HomeMy WebLinkAbout10-1151• 1
Thomas M. Ballaron, Assistant Counsel
PA Supreme Court ID #23370
Pennsylvania State Police
Bureau of Liquor Control Enforcement
3655 Vartan Way
Harrisburg, PA 17110
(717) 540-7411
Counsel for Petitioner
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PENNSYLVANIA STATE POLICE
BUREAU OF LIQUOR CONTROL
ENFORCEMENT,
Petitioner
VS.
SUPERINTENDENT JOHN A. PALAKOVICH
CAMP HILL STATE CORRECTIONAL
INSTITUTION
2500 LISBURN ROAD
CAMP HILL, PA 17001,
Respondent
w
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
PETITION FOR A WRIT OF HABEAS CORPUS Ad TESTIFICANDUM
AND NOW comes your Petitioner, the Pennsylvania State Police, Bureau of Liquor
Control Enforcement (BLCE), by and through its counsel, Thomas A Ballaron, and in support of
the within Petition respectfully represents as follows:
1. The Petitioner is the Pennsylvania State Police, Bureau of Liquor Control
Enforcement located at 3655 Vartan Way, Harrisburg, PA 17110, which is responsible for the
enforcement of the Pennsylvania Liquor Code pursuant to Section 211 of the Liquor Code,
47 P.S. §2-211 et seq.
2. The Respondent herein is Superintendent John A. Palakovich of the Camp Hill
State Correctional Institution, located at 2500 Lisburn Road, Camp Hill, PA 17001.
3. The Petitioner is the plaintiff in the liquor control enforcement action captioned as
follows: Pennsylvania State Police, Bureau of Liquor Control Enforcement vs. Timothy K.
Tindale, Citation No. 08-1093. A copy of the Commonwealth's citation is attached hereto as
Exhibit 1.
4. A hearing on the merits of this enforcement matter is scheduled before The
Honorable Felix Thau, at Brandywine Plaza., 2221 Paxton Church Road, Harrisburg, PA 17110,
on Thursday, March 11, 2010, at 10:00 a.m. A copy of the hearing notice is attached hereto as
Exhibit 2.
5. Ryan Eugene Erlston is a material witness whose testimony is necessary for the
Commonwealth to sustain its burden of proof in the liquor enforcement matter.
6. Ryan Eugene Erlston, Inmate #HP3870, is currently incarcerated in the Cresson
State Correctional Institution. Copies of the Commitment and Sentencing Orders are attached
hereto as Exhibit 3.
7. Ryan Eugene Erlston will be released to and remain in the custody of an on-duty
trooper of the Pennsylvania State Police who will transport him to the hearing and return him to
prison immediately following the hearing on the same day.
8. Ryan Eugene Erlston will be "in-house" transferred from Cresson State
Correctional Institution to Camp Hill State Correctional Institution on March 9th to accommodate
his transportation to and from the hearing location.
9. The Superintendent of the Camp Hill State Correctional Institution, and the
Superintendent of Cresson State Correctional Institution, do not object to releasing custody of
Ryan Eugene Erlston for the purpose of testifying on behalf of the Commonwealth on Thursday,
March 11, 2010.
2
WHEREFORE, your Petitioner respectfully requests this Honorable Court to issue an
Order releasing Ryan Eugene Erlston into the custody of the Pennsylvania State Police on
Thursday, March 11, 2010, in order to facilitate his testimony at the above-mentioned liquor
enforcement hearing.
Respectfully submitted,
PENNSYLVANIA STATE POLICE,
BUREAU OF LIQUOR CONTROL ENFORCEMENT
7
By: Thomas M. Ballaron
Assistant Counsel
3655 Vartan Way
Harrisburg, PA 17110
(717) 540-7414
Attorney I.D. #23370
Counsel for Petitioner
3
7160 3401 4845 5576 8846
COMMONMIEALTH OF PENNSYLVANIA
PENNSYLVANIA STATE POLICE
BUREAU OF LIQUOR CONTROL
ENFORCEMENT
V.
