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COMMONWEALTH OF PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NICHOLAS RYAN LEUSCHEN, ~
Petitioner :
APPEAL OP LIO~wss SUSPENSION
TO: THE HONORABLE JUDGES OF SAID COURT:
Petitioner, Nicholas Ryan Leuschen, by his attorney, Kenneth
F. Lewis, petitions the Court to appeal the suspension of his
driver's license and in support thereof offers the following:
1. Petitioner Nicholas Ryan Leuschen resides at
919 Acri Road, Hechanicsburg, PA 17055.
2. By letter dated Hay 21, 2001, PennDOT notified
Petitioner his license was to be suspended for
violating 75 Pa.C.S. S3362 (exceeding maximum
speed). A copy of the notice attached hereto.
3.Petitioner's suspension is scheduled by
PennDOT to begin June 25, 2001.
4. Petitioner is permitted to appeal the
suspension of his license to the Court of
Common Pleas.
WHEREFORE, Petitioner respectfully requests the Court to
schedule a hearing on the subject suspension and to issue a stay of
the suspension pending such hearing.
Respectf~ly submitted,
I.D. $60383
1101 N. Front St.
Harrisburg, PA 17102
(717) 234-3136
COHXON~EALTII OF PEHHSYLVANIA ....
DEPARTHENI OF ;RAFlSPOR'rATION ....
Buresu of Dr4ver Licensing
Hail Date; HAY 2]° 2003
~1 ACR! R~ PROCE;;/NG ~AT£
FlECHANZCSBUR& PA l?OSS )ATE OF BZRTH
,/
Dear HR, LEUSCHEH;
This ts an Oft'ioi&l Hot,ce O~ ~hm Su~en~ton of your
Privilege 8s idthorJzed by Section IS3BE of the Pennsylvania
Vehicle Code. As a resull of your 05/11/200] conv~Gt~on of
v~oll~ng 5ect~on ~2 of ~he Vehtcle Code, EXCEED~HQ ~AX~-.
HUH SPEED, on 05/04/2001:
~ Your driving privilege Js 6U~PENDED fOP a ~eP~ ~ 90'
follo~ the Instructions Iff this letter far COFlPLYZHG WITH
THZS SUSPENS~OH, PAY[HG THE RESTGRA~ZON FEE ~nd PROVTD;NG
omrmfullY. Even Sf YOU have uenved all the t~me on the
ouopene~on/rovoeat~on, we clflflot re~torm VOUP dr~v~flg ~P~v-
~~~~f~GFF ..........
Y=u molt return mZZ current Pennsylvania dr~vmr~s
cords) ~fl your possession on or- before 06/25/2001. You may
surrender these ~tems before, 06/25/2001, for earlier
credit; ho~ever, ~ou may nut dr~ve after these i~ems are
YOU MAY ~T RE?AZN YOUR D~VEReB LZCEHBE FOR
PURPOSBG. HaNover, ~,ou mmy apply for and obtain a ~hata
of ~9.g0. You mu~t ~resent t~o (2) forms of ~roper Jden-
t~fJcation (e.g., b~rth c,r~f~cate, va)Id U.S. passport,
marriage ~ert~fjfate, eta.) ~n GPde~ ta obtain your ~hoto
Jden~J ficot~on card.
Ol13&9~859SO&9~ ....
~RQV~DZNG PROOF OF Z#SURANCE
N~thJfl the list S0 days of your iuspensSon, we wA~Z send you
s )otter asking that you provide proof Of Ansuranoe at that
wllX be needed ~f you do not own a vehicle reSistered In
Pennsylvania.
ze~oPtent~ P~oa~a make sure that PennDOT ~s not~fied ~f you
move from your current mddress. You may notify PennPOT of
your mddress change by calltn~ Iny of the phone numbers
~$sted a~ ~he end at this ~ett~r. ..._ -..
