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HomeMy WebLinkAbout05-2772 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORT A nON, Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL DIVISION ROSEMARY SCHALL, Petitioner -~tJ~ No.: (/.j--,;( n .z... &.....-. STATUTORY APPEAL PETITION FOR APPEAL FROM ORDER OF DEPARTMENT OF TRANSPORTATION SUSPENDING OPERATOR'S LICENSE TO THE HONORABLE JUDGES OF THE CUMBERLAND COUNTY COURT OF COMMON PLEAS: I. Your Petitioner, Rosemary Schall, is an individual residing at 10 Heather Drive, Carlisle Pa 17013. 2. On or about April 30, 2005, Petitioner received a Notice from the Pennsylvania Department of Transportation notifYing her that her present operator's license, bearing number 14944145, was being suspended effective 6/30/2005. A true and correct copy of this notice is attached hereto and marked as Exhibit "A." 3. This suspension arises out of the Petitioner's alleged medical condition which may be identified as Cerebral Vascular and diabetic conditions. 4. That Petitioner asserts that she is not disabled medically and should still be permitted to drive. 5, That if her license is suspended, she will be unable secure groceries, attend doctors appointments and acquire other necessities oflife. 6. That this is not the intent of section 1519 (c) of the vehicle code. 7. Petitioner's suspension should automatically be stayed upon filing of this petition and upon timely notice to the Department of Transportation. WHEREFORE, your Petitioner respectfully requests that this appeal be granted and, in the interim, this Honorable Court enter a stay of Petitioner's operating privileges pending this appeal. Respectfully Submitted, THE LAW OFFICES OF RICHARD R. GAN Date:sJ~r :--~ ~_J~ ~~ ~ Ri"~lard . an, Esquire Attorney for Petitioner 17 West South Street Carlisle, P A 17013 (717) 241-4300 Supreme Court ID # 68721 ~ . . COMMONWEALTH OF PENNSYL VANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: April 29, 2005 recallns ROSEMARY SCHALL 10 HEATHER DR 8 CARLISLE PA 17013 Dear Ms. ROSEMARY SCHALL: We have received medical information indicating that you have Cerebral Vascular and Diabetic conditions which prevents you from safely operating a motor vehicle. As of 06/03/2005, you may no longer drive. Your driving privilege is hereby recalled indefinitely as mandated by Section l519(c) of the Vehicle Code. This decision has been made by comparing your medical condition with the standards recommended by our Medical Advisory Board and adopted by this Department. This action will remain in effect until we receive medical information that your condition has improved and you are able to safely operate a motor vehicle. In order to comply with this action, you must return all current Pennsylvania driver's licenses, leamer's permits, temporary driver's licenses (camera cards) in your possession on or before the effective date listed above. If you cannot comply with the requirements stated above, a sworn affidavit stating that you are aware of the sanction against your driving privilege must be submitted. When the Department receives your license or affidavit, we will send you a receipt. YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR IDENTIFICATION PURPOSES. However, you may apply for and obtain a photo identification card at any Driver License Center. You have the right to appeal to the Court of Common Pleas (Civil Division) within thirty (30) days of the mail date of this notice. Jfyou file an appeal in the County Court, the Court will give you a time-stamped certified copy of the appeal. In order for your appeal to be valid, you must send this time-stamped copy of the appeal by certified mail to: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104 -- - '., - You stilI must send in your license before the effective date of recall unless you appear in person before a judge and receive an order permitting you to continue driving. If you have any questions or need further information, please contact the Medical Unit, P.O. Box 68682, Harrisburg, P A 17106-8682 or call (717) 787-9662 between the hours of 8:00 a.m. and 4:30 p.m. Sincerely, ~~\~ Rebecca L. Bickley, Director Bureau of Driver Licensing Driver License #: 14944145 , --- ~c ~ 1 & 5' tf:cf/~ - ~ ~Jf (\ ~ v.. " ..... G\ 6'. ". 