TIA10THY K. TINDALE
1239 MARIi;ET ST.
HARRISBURG, PA 17103-2229
DAUPHIN COUNTY
License First Issued: April 4, 2007
CITATION
CITATION NO. 08-1093
Incident No. W03-360793
LID - 57466
License No. R-18685 AP SS EHF
WHEREAS, the Pennsylvania Liquor Control Board has issued to you the above-referenced
license and related permit(s) for the licensed terms ending February 29, 2008 and February 28, 2009;
and
'WHEREAS, the Bureau of Liquor Control Enforcement is in possession of facts which leads it
to believe that you have violated the Liquor Code, the Act of April 12, 1951, P.L. 90, as reenacted and
amended, 47 P.S. §1-101, et M, and the rules and regulations adopted pursuant thereto, in the
following manner:
On August 12, 2007, and August 20, 2007 through March 19, 2008, you, by your
servants, agents or employees, failed to adhere to the conditions of the agreement entered into with the
Board placing additional restrictions upon the subject license, in violation of Section 404 of the Liquor
Code, 47 P.S. §4-404.
Timothy K. Tindale
Citation No. 08-1093
Page 2
2. On August 12, 2007 and December 22, 2007, you, by your servants, agents or
employees, sold, furnished and/or gave or permitted such sale, furnishing or giving of alcoholic
beverages to three (3) male niinors and one (1) female minor, eighteen (18) to twenty (20) years of age,
in violation of Section 493(1) of the Liquor Code, 47 P.S. §4-493(1).
3. On August 12, 2007, December 22, 2007, and one other occasion within the past year,
you, by your servants, agents or employees, permitted seven (7) male minors and one (1) female minor,
seventeen (17) to twenty (20) years of age, to frequent your licensed premises, in violation of Section
493(14) of the Liquor Code, 47 P.S. §4-493(14).
4. On January 12, 2008, you, by your servants, agents or employees, failed to require
patrons to vacate that part of the premises habitually used for the service of alcoholic beverages not
later than one-half hour after the required time for the cessation of the service of alcoholic beverages, in
violation of Section 499(a) of the Liquor Code, 47 P.S. §4-499(a).
5. On January 12, 2008, you, by your servants, agents or employees, permitted patrons to
possess and/or remove alcoholic beverages from that part of the premises habitually used for the service
of alcoholic beverages after 2:30 A.M., in violation of Section 499(a) of the Liquor Code, 47 P. S. §4-
499(a).
6. On January 12, 2008, you, by your servants, agents or employees, permitted music
played by a disc Jockey until 2:55 A.M., in violation of Section 493(10) of the Liquor Code, 47 P.S.
§4-493(10).
Timothy K. Tindale
Citation No. 08-1093
Page 3
NOW THEREFORE, you are hereby cited to appear before an Administrative Law Judge, on a
(late to be scheduled by the Office of Administrative Law Judge, to show cause why such license should
not be suspended or revoked or a fine imposed.
You have the right to retain legal counsel to represent you. If you (10 hire an attorney, he or
she must file a Notice of Appearance with the Office of Administrative Law Judge, Brandywine Plaza,
2221 Paxton Church Road, Harrisburg, Pennsylvania 17110-9661, and forward a copy to the Assistant
Counsel at the address listed below in accordance with 1 Pa. Code Subchapter C. Delay in obtaining
counsel is not reason for any continuance.
You have the right to waive your hearing. Such action is an admission to the charges. Should
you choose to waive, the proper form is enclosed for your convenience. Upon receipt, the Office of
Administrative Law Judge will process the forms and issue an adjudication.
BY ORDER
Bureau of Liquor Ca of Enforc t ent
MAJOR J N P. LUTZ r
Director
Date: June 19, 2008
Andrew J. Lovette, Assistant Counsel
Pennsylvania State Police
Bureau of Liquor Control Ep_forcement.
3655 Vartan Way
Harrisburg, PA 17110
Telephone: (717) 540-7413
VjYti?
COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA LIQUOR CONTROL BOARD
OFFICE OF ADMINISTRATIVE LAW JU7"1E
BRANDYWINE PLAZA
2221 PAXTON CHURCH ROAD
HARRISBURG, PA 17110-9661
TEL (717)540-7419/FAX (717)657-40
January 28, 2010
TIMOTHY K TINDALE
1239 MARKET ST
HARRISBURG PA 17103-2229
RE: Case No(s). 08-1093
LID 57466
Dear Licensee:
CITATION HEARING NOTICE
The hearing on the above citation case(s) to show cause why the license
issued to you by the Pennsylvania Liquor Control Board should not be
suspended or revoked, or a fine imposed, or both has been scheduled for
the time and place hereinafter set forth before Judge THAU.
