HomeMy WebLinkAbout01-1766DUANELEBO
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
LICENSE RECALL APPEAL
LICENSE RECALL APPEAL
AND NOW, comes Petitioner, Duane Lebo, by and through his attorneys, Mancke, Wagner,
Hershey & Tully, and makes the following averments in support of this License Recall:
1. Petitioner, Duane Lebo, is an adult individual and a Pennsylvania licensed driver
with a residence address of 661 West Old York Road, Carlisle, Cumberland County,
Pennsylvania 17013.
2. Respondent, Pennsylvania Department of Transportation, Bureau of Driver
Licensing, has a mailing address at Riverfront Office Center, Third Floor, 1101
South Front Street, Harrisburg, Dauphin County, Pennsylvania 17104-2516.
3. Petitioner received a notice of license suspension by way of letter dated February
24, 2001 fror~ the Department of Transportation indicating that his Pennsylvania
ddving privileges are to be recalled on March 31, 2001. See Exhibit "A" attached
hereto and incorporated herein by reference.
4. The specific issue complained of by the Department of Transportation was that
Petitioner has a seizure disorder that could affect his ability to drive.
5. The Department's recall action is illegal, improper, and invalid for some or all of the
fol!owing reasons:
Petitioner does not have a seizure condition which prevents him from safely
operating a motor vehicle;
Petitioner's accident which triggered the Department's notice, in the opinion
of his treating neurologist, was a fainting episode as a result of severe chest
pain, not a seizure;
Petitioner's treatiT)g neurologist has more information to adequately evaluate
Petitioner than the information received by the Department of Transportation
from the emergency room physician at Cadisle Hospital; and
According to Petitioner's neurologist, he is safe to operate a motor vehicle
notwithstanding any pre-existing medical condition.
The Department's action is in violation of Petitioner's rights under the
Americans with Disabilities Act, the Federal Rehabilitation Act of 1973, and
the Pennsylvania Human Relations Act because Petitioner is an individual
affected with a disability and the Department of Transportation, as an entity
receiving government funding, is therefore subject to the provisions of the
above three mentioned Acts;
WHEREFORE, Petitioner respectfully requests that this Court issue a stay on the
Department of Transportation's proposed action recalling his license effective March 31, 2001 anti
schedule a hearing to determine the validity of the suspension proposed by the Department in
Exhibit "A",
Date: 03/23/0'1
Respectfully submitted,
MANCKE WAGNER HERSHEY & TULLY
· . ey, Esquire
I.D. #43092
2233 North Front Street
Harrisburg, PA '17110
(717) 234-705'1
3
VERIFI(~.ATION
I verify that the statements made in the foregoing document are t~ue and correct to the best
of my knowledge, Information, and belief, I understand that false statements herein are made
subject o the penalties of 18 Pa.C.S. ~4904 relating to unswom falsification to aufl'~orities.
Date: C~ 3/~ ?
~ DUANE L'BO~E~~
CERTIFICATE OF SERVICE
I, '[ammy L. Kelly, an employee of the law firm of MANCKE WAGNER HERSHEY & TULLY,
hereby certify that I am this day serving a copy of the foregoing document to the attomeys or
parties of record in the manner indicated below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail,
postage prepaid, at Harrisburg, Pennsylvania, on the 23~d day of March, 2001, at the address listed
below:
George Kabusk, Esquire
Office of Chief Counsel
PA Department of Transportation
Riverfront Office Center, Third Floor
1101 South Front Street
Harrisburg, PA 17104-2516
MANCKE WAGNER HERSHEY & TULLY
recalszr
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Mail Date: February 24, 2001
DUANE LEBO
661 W OLD YORK RD
CARLISLE PA 17013
Dear Mr, DUANE LEBO:
We have received medical information indicating that you have a Seizure Disorder condition
which prevents you from safely operating a motor vehicle.
As of 03/31/2001, you may no longer drive. Your driving privilege is hereby recalled
indefinitely as mandated by Section 1519(c) of the Vehicle Code.
