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Home My WebLink About13-5772 Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Only: Civil Cover Sheet Docket No: Cumberland County 13. 77 �r l;vs Commencement of Action: S Q Complaint El Writ of Summons El Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: Knicos, Renee PA Dept.of Transportation T Dollar Amount Requested: ❑within arbitration limits I Are money damages requested? El Yes No O 1 (check one) ❑outside arbitration limits N Is this a Class Action Suit? ❑Yes 0 No Is this an MDJAppeal? 0 Yes ❑ No A Name of Plaintiff/Appellant's Attorney: ��P(�l° �� `LDS a 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 ❑ Intentional. ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections ❑Nuisance x Dept.of Transportation ❑ Premises Liability Statutory Appeal:Other S ❑ Product Liability(does not include ❑ Employment Dispute: E mass tort) ❑ Slander/Libel/Defamation Discrimination C El F1 Employment Dispute:Other ❑ Zoning Board T ❑ Other: I ❑ Other: O MASS TORT ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration Bi ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure:Commercial ❑Quo Warranto ❑ Dental ❑ Partition ❑Replevin ❑ Legal ❑ Quiet Title ❑Other: ❑ Medical ❑ Other: ❑ Other Professional: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA �"ee_ kn No. r '3 7d- City>l 4.etAt (Type your name) Vs. Driver's License/Auto Registration Appq a MW cz) , Commonwealth of Pennsylvania =L — rr n Department of Transportation >„ '- Bureau of Drivers Licensing i { cm cp APPEAL OF DRIVER'S LICENSE/AUTO REGISTRATION SUSPENSION >C_' `13 Ag NOW, this (enter today's date) 0 1� , comes the Appellant, (Type your name)- us , by I' /her attorney, and states as follows: ,F 161, 1. Appellant's PA oper�tor; number or automobile registration number is: ;46 � f' ` W 2. PennDOT proposes, by Notice dated (insert"mailing" date here) Q 13 !, � 20� ,to suspend Appellant's driving privileges R1 automobile registration for a period of(Insert length of suspension) �4 1710n �> pursuant to Section of the Vehicle Code, which suspension is to be effective (Insert suspension effective date) ta;t ^ 1 _, 20 1 ?j ****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). ErOther(Specify reason:) l ueao , ► v)D oA.p-errar'rrP— mea-45 15.m �� - '�'he Cj�.xua'1c�, ect�D r1et� 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). Other(specify reason:) e*,p urea- -Porgy 10 h WHEREFORE, Appellant respectfully requests this Honorable Court to sustain the anneal from the suspension of operating privileges or automobile registration. - —0 C� -�� r Respectfully submitted, (S7,,e Ll (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: Type Name: k1 Address: t � -fCel� City/State/Zip Code: Telephone Number: -717 C 4 16'" 0 did Email address: e,it r)- 2 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Harrisburg , PA 17123 SEPTEMBER 07, 2013 RENEE KNICOS WID # 132439283808131 001 143 TOWER CIRCLE PROCESSING DATE 08/31/2013 DRIVER LICENSE # 26640064 CARLISLE PA 17013 DATE OF BIRTH 12/30/1952 Dear Motorist : Your driving privilege is scheduled to be suspended on 10/12/2013 , because you failed to produce proof of financial responsibility on 06/24/2013, the date of your traffic of- fense . 1 . Your driving privilege will be suspended for three months effective 10/12/2013 at 12 : 01 A .M. as authorized by Section 1786 (d) of the Vehicle Code . Please see the enclosed application for restoration fee in- formation . 2 . You will be required to return any current driver 's license or learner ' s permit and/or temporary drivers license (camera card) in your possession . 3. You will be required to provide the Department with proof that all motor vehicles registered in your name are covered by a motor vehicle liability insurance policy or by a program of self-insurance approved by the Department . You will not be permitted to operate a motor vehicle until you have been advised in writing by this Bureau that your privilege has been reinstated . If you do not comply with this notice , this Bureau will refer this matter to the Pennsylvania State Police for prosecution under Section 1571 (A) of the Vehicle Code . EFFECTIVE DATE OF SUSPENSION : 10/12/2013 12 : 01 A.M. In order to comply with this sanction you are required to return any current driver's license, learner's permit and/or 132439283808131 temporary driver's license (camera card) in your possession no later than the effective date listed. If you cannot comply with the requirements stated above , you are required to submit a DL16LC Form or a sworn affidavit stating that you are aware of the sanction against your driving privi- lege . Failure to comply with this notice shall result in this Bureau referring this matter to the Pennsylvania State Police for prosecution under SECTION 1571 (a) (4) of the Ve- hicle Code . Although the law mandates that your driving privilege is under suspension even if you do not surrender your license , Credit will not begin until all current driver ' s license product (s) , the DL16LC Form , or a letter acknowledging your sanction is received in this Bureau . WHEN THE DEPARTMENT RECEIVES YOUR LICENSE OR ACKNOWLEDGE- MENT, WE WILL SEND YOU