DELAY IN OBTAINING LEGAL COUNSEL IS NOT REASON FOR CONTINUANCE.
If you intend to waive your right to the hearing in this citation
matter and if you file the waiver(s) with this office later than the
fifteenth (15th) day prior to the scheduled date contained in this
notice, the hearing may not be cancelled and you may receive minimal or
no consideration with regard to the penalty to be imposed.
DATE & TIME OF HEARING
PLACE OF HEARING:
Very truly yours,
March 11, 2010 at 10:00 AM
Brandywine Plaza
2221 Paxton Church Road
Harrisburg PA 17110-9661
EILEEN S. MAUNUS
Chief Administrative Law Judge
CERTIFIED MAIL - FIRST CLASS MAIL
Return Receipt Requested
CC:
Administrative Law Judge
PSP Counsel
Reporting Agency
File
DC-26 SCI CRESSON
COMMONWEALTH OF PENNSYLVANIA P.O. Box A
DEPARTMENT OF CORRECTIONS Cresson, PA 16699-0001
814-886-8181
DETAINER ACTION LETTER
OFFICE OF CHIEF COUNSEL SCI CRESSON
PA STATE POLICE
BUREAU OF LIQUOR CONTROL ENFORCEMENT DATE:
3655 VARTAN WAY 2/2/10
HARRISBURG PA 17110
ATTN: CONNIE L. YARRISH, LEGAL ASSISTANT 2
RE: REQUEST FOR INFO Inmate's Name: DOC NUMBER:
RYAN EUGENE ERLSTON HP3870
Dear Sir:
The below checked paragraph relates to the above named inmate:
() This office is in receipt of the following report regarding the above named:
Will you please investigate this report and advise what disposition, if any, has been made of
the case. If subject is wanted by your department and you wish a detainer placed, it will be
necessary for you to forward a certified copy of your warrant to us along with a cover letter
stating your desire to have it lodged as a detainer, or indicate you have no further interest in
the subject.
() A detainer has been filed against this subject in your favor charging . Release is
tentatively scheduled for . If this issue has been resolved, please forward the
appropriate documents to remove your detainer. If this detainer is still active, we will contact
your agency closer to the inmate's release date and make arrangements for you to transport
him back to your jurisdiction.
() Enclosed is your detainer warrant. Your detainer against the above named has been removed
in compliance with your request.
( ?1) Other - As per your request for information, I have enclosed the sentence orders for both
cases the inmate is currently serving and the DC16E which reflects the calculations.
Sincerely,
Sandra derula, RS
COMMONWEALTH OF PENNSYLVANIA
DC16E - SENTENCE STATUS SUMMARY DEPARTMENT OF CORRECTIONS
Name: Ryan Eugene Erlston Inmate #: HP3870 Certified Version 5 Dated 12/11/2009 3:26:03 PM
1.
DOC # Commitment Name
HP3870 RYAN EUGENE ERLSTON
DOB Place of Birth
06/23/1988 HARRISBURG PA USA
REFERENCES AND IDENTIFICATION
PBPP # SID # FBI #
26523036 879907MC5
Race
!B
Phila Photo #
Sent
Date I County/State/Federal
2. SENTENCE SUMMARY
Sent Minimum
Indictments Type -
Y M D
05/20/2008 ` Dauphin CP5212 CT2/2007 12 6 1 - 5
Plea: Plead Guilty OTN: K5819251 Judge: LEWIS, RICHARD A.
Offense: CC6106A1 - FIREARM NOT TO BE CARRIED W/O LICENSE
09/12/2008 Northumberland CP201 CT 1/2007 CC 16
Plea: Nolo Contendre OTN: K3576296 Judge: WIEST, WM. HARVEY
Offense: CS13A30 - DRUG - MANUFACTURE/SALE/DELIVER OR POSSESS W/INTENT TO
Sex
M
Maximum
Y M D
24
Rece
ti
D
t
p
on
a
e 05/29/2008 Reentered from DOC #
C
t
lli
Mi
on
ro
ng
nimum Date 07/07/2010 Tle
w Maximum - PV
Cont
lli
M
i fi
ro
ng
ax
mum Date 01/07/2.013 rue
Minimum Expiry Date
RRRI Mi
i
E
n
mum
xpiry Date
Summary or Remarks on Sentence
Remarks Version 5 created to reflect lifting of the Columbia Co Detainer.
