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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