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COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA DEPARTMENT
OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
V.
AVERY M.STEVENS,
Appellant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LICENSE SUSPENSION
APPEAL
ORDER OF COURT
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AND NOW, this day of Ir jg99upon consideration of
this APPEAL FROM SUSPENSION OF OPERATOR'S PRIVILEGE, it is hereby ordered that a
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Hearing on the matter shall be held on 7 day of -_
o'clock __Zhm. in Courtroom No. 3 of the Cumberland County Courthouse.
A supersedeas is granted pursuant to Vehicle Code Section 1550(b)(1) until such time that
this honorable court resolves this appeal.
BY THE COURT:
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COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA DEPARTMENT
OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
V.
AVERY M.STEVENS,
Appellant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 99- %3o.?- ew ! 7:&,-
LICENSE SUSPENSION
APPEAL
APPEAL FROM SUSPENSION OF OPERATOR'S PRIVILEGE
AND NOW comes the Appellant, Avery M. Stevens, by and through her attorney, Jeanne
B. Costopoulos, Esquire, and respectfully avers the following:
1. Appellant resides at 4 E. Louther Street, Carlisle, Cumberland County, Pennsylvania,
17013.
2. Appellant received a Notice dated November 15, 1999, that, as a result of her alleged
failure to attend a departmental hearing, a sanction of 60 days is being imposed as
mandated by Section 1538 of the Pennsylvania Vehicle, effective suspension date
December 20, 1999, at 12:01 a.m. A true and correct copy of the Notice is attached
as Exhibit "A".
3. The Appellant submits that she did not receive notice of a departmental hearing and
that she did not knowingly and/or intentionally fail to attend the departmental hearing.
WHEREFORE, your Appellant respectfully requests your Honorable Court to schedule an
evidentiary hearing on the matter.
Respectfully submitted,
Date:
v
1 54??
Jeanq B. Costopoulos, Esquire
COSTOPOULOS& WELCH
1400 North Second Street
Harrisburg, PA 17102
ID# 68735 Tel. (717) 221-0900
ATTORNEY FOR APPELLANT
COMMONWEALTH OF PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF
PENNSYLVANIA DEPARTMENT CUMBERLAND COUNTY, PENNSYLVANIA
OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee NO:
V.
LICENSE SUSPENSION
AVERY M. STEVENS, : APPEAL
Appellant
ATTORNEY VERIFICATION
Undersigned counsel, Jeann6 B. Costopoulos, Esquire, hereby verifies and states that:
1. She is the attorney for Avery M. Stevens, Appellant.
2. She is authorized to make this verification on her behalf;
3. The facts set forth in the foregoing Appeal are known to her and not necessarily to her
client;
4. The facts set forth in the foregoing Appeal are true and correct to the best of her
knowledge, information and belief.
5. She is aware that false statements herein are made subject to the penalties of 18 Pa. C.S.
4904, relating to unsworn falsification to authorities.
BY:
Date: r l
Jea a B. Costopoulos, Esquire
C STOPOULOS & WELCH
1400 North Second Street
Harrisburg, PA 17102
ID# 68735 Tel. (717) 221-0900
ATTORNEY FOR APPELLANT
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COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA DEPARTMENT
OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
V.
AVERY M.STEVENS,
Appellant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO:
LICENSE SUSPENSION
APPEAL
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing Appeal upon the person
and in the manner indicated below, which service satisfies the requirements of the Pennsylvania
Rules of Civil Procedure, by depositing a copy of the same in the United States Mail, at
Harrisburg, Pennsylvania, through first class certified mail, prepaid and addressed as follows:
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
OFFICE OF CHIEF COUNSEL
THIRD FLOOR, RIVERFRONT OFFICE CENTER
HARRISBURG, PA 17104
BY:
jen BCost opouloEsquire
POULOS & WELCH
1400 North Second Street
Harrisburg, PA 17102
ID# 68735 Tel. (717) 221-0900
ATTORNEY FOR APPELLANT
Date: 11136 QC
E X H I B I T A
COMMONWEALTH OF PENNSYLVANIA ----
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing ----
Harrisburg, PA 17123 ----
NOVEMBER 15, 1999 --
AVERI M STEVENS 993126506392359 002
4 E LOWTHER ST 11/08/1999
25339403
CARLISLE PA 17013 08/26/1981
Dear Motorist:
Due to your failure to attend a departmental hearing, a
sanction of 60 DAY(S) is imposed as mandated by Section 1538
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 ycu do not surrender your license,
Credit will not begin until all current driver's license
product(s), the DL16LC 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 12/20/1999, 12:01 a.m.
Please see the enclosed application for restoration fee in-
formation.
993126506392359
APPEAL
You have the right to appeal
Common Pleas (Civil Division)
date of this letter, NOVEMBER
Peal in the County Court, the
stamped certified copy of
time-stamped certified copy of
to:
this action to the Court of
within 30 days of the mail
15, 1999. If you file an ap-
court will give you a time-
the appeal. Send this
the appeal by certified mail
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
OFFICE OF CH.Tr.F COUMq F1.
THIRD FLOOR, RIVERFRONT OFFICE CENTER
'HARRISBURG, PA. 17104-2516
Sincerely,
SEND FEE/LICENSE/DL-16LC/TO:
Department of Transportation
Bureau of Driver Licensing
P.O. Box 68693
Harrisburg, PA 17106-8693
q4" ?, aid,
Rebecca L. Bickley, Director
Bureau of Driver Licensing
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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COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA DEPARTMENT
OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
V.
AVERY M. STEVENS,
Appellant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 99-7302 CIVIL
LICENSE SUSPENSION
APPEAL
PRAECIPE TO DISMISS
TO THE PROTHONOTARY:
Please mark the above referenced appeal withdrawn and dismissed and cancel the hearing
scheduled before the Honorable George E. Hoffer on Monday, February 7, 2000 at 11:00 a.m.
Respectfully submitted,
Date: ?J
Jeann6 . Costopoulos, Esquire
COS OPOULOS & WELCH
1400 North Second Street
Harrisburg, PA 17102
ID# 68735 Tel. (717) 221-0900
ATTORNEY FOR APPELLANT
COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA DEPARTMENT
OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
V.
AVERY M.STEVENS,
Appellant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 99-7302 CIVIL
LICENSE SUSPENSION
APPEAL
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing Praecipe upon the
person and in the manner indicated below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure, by depositing a copy of the same in the United States
Mail, at Harrisburg, Pennsylvania, through first class certified mail, prepaid and addressed as
follows:
GEORGE H. KABUSK, ASSISTANT COUNSEL
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
OFFICE OF CHIEF COUNSEL
VEHICLE & TRAFFIC LAW DIVISION
THIRD FLOOR, RIVERFRONT OFFICE CENTER
1101 SOUTH FRONT STREET
HARRISBURG, PA 17104-2516
Date:
BY:
Jeann'f B. Costopoulos, Esquire
CO OPOULOS & WELCH
1400 North Second Street
Harrisburg, PA 17102
ID# 68735 Tel. (717) 221-0900
ATTORNEY FOR APPELLANT