Version 4 created to reflect removal of the Dauphin County detainer, CP-22-CR-1857-2008.
Version 3 created to reflect addition of Northumberland County sentence. This does not change the minimum
or maximum.
Version 2 created to correct commitment last name in mainframe.
Version 1 not distributed.
Boot Camp Recommended.
3. SENTENCE STRUCTURE
Commitment Credit
Computation 1 CP5212 CT2/2007 : 08/24/2007 to 12/14/2007, 04/29/2008 to 05/20/2008
12/11/2009 10:35:07 AM Inmate #: HP3870 - Ryan Eugene Erlston Version 5 Closed 12/11/2009 10:35:07 AM Page 1 of 3
Distribution: Inmate PBPP PSP BIS Counselor DC-15 Time File
Name: Ryan Eugene Erlston Inmate #: HP3870 Certified Version No:5 Dated 12/11/2009 3:26:03 PM
3. SENTENCE STRUCTURE (Contn'd)
Computation 2 CP201 CT 1/2007: 12/24/2006 to 02/20/2007
Remarks
Bail/Escape/Interruption Time Data
None
Item Computation 1 Computation 2
Indictments
included CP5212 CT2/2007 CP201 CT 1/2007
Eff Date 01/07/2008 07/15/2008
Expiration of
Minimum 107/07/2010 01/15/2009
Expiration of
Maximum 01/07/2013 07/15/2010
Custody
for Return
-PV
Delinquent
Time
Backtime
Credit
Backtime
Owed
New
Maximum
- PV
Sentence
Computation
Date 10/06/2008 10/06/2008
Basis for
Computation Initial Underlapping Concurrent
Total
Sentence 2Y6M - 5Y 6M - 2Y ?-
Status Active Active
12/11/2009 10:35:07 AM Inmate #: HP3870 - Ryan Eugene Erlston Version 5 Closed 12/11/2009 10:35:07 AM Page 2 of 3
Distribution: Inmate PBPP PSP BIS Counselor DC-15 Time File
Name: Ryan Eugene Erlston Inmate #: HP3870 Certified Version No:5 Dated 12/11/2009 3:26:03 PM
4. NON-INCARCERATED OFFENSES
Sent Date County/State/Federal Indictments
05/20/2008 Dauphin CP5212 CT2/2007
Description: CT3-Purch Etc Alcoh Bev By A Minor-NFP
=Iii;i and CP201 CT 1/2007
pay costs presecution, pay fine of $150.00; and ACT 35 pay a supervision fee of $50.00 a month while
on. Shall provide DNA sample as per Act 185 and pay all costs associated therewith. Comply
ral conditions of special probation by the PBPP.
Comments
5. DE TAINERS
Active Detainers
Detainer# Date ( Agency Agency Identification OTN Type
None
Deleted Detainers (For those deleted since last DC16)
Detainer# Date Agency Agency Identification OTN I Type
Deleted
Remarks SENTENCED 10/28/09 TO 11D TO 23M WITH AUTOMATIC PAROLE WITH CREDIT FOR 11D/23 M
PROBATION STARTING 10/28/09 UNDER COUNTY SUPERVISION
6. PRIOR DOC NUMBERS
Last Modified By: Gerula, Sandra D
Signed Off By: Koontz, Michele A
Certified By: Gerula, Sandra D
Institution: Cresson
12/11/2009 10:35:07 AM Inmate #: HP3870 - Ryan Eugene Erlston Version 5 Closed 12/11/2009 10:35:07 AM Page 3 of 3
Distribution: Inmate PBPP PSP BIS Counselor DC-15 Time File
7. ACTIONS: BOARD OF PARDONS
SCI CRESSCt _
SEP 17 2008
COMMONWEALTH bPE SYLVANIA * IN THE COURT OF COMMON PLEAS
INMA REC Hg OF NORTHUMBERLAND COUNTY, PA
* CRIMINAL COURT DIVISION
* NO. CR-07-201
RYAN E. ERLSTON, OTN: K 357629-6
DEFENDANT * CHARGE: POSSESSION WITH INTENT
TO DELIVER (CT. 1)
SENTENCE
AND NOW, this 12d day of September, 2008, the Defendant, Ryan E. Erlston, having pled no
contest, is hereby sentenced to pay the costs of prosecution, pay a fine in the amount of One Hundred Fifty
($150.00) Dollars and in accordance with the law pursuant to Act 35 pay a supervision fee of Fifty
($50.00) Dollars a month while on supervision to the Collector of Court Costs.
