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HomeMy WebLinkAbout14-5567S E C T I 0 N A S E C T I 0 N Supreme CouriOf Pennsylvania Court; of-Commo,i Pleas C�iviICove Sheeet C(i kfq ►'s 4 `,>'Y County For Prothonotary Use Only: 14/4 Sr`l 1 Docket No: /g- _55'67 art, The information collected on this form is used solely for court administration /ruiposes. 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: ' etition Declaration of Taking Complaint ® Writ of Summons 0 Transfer•from Another Jurisdiction : Lead Plaintiff's Name: StC✓u'1 Mar4' M Pa4pl d- t -et. anya.& Lead Defendant's Name:corn,ci U'CO, O f 0C6✓'I4►rn Dollar Amount Requested: 1 within arbitration limits Are money damages requested? 'L Yes IM o (check one) outside arbitration limits Is this a Class Action Suit? Yes it o Is this an MDJAppeal? Yes LTT1'io Name of Plaintiff/Appellant's Attorney: eck here if you have no attorney (are a Self -Represented Pro Se] 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 O Motor Vehicle O Nuisance O Premises Liability O Product Liability (does not include mass tort) 0 Slander/Libel/ Defamation O Other: MASS TORT O Asbestos O Tobacco • Toxic Tort - DES O Toxic Tort - Implant • Toxic Waste ▪ Other: PROFESSIONAL LIABLITY O Dental O Legal O Medical O Other Professional: CONTRACT (do not include Judgments) O Buyer Plaintiff O Debt Collection: Credit Card O Debt Collection: Other O Employment Dispute: Discrimination O Employment Dispute: Other O Other: REAL PROPERTY • Ejectment O Eminent Domain/Condemnation O Ground Rent O Landlord/Tenant Dispute ▪ Mortgage Foreclosure: Residential O Mortgage Foreclosure: Commercial i__ Partition O Quiet Title O Other: CIVIL APPEALS Administrative Agencies O Board of Assessment O Board of Elections ept. of Transportation 0 Statutory Appeal: Other O Zoning Board • Other: MISCELLANEOUS O Common Law/Statutory Arbitration O Declaratory Judgment O Mandamus 0 Non -Domestic Relations Restraining Order 0 Quo Warranto 0 Replevin Other: Updated 1/1/2011 iy-5.67 } N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S - e..v rl10✓'3-� 4 Pct( iv\ p A all 66 5 7 7.i Coes'nc Lee. Karo Vfr No. Ora- 9-L-1 (Type your name) Vs. Driver's License/Auto Registration Appeal ITrn tis APPEAL OF DRIVER'S LICENSE/AUTO REGISTRATION SUSPENSION AND NOW, this (enter today's date) geff ` ft , 20 t' comes the Appellant, (Type your name) Commonwealth of Pennsylvania Department of Transportation Bureau of Drivers Licensing by his/her attorney, 1. Appellant's PA operator's nurnber or automobile registration number is: and states as follows: 2. PennDOT proposes, by Notice dated (insert "mailing" date here) o / / 7/ , 20 / 1 to suspend Appellant's driving privileges • 3 1/110 w4'kS automobile registration for a period of (Insert length of suspension) pursuant to Section ?' Co°196 0of the Vehicle Code, which suspension is to be effective (Insert suspension effective date) 09/a/ ,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) 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:) 1c ipso (C)JIAC -e V&1 e %/.S 2 -5 -fid . 3// 93 1 -OR - 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:) WHEREFORE, Appellant respectfully requests this Honorable Court to sustain the appeal from the suspension of operating privileges or automobile registration. Respectfully submitted, &AAA <ee/34,cuziAr- (Sign name here) s re v e'l 74. Pa im- Cr)6'nGc 1-ee 3vocev' (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: Address: City / State / Zip Code: Telephone Number: Email address: coil it ttek 6 >^Q' +` <earick Ori'v Q tart.--) At ecl4 C24i -e CS b c;:. PA 1 ? O6 717 Goa --)-7 2 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF MOTOR VEHICLES PO BOX 68674 HARRISBURG, PA 17106-8674 www.dmv.state.pa.us STEVEN MARTIN PALM & CORINA LEE BROWN 82 LINDA DR LOT 27 MECHANICSBURG, PA 17050 WID* 142229999017773 001 TITLE* 65086892 PROCESSING DATE 140810 TRANSACTION CODE 00060 OFFICIAL NOTICE MAIL DATE: 08/17/14 Dear Customer: The Department recently requested that you provide us with proof of financial responsibility (insurance) for the following vehicle: MAKE: SATURN YEAR: 2007 BODY TYPE: SEDAN LICENSE PLATE#: HJZ0531 TITLE#: 65086892 VIN#: 1G8AZ58F67Z167026 This information was requested because NATIONWIDE PROP AND CASUAL INS notified us that the insurance policy covering the vehicle listed above was terminated on 06/20/14. Either no response was received or the information you provided was not acceptable. As a result, the registration for the vehicle listed above will be suspended for three months effective 09/21/14 at 12:01 A.M. as authorized by Section 1786(d) of the Vehicle Code. THIS IS A FINAh ORDER OF SUJSPENSION. 