Loading...
HomeMy WebLinkAbout11-4582LAUREN STASKO 323 S. SPORTING HILL ROAD MECHANICSBURG, PA 17050 LAUREN STASKO OF THE PRp HOMO 2011 MAY 26 AM 8: 2 CUPENNSYND COUNTY NIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO.: CV 2011 LS G;,l. I -fe: ? ?"? COMMONWEALTH OF PENNSYLVANIA go Z/5 DEPARTMENT OF TRANSPORTATION BUEAU OF DRIVER LICENSING APPEAL FROM THE SUSPENSION OF OPERATING/REGISTRATION PRIVILEGES AND NOW, Petitioner, Lauren Stasko, respectfully avers as follows: 1. Petitioner, Lauren Stasko, resides at 323 S. Sporting Hill Road, Mechanicsburg, Pennsylvania, 17050. 2. Petitioner's Pennsylvania Operator's/Title Number is #27139643. 3. PennDOT proposes by Notice dated May 12, 2011 to suspend Petitioner's operating privileges for a period of six (6) months, pursuant to section 1523(b) and 3736 of the Vehicle Code, effective June 16, 2011. 4. The said Order of the Director of the Bureau of Driver Licensing is illegal, arbitrary, unreasonable, and an abuse of discretion. WHEREFORE, Petitioner respectfully requests that this Honorable Court allow her to take an appeal from the suspension of her operating privileges. Respecjfj$ly Submitted 'Attorney for Petitioner Matthew J. Monaghan I D # 201607 2132 Market Street Camp Hill, PA 17011 Date ,e1 ?s7747 VERIFICATION I, Lauren Stasko, verify that the facts set forth in the Appeal From the Suspension of Operating Privileges are true and correct to the best of my knowledge, information and belief. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities, which may include two (2) years and imprisonment and fines of up to $5,000.00. Date Signature of Petitioner LAUREN STASKO IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. NO.: CV 2011 LS COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUEAU OF DRIVER LICENSING AFFIDAVIT OF SERVICE I, Matthew J. Monaghan, Esq., attorney for Petitioner, Lauren Stasko, hereby verify that on day of May, 2011, 1 served the Commonwealth of Pennsylvania, Department of Transportation, Bureau of Driver Licensing with a true and correct copy of the Suspension Appeal by the United States Postal Service, first class mail, postage prepaid, certified, restricted delivery, return receipt requested. sa a Date Matthew J. Monaghan, Esq. Attorney for Petitioner, Lauren Stasko '?3 LAUREN STASKO VS. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUEAU OF DRIVER LICENSING IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.: CV 2011 LS c 3 f-- i M c» r i ? 3 's r .. SCHEDULING AND SUPERSEDEAS ORDER VuA/? AND NOW, this day o?N 2011, upon presentation of the within Appeal from Suspension of Operating/Registration Privilege, it is hereby ordered that hearing on this matter shall be held on the .36-th day of A /t , 2011, at//,o 100o'clock A m. in Courtroom No. of the Cumberland County Courthouse, Carlisle, PA. The action of the Pennsylvania Department of Transportation in suspending the driving privileges of the petitioner is hereby stayed pending a final decision of the court to the extent provided under §1550(b) and §1377 of the Motor Vehicle Code. Petitioner must serve a copy of the appeal on the Pennsylvania Department of Transportation. BY E COURT: JUDGE DISTRIBUTION: /Lauren Stasko, 323 S. Sporting Hill Road, Mechanicsburg, PA 17050 'e°? ./Pennsylvania Department of Transportation, Office of Chief Counsel, Third Floor, Riverfront Office Center, Harrisburg, PA 17104-2516 ?/ Matthew J. Monaghan, Esq., 2132 Market Street, Camp Hill, PA 17011 C LAUREN STASKO, IN THE COURT OF COMMON PLE CUMBERLAND COUNTY, PENNSYrNI ? V. No. 11-4582 Civil Term <c X COMMONWEALTH OF = PENNSYLVANIA, DEPARTMENT OF CIVIL ACTION - LAW TRANSPORTATION, BUREAU OF - ;' DRIVER LICENSING, MOTION FOR CONTINUANCE AND NOW, Petitioner, Lauren Stasko, respectfully requests that the hearing scheduled for June 30, 2011 at 11 a.m. be continued and in support therefore avers as follows: 1. On May 26, 2011, Petitioner, Lauren Stasko, filed an Appeal from a suspension of operating privileges. 