HomeMy WebLinkAbout02-0067 SAIDIS
SI-IUFF, FLOWER
& LINDSAY
A1TORI~YS,AT*LAW
26 W. High Street
Carlisle, PA
COMMONWEALTH OF PENNSYLVANIA
VS.
ADAM D. LINDSAY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2002-~~'
APPEAL FROM DRIVERS LICENSE
SUSPENDED
NOW come Adam D. Lindsay and Petitions this Honorable Court as follows:
1. Petitioner resides at 69 Parker Street, Carlisle, Cumberland County,
Pennsylvania.
2. Petitioner is duly licensed to operate motor vehicles in the
Commonwealth of Pennsylvania, Operator's License 25951485.
3. On December 3, 2001, the Director of the Bureau of Driver Licensing,
Pennsylvania Department of Transportation, suspended Petitioner's operating
privileges effective January 7, 2002 under the authority of Section 1532(B) of the Motor
Vehicle Code.
4. The order of the Director of the Bureau of Traffic Safety Operations is illegal,
arbitrary, unreasonable, and an abuse of discretion and contrary to the law.
WHEREFORE, Petitioner respectfully prays that this appeal be allowed and that a
hearing de novo be granted to determine whether Petitioner is subject to suspension of
operating privileges and that this appeal act as a supersedeas pending the hearing,
and that upon conclusion thereof, the order of the Direction of the Bureau of Traffic
Safety Operations be vacated and the appeal sustained.
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
ATTORNEYS FOR PETITIONER
BY: .... /CFfol 3. Lindsay, Esquire
/.J~# 44693
"'26 West High Street
Carlisle, PA 17013
(717) 243-6222
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS*AT*LAW
26 W. High Street
Carlisle, PA
VERIFICATION
I, the undersigned, hereby verify that the statements made herein 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.
Adam D~_lp~nd say
Date:
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
COMMONWEALTH OF PENNSYLVANIA
vs.
ADAM D. LINDSAY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 2002- (,-/
ORDER OF COURT
AND NOW this /~-(Z day of January, 2002, upon consideration
of the within Petition for Appeal from the Order of the Director of Bureau of Driver
Licensing, Department of Transportation, suspending the operating privileges of Adam
D. Lindsay and on Motion of Carol J. Lindsay, Esquire, attorney for Adam D. Lindsay, a
hearing is granted de novo to determine whether the Petitioner is subject to suspension
of his operating privileges.
This appeal shall act as a supersedeas of the suspension Order.
A hearing is set for the /~'~ dayof
Room No. ~ , of the Courthouse at Carlisle, Pennsylvania at
o'clock f . . m.
,2002 in Court
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
COMMONWEALTH OF PENNSYLVANIA
VS.
ADAM D. LINDSAY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:
: NO. 2002- 67
PRAEClPE TO WITHDRAW APPEAL
TO THE PROTHONOTARY:
Please withdraw the Appeal of Adam D. Lindsay from the Order of the Director
of Bureau of Driver Licensing, Department of Transportation, in the captioned case.
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
ATTORNEYS FOR ADAM D. LINDSAY
BY:
26 West High Street
Carlisle, PA 17013
(717) 243-6222
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
COMMONWEALTH OF PENNSYLVANIA
vs.
ADAM D. LINDSAY
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:
: NO. 2002- 67
CERTIFICATE OF SERVICE
AND NOW, THIS -~7 DAY OF
2002, I, CAROL J. LINDSAY, ESQUIRE, OF THE LAW FIRM OF SAIDIS, SHUFF, FLOWER &
LINDSAY, A~-FORNEYS, HEREBY CERTIFY THAT I SERVED THE WITHIN PRAEClPE TO
WITHDRAW THIS DAY BY DEPOSITING SAME IN THE UNITED STATES MAIL, FIRST CLASS,
POSTAGE PREPAID, IN CARLISLE, PENNSYLVANIA, ADDRESSED TO:
REBECCA L. BICKLEY, DIRECTOR
BUREAU OF DRIVER LICENSING
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
P .O. BOX 60067
HARRISBURG, PA 17106
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
ATTORNEYS FOR ADAMJ~ LINDSAY
BY: ~~
'- ~3~rol J. Lindsay, Esquire
t!g# 44693
26 West High Street
Carlisle, PA 17013
(717) 243-6222