This decision has been made by comparing your medical condition with the standards
recommended by our Medical Advisory Board and adopted by this Department. This action will
remain in effect until we receive medical information that your condition has improved and you
are able to safely operate a motor vehicle.
Since you have a seizure disorder, you must remain seizure free for a six month period, with or
without medication, before you will be eligible for reinstatement of your driving privilege. Our
records indicate that your seizure occurred on 2/8/01.
In order to comply with this action, you must return all current Pennsylvania driver's licenses,
learnerg permits, temporary driver's licenses (camera cards) in your possession, on or before the
effective date listed above. If you cannot comply with the requirements stated above, a sworn
affidavit stating that you are aware of the sanction against your driving privilege must be
submitted. When the Department receives your license or affidavit, we will send you a receipt.
YOU MAY NOT RETAIN YOUR DRIVEI~'S LICENSE FOR IDENTIFICATION
PURPOSES. However, you may apply for and obtain a photo identificatiou card at any Driver
License Center. You nmst present two (2) forms of proper identification (e.g., birth certificate,
valid U.S. passport, marriage certificate, etc.) iii order to obtain your photo identification card.
You have the right to appeal to the Court of Common Pleas (Civil Division) within thirty (30)
days of the mail date of this notice. If you file an appeal in the County Court, the Court will give
you a time-stamped certified copy of the appeal. Il/order for your appeal to be valid, you must
send this tilne-stamped certified copy of the appeal by certified mail to:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfl'ont Office Center
Harrisburg, PA 17104
You still must send in your license before the effective date of recall unless you appear iu person
before a judge and receivk an order permitting you to coutinue driving.
If you have any questions or need further information, please contact the Medical Unit, P.O. Box
68682, Harrisburg, PA 17106-8682 or call (717) 787-9662 between the hours of 8:00 a.m, aud
4:30 p.m.
Driver License #:
Sincerely,
Rebecca L. Bickley, Director
l~ureau of Driver Liceusing
15713702
~z
r- ITl
DUANELEBO :
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. OIt
LICENSE RECALL APPEAL
ORDER OF COURT
AND NOW, thiso2'~'~ day of ~-0)~./zc~, 2001, the court being advised that this matter is a
medical recall and that Petitioner is entitled to an independent determination by the Court as to
whether or not he is entitled to a supeo~,deas pending the outcome of a ,hearing, a hearing on the
supersedeas only is scheduled for .:~z~z~ ~/..~j~, 2001 at/-' o clock ._.q...m. in Courtroom
#'7'.
A hearing on the merits of this appeal is scheduled for the ~'~ day of ~,.z.~t ~ ,2001,
at 9; ~ o'clock _~L.m. in Courtroom Number z~ , Cumberland County ~ourthouse, One
Courthouse Square, Carlisle, Cumberland County, Pennsylvania, all proceedings to stay
meanwhile.
Notice of the hearing on the merits shall be given by Petitioner's counsel to the Department
of Transportation at least sixty (60) days 3riot to the date of said hearing.
Distribution:
Prothonotary's Office
Office of Chief Counsel, PennDOT
BY THE COURT:
1101 S. Front St., Harrisburg, PA 17104-2516
David E Hershey, Esquire
2233 N. Front St., Harrisburg, PA 17110
THREE SPRINGS
FAMILY PRACTICE
H. ROBERT DAVIS, MD
MICHAEL O. DANIELS, MD
DAVID A. DELL, MD
KELLI L. SCURFIELD, PA-C
David E. Hershey
Mancke, Wagner, Hershey & Tully
2233 N. Front Street
Harrisburg PA 17110
Re: Duane L. Lebo
DOB 11/22/52
Dear Mr. Hershey:
This letter is in response to your correspondence concerning Duane Lebo.
In review, Mr. Lebo experienced the onset of chest pains in early February. On
February 8th, he apparently had a rather severe episode of discomfort in his
chest while operating his motor vehicle at the Sheetz convenience store in Mt.
