HomeMy WebLinkAbout04-2125COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
WILLIAM GUY FREUNDEL,
Appellant
IN THE COURT OF
COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
No. oqL R. IA~'~ CIVIL
NOTICE OF APPEAL OF LICENSE SUSPENSION
Appellant, William G. Freundel, is an adult individual who currently resides at
2731 Rosegarden Blvd., Mechanicsburg, Cumberland County, PA 17055.
Appellee, Commonwealth of Pennsylvania, Department of Transportation,
Bureau of Drivers' Licensing, is a Commonwealth agency with offices in
Harrisburg, Dauphin County, Pennsylvania.
On April 3, 2004, the Appellant was charged with one (1) count of 75 Pa.C.S.
[1543(b) Driving Under Suspension (DUI related).
On April 7, 2004, the Appellant pled not guilty to that offense and a trial was
scheduled for April 23, 2004, and then continued to April 26, 2004, and it was
again continued from that date. It is now scheduled for May 21, 2004.
Mr. Freundel has not been convicted of driving under suspension
Mr. Freundel was never charged with 75 Pa.C.S. [1543(a).
On April 27, 2004, Appellee mailed an official Notice of Suspension to Mr.
Fmendel due to a conviction of violating 75 Pa.C.S. ~1543(a). Attached
heretofore as Exhibit A.
WHEREFORE, your Appellant respectfully requests This Honorable Court to
set a hearing and deny the Commonwealth's request that his license be suspended.
Date:
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
Attorney for the Appellant
Attorney I.D.# 77961
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
APR-Id-2004 SUN 12:30 PM HOMESTEAD GROUP FAX NO, 7177630290 P, 02
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of DrSver Licensing
Mai[ Date: APRIL 27, 2004
WILLIAM GUY FR£UNDEL
2731 ROSEGARDEN BLVD
M£CHANICSBURG PA 17055
BID # D411192&3342610 001
PROCESSING DATE 0~/2D/2004
DRIV£R LICENSE e 22795254
DATE OF BIRTH 04/t7/1946
LICENSE IN BUREAU
Dear NRo FREUNDEL:
This is an o~ictal Not/ce of the Suapenslon of your Driving
Privilege as authorized by Section 154~ of the Pennsylvania
Vehicle Code. ~s a result of ~our Oq/OT/2OOq conviction of
violating Section lSqSA of the Vehicle Cad~ DRIVING NMILE
SUSP/REVOKE on
Your drivina privilege is SUSPENDED fOP a pePlod of 1
YEAR(S) effective Oq/O5/200S at lI:01 a.m.
This suspension is in addition to any other suspensions
already on ~our record.
PROVIDING PROOF OF ~NSU~ANCE
~thin the last 5g days of your Suspension/revocation, ~e
~ill send you a letter asking that You provide proof of
insurance at that time. This letter wil! list acceptable
documents and what ~ill be needed if you do not o~n a vehi,;le
registered in Pennsylvania,
IMPORTANT: Pieaze make sure that PennDOT ~s notified if
move from your current address. You may notify PennOOT of
your address change by calling any of the phone numbers
listed at the end of this letter.
SUN 12:30 PM Hr ~m~D GROUP F~× NO, ?ITT68P~q ?, 03
AFPE~
You have the r/ght to appeal this actien to the Cmart af
Common Fleas ~Civ~l Divisien) w/thin ~0 days ef the mail
date~ APRIL ~7, 200~, cf th/s letter, Z~ you file an a~Deal
be valid~ you must send this t/me-stamped certified copy of
the a~;eal by certified mail tm:
Pennsylvania Deoartment of Transportat/an
Office of Chief Counsel
Th/rd Floor, Riverfront Off/ce Center
Harr/sbur9, PA ~7~0~-2516
Remember, this is an OFFZCZAC NOTICE OF SUSPENSION.