A RECEIPT. IF YOU DO NOT RECEIVE THIS RECEIPT WITHIN 15 DAYS CONTACT THE DEPARTMENT IMMEDIATELY. OTHERWISE , YOU WILL NOT BE GIVEN CREDIT TOWARD SERVING THIS SANCTION . APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date , SEPTEMBER 07 , 2013, 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 your appeal to be valid , you must send this time-stamped certi- fied copy of the appeal by certified mail to : Pennsylvania Department of Transportation Office of Chief Counsel Third Floor , Riverfront Office Center Harrisburg , PA 17104-2516 Sincerely, 9�w�- - - Z g e4 Janet L . Dolan , Director Bureau of Driver Licensing 132439283808131 SEND FEE/LICENSE/DL-16LC/T0: INFORMATION (8 : 00 AM TO 5 : 00 PM) Department of Transportation IN STATE 1-800-932-4600 Bureau of Driver Licensing OUT-OF-STATE 717-412-5300 P .O. Box 68693 TOO IN STATE 1-800-228-0676 Harrisburg , PA 17106-8693 TOO OUT-OF-STATE 717-412 75380 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF MOTOR VEHICLES PO BOX 68674 HARRISBURG, PA 17106-8674 www.dmv.state.pa.us WID# 132459999000105 001 TITLE# 60358118 PROCESSING DATE 130901 TRANSACTION CODE 00340 RENEE KNICOS 143 TOWER CIR CARLISLE, PA 17013 OFFICIAL NOTICE MAIL DATE: 09/08/13 Dear Customer: The Department was recently notified that a traffic offense occurred on 06/24/13 involving the following vehicle: MAKE: HONDA YEAR: 2004 BODY TYPE: STATION WAGON LICENSE PLATE##: FRF4141 TITLE##: 60358118 VIN##: SIISRD78824U235403 At the time the offense occurred, you were unable to provide proof of financial responsibility (insurance). As a result, the registration for the vehicle listed above will be suspended for three months effective 10/13/13 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 for 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 If you believe your insurance coverage was terminated in error or you did not receive proper notice of your insurance termination, you should file a complaint with the Pennsylvania Insurance Department, Bureau of Consumer Services. Complaints can be filed via the website at www.insurance.pa.gov or mailed to the Pennsylvania Insurance Department, Bureau of Consumer Services 1209 Strawberry Square, Harrisburg, PA 17120. Please include your insurance company name and policy number with your complaint. By Order of Director Bureau Bureau of Motor Vehicles Department of Transportation Information (8:00 AM to 5:00 PM) Pennsylvania 800-932-4600 Out of State 717-412-5300 TDD Pennsylvania 800-228-0676 TDD Out of State 717-412-5380 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA SRenee Knicos No. /3 � 77v7- �' �`• (Type your name) Vs. Driver's License/Auto Registration Appeal Commonwealth of Pennsylvania Department of Transportation Bureau of Driver Lice nsing M 00 Cn CERTIFICATE OF SERVICE wM' C-) CD fcLW The undersigned hereby certifies that on , 20 /3 , 1 caused �o§-e r -< mailed by regular mail,postage prepaid, a copy of the Appeal, Order Scheduling Hearing, and all attachments,to: Office of Chief Counsel Vehicle and Traffic Law Division Riverfront Office Center,3'd Floor 110 5outfi Front Street Harrisburg,PA 17104-2516 Date: A)/ ,2,0 /,141 Signature: Type your Name: Ren Knicos Address: 143 Tower Circle City/State/Zip Cade: Carlisle,PA 17013 Telephone: (717)245-2105 **This form must be completely filled out and filed in the Prothonotary's office promptly after mailing the documents to PennDOT** w LI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Renee Knicos No i?- (Print your name) . • • Vs. Driver's License/Auto Registration Appeal • Commonwealth of Pennsylvania . Department of Transportation . Bureau of Driver Licensing ORDER SCHEDULING I H�E-AARRING ON APPEAL AND NOW, this /Q day of &Z!I L/2_ , 2013_, a hearing is scheduled on the appeal of Petitioner for the /7.14 day of G LUa/LLl ,20/7 at 9 : 3O , M in Courtroom # li of the Cumberland County Courthouse, One Courthouse Square, 4th 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. By the Court, / ' . 1/IL.% - Judge H;-t f _.___ :„ .- , 2 rIZ' j> 2 . . - utroS CD .r , ....= ?eVA.)e-IC:4- ::. , ,,, .,....(7,_ it)//0//3 =te 1/i RENEE KNICOS, : IN THE COURT OF COMMON Petitioner : PLEAS OF CUMBERLAND : CUMBERLAND COUNTY v. • COMMONWEALTH OF PENNSYLVANIA, : NO. 13-5772 CIVIL TERM DEPARTMENT OF TRANSPORTATION, : BUREAU OF DRIVER LICENSING, : DRIVER LICENSE Respondent : SUSPENSION APPEAL ORDER AND NOW, this 17TH day of January, 2014, the appeal filed in the above- captioned matter is: REMANDED to the Department of Transportation for correction of its records. DISMISSED and the suspension which is the basis of this appeal shall be REINSTATED. SUSTAINED and the suspension which is the basis of this appeal shall be RESCINDED. WITHDRAWN and the suspension which is the basis of this appeal shall be REINSTATED. CONTINUED and RESCHEDULED for the day of , 2014, at .m., in Courtroom Room No. of the Cumberland County`7 Courthouse, C;) a<s Carlisle, Pennsylvania. tom_=- C)>. ' cs � BY THE COURT: Lip J= L.- CO - / J. Attest: Renee Knicos, 143 Tower Circle, Carlisle, PA 17013 .. Philip M. Bricknell, Esq., PennDOT, Riverfront Office Center, Office of Chief Counsel, 3rd Floor, 1101 South Front Street, Harrisburg, PA 17104-2516 3I.€ I7Z L