JUL1TI,1,,,~,~J J '. ~ ! "Li"~U,:,,,,jjhlf*,1');lh\\%~~'~~Ila~jtIWfuI0'iii-k1~'l~~'fu~:1' 't!!!!lil'ftll.lll'JIi l. .!ilIi!"~, () a 0 c N " <"" VO] ,- --, mji:'i ". fhpg -- Z::r" ~ ':7("-::: N -':--1m V3 p" 1'0 :::UO -<~:~ () i r::c~ -~.() -- -0 ~'r,-'-r; p,...., ::li'~ r, ::J z\,.} ~,1;,;.(') >2 ~ f...--::;;:,rn ~ Z .,- ';! :< ~ :xl -< _.~~~"._,;",~,"';, ",;""",',, ,'e,<", __ ~ " __ ,"_' " '. ,,'u" r, ~......,""""',o"..~"._~. "''fJ!iI,-II~~ ~_~~_4_ ~ 'JIil ~ ,t"~,,..i ~ '~< M......~"'" il!i:ilK'jllllti.lf. 11'*,j ~";,1'!!',3:~""-,, STEPHEN E. SEYMORE, Appellant P : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :: NO. 0l- ~Cel 0 cw.<:t COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF TRANSPORTATION, : Suspension BUREAU OF DRlVERUCENSING, Appellee AND NOW this / 1 ~ day 0;';::: ~F~~2001, upon consideration of the within APPEAL OF OPERATORS UCENSE S~}PENSIO~it is hereby ordered that a,hearing shaI1 be held regarding this matter at on the ;;.stn dayofllAAlUAteY ?olJ-J.. at8. 30et'..~. in Courtroom No...5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. A supersedeas is granted pursuant to Vehicle Code Section 155O(b )(1) until such time that this honorable court resolves this appeal. 1. b /A;tl de / D:' Distribution: -PA Dept. of Transportation, Office of Chief Counse~ Third Floor, Riverfront Office Center, . Harrisburg, P A 17104 n' (1'.~ . J -PatrickF.Lauer, Jr., Esq., 2108 Market St., CampHill,PA 17011 L- ~ -fYl' N. J 1:J9-{J r l"R 1\3 II it - ~.,,~ , ~ ~ "c,',,,'_ """" - ,'~' ',,.;_'C d'''~'''''I.o''",,''';~ ., ".,,~, "l,~,"r 1:::'< '-rm ~' r~ '~'7- .- '"'~"~lncr:m'rtfjr-1i1S~Jr~~~ '-', --, -'\ ::-"-J ():' ,,-C_" - _ L,r~!ffl~.l~~~,~;I'I#l:-",~,"'lf,'~!~:iff'llHP'-'W'<-""(l\Yiif,jijm!~1ll~@i1!llJ'R%'-!lF""11;"f~>','"'-:,"~;"[';c! ~'~","} . -' - ,<" ;,'P:-"'" - '''-''''''''~(lc:'''''f4r<orr,~W;~i'li~,,''H)j;lF;TW~-l ,',.,:(r"""";.;'11%''t'"$'~'l~Y!-f!Jlif~~ _-""~~ 'I.. > '~, 'I ,~"'...." -"Y, ~='t'~=- "I .....' ",,'~,," ~......." -~~""'~"d.Jj1~liiiL- I" '~h"".~?~__ STEPHENE. SEYMORE, Appellant v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :' NO. t3/- 10(016 COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF TRANSPORTATION, : Suspension BUREAU OF DRlVERUCENSING, Appellee A PPEAT. OR T .Tn.N~E ~TTSPEN~TON AND NOW comes the Appellant, Stephen E. Seymore, by and through his attorney, Patrick F. Lauer, Jr., Esquire, and respectfully avers the following: 1. Appellant resides at 908 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Appellant received a notice dated October 31,2001, that as a result of his conviction on May 16, 2001 of PemJSylvania Vehicle Code Section 3731, driving under the influence, his driving privileges were being suspended for a period of one year, effective suspension date December 5, 2001, at 12:01 a.m. A true and correct copy of the Notice is attached as Exhibit "A". 3. The Appellant filed an appeal with Superior Court on August 21, 200 1 and said case is docketed at 1366 MDA 2001. 4. The Appellant submits that there has not been a final disposition ofhis appeal and that he would be unduly prejudiced if the suspension were to be imposed at this time. 5. There was insufficient evidence to convict the Appellant. WHEREFORE, your Appellant respectfully requests your Honorable Court to schedule an ; evidentiary hearing on the matter and to reverse the Department's Order to suspend his Pennsylvania I' operating privileges. Respectfully submitted, , tM f twY PatrickF. Lauer, Jr., Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 10#46430 Tel. (717) 763-1800 Date: II J,;)+ / /)1 I I II - ~r."i " ~'.~~~', ,oil - ~ .-" 'iDY" .