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HomeMy WebLinkAbout07-6949 GEORGE GILES MCLEWEE, JR., PETITIONER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. RE: STATUTORY APPEAL PETITION - CHEMICAL TEST REFUSAL COMMONWEALTH OF 07_ G 9V? PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, DOCKET NO: CV 2007 BUREAU OF DRIVER'S LICENSING, RESPONDENT OPERATING PRIVILEGE SUSPENSION APPEAL TO THE HONORABLE JUDGES OF SAID COURT: ONO Tee, AND NOW, comes the above-named Petitioner, George Giles McLewee, Jr., by and through his Attorney, Shawn M. Curry, Esquire, and hereby appeals from a Notice of Suspension issued by the Pennsylvania Department of Transportation, Bureau of Driver's Licensing, and avers the following in support thereof: 1. This Court has jurisdiction over this case by virtue of 42 Pa.C.S.A. §933(a) and 75 Pa.C.S.A. §1550(a). 2. The Petitioner is George Giles'!McLewee, Pennsylvania Operator Number 24425524, whose place of residence is 36 Lantern Lane, Shippensburg, PA 17257, with a date of birth of ctober 2, 1961. 3. Respondent is the Bureau of Dlriiver's Licensing of the Commonwealth of Pennsylvania, Department of ransportation, which has its principal place of ?,II business at the Riverfront Office Center, 1101 South Front Street, Harrisburg, Pennsylvania. 4. The Appeal is taken from an Official Notice bearing a mailing date October 19, 2007. With that Notice the Bureau of Driver's Licensing notified Petitioner that it was suspending his privilege of operating a motor vehicle for the period of eighteen (18) month(s), effective November 23, 2007, at 12:01 a.m., pursuant to Section 1547(b)(1)(ii) of the Pennsylvania Vehicle Code, as a result of an alleged refusal by Petitioner to submit to chemical testing on September 16, 2007. A true and correct copy of the Bureau's Notice of Suspension is appended to this Petition as Exhibit "A". 5. The eighteen (18) month suspension of Petitioner's operating privilege is improper and illegal because: a. Petitioner's alleged refusal occurred incident to his being charged with driving under the influence, as a first offense, and the Police Criminal Complaint simply charges him with a DUI-General Impairment charge only; thus, the eighteen (18) month suspension pursuant to Section 1547(b)(1)(ii) of the Pennsylvania Vehicle Code is not proper. A true and correct copy of the Police Criminal Complaint is appended to this Petition as Exhibit "B." b. The procedural prerequisites that law enforcement must follow in order to obtain a valid sample Were not met in this case. 6. The Petitioner requests relief pulrsuant to 75 Pa. C.S.A. §1550 (b)(1) - Supersedeas. As this matter is timely filed and service has been effected upon the Department's legal office, and none of the enumerated exceptions under 75 Pa. C.S.A. §1550 (b)(1) (ii) or (iii) exist, the Petitioner specifically requests that this Honorable Court in its Order grant Supersedeas to stay the Department's planned suspension. WHEREFORE, Petitioner, George Giles McLewee, Jr., respectfully requests this Honorable Court hold a de novo hearing on his Appeal from the suspension of his operating privilege and will invalidate the illegal taking of his privilege and the improper action of the Department of Transportation, Bureau of Driver's Licensing, to suspend his operating privilege. Respectfully submitted, Shawn M. urry, Es re Attorney for Petitioner Attorney ID#: 202061 4807 Jonestown Road, Suite 148 Harrisburg, Pennsylvania 17109 Telephone: (717) 657-3900 Fax No.: (717) 657-2060 EXHIBIT A COMMONWEALTH OF PENNSYLVANIA DEPARTMENT F TRANSPORTATION Bureau of Driv Mail Date: 0 OBER 19, 2007 GEORGE GILES MCLEWEE.JR WID # 072856691086592 001 36 LANTERN LN PROCESSING DATE 10/12/2007 DRIVER LICENSE 24425524 SHIPPENSBURG PA 17257 DATE OF BIRTH 10/02/1961 Dear MR. MCLEWEE: This is an Official Notice of the Suspension of your Driving Privilege as authorized by Section 1547BIII of the Pennsylvania Vehicle Code.' As a result of your violation of Section 1547 of the Vehicle Code, CHEMICAL TEST REFUSAL, on 09/16/2007: ¦ Your driving privilege is SUSPENDED for a period of 18 MONTH(S) effective 11/2$/2007 at 12:01 a.m. COMPLYING WITH THIS SUSPENSXON You must return all current