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JOHN ALAN VORCHAK,
Petitioner
VS.
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION
Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9 1 (o S(o l "l 1 v4-? 1n??
AND NOW, this a '7 t1 day of October, 1999, upon
consideration of the within Petition, it is hereby ordered and
decreed that a hearing be held on the day of /fill &,
) 3 C, at ` 0 ooclock in Courtroom , Cumberland County
Courthouse, Carlisle, Pennsylvania.
Notice of said hearing shall be sent by certified mail to the
Department of Transportation by Petitioner's attorney at least
sixty days prior to the date of the hearing.
FILED-orpCE
OF TF; cn T")%13TARY
99 OCT 29 Pf' 2:00
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JOHN ALAN VORCHAK,
Petitioner
VS.
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION
Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99, 6 561, Cava -74v-1
AND NOW, this day of October, 1999, comes John Alan
Vorchak, by his attorney, Anthony L. DeLuca, Esquire who
respectfully represents:
1.
Your Petitioner, John Alan Vorchak is an adult individual
residing at 1558 Boiling Springs Road, Boiling Springs, Cumberland
County, Pennsylvania.
2.
Your Petitioner is a licensed automobile operator in the
Commonwealth of Pennsylvania.
3.
Your Petitioner has received notice of a license suspension,
a copy of which is attached hereto and made a part hereof as
Exhibit "A".
4.
Your Petitioner believes, and therefore avers, that said
license suspension is illegal, improper and unjust for reasons
which include, but are not limited to, the following:
A. The school bus was not stopped in the intersection;
B. The school bus was more than ten (10) feet away from
Petitionerls vehicle;
C. The flashing red signal lights were not actuated; and
D. The color of Petitioner's vehicle was not included in the
report of the school bus operator.
I WHEREFORE, Your Petitioner respectfully requests that this
Honorable court hold a hearing to determine the validity of the
suspension outlined in Exhibit °A°.
Respectfully Submitted,
Anthon
y sLuca, Esqu re
113 FrontStreet
P.O. Box 358
Boiling Springs, PA 17007
(717) 258-6844
M
VERIFICATION
I hereby verify that the facts and information set forth in
the foregoing Petition are true and correct to the best of my
knowledge, information, and belief. I understand that any false
statements contained herein are subject to the penalties of IS Pa.
C.S. Section 4904, relating to unsworn falsification to
authorities.
Dated: ?g? 4,c•l9
,
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COMMONWEALTH OF PENNSYLVANIA --'-
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing -'--
Harrisburg, PA 17123 ----
SEPTEMBER 30, 1999 ----
JOHN ALAN VORCHAK 992669283109160 001
1558 BOILING SPRINGS RD 09/23/1999
13943342
BOILING SPGS PA 17007 11/30/1945
Dear Motorists
As a result of your conviction on 09/03/1999 of violat-
ing section 3345A of the Vehicle Code PASSING A SCHOOL BUS
on 06/03/1999, 5 points have been assigned to your record.
As mandated under Section 1535 of the Vehicle Code, a
60 DAY(S) suspension is hereby imposed.
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 OL16LC 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(x)(4) of the Ve-
hicle Code.
Although the law mondatos 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 BL16LC Form, or a letter acknowledging your
sanction is received in this 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 11/04/1999, 12:01 a.m.
Please see the enclosed application for restoration fee in-
formation.
EXHIBIT "A"
992669283109160
You will be notified of any outstanding restoration re-
quirements approximately 30 days before the eligibility date
of the restoration of your driving privilege. You must
follow those instructions very carefully in order to have
your driving privilege restored.
APPEAL
You have the right to appeal this action to the Court of
Common Pleas (Civil Division) within 30 days of the mail
date of this letter, SEPTEMBER 30, 1999. If you file an
appeal in the county Court, the Court will give you a time-
stamped certified copy of the appeal. 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/T0: INFORMATION (7:00
Department of Transportation IN STATE
Bureau of Driver Licensing OUT-OF-STATE
P.D. Box 68693 TOO IN STATE
Harrisburg, PA 17106-8693 TOO OUT-OF-STATE
AM TO 9:00 PM)
1-800-932-4600
717-391-6190
1-800-228-0676
717-391-6191
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JOHN ALAN VORCHAK, : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. : CIVIL ACTION -LAW
NO. 99-6561 Civil Tenn
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF TRANSPORATION
Defendant
Sir:
Kindly discontinue the above captioned matter.
By: -
r rony . e Ica
113 Front Str t
P.O. Box 358
Boiling Springs, PA 17007
(717) 258-6844
TO: Curtis R. Long, Prothonotary
DATE: March 28, 2000
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