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HomeMy WebLinkAbout05-1712 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05 - 17/)... C;-u:L~0L~ MICHAEL C. SCHUBERT Appellant COMMONWEALTH OF PENNSYLVANIA : PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee LICENSE SUSPENSION APPEAL APPEAL FROM SUSPENSION OF OPERATOR'S PRIVILEGE AND NOW, comes the Appellant, Michael C. Schubert, respectfully avers the following: 1. Appellant resides at 418 7th Street, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. The Appellant received a Notice dated March 4,2005, that as a result of his failure to attend a departmental hearing, a sanction of 60 days was being imposed as mandated by Section 1538 of the Vehicle Code, effective date of Suspension April 8, 2005, at 12:01 a.m. A true and correct copy of the Notice is attached as Exhibit "A". 3. The Appellant submits that he did not receive notification to attend a departmental hearing. 4. The Appellant further submits that he did not refuse to submit to a departmental hearing. 5. The Appellant submits his actions do not constitute a refusal or failure to attend a departmental hearing. Wherefore, your Appellant respectfully requests your Honorable Court to schedule an evidentiary hearing on the matter. Respectfully submitted, It)~ r;;L /;,J Michael C. Schubert] 418 7th Street New Cumberland, P A 17070 Date: \. MICHAEL C. SCHUBERT Appellant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. COMMONWEALTH OF PENNSYLVANIA : PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, LICENSE SUSPENSION APPEAL BUREAU OF DRIVER LICENSING, Appellee CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Appeal upon the person and in the manner indicated below, which service satisfies the requirements ofthe Pennsylvania Rules of Civil Procedure, by depositing a copy of the same in the United States Post Office, New Cumberland, Pennsylvania, through first class certified mail, prepaid and addressed as follows: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center, Harrisburg, P A 171 04-2516 Respectfully submitted, /lid (t.l) Michael C. Schubert 418 7th Street New Cumberland, P A 17070 Date: ~ COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Harrisburg, PA 17123 MARCH 04, 2005 MICHAEL C SCHUBERT 418 7TH STREET NEW CUMBERLAND PA 17070 WI>> t 050566543908628 002 PROCESSING DATE 02/25/2005 DRIVER LICENSE t 26205281 DATE OF BIRTH 07/29/1981 Dear Motorist: Due to your failure to attend a departmental hearing, a sanction of 60 DAyeS) is imposed as mandated by Section 1538 of the Vehicle Code. In order to comply with this sanction yoU are required to return any current driver's license, learner's permit and/or 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 sanctlon agalnst your drlvlng privilege. 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 Vehicle Code. Although the law mandates that your driving privilege is under suspension even if you do not surrender your license, Cl'edit 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 ACKNOWLEDGEMENT, 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. The effective date of suspension is 04/08/2005, 12:01 a.m. Please see the enclosed application for restoration fee information. -to. N Vj \l V? III - ~ C> ~ ~ ~ ~ Q \~. ~ c? .:...r' -,'!' ~;, -;;:..1 0-' - ,?-- ..-\ -<. o ~n -:.1,-f' rnp -0 cD. ...r-j.\-/ (')b :_::,~. "-\; (-~~ (~ ~::5r\"\ ":--\ ,-:io1o ~ ...,,'" ..- - -- ,,:;-,' "::J :;:..c.:, (...>'"' U' - I) RECEIVED MAR 31 2005 '(I' v. IN THE COURT OF COM ON PLEAS OF CUMBERLAND COUNT , PENNSYLVANIA NO. OS -no C/' : L Cr~ MICHAEL C. SCHUBERT Appellant COMMONWEALTH OF PENNSYLVANIA : PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee LICENSE SUSPENSION PPEAL ORDER OF COURT de r:^.- [) AND NOW, this 'I day of tAfY1.LX' 2005, upon consider tion of this APPEAL FROM SUSPENSION OF OPERATOR'S PRIVILEGE, it is hereby Order d that a hearing on . ~ the matter shall be held on the t.o (J day of Fn.J 2005, at J' o'clock pm in Courtroom No. J.- of the Cumberland County Courthouse. A supersedeas is granted pursuant to Vehicle Code Section 1550(b) 1) until such time that this honorable court resolves this appeal. BY THEeOURT:~:/ /// / J. Distribution: -Pennsylvania Department of Transportation, Office of Chief Couns Office Center, Harrisburg, PA. 17104-2516 -Michael C. Schubert, 418 7th Street, New Cumberland, PA 17070 Floor, Riverfront .~ It-. 6 r- )Is- co (:;, <"- ,:.:: u!. ~;:: 2 ,-- 1.1";:1 C';") <.:--::> c'-' u_ <:') --'--'-'~'------" v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA No. 05-1712 CIVIL MICHAEL C. SCHUBE!tf PETITIONER COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, RESPONDENT LICENSE SUSPENSION APPEAL ORDER AND NOW, this '.(:) day of )l!v\Y , 2005, the appeal filed in the above referenced matter is REMANDED to the Department to RESCIND the 60 DAY SUSPENSION imposed pursuant to 1538(b)(4) of the Vehicle Code as a result of the petitioner's failure to attend a departmental hearing for his second accumulation of six points, and based upon the parties agreement that the Department will RESCHEDULE the petitioner for a Section 1538 Departmental Hearing. The Department shall send notice of the rescheduled hearing to the petitioner's address of record with the Department. Additionally, the petitioner agrees to waive the six month notification requirement as provided by Section 1551 of the Vehicle Code. DISTRIBUTION: ~eorge H. Kabusk, Esquire, PennDOT, Riverfront Office Center, 1101 South Fron troot, Harrisburg, PA 17104-2516 I )tfichael C. Schubert, Pro Se, 418 7th Street, New Cumberland, P A 17070 ..J (\.~cP 0\90 VNv'^liSNN3d A.1Nnm 0' J\f1:j:J\:W.Jn8 L'1 :8 Hd 9- NOr sooz AWION0H10lXl 3HJ. :10 3Ol:l:\o-<:l31l:1