--' .: -- j -It,@'-'' -'<"" '"- ~~~,~ ." r~:\jt~&~"~~" STEPHEN E. SEYMORE, Appellant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :. NO. 0[- Ct>CaJ6 COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF 1RANSPORTATION, : Suspension BUREAU OF DRNERLICENSING, Appellee A 'J'TORNF,V VF.R1FJ('A nON I, Patrick F. Lauer, Jr., Esquire, undersigned counsel for Appellant, Stephen E. Seymore, hereby verifies and states that: 1. I am the attorney for Appellant, Stephen E. Seymore; 2. I am authorized to make this verification on my client's behalf; 3. The facts set forth in the foregoing Appeal are known to me and not necessarily to my client; 4. The facts set forth in the foregoing Appeal are true and correct to the best of my knowledge, information and belief; and 5. I am aware that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Respectfully submitted, ~ Date:~ PatrickF. Lauer, Jr., E uire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 10#46430 Tel. (717) 763-1800 II __ J," ,~ + ol '. r"lifr - '" -,' - o"l~[4f~~>' STEPHEN E. SEYMORE, Appellant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. :. NO. ()/- G,~J6 COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF TRANSPORTATION, : Suspension BUREAU OF DRIVERllCENSING, Appellee rERTJFJl'A n. OF SF,RVTrE I hereby certifY that I am this day serving a copy of the foregoing Appeal upon opposing counsel by depositing a copy of the same in the United States Mail, Camp Hill, Pennsylvania, through first class mail, certified, return receipt requested, postage paid and addressed as fonows: Pennsylvania Department ofTransportajion Office of ChiefCounse1 Third Floor, Riverfront Office Center Hanisburg, PA 17104 Respectfully submitted, Date: fr lz 11 () f f I 14L.t.Y 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 10#46430 Tel. (717) 763-1800 ,,.:"'~ -, -,,' - "' ;]. ~'~ --'- '"'~%;.jb~~ COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: OCTOBER 31, 2001 STEPHEN E SEYMORE 908 ALLENVIEW DRIVE MECHANICSBURG PA 17055 WID i 012976117507150 DOL PROCESSING DATE 10/24/2001 DRIVER LICENSE i 21684591 DATE OF BIRTH 09/20/1968 Dear MR. SEYMORE: Ihis is an Official Notice of the Suspe"sion of your Driving Privilege as authorized by Section 1532B of the PennsYlvania Vehicle Code. As a result of your 05/16/2001 conviction of violating Section 3731 of the Vehicle Code DRIVING UNDER INFLUENCE on 04/15/2000: . Your driving privilege is SUSPENDED fo~ a pe~iod of 1 VEAR(S) effective 12/05/2001 at 12:01 a.m. *********************************************************** I WARNING: If you are convicted of driving while your I I license is suspended/revoked the penalties will be a I I MINIMUM of 90 days imprisonment AND a 1,000 fine AND I I your driving privilege will be suspended/revoked for I I a MINIMUM 1 year period I ****~****************************************************** Before PennDOT can restore your driving privilege, you must follow the instructions in this letter for COMPLYING WITH THIS SUSPENSION, PAYING THE RESTORATION FEE and PROVIDING PROOF OF INSURANCE. You should follow ALL inst~uctions ve~Y carefu~lY. Even if you have se~ved all the time on the suspension/~evocation, we cannot ~esto~e your d~iving p~iv- ilege until all the ~equi~ements a~e satisfied. COMPLYING WITH THIS SUSPENSION You must return all current PennsYlvania driver's licenses, learner's permits, temporary driver's licenses (camera cards) in your possession on or before 12/05/2001. You may surrender these items before, 12/05/2001, for earlier credit; however, you may not drive after these items are surrendered. YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR IDENTIFICATION PURPOSES. However, you may apply for and obtain a photo identification card at any Driver License Center for a cost ~'~ I , '. ,'","",J, 012976117507150 of 9.00. You must present two (2) forms of proper iden- tification (e.g., birth certificate, valid U.S. passport, marriage certificate, etc.) in order to obtain Your photo identification card. You will not ~eceive c~edit towa~d se~ving any suspension until we ~eceive you!' license(s). Complete the following steps to acknowledge this suspension. 