1 't- ~ v, \ & P ('l r--~) ;~:' (""; (J'; -n ,. ~? " :',i ;',) - C-1 , ~ c..:: C) ..t;- COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION, Respondent RECEIVED MAY 272005 yp. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION v. ROSEMARY SCHALL, Petitioner No.: 2005- :<.:77 ~ STATUTORY APPEAL ORDER After reading the attached petition and the court being otherwise fully advised in the premises IT IS ORDERED THAT hearing in this matter shall occur on the /11 day Of~ in ccb \I: 00 t>..tA. courtroom number ~ ,Cumberland county Courthouse. It is "'.~L_ I J.uJ 110M 'b.. Or<ttf'> ,- ,.. .;~/ i.... ~ l1:dhll PIBl_JI._j~ B~pQ.buC,A 6f~eft&tillll. B~p",~aa.e1'S dri"i~~ ... pfivilegl>o "h~l\ be ~ed I^'udh.." Ii,,, uul\..v~;;Fi5fthis 11e8rin!-. ,;/ / ,. " ~ IT IS SO ORDERED. / c7wne d15ated Ir ,l O(J S- . ( ,." ." ~ sr,Q'(:"t. ."v;!: u\OJl Vi -.:1111/1 ro\t L~iP'VO 1\ U " I I.:-J COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ROSEMARY SCHALL 05-2772 CIVIL TERM ORDER OF COURT AND NOW, this 'j)- day of August, 2005, the hearing on the merits of this appeal from an order of the Department of Transportation suspending the operating privilege of Rosemary Schall IS CONTINUED GENERALLY for a period of thirty days. If by thirty days petitioner seeks a hearing such hearing shall be scheduled. If petitioner does not seek a hearing within thirty days the Department shall file a petition to dismiss the appeal based on petitioner failing to proceed to meet h,erJwrden o~, y By the,..cou rt, /. '// . / / ,/ / ~ Edgar B. Bayley, J. ~rge H. Kabusk, Esquire Office of Chief Counsel Vehicle & Traffic Law Division 1101 S. Front Street Harrisburg, PA 17104-2516 ~hard R. Gan, Esquire 17 W. South Street Carlisle, PA 17013 :sal !"(' t. \J .f' ,(, li.J "0'-' \ """j ""'''7 - ;,it, )U1,j\"o , ROSEMARY SCHALL, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2005-2772 COMMONWEALTH OF PENNSYLVANIA, : DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, RESPONDENT LICENSE RECALL APPEAL MOTION TO DISMISS APPEAL FOR FAILING TO PROCEED AND NOW comes the Department ofTransportatioIl (hereinafter referred to as "Department") by and through its attorney, George H. Kabusk, Assistant Counsel, and hereby respectfully represents as follows: 1. The Department of Transportation notified the petitioner by notice dated April 29, 2005, that as a result of the Department receiving medical information indicating that she had a Cerebral Vascular and Diabetic condition which prevents her from safely operating a motor vehicle and pursuant to Section l5l9(c) of the Vehicle Code, relating to Medical Recall, on her driving privilege was being indefinitely recalled effective June 3, 2005. See Department's exhibit 1, sub-exhibit 1. 2. The petitioner filed an appeal on or about May 27, 2005. 3. A hearing was scheduled for August 1,2005, at II :00 a.m. in courtroom 2 in the Cumberland County Courthouse, Carlisle, Pennsylvania. 4. An order was issued dated August I, 2005 which stated: AND NOW, this 1st day of August, 2005, the hearing on the merits of this appeal from an order of the Department of Transportation suspending the operating privilege of Rosemary Schall is CONTINUED GENERALLY for a period of thirty day. Ifby thirty days :petitioner seeks a hearing such hearing shall be scheduled. If petitioner dOles not seek a hearing within thirty days the Department shall file a petition to dismiss the appeal based on petitioner failing to proceed to meet her hurden of proof. 5. The petitioner has not sought a hearing on the merits. WHEREFORE, the Department respectfully requests that the appeal be dismissed on the basis that the petitioner has failed to proceed to meet her burden of proof. Respectfully submitted, ~! ) ~ . W<' George. usk, Esquire Assistant Counsel Office of Chief Counsel Riverfront Offil:e Center-3rd Floor 1101 South Front Street. Harrisburg, PA 17104-2516 (717) 787-2830 Dated: September 23,2005 DL,326 (9/95) CERTIFICATION . DATE July 1, 2005 I hereby certify that Rebecca L. Bickley, Director of the Bureau of Driver Licensing of the Pennsylvania Department of Transportation, is the legal custodian of the Driver License records of the Pennsylvania Department of Transportation. As the Director of the aforesaid Bureau, she has legal custody of the original or microfilm records which are reproduced in the attached certification. