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Home My WebLink About01-2807 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH ANDREW HARRISON, : NO. Or- Petitioner : : CIVIL ACTION - LAW V. APPEAL FROM COMMONWEALTH OF PENNSYLVANIA, SUSPENSION OF Departmem of Transportation, OPERATOR'S LICENSE Respondent : PRIVILEGES APPEAL FROM SUSPENSION OF OPERATOR'S LICENSE PRIVILEGES TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, this 9th day of May, 2001, comes the Petitioner, Keith A. Harrison. by his attorney, G. Patrick O'Connor, Esquire, and presents the following appeal: 1. The Petitioner, Keith A. Harrison, is an adult individual residing at 26 York Circle, Mechanicsburg, Cumberland County, PA 17055. 2. The Petitioner has been notified by the Department of Transportation that, effective June 13, 2001, his driver's license privilege has been suspended for a period of six (6) months as authorized by Section 1532(b) of the Pennsylvania Vehicle Code, as a result of an alleged violation of Section 3367(a) of the Vehicle Code, RACING ON HIGHWAYS, on April 20, 2001. A copy of said notice is attached as Exhibit "A" and incorporated herein by reference. 3. The Petitioner pleaded guilty to the charge of RACING ON HIGHWAYS on or about May 1, 2001, to the District Justice in Magisterial District No. 09-3-03, Mount Holly Springs, Pennsylvania, in the mistaken belief that his license would not be suspended for six months as the result of the conviction. Respectfully submittexl, .//G. Palrick O'Connor, Esquire Attorney No. 64720 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 Attorney for Petitioner VERIFICATION I, Keith A. Harrison, state that I am the Petitioner in the above case and hereby certify that the information provided herein is true and accurate to the best of my knowledge, information and belief. I realize that false statements herein are subject to the penalties for unswom falsification to authorities under 18 Pa.C.S. Sec. 4904. '-l(eith A. i-[arrison DATE: .~-' ~' 0 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND 'COUNTY, PENNSYLVANIA KEITH ANDREW HARRISON, : NO. Petitioner : : CIVIL ACTION - LAW V. ; : APPEAL FROM COMMONWEALTH OF PENNSYLVANIA, : SUSPENSION OF Department of Transportation, : OPERATOR'S LICENSE Respondent : PRIVILEGES CERTIFICATE OF SERVICE I hereby certify that I have, this day, served the herein petition to the party indicated below by depositing same in the United States mail, certified mail, postage prepaid, at Camp Hill, Pennsylvania: Office of Chief Counsel Atto: George H. Kabusk, Esquire Pennsylvania Department of Transportation Riverside Office Center 1101 S. Fwnt Street Harrisburg, PA 17104 //G. Patrick O Connor, Esquire Attorney No. 64720 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 Attorney for Petitioner CONNONNEALTH OF PENNSYLVANIA .... DEPARTHENT OF TRANSPORTATION Bureau of Driver Licensing .... Hail Date= NAY 09, 2001 .... K£ITH AN]REM HARRISON PROC£SSING ~AT£ aG YORK CIRCLE ~R[¥ER LICENSE · el3OS?D3 MECHAN~CSBURG PA ~TOSS ~ATE OF B~RTH Dear HR. HARRTSQH= This is an OfflctaZ Notice of the Suspension of your Driving Privilege as authorized by Sect/on 15328 of the Pennsylvania Vehicle Code. As a result of your 05/01/2001 conviction of violating Section 3367 of the Vehicle Code RACING ON HIGHWAYS on 04/20/2001= · Your driving privilege is SUSPENDE~ for a per~od of & MONTH(S) effective 06/13/2001 at 12.01 a.m. re PennDOT can restore your driving privilege, you must ~e~e. the instructions in this letter for COH~L~L~,.