2. The Commonwealth is represented by Philip Bricknell from the Pennsylvania Department of Transportation. 3. The matter is scheduled for a hearing on June 30, 2011 at 11 a.m. in Court Room No. 3. 4. The parties may be able to resolve the matter without the need for a hearing. 5. Petitioner respectfully requests that the matter be continued for purposes of determining whether the Petitioner and the Commonwealth of Pennsylvania can resolve the matter. 6. Philip Bricknell, Esquire, from the Commonwealth of Pennsylvania, Department of Transportation, Bureau of Driver Licensing, concurs in the request for a continuance. WHEREFORE, Petitioner respectfully requests that the hearing scheduled for June 30, 2011 at 11 a.m. be continued. '- I /?C) Date: Respectfully Submitted Attorney fo Petitioner Matthew J. Monaghan, Esquire I D # 201607 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 W CERTIFICATE OF SERVICE I, Matthew J. Monaghan, Esquire, hereby certify that I have caused a true and correct LAUREN STASKO, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 11-4582 Civil Term COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CIVIL ACTION -LAW TRANSPORTATION, BUREAU OF DRIVER LICENSING, copy of the Petitioner's Motion for Continuance to be served upon the following counsel of record via United States Postal Service, First Class Mail, postage prepaid, addressed as follows: Philip Bricknell, Esquire Commonwealth of Pennnsylvania Department of Transportation Office of Chief Counsel, V Floor River Front Office Center Harrisburg, PA 17104-2516 Date: b161 Attorneffor Petitioner Matthew J. Monaghan, Esquire I D # 201607 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 ` FILED-OFFt^QE OF THE PROTH©!1A 1011 JUN 29 PM 12. '33 CUMBERLAND COUNTY PENNSYLVANIA LAUREN STASKO, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, No. 11-4582 Civil Term CIVIL ACTION - LAW ORDER AND NOW, this day of June, 2011, upon presentation of the attached Motion for Continuance, it is hereby Ordered that the hearing on this matter that had originally been scheduled for the 30th day of June, 2011 at 11:00 a.m. in Court Room No. 3, has been fA continued and the new hearing will be held on the /-f day of 2011, at'T• Xo'clock k.m. in Court Room No. 3, Cumberland County Courthouse, Carlisle, PA. The action of the Pennsylvania Department of Transportation in suspending the driving privileges of the petitioner remain stayed pending a final decision of the Court to the extent provided under §1550(b) and §1377 of the Motor Vehicle Code. BY COURT: J. Coco ,? . v-(' pp, be 1?an p4 - &C 7rru l . 3 ALe t LAUREN STASKO, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. 11-4582 Civil Term No -M r? COMMONWEALTH OF . PENNSYLVANIA, < 3 , DEPARTMENT OF CIVIL ACTION--LAW S , TRANSPORTATION, BUREAU OF DRIVER LICENSING n :- , MOTION FOR CONTINUANCE AND NOW, Petitioner, Lauren Stasko, respectfully respectfully requests that the hearing scheduled for August 15, 2011 at 9:30 a.m. be continued and in support therefore avers as follows: 1. On May 26, 2011, Petitioner, Lauren Stasko, filed an Appeal from a suspension of operating privileges. 2. The Commonwealth is represented by Philip Bricknell from the Pennsylvania Department of Transportation. 3. The matter is scheduled for a hearing on August 15, 2011 at 9:30 a.m. in Court Room 3. 4. The parties may be able to resolve the matter without the need for a hearing. 5. Michael O. Palermo, Esquire, on behalf of Lauren Stasko has filed a petition under the PCRA against undersigned counsel. 6. Petitioner respectfully requests that the matter be continued for purposes of determining whether the Petitioner and the Commonwealth of Pennsylvania can resolve the matter. 