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Home My WebLink About04-1725DEPARTMENT OF TRANSPORTATION : COMMONWEALTH OF PENNSYLVANIA: MEREDITH FREESTON, Appellant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. : APPEAL FROM LICENSE SUSPENSION PETITION FOR APPEAL OF LICENSE SUSPENSION AND NOW, comes Appellant, Meredith Freeston, by and through her attorney, Gregory Barton Abeln, Esquire, who files the following petition: 1. Meredith Freeston is an adult individual currently residing at 1322 Barton Drive, Ft. Washington, Pennsylvania 19034. 2. On April 12, 2004, Pennsylvania Department of Transportation sent to Appellant a notice of License Suspension, a copy of which is attached hereto and incorporated herein by reference as Exhibit "A". 3. Appellant has a valid Pennsylvania operator's license in her possession. 4. The Appellant has appealed her conviction for underage drinking on January 13, 2004, and is pending a hearing in the court of common pleas on the criminal summary appeal. 5. If the criminal appeal is sustained, this civil appeal becomes moot. WHEREFORE, Appellant requests this Honorable Court to set a time for a hearing on the priority of Appellant's license suspension and immediately stay the imposition of her license suspension pending the result of said hearing. Date Respectfully submitted, ABELN LAW OFFICES Gregory Barton Abeln, Esquire ID # 35,960 Attorney for Appellant 37 East Pomfret St. Carlisle, PA 17013 717/245-2851 04-1B-2004 O~:Olpm From-SYSTEMS +~1086035B9 T-S04 P.001/~02 F-753 CONNONWEALTH OF PENNSYLVANIA DEPARTNENT OF TRANSPORTATION Bureau of Driver Llcens~ng Mail Date: APRIL 19, 200q MEREDITH C FREESTON 1322 BARTON DRIVE FT ~SHINGTON PA $9034 WID e 04103611727501~ 001 PROCESSING DArE 04/12/2004 DRIVER LICENSE t 270q279& DATE OF BIRTH 04/20/1985 Dear liS. FREESTON; As a result of your Section 6508 (offenses related to alcohol); your ~r~v~ege ~ being SUSPENDED for a ;erred of ~ YEAR(S) as mand;~:ed by section 1552D of the vehicle code. ?he effaot~ve date of mumpenm~on 2s 04/29/200~, 12:01 a.m. Th~s ,uspens~on ~s in addition to an~ other suspensions al- PROV~DI~ PR0~F OF ;NSURANCE W~thJrt the Jast $0 days of your suspension/revocation, we wil] .end You a letter asking that you Drov~de Proof of ~n- sura~',ce at that t~me. Th~s ~etter wi~! l~st acceptable daces, ants and what ~ll be needed if you do not o~n s vehicle regal, tared ~n Pennsylvania. ~HPO~TAN?: P~ease sake sure that PennDOT ~s no%iliad 2f YOU move from your current address. You may not~fy PsnnDOT of ~Jst~!,d at the end of this ~etter. A~PEA~ You have the right to appeal this act%on to the Court of Commc:,n Pleas (C~vi! Division) w~th~n ~0 days of the tn th(~ county court, the Court wtll give you a ttme-~tam;ed ~e v~,~Ld, ~ou must send th~s t~me-stamued cert/f~ed co;~ of the a,n~eol ay certified mai! tu~ Pennsylvani~ Department of Transnortation Off/ce of Chief Counse! Th/rd Floor, R~verfront Off~ce Center 04-76-2004 0~:01~; F?om-SYSTEBS +~106~03~8~ t-BOd P.002/~02 F-753 G~lO~I17Z750&S I~eme~ber, this i$ an oFle~C~[AI. NOT2CE OI= SUSPENSION. Sincerel~/~ Rebecca C. aickZey, Director Bureau of Driver Licensing ZNFORHAT[ON 7;00 a,m- to 9:00 p.m. ~N STATE J-800-952-~600 TDD IN STATE 0UT-C~F-STATE 717-~9~-619D TDD OUT-OF-STATE WEB $;;T£ ADDRESS ~wu.dmv.sta~eona.us ~-800-228-0676 DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PENNSYLVANIA MEREDITH FREESTON, Appellant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. APPEAL FROM LICENSE SUSPENSION CERTIFICATE OF SERVICE I hereby certify that on this date a true and exact copy of the foregoing PETITION FOR APPEAL FROM LICENSE SUSPENSION was sent to the following address by United States Mail and Facsimile. DEPARTMENT OF TRANSPORTATION Office of Chief Counsel Room 103 Transportation and Safety Building Harrisburg, PA 17120 Respectfully submitted, ABELN LAW OFFICES Darlene F. Mellinger Legal Assistant 37 East Pomfret St. Carlisle, PA 17013 717/245-2851 DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PENNSYLVANIA V. IN THE COUKT OF COMMO3q~LEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. t,q~O~-' ]-:/~"O.'o, fl MEREDITH FREESTON, Appellant APPEAL FROM LICENSE SUSPENSION ORDER OF COURT xd ANDNOW, tNis3 dayof ff~::~7 ,2004, upon presentation and consideration of the within Petition For Appeal From License Suspension, a hearing is set for the /_~l~ay of ~/,t~_._,2004, al~:.~0o'clockt~ .m. in Courtroom No. ~of the Cumberland County Courthouse. FURTHERMORE, the motor vehicle license suspension in this case is stayed pending the disposition of this appeal hearing. Gregory Barton Abeln, Esquire ~ ~ Pennsylvania Department of Transportation, Offic~ of Lhief Counsel DEPARTMENT OF TRANSPORTATION COMMONWEALTH OF PENNSYLVANIA MEREDITH FREES TON 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTy, PENNSYLVANIA NO. CP-21 -CV-1725-2004 APPEAL FROM LICENSE SUSPENSION PRAECIPE TO WITHDRAW APPEAL TO THE PROTHONOTARY, CUMBERLAND COUNTy COURTHOUSE. Please mark this license suspension appeal as w/th&awn. Date~ Respectfully submitted, ABELN LAW OFFICES egory Barton Abeln, Esquire~-~-x~ ID #35,960 Attorney for Petitioner 37 East Pomfret Street Carl/s/e, PA 17(}13-3313 717/245-285 DEPARTMENT OF TRANSPORTATION : COMMONWEALTH OF PENNSYLVANIA: V. MEREDITH FREESTON : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CP-21.CV. 1725-2004 APPEAL FROM LICENSE SUSPENSION CERTIFICATE OF SERVICE I hereby certify that on this date a true and exact copy. of the foregoing PRAECIPE TO WITHDRAW APPEAL was sent to the following address by United States Mail and Facsimile. DEPARTMENT OF TRANSPORTATION Office of Chief Counsel Room 103 Transportation and Safety Building Harrisburg, PA 17120 Respectfully submitted, ABELN LAW OFFICES Date ~ - ! 3-O ~' 37 East Pomfret Street Carlisle, PA 17013-33~3 717~45-2851