RpPEAL
You have the ri;ht to lpPim] this action to the
¢o~mon Pleas (C~v~Z D~visSon) ~ith~n ~0 days
de'~-,-~J~r-~r~ ~lF~-~-~'f~thts' ~etter. %f you f~Xe in e~peaX
in the ~ounty gouft, the ¢oumt ~lll give -
0i razed, you must sYnd'thAs time-stamped certified copy of
the aPpea! by certified msAl to;
PennsyZvan~e Department of Transportation
Office of Chief
Third F~oer, R~verfront Office Center
Hsrrisburg~ PA
Remember, this ~s an OPFZC2AL NOTZGB OF SUIPENSZON. You
,uat return aZ! current P~nnsy~vanLa driver license prodUCtS
to PsnnDO~ by 06/2S/2OOZ.
Rebecca L. lickley, Director
Bureau of Dr~ver L'lGens].na
SEND FEE/LZCENSE/DL-1&LC/TO~ ZHFORHAT~OH (7:00 AH TO 9:00 PN)
Daeertma~t ev Trana~ortat~on ZN STATE ~-800-9~2-q&00
Bureau of Driver Llceflsine OUT-OF-STATE
P.O. Box 6B&93 TOD ZN STATE l-8BO-22E-0676
Harrisburg, PA ~7~0&-S&~ TOD OUT-OF-STATE
~ hereby verify that the statements made in the fore
document are true and COrrect. ~
herein are made subject ~..L understand that false et ~ ....
4904, relatin- t -vune Penalties of
~ o Unsworn falstfic~;~- ~ 8 Pa.c.$. Sectio~
~--~. =o authorities.
Dated:/"
cOMMONWEALTH OF PENNSYLVANIA .' IN THE coURT OF COMMON PLEAS OF
.. CUMBERLAND coUNTY, PENNSYLVANIA
v. :No.
NICHOLAS RYAN LEUSCHEN, :
Petitioner :
AND NOW, this ~ day of ~, 2001, upon
consideration of the within Petition, it is hereby ORDERED and
DECREED that a hearing n this matter be held on the ~day of
~/¢ ,2001, ~n courtroom No. ~ at//:~ o'olock
~ .m., in the cumberland County Courthouse.
A Stay of Petitioner's License Suspension is hereby
issued pending the disposition of the Appeal.
BY THB~
· .
Di~ . PA 17102
~.-.' s .- 1101 N. Front St., Hbg ,
office of chief Counsel~ Thmrd Floor,
PennDO~,
Rlverfront office Center, Harrisburg, PA 17104
COMMONWEALTH OF PENNSYLVANIA : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v. = NO. 01-3225
NICHOLAS RYAN LEUSCHEN, ' ~'~"', 'L ~:~ ~----/,°~44/_ L~I ~
Petitioner :
AND NOW, this ~ day of July, 2001, it is hereby
ORDERED and DECREED that the hearing on Petitioner,s driver,s
license suspension appeal scheduled for July 27, 2001 is continued
so that the underlying offense which is the basis for the
suspension may be resolved.
This matter shall be held on the ~___~day of October,
2001, in Courtroom No. 5 ~at:~o'clock ~ .m., in the
Cumberland County ~house.
~DWARD E. GUIDO, j.
Kenneth F. Lewis, Esq., 1101 N. Front St., Hbg., PA 17102
PennDOT, Office of Chief Counsel, Third Floor,
Riverfront Office Center, Harrisburg, PA 17104
COMMONWEALTH OF PENNSYLVANIA : IN THE COURT OF CONNON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. 01-3225
NICHOLAS RYAN LEUSCHEN, :
Petitioner :
PRAECIPE TO WITHDRAWAL APPEAL
OF LICENSE SUSPENSION
TO THE PROTHONOTARY:
As the suspension which is the subject of the above
appeal has been withdrawn by PennDOT (thus making the Petition
moot), please withdraw the Petition and cancel the hearing
scheduled for October 12, 2001 before the Honorable Edward E.
Guido.
DA?E: 8/16/01
I.D. ~69383
1101 N. Front St.
Harrisburg, PA 17102
(717) 234-3136