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Home My WebLink About03-4859ARTHUR T. LIEBRUM, Petitioner DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA LICENSE SUSPENSION APPEAL AND NOW, this day of ~ ~ k ~ ~ ,2003, comes Arthur T. Liebrum, through his attomeys, Mancke, Wagner & Spreha, who respectfully represent: 1. Your Petitioner is an adult individual residing at 309 Sand Bank Road, Mt. Holly Springs, Cumberland County, Pennsylvania. 2. Your Petitioner has received a notice of license suspension, a copy of which is attached hereto and made a part hereof as Exhibit 'A.' 3. Said Exhibit %" indicates your Petitioner is being suspended for a pedod of 6 months, effective September 24, 2003, as a result of an alleged conviction for violating §3736. 4. Your Petitioner believes said suspension is illegal, unjust and improper for reasons which include, but are not limited to, the following: (a)Your Petitioner was not guilty of reckless driving on July 2, 2O03; (b) Your Petitioner is filing an appeal from the alleged conviction, which appeal is being filed in the Court of Common Pleas of Dauphin County and which appeal will require a hearing; WHEREFORE, Your Petitioner prays Your Honorable Court to hold a headng to determine the legality and the propriety of the license suspension outlined in Exhibit A. Respectfully submitted, 2233 N. Front Street, Harrisburg, PA 17110 717-234-7051, Attorney for Petitioner CONMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: AUGUST 20, 2003 ARTHUR T LIEBRUM 309 SANDBANK ROAD MT HOLLY SPGS PA 17065 WID ~ 032259283727169 001 PROCESSING DATE 08/13/2003 DRIVER LICENSE ~ 22643157 DATE OF BIRTH 11/26/1971 Dear MR. LiEBRUM: This is an Of~iclal Notice o~ the Suspension of your Driving Privilege as authorized by Section i532B of the Pennsylvania Vehicle Code. As a result of your 08/11/2003 conviction of violating Section $756 of the Vehicle Code RECKLESS DRIVING on 07/07/2003: Your driving privilege is SUSPENDED ~or a period MONTH(S) e~fective 09/24/2003 at 12:01 a.m. Before PennDOT can restore your driving privilege, you must follow the instructions in this letter for COMPLYING WITH THIS SUSPENSION, PAYING THE RESTORATION FEE and PROVIDING PROOF OF INSURANCE. YOU should ~ollow ALL instructions very carefully. Even if you have served all the time on the suspension/revocation, we cannot restore your driving priviZege until all the requirements are satisfied. COMPLYING WITH THIS SUSPENSION You must return ali current Pennsylvania driver's licenses, learner's permits, temporary driverms lJcense~ (camepa cards) in Your possession on or before 09/2q/2003. You may surrender these items before, 09/2fi/2005, for earlier credit; however, you may not drive after these items are surrendered, YOU MAY NOT RETAZN YOUR DRZVERmS LZCENSE FOR ZDENTZFZCATZON PURPOSES. However, you may apply for and obtain a photo identification card at any Driver License Center for a cost of 10.00. You must present two (2) forms of proper identification (e.g. , birth certificate, valid U.S. passport, marriage certificate, etc.) in order to obtain your photo identification card. You will not receive credit toward servlng any until we recelve your license(e). Complete the steps to-acknowledge this suspension. ' ~ EXHIBIT suspension following 052259283727169 Return all current Pennsylvania driver's licenses, learner's permits and/or camera cards to PennDOT. If you do not have any of these item$~ send a sworn notarized letter stating you are aware of the suspension of your driving privilege. You must specify in your letter why You are unable to return your driver's license. Remember: You may not retain your driver's license for identification purposes. Please send these items to: Pennsylvania Department of Transportation Bureau of Driver Licensing P.O. Box 6869~ Harrisburg, PA 17106-8695 2. Upon receipt, review and acceptance of your Pennsylvania driver's license(s), learner's permit(s), and/or a sworn notarized letter, PennDOT will send you a receipt confirming the date that credit began. If you do not receive a receipt from us within $ weeks, please contact our office. Otherwise, you will not be given credit toward serving this suspension. PennDOT phone numbers are listed at the end of this letter. If you do not return all current driver license products, we must refer this matter to the Pennsylvania State Police for prosecution under SECTION 1571(a)(4) of the Pennsylvania Vehicle Code. PAYING THE RESTORATION FEE You must pay a restoration fee to PennDOT to be restored from a suspension/revocation of your driving privilege· To PaY your restoration fee, complete the following steps: 1. Return the enclosed Application for Restoration. The amount due is listed on the application. 2. Write your driver's license number (listed on the first page) on the check or money order to ensure proper credit. 3. Follow the payment and mailing instructions on the back of the application. 032259283727169 PROVIDING PROOF OF INSURANCE Within the last $0 days of your suspension/revocation, we will send you a letter asking that you provide proof of insurance at that time. This letter will list acceptabie documents and what will be needed if you do not own a vehicle registered in Pennsylvania. ZmpoPtant: Please make sure that PennDOT is notified if you move from your current address. You may notify PennDOT of your address change by calling any of the phone numbers listed at the end of this letter. APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 50 days of the mail date, AUGUST 20, 2005, of this letter. Zf you file an appeal ~n the County Court, the CouDt w~ll give you a t~me-stammed certif~ed copy of the appeal. In order for your appeal to be valid, you must 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 Remember~ this is an OFFZC~AL NOT~CE OF SUSPENSION. You must return all current Pennsylvania driver license products to PennDOT by Sincerely, Rebecca L. Bickley, Director Bureau of Driver Licensing SEND FEE/LICENSE/DL-I6LC/TO= Department of Transportation Bureau of Driver Licensing P.O. Box 68695 Harrisburg, PA 17106-8693 INFORMATION (7:00 IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE AM TO 9:00 PM) 1-800-932-4600 717-391-6190 1-800-228-0676 717-591-6191 VERIFICATION I hereby verif7 that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsification to authorities. Date ARTHUR T. LIEBRUM, Petitioner VS, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING Respondent IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ORDER AND NOW, this !/~g'day of ~ ,2003, upon consideration of the within Petition, it is hereby ordered and decreed that a headng be held on the ~ ~*~ day of'~]/~c~, 2003, at ~,~*-~ o'clock in Courtroom ;~ , Cumberland County Courthouse, Harrisburg, Pennsylvania. Notice of said headng shall be sent by certified mail to the Department of Transportation by Petitioner's attorney at least sixty days pdor to the date of the headng. By the Court: ' ,~/ ARTHUR T. LIEBRUM, PETITIONER : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, RESPONDENT : 03-4859 CIVIL TERM ORDER OF COURT day of November, 2003, upon agreement of the AND NOW, this _ <~ parties, the hearing scheduled this date is continued until 1:45 a.m., December 15, 2003. Edgar B ~- Edward F. Spreha, Jr., Esquire For Petitioner George Kabusk, Esquire For the Department of Transportation :sal ARTHUR T. LIEBRUM, : Petitioner : V. : DEPARTMENT OF TRANSPORTATION : BUREAU OF DRIVER LICENSING, : Respondent : IN RE: LICENSE IN THE COURT OF cOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4859 CIVIL TERM SUSPENSION APPEAL ORDER OF COURT AND NOW, this 15th day of December, 2003, it appearing to the Court that the underlying conviction has been amended from a violation of Section 3736 of the Vehicle Code to a violation of Section 3714 of the Vehicle Code. Consequently, this matter is remanded to the Bureau for appropriate action. Edward E. Guido, J. Edward F. Spreha, Jr., Esquire For the Petitioner George H. Kabusk, Esquire For the Respondent :lfh