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Home My WebLink About14-6612` Supreme C Cou s E C T I 0 N A � s E C S 0 ennsylvania leas f County For Prothonotary Use Only: /M ST�ti1A Docket No: • /V'— 66/2 62)(/ The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadin. s or other papers as required by law or rules of court. Commencement of Action: Petition Declaration of Taking Complaint • Writ of Summons jEr �j Transfer from Another Jurisdiction !• Lead Plaintiffs Nape: Sea. /141e -40A i �4p4el/ A Lead Defendant's Name: C.p�. e-` P4 ileparitioeqi i ksper71o.6 GI Dollar Amount Requested: • within arbitration limits Are money damages requested? X Yes f No (check one) • outside arbitration limits Is this a Class Action Suit? 11 Yes PI No Is this an MDJAppeal? • Yes a No /� Name of Plaintiff/Appellant's Attorney: ~l �r F /1''t `t /r S jr'- a Self -Represented [Pro Se] Litigant) U Check here if you have no attorney (are Nature of the Case: Place an "X" to the left of the Q 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) Q Intentional Q Malicious Prosecution Q Motor Vehicle Q Nuisance Q Premises Liability Q Product Liability (does not include mass tort) Q Slander/Libel/ Defamation Q Other: CONTRACT (do not include Judgments) ® Buyer Plaintiff Q Debt Collection: Credit Card Q Debt Collection: Other ® Employment Dispute: Discrimination Q Employment Dispute: Other CIVIL APPEALS Administrative Agencies O Board of Assessment Q Board of Elections pn Dept. of Transportation Statutory Appeal: Other b fl Zoning Board Other: MASS TORT ® Asbestos Q Tobacco ® Toxic Tort - DES ▪ Toxic Tort - Implant Q Toxic Waste ® Other: PROFESSIONAL LIABLITY ® Dental Q Legal ® Medical Q Other Professional: O Other: REAL PROPERTY Q Ejectment Q Eminent Domain/Condemnation Q Ground Rent Q Landlord/Tenant Dispute ® Mortgage Foreclosure: Residential O Mortgage Foreclosure: Commercial Q Partition Q Quiet Title ® Other: MISCELLANEOUS Q Common Law/Statutory Arbitration Q Declaratory Judgment O Mandamus Q Non -Domestic Relations Restraining Order 0 Quo Warranto ® Replevin Other: Updated 1/1/2011 SEAN MICHAEL CAMPBELL : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs COMMONWEALTH OF PENNSYLVANIA . DEPARTMENT OF TRANSPORTATION . BUREAU OF DRIVER LICENSING No: /T 6w2. ae APPEAL FROM THE SUSPENSION OF OPERATING PRIVILEGES-<< <ci TO THE HONORABLE JUDGES OF CUMBERLAND COUNTY: AND NOW, comes Petitioner, Sean Michael Campbell, by his counsel, Taylor P. Andrews, Esq. and respectfully avers as follows: 1. Petitioner resides at and has a mailing address of 13 South 19th Street, Apt B, Camp Hill, PA 17011. 2. Petitioner's Pennsylvania Operator's (Driver's License) Number is 28153851. 3. PennDOT proposes by Notice dated October 22, 2014 to suspend Petitioner's driving privileges for a period 3 months, pursuant to Section 1786(d) of the Vehicle Code, effective November 26, 2014. A copy of said Notice is attached hereto as Petitioner's Exhibit A. 4. The suspension of Petitioner's operating privileges is unlawful for the following reason: The suspension was prompted by a guilty plea that was subsequently vacated and changed to a not guilty plea. The guilt of the Petitioner with regard to the underlying charges has not yet been finally determined. WHEREFORE, Petitioner respectfully requests that this Honorable Court allow him to take an appeal from the suspension of his operating privileges. its-. -7 el /1 s- 11716- 313Yo, Respectful) bmitted, Tay, • r P Andrews, Esquire Atts6y for Petitioner 78 West Pomfret Street Carlisle, PA 17013 717-243-0123 Supreme Court ID # 15641 -71 ca n t . -n C c I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A § 4904, relating to unsworn falsification to authorities. 1( /5/14 Date Sean Michael Campbell, Petitioner Address: 13 South 19th Street, Apt B City/State/Zip: Camp Hill, PA 17011 Phone: 717-254-0204 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Harrisburg, PA 17I23 OCTOBER 22, 20I4 SEAN MICHAEL CAMPBELL 13 S 19TH ST APT B CAMP HILL PA 17011 Dear Motorist: NID # 142889283267344 001 PROCESSING DATE 10/15/2014 DRIVER LICENSE # 28153851 DATE OF BIRTH 05/25/1986 Your driving privilege is scheduled to be suspended on 11/26/2014, because you failed to produce proof of financial responsibility on 10/01/2014, the date of your traffic offense. 1. Your driving privilege will be suspended for three months effective 11/28/3014 at 12:01 A.M. as authorized by Section 1786(d) of the Vehicle Code. The Restoration Fee is based on the Consumer Price Index and subject to change. For the current restoration fee amount due, please visit PennDOTvs website at www.dmv.state.pa.us to obtain a copy of your restoration requirements letter. If you do not have internet access, please call PennDOT's Customer Care Center at 1-800-932-4800 to request a COPY of your restoration requirements letter. 