~T~ ro~ .......... o~v~c THE RESTORATION FEE ano r~uv,~.o.~ THIS SUsP~a~un, ...~_- _.__.a a-~-w ALL ~flotructtone very PROOF OF INSURANCE. You .---~ -----~ ..... 'l~e on the efullY. Even If you have eervea a~A ;ns ~ car . ----- ~e cannot restore your driving ouopene~on/revoom~un, pr~v~2ege untO2 e~2 the requirements ere aet~af~ed. COHPLYING WITH THIS SUSPENSION You must return all current P=nns¥1vania driver's licenses, learner~s permits, temporary driver's licenses (camera cards) in your possession on or before ~&/15/2001. You may surrender these items before~ 0&/15/2001~ for earlier credit; however, you may not drive after these items are surrendered. YOU MAY NOT RETAXN YOUR DRXVEReS LZCENSE FOR XDENTZF~CATION PURPOSES. He,ever, you may apply for and obtain a photo identification card at any Driver License Center for a cost of $9.00. You must present t~o (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 ~111 not receive credit toward earring any ouopenelon MiltS1 Me receive your 11canoe(e)- Complete the folloMing steps to acknowledge this su~X~ilB~]~kfl EXHIBIT 021229285785&$0 eturn a urrent PennSylvania driver'S license~ R , l~-.c~;ts and/or camera cards to pe~n"~T'.,o~ learner s ~='~'_. any of these ItemS, sen- = ye. do ne, -~'"st,ting you ,r, ,.,r, of th~ notarized le;~er . . . - You must specify in of your driving prlvlle~. ~o return your driver's re un,-~- - · letter ~hY you a ...... t retain your driver s . Remember: you wdy "~ nl.~== ~end these ~cenSe. ;a.~jf$cation purposes, r~G=o- - license for - items to= penn~yZva.~a Department of Transportation Bureau af Driver L~censing P.O. Box &S&95 isburg, PA Hart ~ acceptance of your Pennsylvania pon receipt, reVl , .... -* (s)~ and/or a s~orn 2. ~--..r,s license(s), ~earner = ~G....t ..... a receipt .ri .... - --nOT rill sena ~-- notarized letter, · ·h, d,te that credit b,Oan. ,au confirming t . ~ . _ .~ Mithin ~ weeks; p~ease con~_.~ -~;ice. Othervise~ you w~_---~ .~one numbers are listed at the · -- current driver license $ If you do not return a~ · refer this matter to the Pennsylvania productS, fie m~st ........ ~inn under SECTION State Police TOt Pru=~-:° ~_~. of the Pennsylvania Venlc*e pAYING TNB RESTORATION FEE rati.n fee to PennDOT to be restored You must pay a restO ~-- -~ uour driving privilege. To from a suspension~rev~ca'3~.~'e;e the folio.lng steps, pay your restoration reee Return the enclosed AppliCation for Restoration. The amount due is Zisted on the application. 2. ~rite your driverws license number (listed on the first page) on the check or money order to ensure proper credit. 3. Follo~ the payment and mailing instruct$Ons on the back of the application. O]1229283783&30 PROVZDING PROOF OF INSURANCE NithJn the last 30 days of your suspension, we will send you a letter asking that you provide proof of insurance at that time. This letter will list acceptable documents and what wi1! be needed if you do not own a vehicle registered in Pennsylvania. Important: Please make sure that PennDOT is notified if you move from Your current address. You may not/fY PennDOT of your address change by calling any of the phone numbers li~t~d at the end of this letter. APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date, MAY 09, 2001, of this letter. If you flle an appeal in the County Court, the Court w111 glve you & 