7. Philip Bricknell, Esquire, from the Commonwealth of Pennsylvania, Department of Transportation, Bureau of Licensing, concurs in the request for a continuance. WHEREFORE, Petitioner respectfully requests that the hearing scheduled for August 15, 2011 at 9:30 a.m. be continued. Respectfull Submitte Date: Attorney f Petitioner Matthew I Monaghan ID # 201607 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 LAUREN STASKO, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : PENNSYLVANIA V. No. 114582 Civil Term COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF CIVIL ACTION--LAW TRANSPORTATION, BUREAU OF DRIVER LICENSING, . CERTIFICATE OF SERVICE I, Matthew Monaghan, Esquire, hereby certify that I have caused a true and correct copy of the Petitioner's Motion for Continuance to be served upon the following counsel of record via United States Postal Service, First Class Mail, postage prepaid, addressed as follows: Philip Bricknell, Esquire Commonwealth of Pennsylvania Department of Transportation Office of Chief Counsel, 3`d Floor River Front Office Center Harrisburg, Pa 17104-2516 Date: Attorney or Petitioner Matthew J. Monaghan ID # 201607 Dethlefs-Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 0?y v LAUKtN S TASKO, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA C2 CZ -, V. . No. 114582 Civil Term = ::' `? --? COMMONWEALTH OF PENNSYLVANIA , DEPARTMENT OF CIVIL ACTION--LAW ` r' TRANSPORTATION, BUREAU =ca ? ,c OF DRIVER LICENSING r' `?' rF , ORDER H AND NOW, This c9 t? day of July, 2011, upon presentation of the attached Motion for Continuance, it is hereby Ordered that the hearing on this matter that had originally been scheduled for the 15th day of August at 9:30 a.m. in Court Room No. 3, has been continued and the new hearing will be held on the / day of 2011, at9Wo'clock rpm. in Court Room No.._9 ,Cumberland County Courthouse, Carlisle, PA. The action of the Pennsylvania Department of Transportation in suspending the driving privileges of the petitioner remain stayed pending a final decision of the Court to the extent provided under § 1550(b) and § 1377 of the Motor Vehicle Code. R&Aew J. Mond han, '4_)1i ! ip1rlccr.W1, jas q?a9/rl THE COURT: J. 3 3 LAUREN STASKO, IN THE COURT OF cummun Mr-AS CUMBERLAND COUNTY, PENNSYLVANIA V. 11-4582 Civil Term No zm rn- COMMONWEALTH OF . cnr -"r' =ti PENNSYLVANIA, - p DEPARTMENT OF CIVIL ACTION--LAW S TRANSPORTATION, BUREAU z w ; i OF DRIVER LICENSING, ?' •• ORDER AND NOW, This ?`` day of September, 2011, upon presentation of the attached Motion for Continuance, it is hereby Ordered that the hearing on this matter that had originally been scheduled for the 15th day of September at 2:00 p.m. in Court Room No. 3, has been continued and the new hearing will be held on the I? day of AM'10A , 2011, at ('0 o'clockh.m. in Court Room No. ? , Cumberland County Courthouse, Carlisle, PA. The action of the Pennsylvania Department of Transportation in suspending the driving privileges of the petitioner remain stayed pending a final decision of the Court to the extent provided under § 1550(b) and § 1377 of the Motor Vehicle Code. Ma++J.Mono ?6'n rho lip Dr'ic"W-ll, d 4W T: J. O*es Wly LAUREN STASKO, IN THE COURT OF COMMON PLEAS OF Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-4582 CIVIL TERM C COMMONWEALTH OF "v3 O n- PENNSYLVANIA, DEPARTMENT Zr n p r r- OF TRANSPORTATION, BUREAU: Xzo -c ?r OF DRIVER LICENSING, > Respondent CIVIL ACTION - LAW !"C© sQ 3?c'? ZO 3 Z-?t " ORDER OF COURT C :)C ) -? 00 AND NOW, this 7th day of November, 2011, by agreement of the parties, this matter is remanded to the Department so that it may correct its records. By the Court, 4W Edward E. Guido, J. ZDethlefs-Pykosh Law Group 2132 Market Street Camp Hill, PA 17011 F the Petitioner Opp i? Philip Bricknell, Esquire Q((,8 Department of Transportation Office of Chief Counsel, 3rd Floor River Front Office Center Harrisburg, PA 17104-2516 For the Respondent srs