Pennsylvania driver's licenses, learner's permits, temporary driver's licenses (camera cards) in your possession o7 or before 11/23/2007. You may surrender these items be ore, 11/23/2007, 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 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: 072856691086592 Pennsylvania Department of Transportation Bureau of ',Driver Licensing P.O. Box 68693 HarrisburgI, 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, Penn OT 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. APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date, OCTOBER 19, 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, Riverfr nt Office Center Harrisburg, PA 17106-2516 Remember, this is an OFFICIAL NOTICE OF SUSPENSION. You must return all current Penn ylvania driver license products to PennDOT by 11/23/2007. 072856691086592 Sincerely, Janet L. Dolan, Director Bureau of Driver Licensing INFORMATION 800 a.m. to 6:00 .m. IN STATE 1--800-93 -4600 TDD IN STATE 1-800-228-0676 OUT-OF-STATE 717-412-5300 TDD OUT-OF-STATE 717-412-5380 WEB SITE ADDRESS www.dmvi.state.pa.us EXHIBIT B POLICE CRIMINAL COMPLAINT C JWEALTH OF PENNSYLVANIA ? ? COMMONWEALTH OF PENNSYLVANIA COUNTY OF: Cumberland VS. DEFE DANT (NAME AND ADDRESS) Magisterial District # 09-3-01 Geor Giles MCLEWEE JR MDJ Hon Harold E. BENDER First N me Middle Name Last Name Gen. Address 35 W. Orange ST G Shippensburg, PA 17257 36? Lantern LN Shlippensburg, PA 17257 Telephone 717 530 - 7676 L J NCIC'Extradition Code Type 1-Felony Full 4-Felony No Ext. B-Misdemeanor Limited E-Misdemeanor Pending ? 2-Felony Ltd. ? 5-Felony Pend. ? C-Misdemeanor Surrounding States 0 3-Felony Surrounding States ? A-Misdemeanor Full ? D-Misdemeanor No Extradition Distance: DEFENDANT ID NTIFICATION INFORMATION RACE ETHNICITY Number D to Filed OTN/LiveScan Number Complaintlincident Number ® White ? Hispanic ® Non- OPM-INI O / Q$/ 2007 L373867-4 H02-1698815 ? Asian Hispanic DOB POB ? Black ? Unknown 10 / 02 / 61 Pennsylvania ? AmNative erican GENDER Add'l. DOB SSN Add'I. SSN ? Unknown ®Male / / 215 - 82 - 5682 - - ?Female AKA First Name Middle Name Last Name Gen. SID HAIR COLOR GRY (Gray) RED (Red/Aubn.) RED EYE COLOR 25483014 ? BLK (Black) ? ONG (Orange) ? (Blonde/ ? GRN (Green) ? PNK (Pink) Request Lab ? BLU (Blue) ? PLE (Purple) Strawberry ? BLK (Black) ? GRY (Gray) ? MUL Services? ? BRO (Brown) ? PNK (Pink) ? I (White) ?BLU (Blue) ? HZL (Hazel) (Multicolored) ) ? Yes ? No ? GRN (Green) ? SDY (Sandy) E] (Unk/Bald) ® BRO (Brown) ? MAR (Maroon) ? UNK (Unknown) Driver License State PA License Number 24425524 Expires 10 / 03 / 2010 Weight (pounds) DNA ? Yes ® No DNA Location 150 FBI Number 963214JA4 MNU Number Ft. HEIGHT In. Fingerprint Classification 5 04 DEFENDANT VEHICLE INFORMATION Plate # State Hazmat Registration Stickler Comm'I Veh. Ind. School Veh. Oth. NCIC Veh. Code DTP771 PA ? MM/YY of 08 ? ? VIN Year Make Model Style Color lGlJC124XVM158050 1997 Chevrolet Cavalier CID BLK Office of the Attorney for the Commonwealth: ? Ap proved ? Disapproved because: (The Attorney for the Commonwealth may requi that the complaint, arrest warrant affidavit, or both be approved b the Attorne for the Commo nwealth prior to filing. See Pa.R.Crim.P. 507). (Name of the Attorney for the Commonwealth - Please Print or Type) (Si gnature of the Attorney for the Commonwealth) (Date) I, Tpr. Steven P. NESBIT 10233 (Name of the Affiant - Please Print or Type) (PSP/MPOETC - Assigned Affiant ID Number & Badge #) Of Pennsylvania State Police-Carlisle PAPSP1000 I (Identify Department or Agency Represented and Political Subdivision) (Police Agency OR[ Number do hereby state: (check appropriate box) 1. ® I accuse the above-named defendant who lives at the address set forth above ? I accuse the defendant whose name is unknown to me but who is described as ? I accuse the defendant whose name and popular designation or nickname are unknown to me and whom I have therefore designated as John Doe or Jane Doe with violating the penal laws of the Commonwealth ?f Pennsylvania at [ 215 ] Southampton Twp. (Subdivision Code) (Place-Political Subdivision) in Cumberland County [211 on or about 0/16/07, at approx_ 0638 Hours (County Code ^"? ~' ?