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Home My WebLink About07-5741ALEX JUSTIN BOBB, : IN THE COURT OF COMMON PLEAS OF Appellant CUMBERLAND COUNTY, PENNSYLVANIA V. NO.: 0 y- ? y I T?-.-- COMMONWEALTH OF PENNSYLVANIA,: PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, LICENSE SUSPENSION APPEAL BUREAU OF DRIVER LICENSING, Appellee APPEAL OF OPERATOR'S 1.1CF,NSF, SUSPENSION AND NOW, comes the Appellant, Alex Justin Bobb, by and through his attorneys, the Law Offices of Patrick F. Lauer, Jr., LLC, respectfully avers the following: 1. Appellant resides at 55 Longview Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The underlying violation that is alleged for this suspension occurred in Cumberland County. 3. Appellant received a Notice dated September 24, 2007, that as a result of his alleged violation of Pennsylvania Crimes Code Section 6308, offenses related to alcohol, his driving privilege was being suspended for a period of one year, effective date of suspension October 29, 2007, at 12:01 a.m. A true and correct copy of the Notice is attached as Exhibit "A". 4. Appellant filed a timely Summary Criminal Conviction Appeal before your Honorable Court regarding his conviction on September 10, 2007 and is awaiting a hearing date. 5. Appellant submits that there has not been a final disposition of his appeal and that he would be unduly prejudiced if the suspension were to be imposed at this time. 6. There was insufficient evidence to convict the Appellant. 7. Appellant denies he committed the offense. WHEREFORE, your Appellant respectfully requests your Honorable Court to schedule an evidentiary hearing on the matter and to reverse the Department's Order to suspend his Pennsylvania operating privileges. Date: -27,200-1 Respectfully submitted, Marlin _,,4I ey, Esquire Law Office of Patrick F. Lauer, Jr., LLC 2108 Mark Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 ALEX JUSTIN BOBB, : IN THE COURT OF COMMON PLEAS OF Appellant CUMBERLAND COUNTY, PENNSYLVANIA V. NO.. COMMONWEALTH OF PENNSYLVANIA,: PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, LICENSE SUSPENSION APPEAL BUREAU OF DRIVER LICENSING, Appellee The undersigned, Marlin L. Markley, Esquire, hereby verifies and states that: 1. He is the attorney for the Appellant, Alex Justin Bobb; 2. He is authorized to make this verification on his behalf; 3. The facts set forth in the foregoing Appeal are known to him and not necessarily to his client; 4. The facts set forth in the foregoing Appeal are true and correct to the best of his knowledge, information and belief, 5. He is aware that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unworn falsification to authorities. Respectfully submitted, Date: Z / ? Z ooh Marlin 'r Ma/(ley, Esquire Law Offices f Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 ?()", K, ?) 1- 4 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: SEPTEMBER 24, 2007 ALEX JUSTIN BOBB WID # 072606116487824 001 55 LONGVIEW DRIVE PROCESSING DATE 09/17/2007 DRIVER LICENSE # 28182354 MECHANICSBURG PA 17050 DATE OF BIRTH 05/24/1988 Dear MR. BOBB: As a result of your violation on 09/08/2007 of violating Section 6308 (offenses related to alcohol), your driving privilege is being SUSPENDED for a period of 1 YEAR(S) as mandated by section 1532D of the vehicle code. The effective date of suspension is 10/29/2007, 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 follow ALL instructions very carefully. Even if you have served all the time on the suspension/revocation, we cannot restore your driving privilege until all the requirements are satisfied. COMPLYING WITH THIS SUSPENSION You must return all current Pennsylvania driver's licenses, learner's permits, temporary driver's licenses (camera cards) in your possession on or before 10/29/2007. You may surrender these items before, 10/29/2007, for earlier credit; however, you may not drive after these items are surrendered. YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR IDENTIFICATION 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 serving any suspension until we receive your license(s). Complete the following steps to acknowledge this suspension. 1. Return all current Pennsylvania driver's licenses, learner's permits and/or camera cards to PennDOT. If you do not have any of these items, send a sworn 072606116487824 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 68693 Harrisburg, PA 17106-8693 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 3 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. 3. 