HomeMy WebLinkAbout01-6032COMMONWEALTH OF PENNSYLVANiA,.
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
APPELLEE
JENNIFER L. SIROIS
APPELLANT
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND
COUNTY,
PENNSYLVANiA
NO. ~CML
ORDER
AND NOW, this __ day of October, 2001, upon consideration of the
Appdlant's Notice of Appeal, a heating is set for the ~ day of_~ ~ 200.__,
at ~ _ AM/PM, in Courtroom # _ , Cumberland County Courthouse.
Jo
John A. Aborn, Esquire
8 South Hanover Street
Suite 204
Carlisle, PA 17013
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING
APPELLEE
JENNIFER L. SIROIS
APP~T
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND:
COUNTY,
PENNSYLVANIA
No. ~ CML
NOTICE OF APPEAL OF LICENSE SUSPENSION
Appellant, Jennifer L. Sirois, is an adult individual who currently resides at 20
Stephen Rd., Apamnent B7, Camp Hill, Cumberland County, Pennsylvania.
Appellee, Commonwealth of Pennsylvania, Department of Transportation,
Bureau of Drivers' Licensing, is a Commonwealth agency with offices in
Harrisburg, Dauphin County Pennsylvania.
Your appellant was dried on September 26, 2001, in Wormleysburg,
Cumberland County, for allegedly committing a violation of the Vehicle Code.
On October 4, 2001, Appellant was convicted of Exceeding the Maximum
Speed Limit, pursuant to 75 PaC.S.A. ~ 3362(a)(1).
By letter dated October 12, 2001, Appellee notified Appellant that her
operating privileges would be suspended for a period of one year beginning on
November 16, 2001. A true and correct copy is attached as Exhibit A.
Appellant has appealed her October 4, 2001, conviction to the Court of
Common Pleas of Cumberland County. Said appeal is docketed at 01-2183
Criminal. A certified copy of the Notice of Appeal of the underlying speeding
conviction is attached as Exhibit B
WHEREFORE, your appellant respectfully requests this Honorable Court to
set a hearing and deny the Commonwealth's request that his license be suspended.
Date: October,S_, 2001
Respectfully submitted,
Attorney I.D.//77961
8 South Hanover St.
Suite 204
Carlisle, PA 17013
(717) 249-0900
CERTIFICATE OF SERVICe.
I, John A. Abom, hereby certify that I served a copy of the within Notice of
Appeal upon the Appellee, by mailing a copy of said Notice by certified mail
addressed as follows:
Pennsylvania Depaxi~iient of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516
Dated:
Exhibit B
COHNONNEALTH OF PENNSYLVANIA
DEPARTNENT OF TRANSPORTATION
Bureau of Driver Licensing
Harrisburg, PA 17125
OCTOBER 12, 2001
JENNIFER L SIROIS
20 STEPHEN RD
APT B7
CAMP HILL PA 17011
012789283327034
10/05/2001
24226000
06/01/1977
001
Dear Hotorist:
As a result of your conviction of violating section 5562
of the Vehicle Code EXCEEDING HAXINUH SPEED on 10/0~/2001,
q points have been assigned to your record.
Your total point accumulation is 15 points.
Since your point record shows an accumulation of
points, a sanction of $65 DAY(S) is hereby imposed as man-
dated by Section 1559 of the Vehicle Code.
In order to comply with this sanction you are required to
return any current driver's license~ learner's permit and/or
temporary driver's license (camera card) in your possession
no later than the effective date listed. If you cannot
comply with the requirements stated above, you are required
to submit a DL16LC Form or a sworn affidavit stating that
you are aware of the sanction against your driving privi-
lege. Failure to comply with this notice shall result in
this Bureau referring this matter to the Pennsylvania State
Police for prosecution under SECTION 1571(a)(4) of the Ve-
hicle Code.
Although the law mandates that your driving privilege is
under suspension even if you do not surrender your license,
Credit will not begin until all current driver's license
product(s), the DLi&LC Form, or a letter acknowledging your
sanction is received in this Bureau.
