HomeMy WebLinkAbout13-6207 Supreme Co.A •o Pennsylvania
C011rOrCommo leas For Prothonotary Use Only:
Civil Cbver'Sheet
t Docket No:
Cu �eerr Countyt f�
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the.fili.ng and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S
[I Complaint El Writ of Summons Ix Petition nF Transfer from Another Jurisdiction 0 Declaration of Taking
E
C Lead Plaintiff's Name: Lead Defendant's Name:
Ryan E. Campbell PennDOT
T Dollar Amount Requested: ❑within arbitration limits
I Are money damages requested? 0 Yes Z No (check one) Qoutside arbitration limits
O
N Is this a Class Action Suit? Yes x No Is this an MDJAppeal? F-1 Yes 17x No
A. Name of Plaintiff/Appellant's Attorney:
M Check here if you have no attorney(are a Self-Represented [Pro Sel 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
Intentional [I Buyer Plaintiff Administrative Agencies
Q Malicious Prosecution El Debt Collection: Credit Card 0 Board of Assessment
Motor Vehicle Debt Collection: Other 0 Board of Elections
E] Nuisance ❑x Dept.of Transportation
Premises Liability El Statutory Appeal:Other
S 0 Product Liability(does not include
mass tort) Dispute:
E Discrimination
El Slander/Libel/Defamation
C Q Other: � Employment Dispute:Other El Zoning Board
El
,I,
I Other:
O MASS TORT
0 Asbestos
N [] Tobacco
0 Toxic Tort-DES
n Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
Q Toxic Waste
Ejectment Q Common Law/Statutory Arbitration
Other: 1 Eminent Domain/Condemnation E] Declaratory Judgment
B 0 Ground Rent Q Mandamus
M Landlord/Tenant Dispute Non-Domestic Relations
LJ Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABLITY I❑— Mortgage Foreclosure:Commercial Quo Warranto
0 Dental in Partition El Replevin
0 Legal E] Quiet Title l Other:
C,' Medical E] Other:
0 Other Professional:
Updated 1/1/2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ryan E. Campbell No. /3— fir2 ? 01'a
(Type your name)
tw�:5
Vs. Driver's License/Auto Registration Appr w
Commonwealth of Pennsylvania �;r_ c �%
Department of Transportation r,3 CD
Bureau of Drivers Licensing C7J —=�•
-T
APPEAL OF DRIVER'S LICENSE/AUTO REGISTRATION SUSPENSION.,
AND NOW,this (enter today's date) October 21 2013 ,comes the Appellant, (Type'yoa-F arrie)
Ryan E. Campbell , by his/her attorney, and states as follows:
1. Appellant's PA operator's number or automobile registration number is:
26340445
2. PennDOT proposes, by Notice dated (insert"mailing" date here) October 2 , 2013 ,to suspend
Appellant's driving privileges 1-1 automobile registration for a period of(Insert length of suspension)
18 Months pursuant to Section 1547B111 of the Vehicle Code, which
suspension is to be effective (Insert suspension effective date) November 6 12013
****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).
Other(Specify reason:)
1
-OR-
The suspension of Appellant's automobile registration is contrary to law in that:
F] 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:)
WHEREFORE,Appellant respectfully requests this Honorable Court to sustain the appeal from the suspension
of operating privileges or automobile registration.
Respectfully submitted,
(Sign name here)
Ryan E. Campbell
(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: <y
Type Name: Ryan E.Campbell
Address: 169 E. Pomfret Street
City/State/Zip Code: Carlisle, PA 17013
Telephone Number: 717-226-4296
Email address: rcwrestle141 Ca gmail.com
2
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Mail Date : OCTOBER 02, 2013
RYAN EDWARD CAMPBELL WID # 132686180629648 001
169 E POMFRET ST PROCESSING DATE 09/25/2013
DRIVER LICENSE # 26340445
CARLISLE PA 17013 DATE OF BIRTH 03/05/1983
Dear MR. CAMPBELL :
This is an Official Notice of the Suspension of your Driving
Privilege as authorized by Section 1547B1II of the
Pennsylvania Vehicle Code . As a result of your violation
of Section 1547 of the Vehicle Code , CHEMICAL TEST REFUSAL ,
on 08/24/2013:
■ Your driving privilege is SUSPENDED for a period of 18
MONTH(S) effective 11/06/2013 .at 12: 01 a .m.