Holly Springs. Subsequent events, ascertained from Emergency Room
documentation and Duane's recollection, include EMS notification with transport
to the hospital ER in Carlisle. A grand mai seizure was witnessed by ambulance
personnel, and the ER physician describes Duane as post-ictal (somnolence
after a seizure). Dilantin and phenobarbital levels were recorded as
subtherapeutic. Due to the chest pain and concern for myocardial ischemia,
Duane was admitted to the hospital's chest pain clinic to undergo further
evaluation. He underwent serial enzyme testing, electrocardiograms and a
subsequent exercise echocardiogram. Based upon these studies, the chest
pains were not felt to be of cardiac origin.
Persistent symptoms led him to our office on 2/13/01 for follow-up. An
upper gastrointestinal x ray and abdominal ultrasound were ordered to evaluate
further his symptoms of abdominal (epigastric) and chest pain. These studies
were unrevealing as to a cause for his pain. Subsequently, he developed a
rather sharp pain localizing to the costosternal junction. He was felt to have
costochondritis. However, anti-inflammatory medication did not seem to help;
anti-acid therapy was reinstituted and a consult was requested with Dr. Berk, a
gastroenterologist, to further evaluate his pain.
Mr. Lebo is currently under the care of Dr. Richard Brown for his seizure
disorder. As to specific recommendations concerning his dosage of medication
"~ PI=Ill lOlL .'~
MT. HOLLY SPRINGS, PA ! 7065
303 NORTH BALTIMORE AVENUE
717-486-8550
Page Two
March 16, 2001
Re: Duane Lebo
for seizures, driving precautions, or seizure control, I would defer to Dr. Brown's
expertise as a neurologist. Further work-up of Duane's chest pain is ongoing at
this time.
Sincerely,
David A. Dell, M.D.
DAD/Pg
NEUROLOGY
RICHARD B. BROWN, M.D., f:A.C.P.
2645 NORTH THIRD STREET, SUITE 4S0
HARRISBURG, PENNSYLVANIA 17110-2OO1
March 26, 2001
Judges of Cumberland County
Attn: David E. Hershey, Esquire
2233 North Front Street
Harrisburg, PA 17110
RE: Duane L. Lebo
To Whom It May Concern:
I am the treating neurologist who has cared for Mr. Lebo's convulsive disorder
since February 28, 1980. Mr. Lebo has been a very compliant patient and has had no
seizure activity for at least several years.
There was an event on February 8, 2001, in which he had severe pain in his chest
causing him to faint. His situation was reviewed by a Carlisle neurologist, J. Craig
Jurgensen, M.D. while he was a patient in the emergency department of the Carlisle
Hospital. When I saw the patient subsequently on February 27, 2001, I reviewed the
situation completely and took note of the fact that Mr. Lebo did not have any of the usual
symptoms associated with his seizure activity. Dr. Jurgensen and I independently
concluded that Mr. Lebo had had an episode of syncope associated with severe pain,
however, he was reported to the Pennsylvania Department of Transportation in error as
having had a seizure.
After taking Mr. Lebo's complete history, performing a complete neurological
examination, after having performed appropriate therapeutic drug monitoring, and having
spoken with Dr. Jurgensen, I conclude, with a reasonable degree of medical certainty that
he did not have a seizure on February 8, 2001, and that he is safe to operate a motor
vehicle and is not prohibited from doing so as a result of any medical condition.
Sincerely,
Richard B. Brown, M.D.
RBB/tlp
DL-326 (9/95)
DATE MARCH 29, 2001
CERTIFICATION
I hereby certify that Rebecca L. Bickley, Director of the Bureau of Driver Licensing of the Pennsylvania
Department of Transportation, is the legal custodian of the Driver License records of the Pennsylvania Department of
Transportation. As the Director of the aforesaid Bureau, she has legal custody of the original or microfilm records which are
reproduced Jn the attached certification.
IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL OF THIS
DEPARTMENT THE DAY AND YEAR AFORESAID.
