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Home My WebLink About14-4799S E C T I 0 N A S E C T I 0 N Supreme Cour..tRof Rennsylvania Court of Common'kPleas Civil Cover Sheet l' (9U ✓h 6g ' 'Q n County For Prothonotary Use Only: Docket No: i9- 41799 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 ❑ Lead Plaintiffs Name: k145Sg nl to tiG)2Ct/ Lead Defendant's Name: comfy) nnw.rffr'l411 Are money damages requested? ❑ Yes gi?No Dollar Amount Requested: 1 within arbitration limits (check one) ❑outside arbitration limits Is this a Class Action Suit?. • ❑ Yes R No Is this an MDJAppeal? ❑ Yes 1 No Name of Plaintiff/Appellant's Attorney: 0 A S S $4 n/ (p OFR c iJ ❑ Check here if .von 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) ❑ Intentional O Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability O Product Liability (does not include mass tort) ❑ Slander/LibeU Defamation O Other: MASS TORT O 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 0 Debt Collection: Credit Card ❑ Debt Collection: Other 0 Employment Dispute: Discrimination ❑ Employment Dispute: Other O Other: REAL PROPERTY 0 Ejectment ❑ Eminent Domain/Condemnation O Ground Rent O Landlord/Tenant Dispute ❑ Mortgage Foreclosure: Residential O Mortgage Foreclosure: Commercial ❑ Partition ❑ Quiet Title • Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Statutory Appeal: Other ❑ Zoning Board ® Other: SUg b en 5/rum, PLT cs MISCELLANEOUS • Common Law/Statutory Arbitration Declaratory Judgment Mandamus ❑ Non -Domestic Relations Restraining Order 0 Quo Warranto ❑ Replevin 0 Other: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1A4 Co) E/ cU No. /4.—�� (l4:7 e/M (Type your name) Vs. Driver's License/Auto Registration Appeal Commonwealth of Pennsylvania Department of Transportation Bureau of Drivers Licensing APPEAL OF DRIVER'S LICENSE/AUTO REGISTRATION SUSPENSION AND NOW, this (enter today's date) , 20 , comes the Appellant, (Type your name) , by his/her attorney, and states as follows: 1. Appellant's PA operator's number or automobile registration number is: 2. PennDOT proposes, by Notice dated (insert "mailing" date here) ,20 to suspend Appellant's n driving privileges automobile registration for a period of (Insert length of suspension) pursuant to Section of the Vehicle Code, which suspension is to be effective (Insert suspension effective date) , 20 ****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) riThe 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). C) rn a) =PI Other (Specify reason:) 1 "L7 ry eassil r -Ta CD I —4 c: C) CD 1 -OR - The suspension of Appellant's automobile registration is contrary to law in that: 0R- ThesuspenxionofAppeUant'sautomobi|eregisLmtioniscontraryto|avvinthat: My failure to have insurance was for a period of less than 31 days AND 1 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 reason:) WHEREFORE, Appellant respectfully requests this Honorable Court to sustain the appeal from the suspension of operating privijeges or automobile registration. Respectfully submitted, (Sign name here) 53,49 Ai y- o Loe Cti (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. 49O4relating to unsworn falsification to authorities. Signature: Type Name: ta#5 yki 'k^cr cH Address: 7 7-0 R•I c�� City / State / Zip Code� ��% �u� �`�� 14—A, « L. ^ �-~` ` < �� Telephone Number: .7(7 40,a R< c 0 Email address: 2 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF MOTOR VEHICLES PO BOX 68674 HARRISBURG, PA 17106 www.dmv.state.pa.us INFORMATION (8:00 AM TO 5:00 PM) Pennsylvania. 800-932-4600 Out of State, 717-412-5300 TDD Pennsylv'enia 800-228-0676 TDD Out of Sate 717-412-5380 08/06/14 HASSAN GUERCH 70 TORY CIR ENOLA PA 17025 DEAR MOTORIST: This is a RESTORATION REQUIREMENTS LETTER. Please be aware'that this letter does not authorize you to, operate this vehicle. The purpose of this letter is to provide you with information on what you need to do in order to have the. registration restored on the following vehicle: TITLE NUMBER - 72094365 VIN NO - 19XFB2F50DE233084 MAKE - HONDA EFFECTIVE DATE OF SUSPENSION - 09/01/14 REGISTRATION PLATE RETURN - Credit towards serving your three month term suspension(s) does not begin until you return your registration plate to this Bureau. PROOF OF INSURANCE - In order to have your registration restored you will be required to provide the following within 30 days of your eligibility date. * Current proof of insurance. Submit a copy of either your insurance identification card, the declaration page of your insurance policy, a valid binder of insurance, or an application for insurance to the Pennsylvania Autb Insurance Plan for the described motor vehicle. Please follow the instruction(s) listed above and return thi's document and all other necessary forms in the enclosed self-addressed envelope. Write your title number on all documents and advise the Bureau immediately of any change to your address. Failure to do so may delay the restoration' of your registration privilege. PLEASE NOTE : ORIGINAL DOCUMENTS WILL NOT BE RETURNED. SINCERELY, PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF MOTOR VEHICLES r• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA k-;4$4N6UEee (Print your name) No. /1/-3t-791 `P•7%f 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 ��j day of -1,! , 20 1,/, a hearing is scheduled on the appeal of Petitioner for the /7'4 day of �Ctf �F/l. , 20 gat 9 :3d AM in Courtroom # 6 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`d 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. itiwsmo cop.es $e/iy Thomas A. Placeydge Common Pleas Judge C:) r -1 c r., C) az. CD.__ . HASSAN GUERCH, Petitioner v. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF MOTOR VEHICLES, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 14-4799 CIVIL TERM VEHICLE REGISTRATION SUSPENSION APPEAL ORDER AND NOW, this 18th day of December, 2014, the appeal filed in the above - captioned matter is: Attest: 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 Room No. , 2015, at .m., in Courtrm E:> ...- of the Cumberland County Courtho a,e, r-- •< �' C7 Carlisle, Pennsylvania. J. °MA, (4)AS A. euvikti ✓ Hassan Guerch, 70 Tory Circle, Enola, PA 17025 hilip M. Bricknell, Esq., PennDOT, Riverfront Office Center, Office of Chief Counsel, 3rd Floor, 1101 South Front Street, Harrisburg, PA 17104-2516 Coo J -r APO M (JJ - WOW VAW410C - <Y -.