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 U'041000UGJU11 Nationwide® On Your Side IMPORTANT NOTICE about your... Financial Responsibility ID Card Financial Responsibility Identification Card Prepared on September 11, 2014 • Detach your identification cards along the perforated lines. • Keep this card in your vehicle. • See section following ID Cards for What's enclosed. Pennsylvania law requires insurance companies to provide each Policyholder with an Identification (ID) Card for each insured vehicle. The card shows that a Liability Insurance Policy has been issued which satisfies the financial responsibility requirements of the law. You are required to maintain financial responsibility on each vehicle. It is against Pennsylvania law to use the ID card fraudulently - for example as proof of financial responsibility after the policy is terminated. Your ID Card may be used for vehicle registration and replacing license plates. it must also be shown to any police officer, judge or hearing officer if requested. In the event of an accident your ID card may be used to exchange information with other drivers. If you lose your ID card or - have any questions about its use - just get in touch with your agent. Things In your life change. Make sure your insurance keeps up. Ask your agent for a free On Your Side Review. Sign up for convenient, automatic bill payment with Nationwide Easy Pay. To learn more, ask your agent or log in to nationwide.com/easypay. Manage your account, make a payment, check the status of a claim and receive your bill by email with online Account Access. Visit nationwide.com/manage - see how easy it can be. ❑Financial Responsibility Identification Card Policy Number Effective Data Expiration Date 5837E 930620 Sep9, 2014 Mar 9, 2015 NOT VAUD MORE THAN 1 YEAR FROM EFFECTIVE DATE Year Make/Modal Vehicle Identifkation Number 2007 Saturnllon 2 1 G8AZ58F671167026 24 Hour Claims 1.800.421.3535 Corina Brown and Steven Palm 82 Linda Or Lot 27 Mechanicsburg, PA 17050-1548 Nationwide Property And Casualty Insurance Company PO Box 30000 Raleigh NC 27612-0000 NAIC # 37877 For Billing Questions: 1.877.262.0247 or your Nationwide Agent, Robert C Grove at 717.763.8514. IN THE COURT OF COMMON t3+e,/e/✓1 fit& r d'r' h eat. Ivo COei'nc Lee e vu)bt (Type your name) Vs. Commonwealth of Pennsylvania Department of Transportation Bureau of Driver Licensing PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 90/14— e76 -3--G7 ) c a Driver's License/Auto Registratid Appeal ma, v) CERTIFICATE OF SERVICE f— The undersigned hereby certifies that on - -9— fr , 20 / /-1, I caused to be 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, 3rd Floor 1101 South Front Street Harrisburg, PA 17104-2516 Date: g eft-, 1 9, 20 , f Signature: Type your Name: Address: City / State / Zip Code: Telephone: CoI% is V( Cc K rG a- » (1A-e_e4ciMtics'%uv 10#l70T0 ** This form must be completely filled out and filed in the Prothonotary's office promptly after mailing the documents to PennDOT ** lq-5-5(0) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA steam outi'31'n ectinA COi1ic. LeC, &Va.)" (Print your name) Vs. Commonwealth of Pennsylvania Department of Transportation Bureau of Driver Licensing • pA &I 665- 7,.c No. PA ou-i S5)-1-1,31 Driver's License/Auto Registratio ORDER SCHEDULING HEARING ON APPEAL c.nr— r- -Cc-) Xc T'• AND NOW, this g3 day of S, , 201, a hearing is scheduled on the appeal of Petitioner for the 1 Vh day of bC.t,Elakosql._ , 20 1 at q M in Courtroom # of the Cumberland County Courthouse, One Courthouse Square, 4th Floor, Carlisle, PA 17013, at which time testimony will be taken and argument heard. 37. CO CD 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. By the Cou Th as A. Placey Judge Common Pleas Judge STEVEN MARTIN Palin Corina Lee Brown vs Commonwealth of Pennsylvania Department of Transportation Bureau of Drivers Licensing In the Court of Common Pleas of Cumberland County, Pennsylvania No 14-5567 Civil Term Driver's License/Auto Registration Appel PRAECIPE I Steven Martin Palm would like to plead guilty of not having insurance on my 2007 Saturn. I would like to stop the case that is on Dec. 18 2014. I will turn in my license plate in to department of transportation. For the three months suspension. David D. Buell, Prothonotary 17eceonbeK 5, 20 l Attorney Info: laintiff STEVEN M. PALM & CORINA L. BROWN, Petitioner v. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF MOTOR VEHICLES, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 14-5567 CIVIL TERM VEHICLE REGISTRATION SUSPENSION APPEAL ORDER AND NOW, this 18th day of December, 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 , 2015, at .m., in Courtroom Room No. of the Cumberland County Courthduse, Carlisle, Pennsylvania. BY THE COURT: /tel Attest:--ntriAh VLACel even Palm & Carina Brown, 82 Linda Drive, Lot 27, Mechanicsburg, PA 17050 ,flip M. Bricknell, Esq., PennDOT, Riverfront Office Center, Office of Chief Counsel, 3rd Floor, 1101 South Front Street, Harrisburg, PA 17104-2516 Cor«S Plat 1.L / eV/ Qfry CD J. C) i C:.