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Home My WebLink About11-4304ATlom & LILAKIS John A. Atom, Esquire AttorneyLD. No.: 77961 2 W. High Street Carlisle, Pennsylvania 17013 (717) 249-0900 COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVERS' LICENSING, APPELLEE V. JOSEPH BRADLEY, APPELLANT TO: THE HONORABLE JUDGE OLER.: CIS` THE PROTHONOTARY 2011 JUN 30 PM 1: 59 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Docket No.: 11-4304 Civil Driver License No.: 24403515 UNOPPOSED MOTION TO CONTINUE LICENSE SUSPENSION APPEAL HEARING AND NOW, comes the Defendant, Joseph Bradley, by and through his attorney, John A. Abom, Esquire, ofABOM &KUTULAKIS, L.L.P., who respectfully requests This Honorable Court to continue the License Suspension Appeal Hearing in the above-captioned matter and in support thereof avers the following: 1. Mr. Bradley filed a License Suspension Appeal on May 11, 2011. 2. An Order of Court was issued on May 13, 2011, scheduling a License Suspension Appeal Hearing to occur on July 12, 2011. 3. Undersigned Counsel is unavailable to attend said Hearing. 4. Assistant Counsel for Pennsylvania Department of Transportation, Phillip Bricknell, Esquire, indicated he is not opposed to this Motion to Continue. WHEREFORE, the Defendant respectfully requests This Court continue the License Suspension Appeal Hearing. ?119) (1 Da e Respectfully Submitted ABOM & KUTULAKIS, L.L.P. John A. squire Supreme C t I.D. 77961 2 West Hig Street Carlisle, PA 17013 (717) 249-0900 Attorney far the Defendant CERTIFICATE OF SERVICE I, Emily J. Filiberti, hereby certify that I did serve a copy of the within Motion to Continue, by mailing a copy of said Notice by certified mail addressed as follows: Phillip Bricknell, Esquire Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 ABOM & KUTULAKIS, LLP _ DATE Emily J. Filiberti r ABOM CSZ' &UTLILAKIS John A. Atom, Esquire Attorney I.D. No.: 77961 2 Wert High Street Carlisle, Pennsylvania 17013 (717) 249-0900 COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVERS' LICENSING, APPELLEE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Docket No.: 11-4304 V. JOSEPH BRADLEY, APPELLANT Driver License No.: 24403515 ORDER AND NOW, this day of ~v , 2011, upon consideration of the Defendant's Unopposed Motion to Continue License Suspension Appeal Hearing currently scheduled to occur on July 12, 2011, said Motion is GRANTED and the Hearing in the above- referenced matter is rescheduled to the 13VLI day of 2011, at / ?! .m. at the Cumberland County Courthouse ')"Md John A. Abom, Esquire 2 West High Street Carlisle, PA 17013 Court Administrator's Office Phillip Bricknell, Esquire Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 (-fir `r e,' ma jew -7//q/1f C'7 G -q 3 Zrn V,r r- ? ?a c-s ? o --a f-.7 a c- F w -0 3C w cn w --i rn-n -? rn a. -4c> z -1 oD ri 12<<t -ABOM & uTULAKIS )obn A. Abom, Esquire Attorney I.D. No.: 77961 2 W. High Street Carlisle, Pennsylvania 17013 (717) 249-0900 qj.F 0 Ei_ _ X01 OCT PM Ups ? AND 1't VA N COMMONWEALTH OF PENNSYLVANIA, : DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVERS' LICENSING, APPELLEE V. JOSEPH BRADLEY, APPELLANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Docket No.: 11-4304 Civil Driver License No.: 24403515 PRAECIPE TO WITHDRAW TO THE PROTHONOTARY OF SAID COURT: Kindly withdraw the LICENSE SUSPENSION APPEAL in the above-captioned action with prejudice. A License Suspension Appeal Hearing is scheduled to occur on October 13, 2011. Respectfully submitted, DATE: i C' luk ABOM & KUTULAns, LLP 2 West High Street Carlisle, PA 17013 (717) 249-0900 CERTIFICATE OF SERVICE AND NOW, I, John A. Abom, of ABOM & KUTULAKIS, LLP, hereby certify that I did serve or cause to be served a true and correct copy of the foregoing Praecipe to Withdraw by First Class U.S. Mail at the following: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 ?o i j DATE /0 6 1?- Y I- ! E -0F FI -" T NF PO f Il0X0 T'','_` 2011 OCT -6 Phi 3: 9 'C'UMBERLAND CQIJ )` PENNSYI-yANIA RICHARD J. DITZLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2011-4342 CIVIL TERM HOPE DITZLER, CIVIL ACTION -LAW Defendant IN CUSTODY ORDER OF COURT AND NOW this day of 074r , 2011, upon consideration and review of the foregoing Joint Petition to Withdraw the Complaint and Counterclaim for Custody and Vacate Order of June 29, 2011, it is hereby ORDERED and DIRECTED that the parties' Complaint for Custody and Counterclaim for Custody are DISMISSED, without prejudice, and the Order of June 29, 2011 is vacated. It is further ORDERED and DIRECTED that the hearing scheduled for Monday, August 15, 2011 at 10:00 a.m. is cancelled. J. Cc: ? Hannah Herman-Snyder, Esquire Attorney for Plaintiff M O*ies Monica E. Baturin, Esquire Attorney for Defendant (or O 31 i?