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HomeMy WebLinkAbout14-6371s E C T I 0 N A S E C T I 0 N Supreme Court of Pennsylvania Court of Common Pleas Civil Cover Sheet C...< 47 e '- 4 County For Prothonotary Use Only: Docket No: /Li - 3 7/ The information collected on this fin -in 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 Plaintiff's Name: LS 4EPPL-T- Lead Defendant's Name: fttiNvT Are money damages requested? Yes Dollar Amount Requested: (check one) within arbitration limits • No • outside arbitration limits Is this an MDJAppeal? Is this a Class Action Suit? • Yes :: No ■ Yes C No Name of Plaintiff/Appellant's Attorney: E - Check here if you 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 O Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/ Defamation ❑ Other: CONTRACT (do not include Judgments) ❑ Buyer Plaintiff ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute: Discrimination O Employment Dispute: Other CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections BP Dept. of Transportation Statutory Appeal: Other ❑ Zoning Board ❑ Other: MASS TORT ❑ Asbestos O Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABLITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: O Other: REAL PROPERTY ❑ Ejectment ❑ Eminent Domain/Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute O Mortgage Foreclosure: Residential ❑ Mortgage Foreclosure: Commercial ❑ Partition ❑ Quiet Title ❑ Other: MISCELLANEOUS ❑ Common Law/Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non -Domestic Relations Restraining Order 0 Quo Warranto ❑ Replevin ❑ Other: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA h 44c 4epLz (Type your name) Vs. Commonwealth of Pennsylvania Department of Transportation Bureau of Drivers Licensing No. N' / 31 ( (,4+(11` L 1-11 Driver's License/Auto Registration Appeatr- -4 APPEAL OF DRIVER'S LICENSE/AUTO REGISTRATION SUSPENSION AND NOW, this (enter today's date) 11/ 0 3 , 20 I { , comes the Appellant, (Type your.name) ISIgt. 'EerC.i , by his/her attorney, and states as follows: 1. Appellant's PA ()orator's number or automobile registration number is: 7._/-t S (C 7'1 2. PennDOT proposes, by Notice dated (insert "mailing" date here) Appellant's driving privileges Arit 0/g=. / =o , 201 , to suspend automobile registration for a period of (Insert length of suspension) pursuant to Section PS Sj 6 (le)') of the Vehicle Code, which suspension is to be effective (Insert suspension effective date) / r7._ 0 , 20 1 I ****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; I I 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). Fl Other (Specify reason:) -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:) 1 NA -0 I Ai S u 2iivCe 5 c6 47TI C1-1 t 0 ft OO /NSca (z 4/vcA5 0 N 8/ ///L( W (T 1+ USAA WHEREFORE, Appellant respectfully requests this Honorable Court to sustain the appeal from the suspension of operating privileges or automobile registration. Respectfully submitted, (Sign name here) 4&Pp LT, (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: IS A 6GP(L' s76,--64&4) to APT -6.1 Coni P 1-1(LL, (J pot( 570 - -/006 escgpe @ c.oAl 2 For Roadside Assistance: 800-531 -8555 Report a claim, get coverage and deductible information, request a tow from the accident scene, schedule an appraisal or reserve a rental car using: • usaa.com, . USAA's Mobile App, or • By calling 210-531-USAA (8722), our mobile phone shortcut number #8722 or 800-531 -USAA. Important Notice This identification card is evidence of liability insurance for your vehicle. The card is valid as long as liability insurance remains in force. You may be required to produce your identification card at vehicle registration or inspection, when applying for-a-Jriver's license, following -an accident; or upon a- law enforcement officer's request. FPA1 Rev. 6-13 r 50812-0513_02 9800 Fredericksburg Road Code N. SanAntonioTexas78288 NAIC 25941 USAA° PENNSYLVANIA FINANCIAL RESPONSIBILITY IDENTIFICATION CARD This Card Must Be Carried For Production Upon Demand. It is Suggested That You Carry This Card In The Insured Vehicle. ISAAC J AEPPLI 20 STEPHEN RD APT 8B CAMP HILL PA 17011-1184 NOT VALID MORE THAN SIX MONTHS FROM EFFECTIVE DATE OFFICE ISSUING THIS CARD - 9800 Fredericksburg Road SAN ANTONIO, TEXAS 78288 Policy Number 01709 92 96U 7102 0 Effective Date 08/01/14 o v�-- AUTHORIZED REPRESENTATIVE Applicable with respect to the following Motor Vehicle 1999 MERCEDES WDBHA29G3XA723517 Year Make Vehicle Identification Number CONTACT US: 210-531-USAA(8722) OR 800-531-USAA UNITED SERVICES AUTOMOBILE ASSN Additional copies available at usaa.com Back WARNING: Any owner or registrant of a motor vehicle who operates or permits a motor vehicle to be driven in this Commonwealth without the required financial responsibility may have his registration suspended or revoked. NOTE: THIS CARD IS REQUIRED WHEN f (a) You are involved in an auto accident. 