HomeMy WebLinkAbout11-1975IN RE: : IN THE COURT OF COMMON PLEAS
RANDOLPH A. FREED, JR., : CUMBERLAND COUNTY, PENNSYLVANIA
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PETITION TO APPEAL `<w -
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AND NOW comes Randolph A. Freed, Jr., pro se, and files an appeals as fs: y ?_
1. Petitioner/Appellant is Randolph A. Freed, Jr., who is an adult individual presently
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residing at 235 Key West Blvd, Carlisle, Cumberland County, Pennsylvania.
2. Petitioner/Appellant was convicted of violating Section 3802C of the Vehicle Code on
May 29, 2010.
3. Petitioner/Appellant received an official Notice of the Revocation of his driving
privileges on or about January 27, 2011.
4. Petitioner/Appellant hereby appeals the revocation of'his driving privileges in
accordance with the conviction docketed at Cumberland County Court No. 1798 of 2010.
Respectfully submitted,
Randol A. Freed, Jr
Pro Se
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CERTIFICATE OF SERVICE
I, Randolph A. Freed, Jr., hereby certify that I have served a copy of the foregoing
document on the following person(s) by depositing a true and correct copy of the same in the
United States Mail, by way of United States Mail, first class, postage prepaid, at Carlisle,
Cumberland County, Pennsylvania addressed to:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg PA 17104
Randolp A. Freed, Jr.
235 Key West Blvd
Carlisle PA 17013
Dated: 2-17- //
RANDOLPH A. FREED, JR.,
Appellant
VS.
COMMONWEALTH OF PA,
DEPARTMENT OF TRANS.,
BUREAU OF DRIVER
LICENSING
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 11-1975 CIVIL
IN RE: APPEAL FROM SUSPENSION OF OPERATOR'S PRIVILEGE
ORDER
AND NOW, this !AI?7 day of March, 2011, hearing on the above-captioned appeal
from suspension of operator's privilege is set for the 6`0 day of , 2011, at
a`Z DU o'clockP.m., in Courtroom Number 4, Cumberland County Courthouse, Carlisle,
PA.
BY THE COURT,
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Kevin A. Ass, P. J.
Office of Chief Counsel
PennDOT
Randolph A. Freed, Jr.
Appellant
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72
RANDOLPH A. FREED, JR.,
Appellant
VS.
COMMONWEALTH OF PA,
DEPARTMENT OF TRANS.,
BUREAU OF DRIVER LICENSING,
Appellee
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 11-1975 ,
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MOTION FOR CONTINUANCE
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AND NOW, comes Appellant, Randolph A. Freed, Jr., by and through his attorney,
Andrew H. Shaw, Esquire, and respectfully avers the following:
1. Appellant resides at 235 Key West Boulevard, Carlisle, Pennsylvania.
2. A hearing is scheduled in this matter for May 5, 2011. A copy of the Order for the
hearing is attached hereto as Exhibit A.
4. Appellant's attorney is unavailable on May 5, 2011 due to a death in the family.
5. Concurrence in this Petition was sought from Appellee's Counsel, Phillip M. Bricknell,
Esquire. Mr. Bricknell concurs in this Motion.
6. No other judge has ruled upon matters related to this action.
WHEREFORE, the Appellant requests this Honorable Court to Continue this matter to a
time suitable for all parties and their legal counsel.
Date:
Respectfully Submitted,
By
Andrew Shaw, Esquire
200 S. Spring Garden Street
Suite 11
Carlisle, PA 17013
(717) 243-7135
(717) 243-7872 facsimile
Attorney for Petitioner
RANDOLPH A. FREED, JR.,
Appellant
VS.
COMMONWEALTH OF PA,
DEPARTMENT OF TRANS.,
BUREAU OF DRIVER
LICENSING
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 11-1975 CIVIL
IN RE: APPEAL FROM SUSPENSION OF OPERATOR'S PRIVILEGE
ORDER
AND NOW, this I,,7 day of March, 2011, hearing on the above-captioned appeal
from suspension of operator's privilege is set for the d_*0 day of , 2011, at
oZ D-U o'clock?.m., in Courtroom Number 4, Cumberland County Courthouse, Carlisle,
PA.
BY THE COURT,
Office of Chief Counsel
PennDOT
? Randolph A. Freed, Jr.
Appellant
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Kevin A. S, P. J.
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EXHIBIT
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CERTIFICATE OF SERVICE
I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the
following document, Motion for Continuance, was served this date on the below named,
by e-mail and by placing same in the United States mail, first-class, postage prepaid
thereon, addressed as follows:
Phillip M. Bricknell, Esquire
Governor's Office of General Counsel
Department of Transportation
Office of Chief Counsel I Vehicle & Traffic Law Division
River Front Office Center, 3rd Floor
1101 South Front Street I Harrisburg, PA 17104-2516
Attorney for Appellant
Date:
Andrew H. Shaw,
V
RANDOLPH A. FREED, JR., : IN THE COURT OF COMMON PLEAS OF
Appellant : CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW z
COMMONWEALTH OF PA, : NO. 11-1975
DEPARTMENT OF TRANS., r .-
BUREAU OF DRIVER LICENSING,
Appellee
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ORDER
AND NOW on this %5q day of May, 2011, upon receipt of the attached Motion
for Continuance, it is hereby ORDERED AND DIRECTED that the hearing scheduled for May
5, 2011 is continued. A hearing is hereby scheduled for the oU-4 day of
2011 at /i 30 o'clock q m., in Courtroom Number Cumberland
County Courthouse, Carlisle, PA.
BY THE COURT:
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Phillip M. Bricknell, Esquire, Office of Chief Counsel
Andrew H. Shaw, Esquire, attorney for Appellant
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ADO
RANDOLPH A. FREED, JR., IN THE COURT OF COMMON PLEAS OF
Appellant CUMBERLAND COUNTY, PENNSYLVAN A
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VS. CIVIL ACTION - LAW r"M _
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NO. 11-1975 CIVIL x;
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COMMONWEALTH OF PA,
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DEPARTMENT OF TRANS., `
BUREAU OF DRIVER -n
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LICENSING :? S5 D,r
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IN RE: APPEAL FROM SUSPENSION OF OPERATOR'S PRIVILEG E
ORDER
AND NOW, this 2 1 day of May, 2011, the Court being satisfied that the
appellant's driving record contains the requisite number of Driving Under the Influence
convictions to support the current license suspension and that his remedy, if any, lies in the
criminal courts, the within appeal from suspension of operator's privilege is DENIED.
BY THE COURT,
.? Office of Chief Counsel
PennDOT
Randolph A. Freed, Jr.
Appellant
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