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DEPARTMENT OF TRANSPORTATION
COMMONWEALTH OF PENNSYLVANIA,
Appellee
V.
NICHOLAS A. RAMESEY
Appellant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q9- YY39 `,,a T,e.-.`
AND NOW, thisd02?lay of a (c I , 199L, upon presentation and consideration of
the within Petition For Appeal From License Suspension, a hearing is set for the eday of
Ck-e-k&U, 199j, at //; dU o'clock y.m, in Courtroom No. -?Lof the Cumberland County
Courthouse.
FURTHERMORE, the motor vehicle license suspension in this case is stayed pending the
disposition of this appeal hearing.
By the
4-,
J.
cc: Gregory Barton Abeln, Esquire
Pennsylvania Department of Transportation, Office of Chief Counsel
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DEPARTMENT OF TRANSPORTATION
COMMONWEALTH OF
PENNSYLVANIA,
Appellee
V.
NICHOLAS A. RAMESEY
Appellant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
NO. 99-yy39CL?,e-e 7?
PETITION FOR APPEAL. OF LICENSE SUSPENSION
AND NOW, comes Appellant, Nicholas A. Ramesey, by and through his attorney,
Gregory Barton Abeln, Esquire, who files the following petition:
1. Nicholas A. Ramesey is an adult individual currently residing at 1159 Metzler Road,
Wells Tannery, Pennsylvania 16691.
2. On June 29, 1999, Pennsylvania Department of Transportation sent to Appellant a notice
of License Suspension, a copy of which is attached hereto and incorporated herein by reference
as Exhibit "A".
3. Appellant has a valid Pennsylvania operator's license in his possession.
4. The Appellant has appealed his conviction for underage drinking on for October 28,
1998, and is pending a hearing in the court of common pleas on the criminal summary appeal.
The Appellant believes that he will prevail in the criminal appeal because the evidence
was insufficient to convict him as a matter of law. See Commonwealth v. Williamson, 532 Pa.
568, 616 A. 2d 980 (1992).
6. If the criminal appeal is sustained, this civil appeal becomes moot.
WHEREFORE, Appellant requests this Honorable Court to set a time for a hearing on the
priority of Appellant's license suspension and immediately stay the imposition of his license
suspension pending the result of said hearing.
Date -720 CQ
Respectfully submitted,
ABELN LAW O FICE
?C
Gregory Barton Abeln, Esquire
ID # 35,960
Attomey for Appellant
37 East Pomfret St.
Carlisle, PA 17013
717/245-2851
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Harrisburg, PA 17123
JUNE 29, 1999
NICHOLAS A RAMESEY 991736114623105 001
1159 METZLER RD 06/22/1999
WELLS TANNERY PA 16691 24648949
08/04/1978
LICENSE IN BUREAU
Dear MR. RAMESEY:
As a result of your violation on 04/17/1999 of violating
Section 6308 (offenses related to alcohol), your driving
privilege is being SUSPENDED for a Period of 1 YEAR(S) as
mandated by section 1532D of the vehicle code.
The effective date of suspension is 06/29/1999, 12:01 a.m.
The above mentioned sanction is in addition to any
Previously issued sanction(s).
You have the right to appeal the Department's action to the
Court of Common Pleas (Civil Division) within 30 days of the
mail date (JUNE 29, 1999) of this notice. PLEASE NOTE that
this Civil Appeal is in addition to any appeal you have to
file from the criminal conviction.
THE APPEAL MUST BE SENT BY CERTIFIED MAIL T0:
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
OFFICE OF CHIEF COUNSEL
THIRD FLOOR, RIVERFRONT OFFICE CENTER
HARRISBURG, PA. 17104
Sincerely,
Rebecca L. Bickley, Director
Bureau of Driver Licensing
DEPARTMENT OF TRANSPORTATION
COMMONWEALTH OF
PENNSYLVANIA,
Appellee
V.
NICHOLAS A. RAMESEY
Appellant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
NO.
CERTIFI AT .OF RVI
I hereby certify that on this date a true and exact copy of the foregoing Petition for Appeal
from License Suspension was sent to the following address by United States Mail, certified,
return receipt requested:
DEPARTMENT OF TRANSPORTATION
Office of Chief Counsel
Third Floor, River Front Office Center
Harrisburg, PA 17104
Date
Respectfully submitted,
?BEL OFFICES
Johanna L. ck
Legal Assistant
37 East Pomfret St.
Carlisle, PA 17013
717/245-2851
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DEPARTMENT OF TRANSPORTATION IN THE COURT OF COMMON PLEAS
COMMONWEALTH OF OF CUMBERLAND COUNTY, PA
PENNSYLVANIA,
Appellee
V.
NO. 99-4439 Civil Term
NICHOLAS A. RAMESEY
Appellant
PRAECIPE TO WITHDRAW APPEAL
TO THE PROTHONOTARY, CUMBERLAND COUNTY COURTHOUSE.
Please mark this license suspension appeal as withdrawn.
Date l ? 1
Respectfully submitted,
ABELN LAW O IC
eiga
Gregory Barton Abeln, Esquire
ID #35,960
Attorney for Petitioner
37 East Pomfret Street
Carlisle, PA 17013-3313
717/245-2851
DEPARTMENT OF TRANSPORTATION
COMMONWEALTH OF
PENNSYLVANIA,
Appellee
V.
NICHOLAS A. RAMESEY
Appellant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
NO. 99-4439 Civil Term
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing PRAECIPE TO WITHDRAW
AN APPEAL by mailing a true and exact copy addressed to the following:
George H. Kabusk, Esquire
Office of Chief Counsel
Department of Transportation
River Front Office Center-3rd Floor
1101 South Front Street
Harrisburg, PA 17104-2516
Date Id
Respectfully submitted,
ABE, ,N L OFFICES
Johanna k
Legal Assistant
37 East Pomfret Street
Carlisle, PA 17013-3313
717/245-2851
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