HomeMy WebLinkAbout04-5942
CRAIG T. DUNKLE
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
: NO.
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v.
CIVIL APPEAL - LAW
COMMONWEALTH OF
PENNSYLVANIA
DEPARTMANT OF
TRANSPORTATION
APPEAL FROM LICENSE SUSPENSION
PETITION FOR APPEAL FROM SUSPENSION OF DRIVING PRIVILEGES
AND NOW comes Craig T. Dunkle, by his attorneys, Caldwell & Kearns, and presents
the following Petition for Appeal from Suspension of his Driving Privileges.
1. Petitioner is an adult individual who resides at 225 Fox Drive, Mechanicsburg,
Pennsylvania, 17050.
2. The Petitioner is licensed as a motor vehicle operator by the Commonwealth of
Pennsylvania, Department of Transportation, License No. 27211898.
3. By official notice, dated November 4,2004, your Petitioner received notification
from the Commonwealth of Pennsylvania, Department of Transportation, that his driving
privileges were suspended for a period of one year, effective October 31, 2003. The suspension
is based upon an adjudication for underage drinking.
4. The underlying adjudication has been appealed to the Cumberland County Court
of Common Pleas. The appeal is docketed at number CP-21-SA-0000184-2004.
5. It is respectfully requested this Honorable Court issue an Order staying the
suspension of this matter until the disposition of the Petitioner's Appeal on the underlying
adjudication.
WHEREFORE, your Petitioner prays this Honorable Court to issue an Order
staying this suspension in the above referenced matter pending the results of the Appeal
in underlying adjudication in which the suspension is based upon.
Respectfully submitted,
CALDWELL & KEARNS
Dated: 1I (" Y I D1
CERTIFICATE OF SERVICE
AND NOW, this ~day of November, 2004, I hereby certify that I have
served a copy of the within document on the following by depositing a true and correct
copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, certified, postage
prepaid, addressed to:
COMMONWEALTH OF PENNSYL VANIA
DEPARTMENT OF TRANSPORTATION
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, P A 17104
CALDWELL & KEARNS
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CRAIGT. DUNKLE,
Petitioner
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 04-5942 Civil
COMMONWEALTH OF
PENNSYLVANIA DEPARTMENT OF
TRANSPORTATION
CIVIL APPEAL - LAW
APPEAL FROM LICENSE SUSPENSION
PRAECIPE TO WITHDRAW APPEAL
On behalf of the Petitioner, please withdraw the appeal in the above.captioned case.
Respectfully submitted,
~ /
y:
o -Lv'. Marsico, Esquire
S 1. LD. No. 69804
I North Front Street
Harrisburg, PA 17110-1533
(717) 232-7661 - Phone
(717) 232 - 2766 - Fax
Attorneys for Petitioner
Date: September 7, 2005
CERTIFICATE OF SERVICE
I certify that I am this day serving a copy of the foregoing document upon the
person(s) and in the manner indicated below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail at
Harrisburg, Pennsylvania, with first-class postage, prepaid, as follows:
George H. Kabusk, Assistant Counsel
Commonwealth of Pennsylvania
Department of Transportation
Office of Chief Counsel
1101 South Front Street
Third Floor, Riverfront Office Center
Harrisburg, PA 17104-2516
Respectfully submitted,
~h~
, K. Marsico, Esquire
. Ct. J.D. No. 69804
3631 North Front Street
Harrisburg, PA 17110-1533
(717) 232-7661 - Phone
(717) 232 - 2766 - Fax
Attorneys for Petitioner
Date: September 7, 2005
04-376/92462
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