IT IS DIRECTED that the Defendant shall undergo imprisonment in a State Correctional
Institution for a period of not less than six (6) months nor more than twenty-four (24) months, with credit
being given for fifty-nine (59) days of time spent in confinement on this offense, unless by operation of law
it shall be computed otherwise. This sentence shall run concurrent to Dauphin County sentence.
IT IS DIRECTED that the Defendant be sent and delivered to the State Correctional Diagnostic
and Classification Center at Camp Hill, located at the State Correctional Institute at Camp Hill,
Pennsylvania, and thereafter to such Correctional Institution as shall be designated by the Deputy
Commissioner for treatment in accordance with the law and stand committed until this sentence of the
Court is complied with.
If the Defendant is accepted for supervision by the Pennsylvania Board of Probation and Parole,
the Defendant shall comply with all General Conditions of Special Probation as set forth in 37 Pa. Code
§65.4.
The Defendant shall provide a DNA sample as per Act 185 requirements and pay all costs
associated therewith.
BY THE COURT:
Wm. Harvey Wiest, Ju T
cc: District Attorney
Michael Romance, Esq.
Probation ` Fry, tr„
Sheriff `;.'? :•;
NCP (3) I1TOI,L?'??,IIZ?????hi?Zht?S
SCI Records aw uasfi
PA Board of Probation & Parole
Court Costs
Court
Extracted from the records
and ertified this l??da
of _ A A.D. 200Y
Clerk of Courts
My Commission Expires First
Monday of January, 2010
V?? ?u
DC-30CB (PART 1)
Rev. 12x/05
COURT COMMITMENT
STATE OR COUNTY CORRECTIONAL INSTITUTION
Commonwealth of Pennsylvania
v.
Ryan Eugene Erlston
COMMITMENT NAME: (Erlston, Ryan Eugene)
SEX DATE OF BIRTH SID OTN
F pX M 0612311988 265-23-03-6 K 581925-1
MANDATORY SENTENCE BOOT CAMP RECOMMENDED
- -110
P 3 Type or Print Legibly
i JOMMONWEALTH OF PENNSYLVANIA
DEPARTMENT
OF CORRECTIONS
BOX 598 CAMP HILL, PA 17001-0598
Attn: Central Office Records
U DC-300B (PART II) Attached
COURT OF INITIAL JURISDICTION COMMON PLEAS
COMMITTING COUNTY: Dauphin
COURT NUMBER AND TERM: 0005212-2007 Ct. 2
COUNTY REFERENCE #:
U Yes u No 0 Yes No
The above defendant after X Pleading Guilty Nolo Contendere Being Found Guilty GBMI
was on 05/20/2008, sentenced by Richard A. Lewis to Confinement for a term of not less than years, 30 months, days
not more than years, 60 months, days, or Other for the offense of Firearms Not To Be Carried W/O License (Section 18
§6106 §§A1 of the Crimes and Offenses Code). It-is further ordered that the said defendant be delivered by the proper authority to and
treated as the law directs at the SCI Camp Hill facility located at 2520 Lisburn RD, PO Box 8837, Camp Hill, PA 17001-8837.
Fine
Cost:
Restitution:
Amount $1,000.00 Amount $560.00 Amount $0.00
Balance $1,000.00 Balance $560.00 Balance $0.00
CREDIT FOR TIME SERVED (EXPLANATION OF CREDIT COMPUTATION ON PAGE TWO)
135 Days
THIS SENTENCE IS CONCURRENT WITH:
THIS SENTENCE IS CONSECUTIVE TO:
PROSECUTING ATTORNEY: DEFENSE ATTORNEY.