0 (b) You are convicted of a traffic offense other than a parking offense that requires a court appearance. d (c) Upon request of a police officer when you are stopped for violating any provision of the Vehicle Code (75 PA. C.S. 101-9910). You must provide a copy of this card to the Department of Transportation when you request restoration of your operating privilege or registration privilege which has previously been suspended or revoked. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF MOTOR VEHICLES PO BOX 68674 HARRISBURG, PA 17106-8674 www.dmv.state.pa.us ISAAC JOSEPH AEPPLI 46 GREENMONT DR ENOLA, PA 17025 WIDt 142829999022439 001 TITLE* 66633759 PROCESSING DATE 141009 TRANSACTION CODE 00060 OFFICIAL NOTICE MAIL DATE: 10/16/14 Dear Customer: The Department recently requested that you provide us with proof of financial responsibility (insurance) for the following vehicle: MAKE: MERCEDES BENZ YEAR: 1999 BODY TYPE: SEDAN LICENSE PLATE{#: JLG0659 TITLE#: 66633759 VIN#: WDBHA29G3XA723517 This information was requested because GEICO CASULTY CO notified us that the insurance policy covering the vehicle listed above was terminated on 08/01/14. 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 11/20/14 at 12:01 A.M. as authorized by Section 1786(d) of the Vehicle Code. THIS IS A FINAL ORDER OF SUSPENSION. 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 If you believe your insurance coverage was terminated in error or you did not receive proper notice of your insurance termination, you should file a complaint with the Pennsylvania Insurance Department, Bureau of Consumer Services. Complaints can be filed via the website at www.insurance.pa.gov or mailed to the Pennsylvania Insurance Department, Bureau of Consumer Services 1209 Strawberry Square, Harrisburg, PA 17120. Please include your insurance company name and policy number with your complaint. By Order of Director Bureau of Motor Vehicles Department of Transportation Information (8:00 Pennsylvania Out of State TDD Pennsylvania TDD Out of State AM to 5:00 PM) 800-932-4600 717-412-5300 800-228-0676 717-412-5380 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA lsF (Type your name) Vs. Commonwealth of Pennsylvania Department of Transportation Bureau of Driver Licensing No. �y 6 37 / civ; / Driver's License/Auto Registration Appeal CERTIFICATE OF SERVICE The undersigned hereby certifies that on /C ✓ 3) , 20 /11 , I caused to be mailed by regular mail, postage prepaid, a copy of the Appeal, Order Scheduling Hearing, and all attachments, to: Date: i( � , 20 /6-( Office of Chief Counsel Vehicle and Traffic Law Division Riverfront Office Center, 3rd Floor 1101 South Front Street Harrisburg, PA 17104-2516 Signature: C f Type your Name: JS A} -e iFPLi Address: %O STPHCN (O 41°TE?6 City /State / Zip Code: C MAP N /L /. PA 1700 Telephone: 6.7 v " R4/ —10J6 rL� ** This form must be completely filled out and filed in the Prothonotary's office promptly after mailing the documents to PennDOT ** U.S. Postal Service'° CERTIFIED MAIL° RECEIPT Domestic Mail Only For delivery information, visit our website at www.usps.como. 1820 0001 r O N Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fee Sent To 0106 Postmark Here .,1201.4 P PeoA 0 6 Pr a Street&Apt.No., QVrladr('1{r orPOBoxNo. !l i0) S._F2l?NT.-ST' 1 City, State, ZIP+4 (1- PS Form 3800, July 2014 verse for Instructions IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA )5A4c /4 cPpLi (Print your name) Vs. Commonwealth of Pennsylvania Department of Transportation Bureau of Driver Licensing No. Iy-6,371 0 -,,rn ci Driver's License/Auto Registration2prgeal-A‹ ORDER SCHEDULING HEARING ON APPEAL AND NOW, this LP day of ,14z22T , , 20/4/, a hearing is scheduled on the appeal of Petitioner for the 011 day of��11,ll) , 20/5- at 9 in Courtroom # y 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.