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HomeMy WebLinkAbout13-4559 Supreme CVu nnsylvania Con f-col"Mmo leas For Prothonotary Use Only: CN t (7 N& b Docket No: A.:' County The information collected on this fornz is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required bj,law or rules of court. Commencement of Action: M, Complaint M! Writ of Summons Eg"Petifion S Transfer from Another Jurisdiction Declaration of Taking E Lead Plaintiffs Name: Lead Defendant's Name: C T _?F_K D-cDT Dollar Amount Requested: Elwithin arbitration limits I Are money damages requested? El Yes 0 No (check one) 71 outside arbitration limits 0 N Is this a Class Action Suit? El Yes M-N No Is this an MDJAppeal? 0 Yes E] No A Name of Plaintif ppellant's Attorney: OCheck here if you have no attorney (are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS 0 Intentional Buyer Plaintiff Administrative Agencies Malicious Prosecution Q Debt Collection:Credit Card Board of Assessment Motor Vehicle Debt Collection: Other `Dept.ard of Elections Nuisance of Transportation Premises Liability El Statutory Appeal: Other S Product Liability(does not include E] Employment Dispute: E mass tort) Slander/Libel/Defamation Discrimination 0 Employment Dispute:Other Zoning Board C Other: T El Other: 1 0 Other: o MASS TORT E] Asbestos N Tobacco Toxic Tort-DES Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Toxic Waste El Ejectment M Common Law/Statutory Arbitration B Other: El Eminent Domain/Condemnation Declaratory Judgment El Ground Rent 0 Mandamus El Landlord/Tenant Dispute E3 Non-Domestic Relations FRI Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY F1 Mortgage Foreclosure:Commercial Ej Quo Warranto 0 Dental 0 Partition El Replevin rl Legal rl Quiet Title 0 Other: [] Medical E] Other: F1 Other Professional: Updated 11112011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 0.m c O(1— LV S No. +ec k l (Type your name) C C- Vs. Driver's License/Auto Registration A Commonwealth of Pennsylvania —C? N Department of Transportation —� Bureau of Drivers Licensing CD APPEAL OF DRIVER'S LICENSE/AUTO REGISTRATION SUSPENSION AND NOW, this (enter today's date) A u—a 20 1? , comes the Appellant, (Type your name) -E)G.�Mt Y�S0�1-E y is/her attorney, and states as follows: 1. Appellant's PA operator's number or automobile registration number is: HKA 9Fg3 2. PennDOT proposes, by Notice dated (insert"mailing" date here) j 14 , 20 13 to suspend Appellant's driving privileges automobile registration for a period of(Insert length of suspension) 7�zc/CL -5 pursuant to Section�1 gY� of the Vehicle Code,which suspension is to be effective (Insert suspension effective date) e Q 1 , 20 1 ****A copy of the Notice sent by PennDOT is attached to this Appeal**** 3. The suspension of Appellant's operating privileges is contrary to law in that: (Check those which apply) The police lacked reasonable grounds to stop Appellant and/or request Appellant to submit to a chemical test. Appellant did not knowingly or intelligently refuse a chemical test; The conviction on which Appellant's suspension is based was overturned by successful appeal, OR is currently under appeal. (Attach a copy of the court docket this Appeal). 3� F] Other(Specify reason:) a 75" CeA 1 -OR- The suspension of Appellant's automobile registration is contrary to law in that: ❑ My failure to have insurance was for a period of less than 31 days AND I did not drive nor permit anyone else to drive my vehicle during the time it was without insurance. (Attach proof of insurance to this Appeal and either a notarized statement of PennDOT form MV-221 to document non-operation of the vehicle). dOther(specify reason:) _T- was r)Df Comf k4el 5urc what C)a,f e CLvtCe,/bo- it jr �rorn 1'o5u,Y-o r-LC-e y feGtevccj ole,- fey C age �6- n ervlaj i +hQ+ S+C,+e� 0,nD4�r daAe, - _a.Yy) Cur en � r Ie [Y1 Cofl a O e o f t sh —_ WHEREFORE, Appellant respectfully requests this Honorable Court to sustain the appeal from the suspension P of operating privileges or automobile registration. Respectfully submitted, G� (Sign name here) ba.M c 1�oc l�,qjc- 50 A —F Va-vL S (Type name here) VERIFICATION The undersigned hereby states that the statements made in the attached Appeal of Suspension or Registration are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements in the attached Appeal are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Signature: A�����'1��G� Type Name: D lane �b�' `QY150Y llCr S Address: J��a c9� 5, {{140,yiol)e-I( —4 City/State/Zip Code: ( r- r S 1 )-7 ill. Telephone Number: (�/�� ��a�o���� Email address: rGt y1�bY�Yvl 1�GL @ aL CO YYl 2 OT GO)le gt aS an ct- 1-5 i � � AeGh) 1��1 k�oss rno c��2 `Plo zc, Q `der�I Da9�os�-�cs �n a�l3� p 1"Y) vclLGl-C T- I Y1vA �l ofSV) SCVIOOI J 4 + ,fef, f-e w l 1 nod be +0 f(ad cA 30 C,� 51vA a-150" T f I dc)�j c�4 ct.,�o b I v-%o- b e- tile- �o �P � COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF MOTOR VEHICLES PO BOX 68674 HARRISBURG, PA 17106-8674 www.dmv.state.pa.us WID# 132039999013131 001 TITLE# 67555095 PROCESSING DATE 130722 TRANSACTION CODE 00060 DAMITA D RANSON—EVANS 119 S HANOVER ST CARLISLE, PA 17013 OFFICIAL NOTICE MAIL DATE. 07/29/13 Dear Customer: The Department recently requested that you provide us with proof of financial responsibility (insurance) for the following vehicle: MAKE: PONTIAC YEAR: 2008 BODY TYPE: SEDAN LICENSE PLATE,##: HKA9843 TITLE##: 67555095 VIN##: 1G2ZG57B684226074 This information was requested because GFICO CASUL,TY CO notified us that the insurance policy covering the vehicle listed above was terminated on 06/02/13. Either no response was received or the information you provided was not acceptable. As a result, the registration for the vehicle listed above will be suspended for three months effective 09/02/13 at 12:01 A.M. as authorized by Section 1786(d) of the Vehicle Code. THIS IS A FINAL ORDER OF SUSPENSION. You are required to return your current registration plate, sticker and card to the Department immediately. Credit toward serving this suspension will not begin until the Department receives your registration products. Additionally, you are required to pay a restoration fee in the amount of$50 to the Department in accordance with Section 1960 of the Vehicle Code. Please make check or money order payable to the PA Department of'Transportation. Do not send cash. You can also pay by credit card online at www.dmv.state.pa.us by selecting "Pay Your Financial Responsibility Restoration Fee". Within 30 days of your eligibility date f'or restoration, you will also be required to show proof of insurance for this vehicle. We have enclosed a self-addressed envelope for your use when corresponding and a mailing label to assist with the return of your registration plate, sticker and card. When the Department receives your registration products, we will send you a letter within 3 weeks confirming that they were received. If, after 3 weeks of mailing your registration plate, sticker and card to the Department you do not receive a letter stating your registration products were received, please contact us immediately. You have the right to appeal this suspension to the Court of Common Pleas of the county of your residence within thirty(30) days of the mail date of this letter. If you file an appeal in the County Court, the Court will give you a time-stamped certified copy of the appeal. In order for the appeal to be valid, you must send this time stamped certified copy of the appeal by certified mail to: Pennsylvania Dept of Transportation Office of Chief Counsel 1101 S Front Street-3rd Floor Harrisburg, PA 17104-2516 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA No. w- 1 (Print your name) Vs. Driver's License/Auto Registration Appeal Commonwealth of Pennsylvania Department of Transportation Bureau of Driver Licensing ORDER SCHEDULING HEARING ON APPEAL AND NOW, this day of__14LAe, 20_L3, a hearing is scheduled on the appeal of Petitioner for the day of 20 & at q M in Courtroom #k— of the Cumberland County Courthouse, one Courthouse Square, 4t" Floor, Carlisle, PA 17013, at which time testimony will be taken and argument heard. A copy of this Order has been served on Appellant. It shall be Appellant's responsibility to serve a copy of this Appeal, all attachments, and this Order on the attorney for the Commonwealth, at the following address: Office of Chief Counsel Vehicle and Traffic Law Division Riverfront Office Center, 3`a Floor 1101 South Front Street Harrisburg, PA 17104-2516 It shall further be Appellant's responsibility to file a Certificate of Service with the Prothonotary stating that service was made on the Commonwealth of Pennsylvania. y the Court, Judge C--) CZ CC3, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA D m i c- 2n n Sbn-Eva.YAS No. J ' `��J C, f (Type your name) Vs. Driver's License/Auto Registration Appeal Commonwealth of Pennsylvania Department of Transportation Bureau of Driver Licensing CERTIFICATE OF SERVICE The undersigned hereby certifies that on PI,�vA;Z 3 , 201,3 , I caused to be mailed by regular mail, postage prepaid, a copy of the Appeal, Order Scheduling Heag, FMd ono all attachments, to: y a Office of Chief Counsels Vehicle and Traffic Law Division t" " C-5-n Riverfront Office Center, 3`d Floor "P,C-) F, ZG- irli 1101 South Front Street ��. }, Harrisburg, PA 17104-2516 . :rK Date:Auga,& d3 , 20 13 Signature: _ Type your Name: M') a r►S0✓l Z��/Q✓�S Address: S, J4Q-y101Jer �+ City/State/Zip Code: CO-f 's Ae , Pry Telephone: ( J���oZo1-a5u5w ** This form must be completely filled out and filed in the Prothonotary's office promptly after mailing the documents to PennDOT ** IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA DAMITA RANSON-EVANS . • NO. 13-4559 CCIVIL V. • -0 a w —r . MI =t- COMMONWEALTH OF PENNSYLVANIA, : zpi ,-ri DEPARTMENT OF TRANSPORTATION, • cn+" � ` BUREAU OF MOTOR VEHICLES : .. ORDER ›.- ' r- AND NOW, this I3 day of lvo , 2013, the appeal filed in the above referenced matter is: DISMISSED and the suspension shall be REINSTATED. SUSTAINED and the suspension shall be•RESCINDED. REMANDED to the Department to update its records and to rescind the appealed suspension. WITHDRAWN. CONTINUED AND RESCHEDULED for the day of , 20 , at .m., in Courtroom No. of the Cumberland County Courthouse. BY THE OURT: THE ATTEST: V 5 A• avitrel J. Kelly Edward Solomon, Esq., Office of Chief Counsel, Department of Transportation, 1101 South Front Street, 3rd Floor, Harrisburg, PA 17104-2516 Damita Ranson-Evans, 119 S. Hanover Street, Carlisle, PA 17013 �� -�: �tf Cab€ 6 J. 'P1k i . Cop y llha/4.3