Dauphin County District Attorney's Office Lawrence Joseph Bartel III
DISPOSITION ON NON-INCARCERATION OFFENSE(S): (THIS BLOCK NOT TO BE USED FOR INCARCERATION OFFENSE)
Ct. 1 - Aggravated Assault - Withdrawn
Ct. 3 - Purch Etc Alcoh Bev By A Minor - No Further Penalty - Guilty Plea
AOPC 2116 REV. 05/21/2008
USED FOR
SENTENCE CERTIFICATION
In witness, whereof I have hereunto set my hand and seal of said
court, this _20 day of _May
2008
(SEAL) r
y, AUTHOR ED SIGN URE
Pagel of 2 Printed: 05121/2008 8:58AM
Y? f/7 K/
Crime Victim's Compensation Fund -
Victim/Witness Services Fund:
Amount $60.00
Balance $60.00
EFFECTIVE DATE OF SENTENCE
05/20/2008
I ne sentence for Erlston, Ryan Eugene was computed as follows:
Date of
Sentence County or
Ma
i
t
i
l Di
t
i Court Number
a
d Type Sentence Minimum Maximum Judge or OTN
g
s
er
a
s
ct
r n
Tenn
Yrs.
Days
Yrs.
Mos.
Days Magisterial
District Judge (Include Alpha
Suffix)
05/20/2008 Dauphin 0005212-2007 Ct 2 0 30 0 0 60 0 Lewis, Richard A. K 581925-1
Total Sentence
Credit for Time Served
Locked Up (Location) Dates No. of Days
From To
Dauphin County Prison 08/24/2007 12114/2007 113
Dauphin County Prison 04/29/2008 05120/2008 22
Total 135
All Detainers Must Be Attached To This Form Total Number Of Detainers Attached
Dated Indict - Warrant Nos. Remarks
Recommendations of the Court
Ct. 1 F2 - withdrawn. Ct. 2 F3 $1000 fine + costs. Eli ible for Boot Cam r). Ct. 3 S $100 fine + costs.
The Following Additional Reports are Attached
(DC-'300B, Parthll) t 11 Arrest Report ? FBI
? Pre / Postsentence ? Behavior Clinic El PSP
Investigation
Sentencing Sheet Sentencing Statement of
Guidelines Costs The Following Additional Reports will be Forthcoming
? Arrest Report El Presentence or
Postsentence Investigation
USED FOR
SENTENCE CERTIFICATION
AOPC 2116 REV. 05/2112008 Page 2 of 2 Printed: 05/21/2008 8:58AM
DC-14
CUMULATIVE
ADJUSTMENT RECORD
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF CORRECTIONS
SID
CSCU
Institudon
HP3870 I Erlston, Ryan E.
06/10/2008 Per Carol Nuhfer called Northumberland County Clerk of Courts 1-570-
988-4148 requesting a aled Sentencing Orders for OTN K4687793, CP202-2007
and OTN K3576296, CP201-2007 be faxed to us before original is mailed. Spoke with
Pat. Pat stated inmate has not been sentenced on either case yet. She stated these
are open cases- -------------------------------------- End of Text ---------------------------------
06/11/2008 Called Dauphin County Clerk of Courts 1-717-255-2692 regarding whether OTN
K7807450, CP1857-2008 should be lodged as a Detainer. Left message for Elizabeth
to fax a copy before sending original in mail. Elizabeth called back stating we need to
lodge Detainer. She will fax a copy before mailing certified copy. Received fax. --------
----------------------------------------------------- End of Text
11? ?J
Gloria Weaver
Records Specialist
USED FOR
SENTENCE CERTIFICATION
VERIFICATION
I, Thomas M. Ballaron, Assistant Counsel for the Pennsylvania State Police, Bureau
of Liquor Control Enforcement, verify that the statements made in this document are true and
correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§4904, relating to unsworn falsification to authorities.
