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Home My WebLink About10-7721THOMAS D. STIRLING, IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA COMMONWEALTH OF -D=C G -? PENNSYLVANIA, DEPT. REGISTRATION SUSPENSION APPF.r?,i M rn r- -- OF TRANSPORTATION, cn ` o . rM BUREAU OF DRIVER LICENSING in CY? ? c:, C7 -_rr CD C= w -- ? z t: APPEAL FROM THE SUSPENSION OF REGISTRATION PRIVILEGIS ji ? AND NOW, this LP day of December, 2010 comes the Petitioner, Thomas D. Stirling, by and through her undersigned attorney, Joseph L. Hitchings, Esquire and files this Appeal from the Suspension of Registration Privileges and avers in support thereof as follows: 1. Petitioner, Thomas D. Stirling, is an adult individual residing at 1013 S. Waterford Way, Mechanicsburg, Pennsylvania 17050. 2. Petitioner is a licensed driver in the Commonwealth of Pennsylvania, License No. 26 969 045, and is the owner of a 2004 Ford Station Wagon, VIN # 1 FMZU73K74UB 13486, Title 60649026, License Plate # HMJ7215. 3. The Pennsylvania Department of Transportation proposes by Notice dated November 16, 2010, to suspend Petitioner's registration for the above vehicle, for a period of three (3) months, pursuant to Section 1786(d) of the Vehicle Code, effective December 21, 2010. 4. The proposed registration suspension is unlawful as the Petitioner was without insurance coverage on the subject vehicle for less than thirty (30) days, and he did not operate or permit operation of the subject vehicle during the period when there was no insurance coverage on the vehicle. '792.00 j)c(-Q4y eK=-g 1a% fl.AL asaa WHEREFORE, Petitioner, Thomas D. Stirling, respectfully requests that his Appeal from the Suspension of Registration Privileges be granted, and the suspension of his registration be dismissed and rescinded. Respectfully submitted, Law Office of Joseph L. Hitchings Date: a IS- ) Q By: Attorney ID No.: 6555,1,.----) 5000 Ritter Road, Suite 202 Mechanicsburg, Pennsylvania 17055 (717) 458-8123 Fax: (717) 790-6019 Attorney for Petitioner VERIFICATION I, Thomas D. Stirling, verify that the statements made in this Appeal 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. -Z ',' in. , -T 2,r5: -- /-a Date homas D. Stirling THOMAS D. STIRLING, Petitioner V. COMMONWEALTH OF PENNSYLVANIA, DEPT. OF TRANSPORTATION, BUREAU OF DRIVER LICENSING IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.. REGISTRATION SUSPENSION APPEAL CERTIFICATE OF SERVICE I, Joseph L. Hitchings, Esquire, hereby certify that on this date I have served a certified copy of the attached Appeal on the parties listed below in the manner indicated: Via US certified mail postage pre-paid, return receipt requested Pennsylvania Dept of Transportation Office of Chief Counsel 1101 S. Front Street - 3`d Floor Harrisburg, PA 17104-2516 /14/1 1 C) Date Respectfully submitted, Law Office of Joseph L. Hitchings X-1 &? ?-- oseph L. rtchi sc $000 Ritter Road, uit Mechanicsburg, Pen (717) 458-8123 Fax: (717) 790-6019 Attorney ID No.: 65551 Attorney for Petitioner 17055 5 DEC 1 7 2010 THOMAS D. STIRLING, IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. No.: l b _ AI-7 l COMMONWEALTH OF PENNSYLVANIA, DEPT. REGISTRATION SUSPENSION APPEAL OF TRANSPORTATION, BUREAU OF DRIVER LICENSING ORDER OF COURT AND NOW, this J&day of December, 2010, upon consideration of the attached Appeal from Suspension of Registration Privileges, a hearing on the appeal is set for the day of J?Q , 2011, at,,2:30aqn/p.m in Courtroom No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. J. Distribution: u7r" c-) r- terry Court Administrator `e n' Prothonotary ' zr? W' oseph L. Hitchings, Esquire -) r 500 Ritter Road, Suite 202, Mechanicsburg, PA 17055 ; z ru nnDot Office of Chief Counsel ,. c n 1101 S. Front Street - 3`d Floor, Harrisburg, PA 17104-2516 cc I r Les, 022v CC4 Z1a 16 THOMAS D. STIRLING, Petitioner V. COMMONWEALTH OF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 10 - 7721 C o -° w C - REGISTRATION SUSPENSION APP Dc> C-) y =o PENNSYLVANIA, DEPT. OF TRANSPORTATION, BUREAU OF DRIVER LICENSING PROOF OF SERVICE y. r I, Joseph L. Hitchings, Esquire, attorney for Petitioner, Thomas D. Stirling 60 hereby certify that the APPEAL was served on PennDot Office of Chief Counsel on December 29, 2010, via Certified Mail, return receipt requested as reflected on the United States Postal Service Certified Mail Card attached hereto. • Complete sterns 1, 2, and 3. Also complete Nsm 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mallpiece, or on the front If space permits. 1. Arlicle Addressed to: Pte. ?? ? ? - ?-, log-aSlb A. signature X ? Agent S. Received by ( Rimed Winne) C. Deft df t' *my D C2 9 D. Is delivery address different from Item 1? D %@ If YES, enter delivery address below: ? No 3. Service Type Certified mail ? Express Lid ? Registered 'K Return Receipt for MaesAnr i ? Insured mail ? C.O.D. 4. Restricted Delivery? (Exha Fee) ? 1M 2. A06cfeNumber 7008 1140 0000 8399 8473 fNa?+e??ir'a?n a?ei PLR Form 3811, Fr xmwy 2004 Donrseuc Rehr Receipt r?ea?sat? o Office of JAL. Hitchings ?seph L.K-Ii 'ngs, ENkin Attorney ID No.: 1 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 458-8123 Fax: (717) 790-6019 Attorney for Petitioner 0 rnF urn C)° -io o-+n z on a M THOMAS D. STIRLING, IN THE COURT OF COMMON.PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. COMMONWEALTH OF PENNSYLVANIA,: DEPARTMENT OF TRANSPORTATION,: BUREAU OF DRIVER LICENSING, . Respondent NO. 10-7721 CIVIL TERM ORDER OF COURT AND NOW, this 11th day of February, 2011, after hearing on the appeal of the suspension of registration privileges, the Court finds that the petitioner did comply with the provisions of the Vehicle Code at Section 1786(d)(2)(i) and did appropriately register his vehicle within 31 days of the lapse of coverage, and therefore the appeal is granted. By the Court, r? Albert H. Masland, J. /Philip M. Bricknell, Esquire For the Department of Transportation Joseph L. Hatchings, Esquire I For Petitioner Ci po CoPies ? <-? prs _ri rn r Z7 r? ?Y