^-w 20070206-1 Page 1 of lk? POLICE CRIMINAL COMPLAINT Da at Ny be Date Filed OTN/LiveScan Number Complaint/incident Number to /is/ 2007 1-373867 H02-1698815 -7 Defendant Name First Name Middle Name Last Name George Giles MCLEWEE JR. The acts committed by the accused are described belo with each Act of Assembly or statute violated, if appropriate: (Set forth a brief summary of the facts sufficient to advise the Zen ant of the nature of the offense(s) charged. A citation to the statute(s) violated, without more, is not sufficient. In a summary case, you must cite the specific section(s) and subsection(s) of the statute(s) or ordinance(s) allegedly violated.) Inchoate Attempt Solicitation Conspiracy Al A2 B Permitting (Title 75 Only) Offense 18 901 A 18 902 A 18 903 (Engaging) (Aiding) Knowled a 75 1575 A _ 1 3802 (a)(1) of the 75 1 M 210 Lead? Offense # Section Subsection PA Stat to (Title) Counts Grade NCIC Offense Code UCR/NIBRS Code PennDOT Data (if applicable) Accident Number E] Safety Zone ? Work Zone Acts of the accused associated with this Offense: VC 3802(a)(1) DUI/UNSAFE DRIVING IN THAT, on or about said date THE DEFENDANT did rive, operate or was in actual physical control of the movement of a vehicle namely, a 1997 black Chevrolet Cavalier bear ing PA Reg # DTP7708 after imbibing a sufficient amount of alcohol such that rendered him incapable of safely drivi ng, operating or being in actual physical control of the movement of the vehicle, in violation of Section 3802 (a)(1) of the 1 i 3A Vehicle Code. Inchoate Attempt Solicitation Conspiracy Al A2 B Permitting (Title 75 Only) Offense 18 901 A 18 902 A 18 903 En a in (Aiding) (Knowledge) 75 1575 A 2 3309 1 of the 75 1 S Lead? Offense # Section Subsection PA Stat to itle Counts Grade NCIC Offense Code UCR/NIBRS Code PennDOT Data if a licable) Accident Number ? Safety zone ? Work zone Acts of the accused associated with this Offense: VC 3309(1) DRIVING WITHIN LANE. IN THAT, on or about said date, THE DEFENDANT did fail to drive as nearly as practicable entirely within a single lane AND/OR moved from the lane without first ascertaining that the movement could be made with safety while driving a vehicle upon a roadway divided into two or more clearlylmarked lanes for traffic at 400 Block Mcculoch RD Shippensburg Twp. Cumberland County, in violation of Section 3309(1) of the PA Vehicle Code. Inchoate Attempt Solicitation Conspiracy 1 A2 B Permitting (Title 75 Only) Offense 18 901 A 18 902 A 18 903 n a in n (Knowledge 75 1575 A 3 3714 a of the 75 1 S Lead? Offense # Section Subsection PA Statu e itle Counts Grade NCIC Offense Code UCR/NIBRS Code PennDOT Data (if a licable) Accident Number ? Safety zone ? Work Zone Acts of the accused associated with this Offense: VC 3714(a) CARELESS DRIVING IN THAT, on or about said date, THE DEFENDANT did rive a vehicle in careless disregard for the safety of persons or property at 400 Block Mcculoch RD. Shippensburg Twp. Cumberland County by driving while intoxicated, in violation of Section 3714(x) of the PA Vehicle Code. i AOPC 412A-06 2000206-1 Page 2 of POLICE CRIMINAL COMPLAINT Do e u ber r Date Filed 1 D; le OTN/LiveScan Number Complaint/Incident Number 1 't _'y 0 1-373867+4 H02-1698815 I First Name Defendant Name George iddle Name iles Last Name MCLEWEE JR. 2. 1 ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges I have made. 1 1 verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section4904 of the Crimes Code (18 PA.C.S.§4904) relating to unsworn falsification to authorities. 4. This complaint is comprised of the preceding page, as well as the attached pages that follow, numbered through specifying offenses and participants, if any. The acts committed by the accused, as listed and hereafter, were against the peace and dignity of the Commonwealth of Pennsylvania and were contrary to the Act(s) of the A sembly, or in violation of the statutes cited. (Before a warrant or arrest can be issued, an affidavit of probably cause must be completed, sworn to before the issuing authority, and attached.) 09/22, 2007 Date Month and Da ear Si nature Affiant AND NOW, on this date / k?=J certify that the complaint has been properly completed and verified. An affidavit of probable cause must be completed before a warrant can be issued. AOPC 412A-06 20070206-1 Page 1 of 1 CRIMINAL COMPLAINT D N be .