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Home My WebLink About14-2413Supreme Cot'U?ennsylvania Cour ;Of .Cammof. Pleas C ' • Cover Sheet Cu ro ; �� County For Prothonotary Use Only: Petition Declaration of Taking Docket No: )(.4 i The information collected on this. form 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 by law or rules of court. Commencement of Action: Petition Declaration of Taking ■ Complaint ■ Writ of Summons — • Transfer from Another Jurisdiction • Lea Plainti s Name: 1 �,b M . vfrits Led Defendant's Name: Li ul n Lu U . a .� '\ PA Dollar Amount Requested: (check one) arbitration limits arbitration limits • within Are money damages requested? ■ Yes No • outside Is this a Class Action Suit? ❑ Yes 1No Is this an MDJAppeal? Yes No • Name of Plaintiff /Appellant's Attorney: Ji,ua,� d F SD if & ta1 i, a Self- Represented [Pro Se] Litigant) ■ Check here if you have no attorney (are 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) ❑ Intentional ❑ Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/ Defamation ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABLITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: CONTRACT (do not include Judgments) ❑ Buyer Plaintiff ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ▪ Employment Dispute: Discrimination ❑ Employment Dispute: Other ❑ Other: REAL PROPERTY ❑ Ejectment ❑ Eminent Domain/Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute ❑ Mortgage Foreclosure: Residential ❑ Mortgage Foreclosure: Commercial ❑ Partition ❑ Quiet Title ❑ Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ept. of Transportation Statutory Appeal: Other in Zoning Board ❑ Other: MISCELLANEOUS ❑ Common Law /Statutory Arbitration ❑ Declaratory Judgment 8 Mandamus Non - Domestic Relations Restraining Order ❑ Quo Warranto ❑ Replevin ❑ Other: Updated 1/1/2011 CALEB M. DEEMS, Petitioner v. 2014 APR 21 P1 3: 1 3 CUMBERLAND COUNTY PENNSYLVANIA : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ill., t1/3 /U/ COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION : LICENSE SUSPENSION APPEAL BUREAU OF DRIVER LICENSING, Respondent LICENSE SUSPENSION APPEAL AND NOW, comes Caleb M. Deems, hereinafter Petitioner, by and through his attorneys, Wagner & Spreha, who respectfully represent: 1. The Petitioner is an adult individual residing at 1332 Ritner Highway, Shippensburg, Cumberland County, Pennsylvania. 2. Respondent, Pennsylvania Department of Transportation, Bureau of Driver Licensing has a mailing address of Riverfront Office Center, Third Floor, 1101 S. Front Street, Harrisburg, Dauphin County, Pennsylvania 17104 -2516. 3. On or about March 31, 2014, the petitioner received an official notice of suspension indicating that his driving privilege was to be suspended for a period of one year as a result of a violation of 75 Pa.C.S.A. §1543(a). 4. The petitioner believes such suspension is improper, unjust and illegal for reasons which include, but are not limited to the following: a. The Petitioner is not guilty of the underlying offense; b. The Petitioner has a summary appeal pending on the underlying conviction in the Court of Common Pleas of Cumberland County. WHEREFORE, the petitioner respectfully requests this Court schedule a hearing to determine the propriety of the suspension. 00,4 'i L) ,7 ff cry 2+364-)oco Respectfully submitted, WAGNER & SPREHA i/f Edward F' •" a, Jr., Esq. Attorney ID o. 78661 Attorney for Petitioner 2233 North Front Street Harrisburg, PA 17110 717- 234 -7051 t e. CALEB M. DEEMS, Petitioner v. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF DRIVER LICENSING, Respondent AND NOW, this day o IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No 1q,)0 to% LICENSE SUSPENSION APPEAL ORDER , 2014, upon consideration of the within Petition, it is hereby ordered and decreed that a hearing be held on the ofd day of 7 a , at 06 o'clock in Courtroom / , Cumberland County Courthouse. Notice of said hearing shall be mailed to the Department of Transportation by Appellant's attorney at least sixty days prior to the date of the hearing. By the Court: Distribution: Court Administration Prothonotary Edward F. Spreha, Jr., Esquire, 2233 North Front Street, Harrisburg, PA 17110 1,/Pennsylvania Department of Transportation, Office of Chief Counsel, c 110.1 South Front Street, 3rd Floor, Harrisburg, PA 17104 -2516 .-03 11 2 � ii/20V (pr- Dn Zp --4 CALEB M. DEEMS, Petitioner v. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Respondent ORDER IN THE COURT OF COMMON PLEAS OF CUMBERLAND CUMBERLAND COUNTY NO. 14-2413 CIVIL TERM DRIVER LICENSE SUSPENSION APPEAL AND NOW, this 20th day of August, 2014, the appeal filed in the above - captioned matter is REMANDED to the Department of Transportation for correction of its records. Attest: BY THE COURT: i Edward F. Spreha, Jr., Esq., 2233 North Front Street, Harrisburg, PA 17110 i 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 exr es nekci,jeelf 44P4 l ILED-OF i t THE PROTHONOTARY AUG 21 Mi . 0 CUMBERLAND COUNTY PENNSYLVANIA CALEB DEEMS, :IN THE COURT OF COMMON PLEAS Petitioner :CUMBERLAND COUNTY, PENNSYLVANIA v. :NO.: 14-2413 CIVIL COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF DRIVER LICENSING, Respondent PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Please withdraw the above -captioned License Suspension Appeal which was filed by the Petitioner. Date: Respectfully submitted, WAGNER & SPREHA By _Ao Edward ' rpa, Jr., Esquire Attorney I.D. ' 78661 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorney for Petitioner