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CHARLES A. KAGENDA,
Petitioner
V.
COP, PENNDOT,
BUREAU OF MOTOR VEHICLES,
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO,
?Ig• 5148 ?c?i¢ Tt?
CIVIL ACTION
?nV? O Ft, AND NOW, this (/? day of 1999, upon consideration of
Petitioner's Petition, it is hereby /ORDERED and DECREED that a hearing in this matter is
scheduled for ?7`e? 6W 9q at 3,30 A. M(& n Court Room No. 3
of tl?z Cumberland County Courthouse.
BY THE COURT:
Judge
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CHARLES A. KAGENDA,
Petitioner
V.
COP, PENNDOT,
BUREAU OF MOTOR VEHICLES,
Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q 9- s/.2 P eu,, Tcu._
CIVIL ACTION
APPEAL FROM SUSPENSION OF DRIVING PRIVILEGES
AND NOW, comes the Petitioner, Charles A. Kagenda, by and through his attorney, Gary
L. Kelley, and respectfully represents as follows:
1. Petitioner is Charles A. Kagenda who resides at 38 Stephen Road, No. 3E, Camp
Hill, Pennsylvania 17011.
2. Respondent is COP, PENNDOT, Bureau of Motor Vehicles.
3. Petitioner is the owner of an automobile insured by Flagship City Insurance
Company.
4. Petitioner maintained his policy in effect with said company and continued to make
payments to maintain her coverage on the subject vehicle.
5. Petitioner has been cited for, inter alia, Operating a Vehicle Without the Required
Financial Responsibility.
6. Petitioner never received any prior notices that his coverage had lapsed.
7. Petitioner continued making payments to the subject insurance company for
coverage on the vehicle and was never informed by the company that it had not received his
payments or that his coverage had lapsed.
8. Petitioner made a good faith effort to maintain coverage on his vehicle and any
lapse in coverage was not the fault of Petitioner.
9. Petitioner was subsequently notified that his driving privileges were going to be
revoked for the above offense.
10. Petitioner presently has an appeal pending on the aforementioned offense in the
Court of Common Pleas of Dauphin County.
WHEREFORE, the Petitioner respectfully requests that this Honorable Court schedule this
matter for a hearing.
Respectfully submitted,
G L. Kelley
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A .I No. 46801
132-134 Walnut Street
Harrisburg, PA 17101
(717) 238-1484
Attorney for Petitioner
CHARLES A. KAGENDA,
Petitioner
V.
COP, PENNDOT,
BUREAU OF MOTOR VEHICLES
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION
CERTIFICATE OF SERVICE
I, GARY L. KELLEY, Esquire, attorney for Petitioner in the above-captioned matter, do
hereby certify that I served a true and correct copy of Petitioner's Appeal From Suspension of
Driving Privileges on Respondent by depositing same in the U.S. Mail, first class, postage
prepaid, on the 23rd day of August, 1999, addressed as follows:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
harrisburg, PA 17104-2516
By: .
GARY WELLEY, Es ire
I.D. #
132-134 Walnut Street
Harrisburg, PA 17101
(717) 238-1484
Attorney for Petitioner
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CHARLES A. KAGENDA IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-5128 CIVIL TERM
BUREAU OF DRIVER LICENSING
COMMONWEALTH OF PENNA.
DEPARTMENT OF TRANSPORTATION
ORDER OF COURT
AND NOW, October 6, 1999, upon oral request by the petitioner
and without objection by George H. Kabusk, Esquire, of the Department of
Transportation, that this matter be continued , this matter is hereby continued
until February 7, 2000, at 9:30 a.m.
George H. Kabusk, Esquire
For PennDOT
Gary L. Kelley, Esquire
For the Petitioner
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CHARLES A. KAGENDA,
Petitioner
V.
BUREAU OF DRIVER LICENSING,
COMM. OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5128 CIVIL TERM
CIVIL ACTION
PRAECIPE FOR WITHDRAWAL OF APPEAL
TO THE PROTHONOTARY:
Please withdraw Petitioner's Appeal in the above matter.
Respectfully submitted,
1 -13 34 'Wfinut PA Street
Harr PA 17101
(717) 238-1484
Attorney for Petitioner
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