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. PROVIDING PROOF OF INSURANCE Within the last 30 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 acceptable documents and what will be needed if you do not own a vehicle registered in Pennsylvania. IMPORTANT: 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. 072606116487824 APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date, SEPTEMBER 24, 2007, of this letter. If you file an appeal in the County Court, the Court will give you a time-stamped certified 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 OFFICIAL NOTICE OF SUSPENSION. You must return all current Pennsylvania driver license products to PennDOT by 10/29/2007. Sincerely, 9?x ?-- - Z g Z411) Janet L. Dolan, Director Bureau of Driver Licensing INFORMATION 8:00 a.m. to 6:00 p.m. IN STATE 1-800-932-4600 TOO IN STATE 1-800-228-0676 OUT-OF-STATE 717-412-5300 TDD OUT-OF-STATE 717-412-5380 WEB SITE ADDRESS www.dmv.state.pa.us ALEX JUSTIN BOBB, : IN THE COURT OF COMMON PLEAS OF Appellant CUMBERLAND COUNTY, PENNSYLVANIA V. NO.. COMMONWEALTH OF PENNSYLVANIA,: PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, LICENSE SUSPENSION APPEAL BUREAU OF DRIVER LICENSING, Appellee 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 Camp Hill, 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 Date: ? -Z 7 Z 007 Respectfully submitted, Marlines kley, Esquire Law Offic of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 PJ r' ? 1 La ___a --` , OQ i ?- r V ,O -? 1 T ? ?? i -.. .: a i ,t _ :. , ? -- t.1, ?? ,; ?., ? i OCT 0 E2DD7P4 ALEX JUSTIN BOBB, Appellant V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: pl- 5'141 l.:ivil TerM COMMONWEALTH OF PENNSYLVANIA,: PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, LICENSE SUSPENSION APPEAL BUREAU OF DRIVER LICENSING, Appellee ORDER OF COURT AND NOW, this day of 0 Ot6&A 2007, upon consideration of this APPEAL OF OPERATOR'S LICENSE SUSPENSION, it is hereby Ordered that a hearing on the matter shall be held on day of kuu 2007, at ?31 co ]o'clock M. in Courtroom No. d- of the Cumberland County Courthouse, Carlisle, Pennsylvania. A supersedeas is granted pursuant to Vehicle Code Section 1550(b)(1) until such time that this honorable court resolves this appeal. J. r Distribution: -PA Dept. of Transportation, Office of Chief Counsel, Third Floor, S rn?t Riverfront Office Center, Harrisburg, PA 17104 -Marlin L. Markley, Law Offices of Patrick F. Lauer, Jr., LLC, /n it, /",y 2108 Market St., Camp Hill, PA 17011 -! 7-1 CZ) ALEX JUSTIN BOBB, Appellant V. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO.: 07-5741 CIVIL APPEAL OF OPERATORS LICENSE : SUSPENSION Kindly withdraw the appeal of operator's license suspension that was filed on October 1, 2007, for the above-captioned case. The Parties agree that a license suspension appeal hearing is no longer needed. M,AAatE. kley, Esquire Law Offic s of Patrick F. Lauer, Jr., LLC 2108 M et Street, Aztec Building Camp ill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 Date: December 14, 2007 Distribution: -PA Dept. of Transportation, Office of Chief Counsel, George H. Kabusk, Esq., Third Floor, Riverfront Office Center, Harrisburg, PA 17104 -Marlin L. Markley, Esq., 2108 Market St., Camp Hill, PA 17011 -Alex Bobb, 55 Longview Drive, Mechanicsburg, PA 17050 -Judge Edgar B. Bayley, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 ;? r x . r Jamie L. Regis, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW V. : IN DIVORCE Dale Regis, Defendant : No. 2006- 5741 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: served on Defendant by personal service. Service !was complete upon acceptance of service by Dale Regis on September 29, 2006. 3. Date of execution of the affidavit required by §3301 (d) of the Divorce Code: by plaintiff- November 01, 2007; Defendant's counter-affidavit filed- November 13, 2007. Defendant is not'opposed to the entry of a divorce decree. 4. Related claims pending: None 5. Date acid manner of service of the notice of intention to file praecipe a copy of which is attached: Served on Defendant by U.S. mail, first class, postage prepaid. November 27, 2007. ??-`-- Date Nicole Berman Certified Leg 1 Intern Anne -Fox Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff w Jamie Regis, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. : DIVORCE Dale Regis, Defendant : NO: 2006- 5741 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after December 05, 2007, the other party can 'request the court to enter a final decree in divorce. If you coo not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ra ? ? C'J r X 17