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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY - CIVIL ACTION
Heather MacDonald,
V.
Petitioner
Commonwealth of Pennsylvania
Department of Transportation,
Bureau of Driver's Licensing
fern
Respondent
APPEAL FROM THE SUSPENSION OF OPERATING PRIVILEGES
TO THE HONORABLE JUDGES,
AND NOW comes Petitioner, Heather MacDonald, by and through her attorney, Dawn
Marron, Esq., and respectfully avers as follows:
1. Petitioner Heather MacDonald resides at 516 Grant Drive, Camp Hill,
Pennsylvania, 17011. Petitioner's Pennsylvania Operator's Number is 27646394.
2. PennDOT proposed by Notice dated November 25, 2009, to suspend Petitioner's
driving privilege's for the period of ONE YEAR pursuant to Section 1543 of the
Pennsylvania Vehicle Code, effective December 30, 2009.
3. The withdrawal and suspension of Petitioner's operating privileges is unlawful, in
that Petitioner's record with PennDOT does not warrant suspension, and
Ak.
Petitioner was not granted an opportunity for a hearing with PennDOT prior to an
automatic suspension.
4. Alcohol was not involved in the driving violations of the Petitioner.
5. Petitioner has custody of a small child and needs her vehicle for custody
exchanges with the child's father as well as for transportation to work.
WHEREFORE, Petitioner respectfully requests that this Honorable Court allow her an
appeal from the suspension of her operating privileges.
Respectfully submitted,
Dawn Marron
PA ID: 79792
Counsel for Petitioner
Marron Legal
603 Market Street
New Cumberland, PA 17070
(717) 238-0212
APY
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY - CIVIL ACTION
DEC 2 9 2009
Heather MacDonald,
V.
Petitioner
Commonwealth of Pennsylvania
Department of Transportation,
Bureau of Driver's Licensing
Respondent
ORDER
AND NOW, this day of day of? , 20/ D , upon
presentation of this petition, and upon motion from Dawn Marron, attorney for Petitioner,
the Court orders and decrees that the
d of
n . The appeal acts as a superce eas pending
this appeal; and that all proceedings are stayed. A hearing is scheduled for
1610
yOo'clock in Courtroom No. in Cumberland County
Courthouse, Carlisle, Pennsylvania.
B
J.
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