- 1 D d t? = OTWLiveScan N umber yvescaoNumber P.ererredl Complaint/Incident Number L373867-4 H02-1698815 First: Middle: Last: George Giles MCLEWEE JR. AFFIDAVIT?of PROBABLE CAUSE This affiant is Tpr. Steven P. NESBIT a member of th Pennsylvania State Police currently assigned to the Patrol Unit at Troop H, Carlisle station. On 09/16/07, at approx. 0635 hours, I was dispatch d to assist EMS with a possible dead motorist. It was related that the motorist was still in his car slumped over the steer ng wheel. The vehicle was parked in a field at 441 Mcculloch RD. Southampton Twp. Cumberland County. Upon arrival to the area I met with Shippensburg Area EMS Shippensburg EMS related that upon responding 1 bearing PA reg DTP7708. Upon approach to the veh steering wheel. They related that the operator was w operator related that he was not drinking however, thi breath and he appeared to be intoxicated. They relate Ln Shippensburg, PA 17257. Shippensburg EMS als realize that they were not police officers. They relate 441 Mcculloch RD. they observed a black Chevrolet Cavalier le they observed a W/N-M with grey hair slumped over the ken up and they began an initial assessment. They related that the r smelled the strong odor of an alcoholic beverage coming from his that they were able to obtain the operators address of 36 Lantern related that as they when talking to the operator he seemed to that all of a sudden the operator turned on his car and drove away. When asked, EMS related that they had cleared the information. After obtaining this information we respol Lantern LN I observed a black Chevrolet Cavalier bea residence. I observed the operator to be passed out b, vehicle was running. With my observations and the in immediately pulled the operator out. The operator wa: from EMS and the vehicle was running. I determined vehicle. I noted the time of the initial observation of the Once the operator was removed from the vehicle, I emanating from his breath and person. I also observe removed from the vehicle stumbled to the rear of the c that he had not driven and was unaware why PSP wa: and he related that it was in his wallet in the front seat as George Giles MCLEWEE JR. of Shippensburg, PA 40 oz Budweiser brand on the front passenger side flo MCLEWEE again denied he was ever driving or drinkii I,Tpr. Steven P. NESBIT -if ACCORDING TO THE LAW, DEPOSE AND SAY T ARE TRUE AND CORRECT TO THE BEST OF MY Sworn to me and subscribed before me this day My commission expires first Monday of January, 1 >cene at 0656. 1 met with EMS at 0700 hours, and obtained this Jed to 36 Lantern LN Shippensburg, PA 17257. Upon arrival, to ng PA REG# DTP7708 parked in the front driveway of the hind the steering wheel. The keys were in the ignition and the )rmation form EMS I opened the door to the vehicle and pulled out of the vehicle due to the fact that he had driven away to be an officer safety issue to let the operator remain in the Chevrolet Cavalier to be 0705 hours. mmediately smelled the strong odor of an alcoholic beverage him to have blood shot and glassy eyes. The operator once r and spit fell from his mouth. When asked, the operator related speaking with him. The operator was then asked for identification if the vehicle. Upon retrieving his wallet the operator was identified iy his PA photo driver's license. At this time I observed an empty r of the vehicle. When asked again what was going on 3 any alcoholic beverages. , BEING DULY SWORN THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT )WLEDGE, INFORMATION AND BELIEF. ez? Signature ofAffiant) , Magisterial District Judge. SEAL AOPC 411C-O6 200 0206-1 Page 1 of CRIMINAL COMPLAINT (LNeScan Number Prefe"d) L373867-4 George I'IGiles AFFIDAVIT 0 PROBABLE CAUSE H02-1698815 MCLEWEE JR. MCLEWEE was unable to stand up without swaying- Zth the above information and observations MCLEWEE was taken into custody for DUI. MCLEWEE was then place into patrol car and transported to Cumberland County Prison for further processing. After leaving MCLEWEE'S residen e I met with Shippensburg EMS at Lantern LN and Rustic DR. Shippensburg, PA. Shippensburg