HomeMy WebLinkAbout10-2544DANIELLE JEAN GEORGE,, IN THE COURT OF COMMON PLEAS OF
Appellant CUMBERLAND COUNTY, PENNSYLVANIA
V. ` No. 16- - I
COMMONWEALTH OF LICENSE SUSPENSION APPEAL
PENNSYLVANIA,
PENNSYLVANIA DEPARTMENT •v
OF TRANSPORTATION, _
BUREAU OF DRIVER r'
'
330
51
ni m
LICENSING, s"
Appellee
APPEAL FROM SUSPENSION OF OPERATOR'S c?
PRIVILEGE
AND NOW comes the Appellant, Danielle Jean George, by and through her attorney,
Michael O. Palermo, Jr., Esquire, and avers the following:
1. Appellant resides at 189 Frost Road, Gardners, Pennsylvania 17324.
2. Appellant received Notice dated March 19, 2010, stating that as authorized by Section 1538
of the Pennsylvania Vehicle Code, as a result of her failure to attend departmental hearing
her driving privilege was being suspended for a period of sixty (60) days, effective
November 20, 2010. A copy is attached hereto as Exhibit "A".
3. This administrative order of the Pennsylvania Department of Transportation suspending /
revoking / recalling / otherwise restricting his license is improper, and done without
statutory authority, and is unlawful as there was no refusal to attend the hearing as
Appellant called Penn Dot and informed them that she did not have a ride to the hearing.
4. Appellant reasonably believed that the hearing would be continued to a date that she
could obtain a ride to the hearing.
ga.?0 I'd -may
WHEREFORE, your Appellant respectfully requests this Honorable Court grant her relief
and that she be granted the right to go forward with a license suspension appeal and pending the
same a Supersedeas be granted.
Respectfully submitted,
Rominger & Associates
Date: April 19, 2010 Tax&A /1-0*4 -
Michael O. Palermo, Jr., squire
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court ID # 93334
Attorney for Appellant
DANIELLE JEAN GEORGE,
Appellant
v.
COMMONWEALTH OF
PENNSYLVANIA,
PENNSYLVANIA DEPARTMENT
OF TRANSPORTATION,
BUREAU OF DRIVER
LICENSING,
Appellee
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No.
: LICENSE SUSPENSION APPEAL
CERTIFICATE OF SERVICE
I, Michael O. Palermo, Jr., Esquire, attorney for Appellant, do hereby certify that I this day
served a copy of the Appeal From Suspension Of Operator's Privilege upon the following by
depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania,
addressed as follows:
Pennsylvania Department of Transportation
Office of Chief Counsel
'Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516
Respectfully submitted,
Rominger & Associates
Date: April 19, 2010
Michael O. Palermo, Jr., Esqui e
155 South Hanover Street
Carlisle, Pennsylvania 17013
(717) 241-6070
Supreme Court ID # 93334
Attorney for Appellant
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Harrisburg, PA 17123
MARCH 19, 2010
DANIELLE JEAN GEORGE WID # 100716543410642 002
189 FROST ROAD PROCESSING DATE 03/12/2010
DRIVER LICENSE # 28023599
GARDNERS PA 17324 DATE OF BIRTH 12/11/1987
LICENSE IN BUREAU
Dear Motorist:
Due to your failure to attend a departmental hearing, a
sanction of 60 DAY(S) is imposed as mandated by Section 1538
of the Vehicle Code.
The effective date of suspension is 11/20/2010, 12:01 a.m.
The above mentioned sanction is in addition to any pre-
viously issued sanction(s).
APPEAL
You have the right to appeal this action to the Court of
Common Pleas (Civil Division) within 30 days of the mail
date, MARCH 19, 2010, of this letter. If you file an appeal
in the County Court, the Court will give you a time-stamped
certified copy of the appeal. In order for your appeal to
be valid, you must send this time-stamped certified copy of
the appeal by certified mail to:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516
Sincerely,
9?-x ?-- Z go",)
Janet L. Dolan, Director
Bureau of Driver Licensing
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