HomeMy WebLinkAbout14-5567S
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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
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