BRADLEY L. MALLORY, SECRETARY OF TRANSPORTATION
I HEREBY CERTIFY THAT THE FOREGOING AND ANNEXED IS A FULL, TRUE AND CORRECT
CERTIFIED PHOTOSTATIC COPY OF:
1) OFFICIAL NOTICE OF RECALL DATED & MAILED 02/24/01, EFFECTIVE 03/31/01; 2) INTIAL REPORTING
FORM, DATE OF EXAMINATION 02/08/01; 3) LETTER DATED 10/13/00, TO THE OPERATOR APPROVING
CONTINUANCE TO DRIVE; 4) CONVULSIVE DISORDER REPORTING FORM DATED 09/28/00; 5) INITIAL
REPORTING FORM, DATE OF EXAM 08/19/00; 6) LETTER DATED 09/18/00 TO THE OPERATOR REQUIRING
PHYSICAL EXAM AND/OR DRIVER'S TEST AND CONVULSIVE DISORDER REPORTING FORM TO BE
COMPLETED BY A PHYSICIAN, AND 7) DRIVING RECORD, WHICH APPEARS IN THE FILE OF THE
OPERATOR DUANE LUTHER LE00, OPERATOR'S NO. 15713702, DATE OF BIRTH 11/27/52, IN THE BUREAU
OF DRIVER LICENSING, HARRISBURG, PENNSYLVANIA.
CERTIFIED TO as prescribed by Sections 6103 and 6109 of the Judicial Code, Act of July 9, 1976, P.L. 586, as
amended, 42 Pa.C.S. §§6103 and 6109.
IN TESTIMONY WHEREOF, I HAVE HEREU NTO SET MY HAND ANt~A~~D Y~AID.
SEAL
REBECCA L. BICKLEY, DIRECTOR ~1~.¥
BUREAU OF DRIVER LICENSING
COMMONWEALTI~S
EXHIBIT
.3'~"~ 'OI L_ICF
recalszr
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Mail Date: February 24, 2001
DUANE LEBO
661 W OLD YORK RD
CARLISLE PA 17013
Dear Mr. DUANE LEBO:
We have received medical information indicating that you have a Seizure Disorder condition which
prevents you frorn safely operating a motor vehicle.
As of 03/31/2001, you may no longer drive. Your driving privilege is hereby recalled indefinitely as
mandated by Section 1519(c) of the Vehicle Code.
This decision has been made by comparing your medical condition with the standards recommended by
our Medical Advisory Board and adopted by this Department. This action will remain in effect until
we receive medical information that your condition has improved and you are able to safely operate a
motor vehicle.
Since you have a seizure disorder, you must remain seizure free for a six month period, with or without
medication, before you will be eligible for reinstatement of your driving privilege. Our records indicate
that your seizure occurred on 2/8/01.
In order to comply with this action, you must return all current Pennsylvania driver's licenses, learner's
permits, temporary driver's licenses (camera cards) in your possession, on or before the effective date
listed above. If you cannot comply with the requirements stated above, a sworn affidavit stating that
you are aware of the sanction against your driving privilege must be submitted. When the Department
receives your license or affidavit, we will send you a receipt.
YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR IDENTIFICATION
PURPOSES. However, you may apply for and obtain a photo identification card at any Driver
License Center. You must present two (2) forms of proper identification (e.g., birth certificate, valid
U.S. passport, marriage certificate, etc.) in order to obtain your photo identification card.
You have the right to appeal to the Court of Common Pleas (Civil Division) within thirty (30) days of
the mail date of this notice. If you file an appeal in the County Court, the Court will give you a time-
stan~ped 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
You still must send in your license before the effective date of recall unless you appear in person before
a judge and receive an order permitting you to continue driving.
If you have any questions or need further information, please contact the Medical Unit, P.O. Box
68682, Harrisburg, PA 17106-8682 or call (717) 787-9662 between the hours of 8:00 a.m. and 4:30
p.m.