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 mai! to= Pennsylvania Department of Transportation Off/ce of Chief Counsel Third Floor, Riverfront Off/ce Center Harrisburg, PA 17104-251& Remember, this is an OFFZCIAL NOTZCE OF SUSPENSION. You must return all current Pennsylvania driver license products to PennDOT by 0&/15/2001. Sincerely, Rebecca L. Bickley, Director Bureau of Driver Licensing SEND FEE/LTCENSE/DL-I&LC/TO'- TNFORRATTON (7sO0 AH TO 9:00 PH')' Department of Transportation I'N STATE 1-800-952-4600 Bureau of Driver Licensing OUT-OF-STATE 717-$9t-6190 P.O. Box &8&9$ TDD TN STATE 1-800-228-0676 Harrisburg, PA 1710&-8&95 TDD OUT-OF-STATE 717-391-6191 I II I : IN TIlE COURT OF coMMON pLEAS OF KEITII A. IIARRISON : cUMBERLAND coUNTY, pEN'NSYLYANIA ¥. : NO. 2001-2507 CIVIL TERM coMMONWEALTH OF pENNSYLVANIA, DEPARTMENT: OF TRANSPORTATION . CIVIL ACTION ' LAW ,. ~ heating nn the AND NOW, this ~ day of MAY, 2001, the License Appeal above captioned matter scheduled for wednesday, Iune 6, 2001, is rescheduled for in Courtroom ~¢ 5 of the cumberland County Courthouse, Carlisle, pennsylvanta B~ ~tdo, 0. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hill, Pa. 17011 For the petitioner George Kabusk, Esquire For the Dept. of Transportation :sld _o~O~ pLeAS _O. If~gggA~ cotmX¥, ~ND~W ~SO~, : CIVIL Ac~IO~ - pefirioner : : ~ppE~L FROM v. : SUSpE~SIO~ OF : OpE~XOW S LICENSE MMO~WEALTH OF PE~SYL~ANI~' : p~ViLEGES DeP~em u-- Res~naen~ O~ER upon co~Xd~fi°n of , .. ~ { day of =~ Cau~ why ' "D NOW, m~s ~ ' x a g~e m ins~t p~on, i~ is he~b~ orde~ an~ decree~ ~ on ~e Kes~ndenl, ~e DeP~menx . .~a not be ~tcd s~11 ~ issu~ heroin pcf~fiou ~nomo ~~ . ~ a.~,e ~t the suSpc~ton o, ~ ' ~n, which ~ ~hefluled to ~e effect on I~e 13, of ~e peri{toner, Ke,th And~w Hf~ti367(a)of the Motor Vehicles Co~ on April 20, 2001, {or ~leged vtolaUOn ot Sec . ~t aside ~' ~less the p~trion~ sh~l be inelioble ~ °~rate a motor 2001, is h~W o&~ re~n' his o~tator's li~ ~.vileges sh~l vehicle in pe~s~lv~a for ~ ~d effect until f~her order of this COUP. in full fore NO. 01-2507 : EITH ANDRE~ HARRISON, : CIVIL ACTION - I~ petitioner : : AppEAL FROM v. : sUSPENSIO~ OF CoMMON~AL~ OF p~iSyL~ANIA, : OpE~TOR,S LICBNSB : p~iLEGES D~m~nt of Tr~p°~6°n' Rgspon~t p~CIPE TO ~TR~ APPEA~ TO THE pRoTHONOTARY" __,~,, &-rc~R'S LICENSE please mark the APPEAL FROM sUSPENSION OF O . ~, ~am in the above-captioned action as WithdraWn Thank pRIVILEGES fried on May v, ~vv-, --- ' ' you foz your consideration' Dated: ~ /(3. pa~C~ '-' AttOrney for p~ttione~ I.D. # 647110 .... ~'d Gettysburg Road . 31u~ '-" ...... C~P Hill, phone: 717-737.7760 IN THE COURT OF cOMMON PLEAS OF CUMBERLAND cOUNTY, p EN NSYLVANIA : NO. 01-2807 KEITH ANDREW HARRISON- : Petitioner : CIVIL ACTION - t. AW : v. : APPEAL FROM SUSPENSION OF : OPERATOR' S COMMONWEALTH OF i~ENNSYI.VANIA, : LICENSE Department of Transportauon, pRIVILEGES Respondent : CERTIFICATE OF SERVIC~E I herebY ceftin' that I have this ,lay served a copy of the foregoing pRAECIPE Tt) WITHDRAW APPEAL upon the person indicated below, bY tint-class U.S. mail, postage-prepaid, fi'om Camp Hill. Pennsylvania, to: Office of Chief Com~sel Atto: George H. Kabusk, Esquire Pennsylvania Department ot 1 ~anspo tauon Riverside Office Center 1101 S. Front Street Harrisburg, PA 17104 DATED: ~ ...... RespextftfllY submitted: ~'Connor, Esqture 3105 Old Gettysburg Road Camp Hill, PA 17011 (717) 737-7760 ID No. 64720 Attorney for the Petitioner Ill