2. You will be required to return any current driver's license or learner's permit and/or temporary drivers license (camera card) in your possession. 3. You will be required to provide the Department with proof that all motor vehicles registered in your name are covered by a motor vehicle liability insurance policy or by a program of self-insurance approved by the Department. You will not be permitted to operate a motor vmhicIe until you have been advised in writing by this Bureau that � Your privilege has been reinstated. If you do not comply with this notice, this Bureau will refer this matter to the Pennsylvania State Police for prosecution under Section 1571 (A) of the Vehicle Code. EFFECTIVE DATE OF SUSPENSION: I1/28/2014 12:01 A.M. 142889283267344 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 sanction against your driving 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) ofthe Vehicle Code. Although the law mandates that your driving privilege is under suspension even if you do not surrender your license, Credit 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. APPEAL You have the right to appeal this action to Common Pleas (Civil Division) within 30 days date, OCTOBER 22, 2014, of this letter. If appeal in the County Court, the Court will time -stamped certified copy of the appeal. your appeal to be valid, you must send this certified copy of the appeal by certified mail the Court of of the mail you file an give you a In order for time -stamped to: Pennsylvania Department of Transportation Office of Chief Counsel 1101 South Front Street Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 ° 142889283287344 SENDFEG/LICENSE/0L-l8LC/TO: Department of Transportation Bureau of Driver Licensing P.O. Box 68693 Harrisburg, PA 17106-8893 Sincerely, Kara N. Templeton, Director Bureau of Driver Licensing INFORMATION (8:00 AM TO 5:00 PM) IN STATE 1-800-932-4600 OUT-OF-STATE 717-412-5300 TDD IN STATE 1-800-228-0878 TDD OUT-OF-STATE 7I7-412-5380 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Mag. Dist. No: MDJ-09-2-02 MDJ Name: Honorable Jessica Brewbaker Address: 18 North Hanover Street, Suite 106 Business Central Building Carlisle, PA 17013 Telephone: 717-240-6564 Taylor Putney Andrews, Esq. Andrews & Johnson 78 W Pomfret St Carlisle, PA 17013 Summary Trial Notice Commonwealth of Pennsylvania v. Sean M Campbell Docket No: MJ -09202 -TR -0002450-2014 Case Filed: 10/1/2014 Comp/Cit #: T 2431194-3 Charge(s) 75 § 4703 §§ A (Lead) OPERATION OF VEHICLE WITHOUT OFFICIAL CERTIFICATE OF INSPECTION A Summary Trial has been scheduled for the above captioned case to be held on/at: Date: Thursday, January 8, 2015 Time: 9:00 AM Place: Magisterial District Court 09-2-02, Carlisle 18 North Hanover Street, Suite 106 Business Central Building Carlisle, PA 17013 717-240-6564 This court has received your plea of NOT GUILTY to the above summary violation(s). The sum of $102.50 has been accepted as collateral for your appearance at trial. You have the right to be represented by an attorney. You have the right to have any witnesses present. It is your responsibility to notify your attorney and/or witnesses of this trial date/time. Failure to appear for your trial shall constitute consent to trial in your absence and if you are found guilty, the collateral deposited shall be forfeited and applied toward the fines and costs. You shall have the right to appeal within 30 days for a trial de novo. If you have any questions, please call the above office immediately. Should you fail to appear for your summary trial, a warrant may be issued for your arrest. ' November 07, 2014 Date Magisterial District Judge Jessica Brewbaker If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. You can make case payments online through Pennsylvania's Unified Judicial System web portal. Visit the portal at http://ujsportal.pacourts.us to make a payment. MDJS 308 1 Printed: 11/07/2014 3:04:16PM COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Mag. Dist. No: MDJ-09-2-02 MDJ Name: Honorable Jessica Brewbaker Address: 18 North Har,over Street, Sulte 106 Business CentraBuilding Carlisle, PA 17013 Telephone: 717-240-6584 Taylor Putney Andrews, Esq. Andrews & Johnson 78 W Pomfret St Cod/a|e, PA 17013 Summary Trial Notice Commonwealth of Pennsylvania V. Sean M Campbell Docket No1-2014 Case Filed: 10/1/2014 Comp/Cit #: T 2431195-4 Charge(s) 75 § 4706 §§ C5 (Lead) PROHIBITION ON EXPENDITURES FOR EMISSION INSPECTION PROGRAM