1. Return all current PennsYlvania driver's licenses, learner's permits and/or C;3mera cards to PennDOT. If you do not have any of these items, send a sworn nota- rized letter stating YOU are aware of the suspension of your driving privilege. You must specifY in your letter whY YOU are unable to return your driver's license. Remember: You may not retain Your driver's license for identification purposes. Please send these items to: Pennsylvania Department of Transportation Bureau of Driver Licensing P.O. Box 68693 Harrisburg, PA 17106-8693 2. Upon receipt, review and acceptance of your PennsYlvania driver's licensees), learner's permit(s), and/or a sworn notarized letter, PennOOT will send yoU a receipt con- firming the date that credit began. If you do not re- ceive a receipt from us within 3 weeks, please contact our office. Otherwise, YOU will not be given credit toward serving this suspension. PennDOT phone numbers are listed at the end of this letter. 3. If YOU do not return all current driver license pro- ducts, we must refer this matter to the Pennsylvania State Police for prosecution under SECTIDN 1571 (a) (4) of the Pennsylvania Vehicle Code. PRISON RELEASE REOUIREMENT (ACTI51) The Court of CUMBERLAND CTY, Court Number 002555, Court Term 2000 has sentenced you to serve a prison term for this vi- olation. Pursuant to Section 1541(13.1) of the Vehicle Code, yoU will not receive credit for this suspension/revocation or any additional suspension/revocation until you complete your prison term and you have complied with the requirements listed in this letter. The Court must certifY your com- pletion to PennDOT. You may wish to contact your probation officer and/or the Court after your release to make sure that PennDOT is properly notified. ,,:,, w;',,,,,,,,,.,..:,,,"";''':C,,",~;''-:;;',''-'+i,,,,:it~">^'~,~ .lL:;:" ~l , >.~ '_ _ l j},!j;W_" ",.- .~ "^' .....<I!iiIr~k' ~~ '" " ' ,",'",- ~ _,,;J_L,_ 4~>:_' . ' 012976117507150 PAYING THE RESTORATION FEE You must pay a restoration fee to PennDOT to be restored from a suspension/revocation of your driving privilege. To pay your restoration fee, complete the following steps: 1. Return the enclosed Application for Restoration. The amount due is listed on the application. 2. Write your driver's license number (listed on the first page) on the check or money order to ensure proper credi t. 3. Follow the payment and mailing instructions on the back of the application. IGNITION INTERLOCK Before your driving privilege can be restored you are re- quired by law to have all vehicle(s) owned by you to be equipped with an Ignition Interlock System. This is a result of your conviction for Driving Under the Influence. If you fail to comply with this requirement, your driving privilege will remain suspended for an additional year. You will re- ceive more information regarding this requirement approxi- mately 50 days before your eligibility date. PROVIDING PROOF OF INSURANCE Within the last 30 days of your suspension/revocation, we will send yOU a letter asking that you provide proof of in- surance at that time. This letter will list acceptable documents and what will be needed if YOU do not own a vehicle registered in Pennsylvania. Impo~tant: Please make sure that PennDOT move from your current address. You may your address change by calling any of listed at the end of this