WHEN THE DEPARTNENT RECEIVES YOUR LICENSE OR ACKNOWLEDGE-
HENT, WE WILL SEND YOU A RECEIPT. IF YOU DO NOT RECEIVE THIS
RECEIPT WITHIN 15 DAYS CONTACT THE DEPARTHENT IHHEDIATELY.
OTHERWISE, YOU WILL NOT BE GIVEN CREDIT TOWARD SERVING THIS
SANCTION.
The e~ecttve date of suspension ts 11/1&/2001, 12:01 a.m.
Please See the
formation, enclosed application for restoration fee
You Will be notified of any out'standing
qUirements approximately $0 days before the
of the restoration of YOur driving privil:est°rati°n re-
follow those inStructio eligibility date
reD. er to have
You have the ri~h~ to aPPeal this action
Common Pleas (C~v~l D' '
,.OCTOOE, -ithin 30 the Court of
appeal to be u=;;. uu¥ o? the appeal .~-ye you m ttme-
~ou must send this ~ rot Your
---~u, .... an Orde-
fled copy of the aPPeal by certified mail to: .
time-stamPed certi~
PennsYlvania Department of TransPortation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 1710~-2516
SEND FEE/LZCENSE/DL-16LC/To.
Department of Transportatio~
BUreau of DriVer Licensing
P.O. Box 68693
Harrisburg, PA 1720&-8693
SinCerely~
Rebecca L. Bickley, Director
BUreau of Driver Licensing
TNFOF~HA TZON
IN STATE
OUT'OF-STATE
TDD IN STATE
TDD OUT-OF-STATE
AH TO 9~00
1'800-932-~600
717-$91-6190
1-800-228-0676
717-391-6291
Exhibit A
IN THE COURT OF COMMON PLEAs, ,.
Sum, nan/Cri.ninal Conviction
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,'~ ............... ~ ............ ~.~ ,¢oT'8:~ ,,y oo~., .o IL]..~.-~ .~ _
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........... ~'?--..~..~ ~.e:.... ........ O,,o.,,,o ........................ /
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............................... . .............. ~......~....
:"'""~.~t..'z/..~/. ......................... '~'-.<.~ ...................
[ "" ])~ ................. O~lense~.~) of Which col1¥ croci
............................................................................................................. . ..........
~ ............................... ' ............... ~'""'"'"<'"'~'~ ~:'2~) '"
......................... ~(........~~- ..................
Name and address of issuing author ly'
...... ~.~...~.....~ ~- _
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NOTICE TO DEFENDANT:
If YOur appeal is from a motor vehicle conviction Other than P~rking, have the Clerk of COurts c~jfy th)S ~Opy and
flail to the following address: ~:~
~e_nn. Dept. of Tm '
PO Box 600:l7 mn,,~l:x~t'~l~ll .~
Harrisburg, PA, 17106 '! ~g ~' ~
~ereby certify that an aPPeal has been filed in the above Captioned matter.
A TRUE COPy FR
In Testimony w~_ . OM RECORD
J 'ure°t, lhereunlosetmyhand
an~l the seal of said Oourt at Carlisle
T~"-J~d ~o, FFJ~;L'~.a:'s
CL~K OF~
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING
APPELLEE
Vo
JENNIFER L. SIROIS
APPELLANT
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND:
COUNTY,
PENNSYLVANIA
No. 01-6032 CML
Praecipie to Discontinue
An now comes the Appellant, by and through her attorneys, Abom&
Kutulakis, LLP, who respectfully requests that the above-captioned action be
discontinued.
Date: February 4, 2002
Respectfully submitted,
~A ~o° ~ :~ ~.°~ .~ e¢9P6Plellant
8 South Hanover St.
Suite 204
Carlisle, PA 17013
(717) 249-0900
CERTIFICATE OF SERVICI~.
I, John A. Aborn, hereby certi~ a copy of the within Notice of
Appeal upon the Appellee, by/~Z.g a copy of sa~d Notice by certified marl
addressed as follows: /
Pennsy~aMa Department of Transportation
_Of_tic_ge/ of Chief Counsel
Thi/e'd Floor, Riverfront Office Center
}~sburg, PA 17104-2S16
Dated: ~/tJ/O ~.._