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HomeMy WebLinkAbout07-6058Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION VS. GREGORY D. FOLSOM, ) Appellant ) NO. 07- G0,5k APPEAL FROM SUSPENSION OF OPERATING PRIVILEGES PETITION FOR APPEAL FROM SUSPENSION OF OPERATING PRIVILEGES TO THE HONORABLE JUDGES OF THE COURT: NOW COMES GREGORY D. FOLSOM, upon a Petition for Appeal from Suspension of Operating Privileges, whereof the following is a statement: 1. 2. 3 Petitioner is GREGORY D. FOLSOM whose address is 2015 Lincoln Street, Camp Hill, PA., Cumberland County, Pennsylvania. Petitioner has received at Notice of Suspension of the operating privileges of Petitioner, as set forth in the Official Notice of Suspension from the Director of the Bureau of Driver Licensing, Department of Transportation, processing date of September 7, 2007 and mailing date of September 14, 2007, is hereby granted, effective October 19, 2007 at 12:01 a.m.. The stated basis for the suspension is: "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." 4. 5 Petitioner did not have notice of a Departmental Hearing. Petitioner did not intentionally fail to attend a Departmental Hearing. 1, 6. Petitioner is willing to attend a Departmental Hearing if he has notice of the hearing. 7. Petitioner believes and therefore avers that the 60 Day suspension of his operating privileges by the Department of Transportation, Commonwealth of Pennsylvania, under the circumstances, is improper. WHEREFORE, Petitioner prays that this Honorable Court enter and Order fixing the time and place of a hearing to determine whether the operating privileges of Petitioner should be suspended or the suspension should be set aside as improper and invalid. Petitioner also seeks a new Departmental Hearing, after proper notice, on the underlying issue that caused the Department to schedule a hearing. Date Respectfully submitted, ?, 11, e ry D. Folsom Pro Se 2015 Lincoln Street Camp Hill, PA 17011 Cellular Telephone: (814) 571-7264 VERIFICATION Subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities, I, GREGORY D. FOLSOM, verify that the averments of fact set forth in the foregoing Petition for Appeal from Suspension of Operating Privileges are true and correct upon my personal knowledge or information and belief. ORY D. FOLSOM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, ) DEPARTMENT OF TRANSPORTATION ) VS. ) } GREGORY D. FOLSOM, ) Appellant ) NO. APPEAL FROM SUSPENSION OF OPERATING PRIVILEGES CERTIFICATE OF SERVICE I hereby certify that on this day, I am serving the foregoing document upon the person and in the manner indicated below, which service satisfied the requirements of Pa. R.C.P. 440. SERVICE BY FIRST CLASS CERTIFIED MAIL RETURN RECEIPT REQUESTED ADDRESSED AS FOLLOWS: Pennsylvania Department of Transportation Office of Chief Counsel 3' Floor, Riverfront Office Center Harrisburg, PA 17104-2516 Date i" go D. Folsom Pro Se 2015 Lincoln Street Camp Hill, PA 17011 Cellular Telephone: (814) 571-7264 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, ) DEPARTMENT OF TRANSPORTATION ) VS. ) GREGORY D. FOLSOM, ) Appellant ) NO. APPEAL FROM SUSPENSION OF OPERATING PRIVILEGES AFFIDAVIT OF RETURN SERVICE I, Gregory D. Folsom, do swear according by law, that I have made service of the Petition For Appeal From Suspension of Operating Privileges upon the Commonwealth of Pennsylvania, Department of Transportation by certified mail, return receipt requested. Service was accomplished on 2007. Attached hereto as evidence of said service is a signed return receipt. Date Gregory D. Folsom Pro Se 2015 Lincoln Street Camp Hill, PA 17011 Cellular Telephone: (814) 571-7264 ??? rv c C7 o O Tr G • • -1 r OCT i s2oozo41 WACLIENTSWOLSOM, GREGORY DYDRIVERS LICENSE APPEAL.DOC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Gtn 'D fvtsoM CIVIL ACTION - LAW JS. COMMONWEALTH OF PENNSYLVANIA, ) DEPARTMENT OF TRANSPORTATION ) ORDER AND NOW, this 7 day of Q Gl?tl y ? NO. 07 - [a 05g Civil Ter% APPEAL FROM SUSPENSION OF OPERATING PRIVILEGES Okol , upon consideration of the within Petition for Appeal from Suspension of Operating Privileges and on motion by Petitioner named above, the Oof , at A7.)0_PM., in Courtroom No. 3 , of the CUMBERLAND County Courthouse, Carlisle, Pennsylvania, is hereby fixed as the time and place for hearing of the within petition. Written notice no later than thirty (30) days prior to the hearing shall be given to the Director of the Bureau of Driver Licensing, Department of Transportation, of the time and place of the hearing. Supersedeas of the suspension of the operating privileges of Petitioner, as set forth in the Official Notice of Suspension from the Director of the Bureau of Driver Licensing, Department of Transportation, processing date of September 7, 2007 and mailing date of September 14, 2007, is hereby granted, effective October 19, 2007 at 12:01 a.m.. J. U t3 ?8 1 loo LRI GREGORY FOLSOM, VS IN THE COURT OF COMMON PLEAS OF Appellant CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee NO. 07-6058 CIVIL TERM CIVIL ACTION - LAW ORDER OF COURT AND NOW, this 6th day of December, 2007, hearing in this matter is continued to February 15, 2008, at 1:30 p.m. to give Petitioner the opportunity to reschedule and attend the departmental hearing. By th ourt, Edward E. Guido, J. x regory D. Folsom 2015 Lincoln Street Camp Hill, PA 17011 Appellant, Pro Se ,ge"'orge Kabusk, Esquire For PennDOT :mlc c n J -I 01 3'0 LORL GREGORY FOLSOM, VS Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6058 CIVIL TERM CIVIL ACTION - LAW COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee ORDER OF COURT And now this 15th day of February, it appearing to the Court that the Department has rescinded the suspension at issue, the appeal is dismissed a By ot. Edward E. Guido, J. ? Gregory D. Folsom 2015 Lincoln Street Camp Hill, PA 17011 Appellant, Pro Se ? George Kabusk, Esquire For PennDOT :mlc Co iES m?ILL 9'1 ;1 W18 ZZ 233 OOOZ j1U ? ?'jr r ??r? t! x i EO