EMS made a positive identification that MCLEWEE was the operator of the black Chevrolet Cavalier. While transporting MCLEWEE he was provided his Miranda rights that he acknowledged. MCLEWEE acknowledged his Miranda warnings however he continued to related that he knew his rights and that I did not need to provide him his rights. I then began to explain the process at Cumber) nd County Prison. MCLEWEE became very upset and uncooperative. He continued to relate that he was not riving and that he had not driven his vehicle or drank alcoholic beverages that day. On 09/16/07, at 0753 hours, MCLEWEE was provid d his implied consent and OCONNELL warnings that he acknowledged. MCLEWEE however refused to sign tht DL 26 and related that he would not submit to a breath test. I related to MCLEWEE that if he did not provide the breath test he would be subject to more enhanced penalties and he again related he would not submit to a breath test. I respectfully request that the MCLEWEE answer to the charges set forth in this complaint.a THE LAW, DEPOSE AND SAY THAT THE FACTS S CORRECT TO THE BEST OF MY KNOWLEDGE, INI Sworn to me and subscribed before me this day of BEING DULY SWORN ACCORDING TO FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND IMATION AND BELIEF. f(a (Sig ature ofAffiant) My commission expires first Monday of Januarys lia , Magisterial District Judge. SEAL GEORGE GILES MCLEWEE, JR., PETITIONER VS. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER'S LICENSING, RESPONDENT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA RE: STATUTORY APPEAL PETITION - CHEMICAL TEST REFUSAL DOCKET NO: CV 2007 AFFIDAVIT OF SERVICE I, Shawn M. Curry, Esquii Department of Transportation, Bure George Giles McLewee, Jr.'s Petiti sending said copy to the Bureau of Certified Mail, Return Receipt Ri addressed as follows: do hereby affirm that I have served upon the of Driver's Licensing, a true and correct copy of for Appeal of Operating Privilege Suspension by iver's Licensing by United States Postal Service, ested, Receipt No,.-I&)4 oGS0 ,,,o 7-1.4,6, 2195 Offic of Chief Counsel Departry ent of Transportation Riverfront ffice Center - 3rd Floor 11 1 S. Front Street Harrisburg, ennsylvania 17104-2516 This affirmation is made with relating to unsworn falsification to au Date: knowledge of the penalties of 18 P.S. §4904 *ties. Respectfully Submitted, MCSHANE & HITCHINGS, LLC By: Shawn . C rry, squire Attorney for Petitioner Attorney ID# 202061 4807 Jonestown Road, Suite 148 Harrisburg, Pennsylvania 17109 Telephone: (717) 657-3900 Fax: (717) 657-2060 -40- n . - C.. t ? C= -? 0 L ril rim1 I N NOV 212007 GEORGE GILES MCLEWEE, JR., IN THE COURT OF COMMON PLEAS PETITIONER CUMBERLAND COUNTY, PENNSYLVANIA VS. RE: STATUTORY APPEAL PETITION - CHEMICAL TEST REFUSAL COMMONWEALTH OF &q49 C1,va le.m PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, DOCKET NO: CV 2007 BUREAU OF DRIVER'S LICENSING, RESPONDENT ORDER OF COURT AND NOW, this A day oN/1, 2007, IT IS HEREBY ORDERED AND DECREED THAT the Petitioner's Motion for a de novo hearing regarding the Bureau of Driver's Licensing of the Commonwealth of Pennsylvania's suspension of the Petitioner's Operating Privilege IS GRANTED. Specifically, the Court further finds that Petitioner's Motion challenging the suspension was timely filed as it was filed within thirty (30) days of the mailing date of the Bureau's Notice. This matter is set for4=he_ day of Obg , at 0('.tk6 o'clock in Courtroom A FURTHER, this Court directs The Department to stay its planned suspension during the pendency of this AI Distribution: Shawn M. Curry, Esquire Office of Chief Counsel ?- ce) -: uj - OD w U- a GEORGE GILES MCLEWEE, JR., Petitioner V. COMMONWEALTH OF PENNSYLVANIA,: DEPARTMENT OF TRANSPORTATION,: BUREAU OF DRIVER LICENSING, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-6949 CIVIL TERM ORDER OF COURT AND NOW, this 6th day of March, 2008, this matter having been called for a hearing this date, and the petitioner representing that he is withdrawing the appeal, it is ordered that the appeal is withdrawn /'e"orge H. Kabusk, Esquire For the Department of Transportation vl`<wn M. Curry, Esquire For Petitioner prs 11 N ?,j? J ?. ' w yyy L Fi+ ry ( ' v V N