Sincerely,
Driver License #:
Rebecca L. Bickley, Director
Bureau of Driver Licensing
15713702
'OL 43 I4-9=~ DEPARTMENT OF TRANSPORTATION FOR BUREAU USE ONLY
\ BURE.~U OF DRIVER LICENS(NG Date Received ~ .,.
INITIAL REPORTING FORM Oriwr~
~.~J~l~l~.~! (Print or Type Requeste8 Information) Reference
DEAR PROVIDER: Although the Department seeks your judgement about your patienCs medical fitness to safely operate
motor vehicle, the decision about your patient's driver's license is ~t responsibility of the Depar~men
Bureau of Driver Licensing which must also take into account ether considerationS'.'. Please complete
PATIENT INFORMATION DATE ~ BIRTH
DIAGNOSIS OF DISORDER OR
P/ease Che~ (~) appfop~ate items
~ Loss or Impairment of e Foot, Lag, ~nger, Th~bs, or Hand. - Condition:
~ Unstable Diabetes
~ Cerebral Vascular Disease
~ Cardiovascular Disease
~ Neurological Disorder ~ ~,* ¢~. ¢~ ~ ~;~:*'
~ Mental Deficiency or Marked Mental Retardation ~%~ ~ ~ ~ [
~ Mental or Emotional Disorder
a Alcohol Abuse FEB i 2 2001
~ Drug or Controlled Substance Abuse ' '~
~ Vision Deficiency ~mDRtVERoF DRIVERSAF~TY D
LICEnSinG
~ Other Medical Condition which would intedere with the patient's ability to drive.- Exp~?':
Comments:
Do these conditions affect the patient's ability, from a medical standpoint only, to safely operate a motor
vehicle? J~J YES i~ NO
SeizureDisordar:,~(~,¥ES C~N,O_ Date of Last Seizure:
Does the patient meet any of the Departmenrs waiver requirements? i~ YES (~ NO
If yes. please explain
ALL INFORMATION IS CONFIDENTIAL AS PROVIDED IN THE PA VEHICLE CODE, SECTION 1518(3)
,,ov,,,,.s,oe. s
mmlO
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Mail Date: October 13, 2000
DUANE LEBO
661 W OLD YORK RD
CARLISLE PA 17013
Dear Mr. DUANE LEBO:
I am pleased to inform you that you have met the Department's medical standards. You may continue
to drive. Please drive safely.
If you have any questions, please contact the Medical Unit at (717) 787-9664, between the hours of
8:00 a.m. and 4:30 p.m.
Driver License #:
Sincerely,
Rebecca L. Bickley, Director
Bureau of Driver Licensing
15713702
DL-121 (?97)
PATIENT INFORMATION
DRIVER'S LICENSE NUMBER
15713702
HEIGHT SEX
FEET~_ I INCHES/[ ~
STREET ADDRESS
661 W OLD YORK RD
CONVULSIVE DISORDER
REPORTING FORM
PA Deparlment ol Transportation
Bureau of Driver Licensing
P.O. Box 68682
Harrisburg, PA 17106-8682
(717) 787-9662
I LAST NAME(S) JR, ETC. I FIRST NAME
LEBO -* DUANE
EYE COLOR SOCIAL SECURITY NUMBER DATE OF BIRTH PHONE NUMBER
CITY STATE ZIP CODE
CARLISLE PA 17013
1. Has the patient been diagnosed as having a seizure disord(~r * ? ....................
,¢~ ~r-~,~l/- /c)~ ~-ooo
If yes, date of last episode
2. Ha~ the patient had an EEG? It yes, date o~ EEG
3. Is the patient being trea~ with medic~tiDm~ ~s~typ~ a~ dosage
4. Does the m~ication affect th~tie~ s ability to safely operate a 'm~r vehicle ..........
5.Does the patient have seizure episodes aEributable to a prescribed change in or removal
from medication? ............................................................
I~ yes, date of last episode?
Has the original medication been reintroduced?
6.Does the patient have seizure episodes always preceded by a specific prolonged aura? .
