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CATHERINE A. VOPiCHAKioner
VS.
COMMONWEALTH OF PENNSYLVANIA, :
DEPARTMENT OF TRANSPORTATION .
Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99- Gsea 12;v4(.
AND NOW, this day of October, 1999, upon
consideration of the within petition, it is hereby ordered and
decreed that a hearing be held on the '? t/7 day of c '
n_ o'clock in Courtroom -V- -, Cumberland county
son at ?-
fy:ps},
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.
BY THE COURT,
rL ..t'I J.
P,
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CATHERINE A. VORCHAK,
Petitioner
VS.
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION
Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY?, PENNSYLVANIA
NO. 99. GS"G L / 'cut:P r[c•
AND NOW, this day of October, 1999, comes Catherine A.
Vorchak, by her attorney, Anthony L. DeLuca, Esquire who
respectfully represents:
1.
Your Petitioner, Catherine A. 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
Petitioner's vehicle;
C. The flashing red signal lights were not actuated; and
D. The color of Petitioners vehicle was not included in the
report of the school bus operator.
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,
GZ SLID ??d..ra ? .!!y/K?CLw? c?.
Anthony L. eLUca, Esquire
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
(717) 258-6844
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 18 Pa.
C.S. Section 4904, relating to unsworn falsification to
authorities.
Dated:
Catherine A. Vorchak
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing -"'
Harrisburg, PA 17123
SEPTEMBER 30, 1999
CATHERINE A VORCHAK 992669283109158 001
1558 BOILING SPRINGS RD 09/23/1999
24568143
BOILING SPGS PA 17007 01/28/1946
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 wi%h 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 OL16LC Ferm, 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"
992669283109158
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:
Department of Transportation
Bureau of Driver Licensing
P.O. Box 68693
Harrisburg, PA 17106-8693
INFORMATION (7:00
IN STATE
OUT-OF-STATE
TOO IN STATE
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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CATHERINE A. VORCHAK,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 99-6562 Civil Tenn
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF TRANSPORATION
Defendant
Sir:
Kindly discontinue the above captioned matter.
TO: Curtis R. Long, Prothonotary
By: / . +.
Anthony . eLuca
113 Front Street
P.O. Box 358
Boiling Springs, PA 17007
(717)258-6844
DATE: March 28, 2000
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