Respectfully submitted,
PENNSYLVANIA STATE POLICE,
BUREAU OF LIQUOR CONTROL ENFORCEMENT
By: Thomas M. Ba aron
Assistant Counsel
3655 Vartan Way
Harrisburg, PA 17110
(717) 540-7414
Attorney I.D. #23370
Counsel for Petitioner
CERTIFICATE OF SERVICE
AND NOW, this ??e'day of February, 2010, I hereby certify that a copy of the
foregoing Petition for a Writ of Habeas Corpus Ad Testificandum of Pennsylvania State Police,
Bureau of Liquor Control Enforcement was served upon the Respondent by First Class Mail:
Superintendent John A. Palakovich
SCI Camp Hill
2500 Lisburn Road
Camp Hill, PA 17001-8837
(717) 737-4531
Superintendent Kenneth Cameron
SCI Cresson
Drawer A. Old Route 22
Cresson, PA 16699-0001
(814) 886-8181
Respectfully submitted,
PENNSYLVANIA STATE POLICE,
BUREAU OF LIQUOR CONTROL ENFORCEMENT
-loo
By: Thomas M. Ballaro
Assistant Counsel
3655 Vartan Way
Harrisburg, PA 17110
(717) 540-7414
Attorney I.D. #23370
Counsel for Petitioner
COMMONWEALTH OF PENNSYLVANIA
GOVERNOR'S OFFICE OF GENERAL COUNSEL
February 16, 2010
Dennis Lebo
Clerk of Courts
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013-3387
RE: Pennsylvania State Police. Bureau of Liquor Control
Enforcement v. Timothy K Tindale
Citation No. 08-1093
Dear Mr. Lebo:
Enclosed are original and four (4) copies of Petition for a Writ of Habeas Corpus Ad
Testificandum by the Pennsylvania State Police, Bureau of Liquor Control Enforcement with
regard to the above-captioned matter. We would request that your offices kindly time-stamp the
enclosed extra copy and return same to our offices for our records. We have enclosed a self-
addressed stamped envelope for your perusal.
Thank you very much.
Sincerely,
Z4?K__?
'-1 13
homas M. Ballaron
Assistant Counsel
TMB:cy
Enclosures
cc: Tanya Brandt, Department of Corrections, Transportation of Inmates (sent via Email)
Superintendent John A. Palakovich, SCI - Camp Hill (w/encl.)
Superintendent Kenneth Cameron, SCI - Cresson (w/encl.)
OFFICE OF CHIEF COUNSEL I PENNSYLVANIA STATE POLICE
BUREAU OF LIQUOR CONTROL ENFORCEMENT Pennsylvania
3655 VARTAN WAY I HARRISBURG, PA 17110 State Police
Ph: 717-540-7414 1 Fx: 717-540-7461 1 www oso state. oa us 11
1"LU ~.~ ~~1tJ,
'~~i~_J
4
''~` `~~'f',~'~
Thomas M. Ballaron, Assistant Counsel
PA Supreme Court ID #23370
Pennsylvania State Police
Bureau of Liquor Control Enforcement
3655 Vartan Way
Harrisburg, PA 17110
(717)540-7411
Z~~Q ~E~ 23 rz' ~~ ~ ~~
s
PENNSYLVANIA STATE POLICE IN THE COURT OF COMMON PLEAS OF
BUREAU OF LIQUOR CONTROL CUMBERLAND COUNTY, PENNSYLVANIA
ENFORCEMENT
vs. NO. ~d -l~S~ ~!V-~ L
l
TIMOTHY K. TINDALE ,
1239 MARKET STREET ,
HARRISBURG, PA 17103-2229 ,
DAUPHIN COUNTY
ORDER OF COURT
~~
AND NOW, to-wit, this ~..3 day of February, 2010, it is hereby ordered that the
Superintendent of the Camp Hill State Correctional Institution produce Ryan Eugene Erlston,
Inmate #HP3870 on March 11, 2010, at or around 8:30 a.m., and release him into the custody of
an on-duty trooper of the Pennsylvania State Police for the purpose of testifying in a hearing
before the Office of Administrative Law Judge, Pennsylvania Liquor Control Board. It is further
Ordered that Ryan Eugene Erlston be returned by the on-duty trooper of the Pennsylvania State
Police to the aforementioned facility immediately after giving his testimony in the above-
captioned case.
BY THE COURT:
oZ-~2„3 ~ld
~~Iot~£S rn~l~
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