If yes, what is the durationpf the ~ura? ~
HOW is it manifested? A ~j~---- ~
How long has the p~tient experienced this aura?
7.Does the patient experience only an aura? ........................................
How long has the patient experienced this aura?
8.Does the patient have a pa~ern of seizure episodes o~urring only during sleep or
immediately upon awakening? .................................................
If yes, how long has the patient experienced this pa~ern?
9. Does the patient have seizure episodes a, ributable to a ~~transient ~llnes~toxic
If yes, please explain
10. Has the patient been diagnosed as having episodes of loss of oonsol~r awareness
whioh would inte~ere with the safe operation of a motor vehiole? ......................
· SEIZURE DISORDER - More than one sei~re or ~ single seizure of elect~cally diagnosed epilepsy.
PHYSICIAN INFORMATION (Please print or ty~)
' DL-13 (~-g3)
DEPARTMENT OF TRANSPORTATION FOR BUREAU USE ONLY
BUREAU OF DRIVER LICENSING Date Received ·
INITIAL REPORTING FORM or~vers
(Print or Type Requested Information) Reference
DEAR PROVIDER: Although the Department seeks your judgement about your patient's medical fitness to safely operate
motor vehicle, the decision about your patient's driver's license is a responsibility of the Department'
Bureau of Driver Licensing which must also take into account other considerationS. Please complete Section
A, B, C, and D.
PATIENT INFORMATION
LE60
I:)~TE Of: 81RTH
DATE OF EXAMINATION:
DIAGNOSIS OF DISORDER O~ DISABILI~:
Piea~e Che~ [~1 ~pro~a~e items
~ Loss or Impairment of a Foot, Leg, ~nger. Th~bs, or Hand. - Condition:
~ Unstable Diabetes
~ Cerebral Vascular Disease
~ Cardiovascular Disease
~ Loss of Consciousness- C=use:
~ Neurological Disorder
~ Mental Deficiency or Marked Mental Retardation
~ Mental or Emotional Disorder
~ Alcohol Abuse
~ Drug or Controlled Substance Abuse
[~ Vision Deficiency ...... - ......
~ Other Medical Condition which would interfere with the patient's ability to drive. - Explain:
Do these conditions affe~ the patient's abii[~, from a medioal standpoint only, to safely operate a motor
vehicle?~YES ~ NO
Does the patient meet any of th~Oepa~me~t's waiver reqdremems? ~ YES ~NO
ff yes, p~ase
PROVIO~R'S NAME
-7-]E'O/V /...
STATE PHYSICIAN
Return this form to:
ALL INFORMATION IS CONFIDENTIAL AS PROVIDED IN THE PA ~EHICLE CODE, SECTION 1518(3)
(7/7)
BUREAU OF DRIVER LICENSING - DRIVER QUALIFICATIONS SECTION - P.O. BOX 6868~
mml7
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Mail Date: September 18, 2000
DUANE LEBO
661 W OLD YORK RD
CARLISLE PA 17013
Dear Mr. DUANE LEBO:
Information submitted to the Department indicates that you may have a Seizure Disorder condition that
could affect/limit your ability to drive. In order to determine if you meet the Department's medical
standards for driving, it is necessary that you undergo a physical examination and/or a driver's test. The
enclosed form(s) must be completed by your physician and returned to the Bureau of Driver Licensing.
I have enclosed a self-addressed envelope for your convenience.
If you fail to comply with this request within 30 days from the date of this letter, your driving privilege
will be suspended.
If you have any questions, please contact the Medical Unit at (717) 787-9664 between the hours of
8:00 a.m. and 4:30 p.m.