A Summary Trial has been scheduled for the above captioned case to be held on/at: Date: Thursday, January 8, 2015 Time: 9:00 AM Place: 09-2-02, Carlisle 18 North Hanover Street, Suite 106 Business Central BuUding Carlisle, PA 17013 717-240-6584 This court has received your plea of NOT GUILTY to the above summary violation(s). The sum of $90.00 has been accepted as collateral for your appearance at trial. You have the right to be represented by an attorney. You have the right to have any witnesses preuenL It is your responsibility to notify your attorney and/or witnesses of this trial date/time. Failure to appear for your trial shall constitute consent to trial in your absence and if you are found gulity, the collateral deposited shall be forfeited and applied toward the fines and costs. You shall have the right to appeal within 30 days for a trial de novo. If you have ariy questions, please calI the above office immediately. Should you fail to appear for your summary trial, a warrant may be issued for your arrest. November 07, 2014 Date Magisterial District Judge Jessica Brewbake If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contac the MagsteriaI District Court at the above address or telephone number. We are unable to provkle transportation. You can make case payments online through Pennsylvania's Unified Judicial System web portal. Visit the portal at http:llujsportaipacourts.us to make a payment. MoJS3Vu 1 Printed: 1107/20143:0418PM COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Mag. Dist. No: .MDJ-09-2-02 MDJ Name: Honorable Jessica Brewbaker Address: 18 North Hanover Street, Sulte 106 Business Central Building Carlisle, PA 17013 Telephone: 717-240-6564 Taylor Putney Andrews, Esq. Andrews & Johnson 78 W Pomfret St Codio{a, PA 17013 Summary Trial Notice Commonwealth of Pennsylvania v. Sean K8Campbell Docket No4 Case Filed: 10h/2014 Comp/Cit #: T 2431196-5 Change(s) 75 g 1786 §§ F (Lead) REQUIRED FINANCIAL RESPONSIBILITY A Summary Trial has been scheduled for the above captioned case to be held on/at: Date: ThursdayJanuary 8, 2015 Time: 9:00 AM Place: Magisterial District Court 09-2-02Carlisle 18 North Hanover Street, Suite 106 Business Central Building Cadix\o, PA 17013 717-240-6564 This court has received your plea of NOT GUILTY to the above summary violation(s). The sum of $365.00 has been accepted as collateral for your appearance at trial. You have the right to be represented by an attorney. You have the right to have any witnesses present. It is your responsibility to notify your attorney and/or witnesses of this trial date/time. Failure to appear for your trial shafl constitute consent to trial in your absence and if you are found guilty, the collateral found guHty, the coIIatera deposited shall be/nrfeitedondoppliedtowo,dthefin000ndnosts. You shall have the right to appeal within 30 days for a trial de novo If you have any questions, please cafl the above office immediately. Should you fail to appear for your summary trial, a warrant may be issued for your arrest. November 07, 2014 Date Magisterial District Judge Jessica Brewbaker If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its servicesplease contac the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. You can make case payments online through Pennsylvania's Unified Judicial System web portal. Visit the portal at http://ujsportai pacourts.US to make a payment. SEAN MICHAEL CAMPBELL : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs COMMONWEALTH OF PENNSYLVANIA . DEPARTMENT OF TRANSPORTATION . BUREAU OF DRIVER LICENSING No: /q/- 66/z O4 -)z--/-,;;;;; ORDER FOR HEARING 'L AND NOW, this /94 day of ' j j{/ y P/ll, 20 / , upon consideration of the petition of Sean Michael Campbell for review of an order of the Department of Transportation suspending petitioner's operating privilege, a hearing is granted to determine whether the action of the Department of Transportation in suspending petitioner's operating privilege should be set aside. A hearing is scheduled for %. 0?0 2014 at q' 3C'clock in Courtroom No: It of the Cumberland County Courthouse, Carlisle, Pennsylvania. The petitioner is directed forthwith to serve a certified copy of the appeal to, Pennsylvania Department of Transportation, Office of General Counsel, 1101 South Front St., Third Floor, Riverfront Office Center, Harrisburg, PA 17104-2516, by certified mail, return receipt requested. It is further Ordered that this petition for appeal acts as a supersedeas pending this appeal; and that all proceedings are stayed. BY THE COURT: cc: (4'ailor P. Andrews, , Es uireAttorney for efendant q Y ennDOT eo t'eS .t tgirk.J rn w c z CD .tet CD';