COMPLYING WITH THIS SUSPENSION
You must return all current Pennsylvania driver 's licenses ,
learner ' s permits , temporary driver ' s licenses (camera
cards) in your possession on or before 11/06/2013. You may
surrender these items before , 11/06/2013, for earlier
credit; however , you may not drive after these items are
surrendered .
YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR IDENTIFICATION
PURPOSES. However , you may apply for and obtain a photo
identification card at any Driver License Center for a cost
of $13 . 50 . You must present two (2) forms of proper
identification (e . g . , birth certificate , valid U .S.
passport , marriage certificate , etc . ) in order to obtain
your photo iaentification °care,-.
You will not receive credit toward serving any suspension
until we receive your license(s) . Complete the following
steps to acknowledge this suspension .
1 . Return all current Pennsylvania driver ' s licenses ,
learner 's permits and/or camera cards to PennDOT. If
you do not have any of these items, send a sworn
notarized letter stating you are aware of the suspension
of your driving privilege . You must specify in your
letter why you are unable to return your driver 's
license . Remember : You may not retain your driver 's
license for identification purposes . Please send these
items to :
132686180629648
Pennsylvania Department of Transportation
Bureau of Driver Licensing
P. O . Box 68693
Harrisburg , PA 17106-8693
2 . Upon receipt , review and acceptance of your Pennsylvania
driver ' s license (s) , learner 's permit (s) , and/or a sworn
notarized letter , PennDOT will send you a receipt
confirming the date that credit began . If you do not
receive a receipt from us within three (3) weeks, please
contact our office. otherwi-se, you wi ] I not be given
credit toward serving this suspension . PennDOT phone
numbers are listed at the end of this letter .
3. If you do not return all current driver license
products , we must refer this matter to the Pennsylvania
State Police for prosecution under SECTION 1571 (a) (4)
of the Pennsylvania Vehicle Code .
PAYING THE RESTORATION FEE
You must pay a restoration fee to PennDOT to be restored
from a suspension/revocation of your driving privilege . To
pay your restoration fee , complete the following steps :
1 . Return the enclosed Application for Restoration . The
amount. due is listed on the application .
2 . Write your driver ' s license number (listed on the first
page) on the check or money order to ensure proper
credit .
3 . Follow the payment and mailing instructions on the back
of the application .
Please note : Paying -the restoration fee DOES NOT -satisfy
the requirement to acknowledge your suspension/revocation .
If you have not acknowledged your suspension/revocation ,
please follow the instructions listed under "Complying with
this Suspension/Revocation" .
132686180629648
APPEAL
You have the right to appeal this action to the Court of
Common Pleas (Civil Division) within 30 days of the mail
date, OCTOBER 02 , 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
certified copy of the appeal by certified mail to :
Pennsylvania Department of Transportation
Office of Chief Counsel
- _- -- Third Rivnrfront Office .Center
Harrisburg , PA 17104-2516
Remember , this is an OFFICIAL NOTICE OF SUSPENSION. You
must return all current Pennsylvania driver license products
to PennDOT by 11/06/2013.
Sincerely,
9�j�- - Z g �/'V
Janet L . Dolan , Director
Bureau of Driver Licensing
INFORMATION 8: 00 a .m. to 5 : 00 p .m.
IN STATE 1-800-932-4600 TOD IN STATE 1-800-228-0676
OUT-OF-STATE 717-412-5300 TDD OUT-OF-STATE 717-412-5380
WEB SITE ADDRESS www.dmv . state .pa .us
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Ryan E. Campbell
No. L
(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 a9V day of JftOT��QhJ , 20Z_j , a hearing is scheduled
on the appeal of Petitioner for the /7q day of 2015;4 at /: 3d /0 M
in Courtroom # I/ 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,3rd 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,
Judge
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Ir-C.
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RYAN E. CAMPBELL, • IN THE COURT OF COMMON
Petitioner • PLEAS OF CUMBERLAND
• CUMBERLAND COUNTY
•
v.
•
COMMONWEALTH OF PENNSYLVANIA, • NO. 13-6207 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.
BY THE COURT:
/14.
J.
Attest:
/ Ryan E. Campbell, 169 East Pomfret Street, Carlisle, PA 17013
✓ Philip M. Bricknell, Esq., Pennsylvania Department of Transportation, Office of Chief
Counsel, Riverfront Office Center, 3rd Floor, 1101 South Front Street, Harrisburg,
PA 17104-2516
Cc?ik,s
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