Rebecca L, Bickley, O/rector
Bureau of Driver Licensing
SEND FEE/LICENSE/DL-16LC/TO~
Department of TransPortation
~ureau of Dr~ver Licensing
F,O, ~ox 68695
Harrisburg, PA 17106-8695
INFORMATION (7:00 AM TO 9:00 PM)
IN STATE l.-aO0-9~2-46D0
OUT-OF-STATE 717-391-6190
TOD IN STATE ).-800-228-B676
TOD OUT-OF-STATE 717-591-6191
CERTIFICATE OF SERVICE
I, John A. Abom, hereby certify that I served a copy of the within Notice of
Appeal upon the Appellee, by mailing a copy of said Notice by certified mail
addressed as follows:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516
Dated:
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
V
WILLIAM GUY FREUNDEL,
Appellant
HAY ~ 3
IN 'THE COURT OF
COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
Ne,. 0C(-otto~'- CIVIL
ORDER
AND NOW, this ~t~ day of ~ , 2004, upon consideration of
the Appdlant's Notice of Appeal, a hearing is set for the/~ day of~
200g _,atql3a OPM, inCoum:oom# / , Cumberland County Courthouse,
Carlisle, Pennsylvania.
to 75 '~ ~.,~.o." ~ ~155~(u) pending said hem2tg. ~ w a
John A. Abom, Esquire
36 South Hanover Street
Carlisle, PA 17013
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516
COMMONWEALTH OF PENNSYLVANIA, :
DEPARTMENT OF TRANSPORTATION, :
BUREAU OF DRIVER LICENSING, :
Appellee
WILLIAM GUY FREUNDEL,
Appellant.
TO THE CLERK OF COURTS:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
No. 04-2125 CIVIL
PRAECIPE TO WITHDRAW LICENSE SUSPI--NSION APPEAL
Please withdraw and dismiss the above-captioned License Suspension Appeal.
Respectfully submitted,
ABOM & KUTULAKIS, L.L.P.
Attorney I.D.# 77961
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
CERTIFICATE OF SERVICE
I, John A. Abom, hereby certify that I served a copy o1' the within Praecipe to
Withdraw and Dismiss License Suspension Appeal upon the Appellee, by first class mail
as follows:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516
.[~y_John A. Abom, E~J'e ~
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
JUL 2 7 2§0~
IN THE COURT OF COMMON PLEAS
CUMBERLA'ND COUNTY PENNSYLVANIA
: No. 04-2125 CIVIL
WILLIAM GUY FREUNDEL,
Appellant.
ORDER
AND NOW, upon consideration of the attached Praecipe to Withdraw and Dismiss,
it is hereby ordered that Appella..nt s License S,uspension Appeal is dismissed, ~ 'j ~c
John A. Aborn, Esquire ~
ABOM & KUTULAKIS, L.L.P. ] .
36 South Hanover Street / ~71~t ~, ('~! ~
Carlisle, PA 17013 n~o ,,v~.~..-v_ '~'.~O~6('/5
Pennsylvania Department of Tra rtatio '~
Office of Chief Counsel ~
Third Floor, Riveffront Office Cente~r
Harrisburg, PA 17104-2516 ~
COMMONWEALTH Of PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
WILLIAM GUY FREUNDEL,
Appellant.
TO THE CLERK OF COURTS:
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY PENNSYLVANIA
No. 04-2125 CIVIL
PRAECIPE TO WITHDRAW LICENSE SUSPENSION APPEAl
Please withdraw and dismiss the above-captioned License Suspension Appeal.
Respectfully submitted,
Date:
ABOM & KUTULAKIS, L.L.P.
~Attorne~ for th; E/;~pqpe~la r t
Attorney I.D.# 77961
36 South Hanover Street
Carlisle, PA 17013
(717) 249-0900
CERTIFICATE OF SERVICE
I, John A. Abom, hereby certify that I served a copy of the within Praecipe to
Withdraw and Dismiss License Suspension Appeal upon the Appellee, by first class mail
as follows:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riveffmnt Office Center
Harrisburg, PA 17104-2516
~,_John . , ~_.~e (j