letter. is notified if you notify PennDOT of the phone numbers '- , "[^IU' ~t'1ii ,- ,L . " , ~ '=' JiJilw'ii:i!iiW,: , ' 012976117507150 APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date, OCTOBER 31, 2001, of this letter. IT YOU Tile an ap- peal in the County Cou~t, the Cou~t will give yOU a time- stamped ce~tiTied COpy oT the appeal. In order for your appeal to be valid, yOU must send this time-stamped certi- fied 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 Remember, this is an OFFICIAL NOTICE OF SUSPENSION. You must return all current Pennsylvania driver license products to PennDOT by 12/05/2001. Sincerely, ~~.~ Rebecca L. Bickley, Director Bureau of Driver Licensing IN STATE OUT-OF-STATE WEB SITE ADDRESS INFORMATION 7:00 a.m. to 9:00 p.m. 1-800-932-4600 TDD IN STATE 717-391-6190 TDD OUT-OF-STATE www.dot.state.pa.us 1-800-228-0676 717-391-6191 .1fJ\:N;~ ':" -:.'; "-"'," ~.d:iLiJlliJ!A;.f'l~M.;f:!:&!,~""d;i;'ilil'';'~Jjb,'1ci.~H!!~~~!'d'' I~llfl~'"'..;'ii....b~~ ~~ - ..--. -0 -ID -D D ~ -0 G .--! ~1mtL ' _ ~ "",-".'M'V~~_'=~L ~~ p) ~ E2- $ ) ~ ~ :J ~, ~, ,,~ ....:-.. '~,- C) c::' C :2'" ~ ""t7 6; ~''- ~:',) IT, f'l -.:.:: -~ --"', ~- ;::;;, !';.) ;:~ (j) >; G\ -<L c::C) " i> r-. ~''',~ Z';-.../ ~.,,~ -.u LJ >c:.: '-' z .,-..,.) > ~ :0 (T'. -< , , I I: " [:- f,' f I ! 1':: i:', ~!ii, .'1 'i ! ~. _"~",~,,,_ ~ ,~~ ,,~.,.,,~,,~,~~ ",,~'~',<_ ," "'~c' "'k,~,.".!J!.)'J.: .. L'- ~W~"""'~ STEPHEN E. SEYMORE, Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 01-6610 CIVIL TERM COMMONWEALTH OF PENNSYLVANIA,: DEPARTMENT OF TRANSPORTATION, : BUREAU OF DRIVER LICENSING, Appellee LICENSE SUSPENSION APPEAL IN RE: CONTINUANCE ORDER OF COURT AND NOW, this 3rd day of May, 2002, at the request of Appellant, and without objection by the Commonwealth, this matter is continued to Monday, September, 23, 2002, at 8:30 a.m. Guido, J. 1}eorge Kabusk, Esquire Attorney for Appellee /&~~ )patrick F. Lauer, Jr., Esquire Attorney for Appellant srs A.;i ~~3 ,--- ^ '... ," "'J_'_".~< =, '-""'-'<" 0-'" _~IT~,.... "h _ ~v_ '-_~~'~ r" ~. r '1 , \"17 r":'l,,':,'i -0 oJ." ,''',\ 'i,A:"> " " t.i\Jv..'.."" ,~- ,~""-",-""-,,,,-;,>,,,;,'--""~-"'r!:;~'.c' ",- ~",>i .. " ,,"'C"_ '" .' '" '~i .....- Jil'in~uni>-Ht"lf"'I~MS7"'''''U;';''~C~",).'i;''"~kliltM~~:i'ffi~"''i$j-:'':'!I,~i~!~"iitf,1j~~iiii!!~iIJl", ~'ii!~lt:"'" ~" - ,",".'. "q~,;'";",',, ","',"" Gl);<.ti~rn",'-;', STEPHEN E. SEYMORE, Appellant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V AN1A v. : NO. 01-6610 COMMONWEALTH OF PENNSYLVANIA,: Appeal of Operators License DEPARTMENT OF TRANSPORTATION, : Suspension BUREAU OF DRIVER LICENSING, Appellee PRA EC'TPE TO WITHnRA W A PPEA T. OF OPERA TORS T .Tl"'ENSE STTSPIi'.NSTON TO THE PROTHONOTARY: Kindly withdraw the license appeal in the above captioned case. The Parties agree that Appellant's license appeal is moot. Respectfully submitted: Date: If (t/cZ- ;J~ ~( 1atrickF. Lauer, Jr., Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 10#46430 Tel. (717) 763-1800 Distribution: -PADept. of Transportation, Office ofChiefCounse~ Attn: George H. Kabusk, Esq., Third Floor, Riverfront Office Center, Harrisburg, PA 17104 -PatrickF. Lauer, Jr., Esq., 2108 Market St., Camp Hill, PA 17011 -Stephen E. Seymore, PO Box 575, Mechanicsburg, P A 17055 -Judge Edward Guido, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013 .,CJ-',';'C!- ~~~.iili!t'tw-,].,t~1.~~~~:M>i~6it:Ui":-"':~'jk'#~;i1';ii.i~~~'~"<-""'" . ~'''..' ,A_.."", "_~" _ ',", ,_ ~,< >'.';" ;__,C "OO~::aifr'~"'''''---'~'' .';', " 'n~,,__ ~~" --'~=lm -""" "n" ,,'.'. "'" CJ <:::> 0 C r,) ~~ -n U') I'" -U " zf"- F Ii' (f) r"> C~ Q ~e~-, v ~~) 5> !- ~ C~ ::-~ -, t"i C' -,,> " is) ?~i ~~5 C~~' ,,- ,~;;~ _.- (.,) S:J -< iP ~