Sincerely,
Driver License #:
Enclosures:
Rebecca L. Bickley, Director
Bureau of Driver Licensing
15713702
DL-121: Convulsive Disorder Reporting Form
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
BUREAU OF DRIVER LICENSING
CERTIFIED DRIVING HISTORY
MAR 27 2001
PAGE 1
DRIVER: DUANE LUTHER LEBO
661 W OLD YORK RD
CARLISLE, PA 17013
DRIVER LICENSE (DL)
LICENSE CLASS : C
LICENSE ISSUE DATE: NOV 30 2000
LICENSE EXPIRES : NOV 23 2004
MED RESTRICTIONS : NONE
LEARNER PERMITS :
LICENSE STATUS : PEND RECALL
DRIVER LICENSE NO : 15713702
DATE OF BIRTH : NOV 22 1952
SEX : MALE
RECORD TYPE : REG LICENSE
COMMERCIAL DRIVER LICENSE (CDL)
CDL LICENSE CLASS :
CDL LICENSE ISSUED :
CDL LICENSE EXPIRES:
CDL ENDORSEMENTS : NONE
CDL RESTRICTIONS : NONE
CDL LEARNER PERMITS:
CDL LICENSE STATUS : PEND RECALL
SB ENDORSEMENT :
PROBATIONARY LICENSE (PL)
PL LICENSE CLASS :
PL LICENSE ORIG ISS:
PL LICENSE ISSUED :
PL LICENSE EXPIRES :
PL LICENSE STATUS :
OCCUPATIONAL LIMITED LICENSE (OLL)
OLL LICENSE CLASS :
OLL LICENSE ISSUED :
OLL LICENSE EXPIRES:
OLL LICENSE STATUS :
*** CONTINUED ***
PAGE 2
CERTIFIED DRIVING HISTORY - MAR 27 2001 - LICENSE NUMBER 15713702 CONTINUED
REPORT OF VIOLATIONS AND DEPARTMENTAL ACTIONS
NO VIOLATIONS OR DEPARTMENTAL ACTIONS DURING THIS REPORTING PERIOD
REPORT OF MEDICALS AND DEPARTMENTAL ACTIONS
ACTION:
ACTION:
MEDICAL EXAM ORDERED
RECALL-GENL MEDICAL EFFECTIVE MAR 31 2001
GENMED RECALL
OFFICIAL NOTICE MAILED FEB 24 2001
NO ACCIDENTS DURING THIS REPORTING PERIOD
*** END OF RECORD ***
PAGE 3
CERTIFIED DRIVING HISTORY - MAR 27 2001 - LICENSE NUMBER 15713702 CONTINUED
IN COMPLIANCE WITH YOUR REQUEST, I HEREBY CERTIFY THAT I
HAVE CAUSED A SEARCH TO BE MADE OF THE FILES OF THE DEPART-
MENT OF TRANSPORTATION, AND HAVE SET FORTH ABOVE AN ACCURATE
SUMMARY OF ALL RECORDS IN THE NAME OF THE PERSON INDICATED.
SINCERELY,
SEAL
DIRECTOR, BUREAU OF DRIVER LICENSING
FOR
SECRETARY OF TRANSPORTATION
COMMONWEALTH OF PENNSYLVANIA SS:
DATE:MAR 27 2001
I HEREBY CERTIFY THAT
BUREAU OF DRIVER LICENSI!
OF TRANSPORTATION IS THE
LICENSING THE
THE DIRECTOR
OF THE ORIGINAL OR MI
OF THE
BICKLEY, DIRECTOR OF THE
THE PENNSYLVANIA DEPARTMENT
OP THE DRIVER
TRANSPORTATION. AS
CUSTODY
THE SUBJECT
IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL
OF THIS DEPARTMENT THE DAY AND YEAR AFORESAID.
SINCERELY,
SECRETARY OF TRANSPORTATION
SEAL
COMMONWEALTH OF PENNSYLVANIA:
DEPARTMENT OF TRANSPORTATION:
BUREAU OF DRIVER LICENCING :
Plaintiff :
V. :
DUANE L. LEBO, :
Defendant :
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND cOLrNTY, PENNSYLVANIA
01-1766 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of March, 2001, the
request for supersedeas is granted, pending full hearing of this
matter.
By the Court,
Terrance M. Edwards, Esquire
For the Commonwealth
David Hershey, Esquire
For the Defendant
it
K~A. Hess, J.