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL OF THIS DEPARTMENT THE DAY AND YEAR AFORESAID. ~,- ~) . ~~ d et-_ ALLEN D. BIEHLER, SECRETARY OF TRANSPORTATION I HEREBY CERTIFY THAT THE FOREGOING AND ANNEXED IS A FULL, TRUE AND CORRECT CERTIFIED PHOTO STATIC COPY OF: 1) OFFICIAL NOTICE OF SUSPENSION (RECALL) DATED & MAILED 04/29105, EFFECTIVE 06/3105; 2) LETTER DATED 03131105 TO THE DEPARTMENT FROM RICHARD C. REH, M.D. OF DUNHAM U.S. ARMY HEALTH CLINIC REGARDING THE DEFENDANT, AND 3) DRIVING RECORD WHICH APPEARS IN THE FILE OF THE DEFENDANT, ROSEMARY M. SCHALL, OPERATOR'S NO. 14944145, DATE OF BIRTH 07114121, IN THE BUREAU OF DRIVER LICENSING, HARRISBURG, PENNSYLVANIA. CERTIFIED TO as prescribed by Sections 6103 and 6109 of the Judicial Code, Act of July 9, 1976, P .L. 586, as amended, 42 Pa.C.S. 996103 and 6109. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL THE DAY AND YEAR AFORESAJO <&~-g. ~ SEAL REBECCA L. BICKLE, IRECTOR /BUREAU OF DRIVER L1CENSINGI IJeRlMr1\1Wt ['fJ1.t Ilfr :t:Io ( recallns COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: April 29, 2005 ROSEMARY SCHALL 10 HEATHER DR 8 CARLISLE PA 17013 Dear Ms. ROSEMARY SCHALL: We have received medical information indicating that you have Cerebral Vascular and Diabetic conditions which prevents you from safely operating a motor vehicle. As of 06/03/2005, you may no longer drive. Your driving privilege is hereby recalled indefinitely as mandated by Section 1519(c) of the Vehicle Code. This decision has been made by comparing your medical condition with the standards recommended by our Medical Advisory Board and adopted by this Department. This action will remain in effect until we receive medical information that your condition has improved and you are able to safely operate a motor vehicle. In order to comply with this action, you must retum all current Pennsylvania driver's licenses, leamer's permits, temporary driver's licenses (camera cards) in your possession on or before the effective date listed above. If you cannot comply with the requirements stated above, a sworn affidavit stating that you are aware of the sanction against your driving privilege musII be submitted. When the Department receives your license or affidavit, we will send you a receipt. YOU MAY NOT RETAIN YOUR DRIVER'S LICENSE FOR IDENTIFICATION PURPOSES. However, you may apply. for and obtain a photo identification card at any Driver License Center. You have the right to appeal to the Court of Common Pleas (Civil Division) within thirty (30) days of the mail date of this notice, 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 your appeal to be valid, you must send this tirne- stamped copy of the appeal by certified mail to: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PAl 71 04 .:rf{ You still must send in your license before the effective date of recall unless you appear in person before a judge and receive an order permitting you to continue driving. If you have any questions or need further information, please contact the Medical Unit, P.O. Box 68682, Harrisburg, P A 17106-8682 or call (717) 787-9662 bet1/{een the hours of8:00 a,m. and 4:30 p.m. Sincerely, ~~,~ Rebecca L. Bickley, Director Bureau of Driver Licensing Driver License #: 14944145 ~, DEPARTMENT OF THE: ARMY DUNHAM If.~ARMY HEAL rH CLINIC 450 GIBNi!R ROAD, SUI'TE #1 CARLISLE BARRACKS, PENNSYLW\NIA 17013-5086 fU:PLY ATTENTIOtt OF March 31,2005 Clinical Services SUBJECT: Lieselotte Schall, DOB July 14, 1921 141'44 \ l{ 5 Bureau of Driver Licensing Driver Qualification Section P,Q. Box 68682 Harrisburg, PA 17106-8682 ~ " ~ f Dear Sirs: Mrs. Lieselotte Schall is an 83-year-old lady who receives her medical care at Dunham U.S. Anny Health Clinic. She has been observed driving in our parking lot by staff members and it appears she is having difficulty. In the interest of public safety, I would like you to consider revoking her driving privileges. The patient has obesity, diabetes mellitus, arthritis, and heart disease. These conditions have caused weakness and problems with coordination. I do not belJeve she would pass either the medical or practical portions of a driver's license exam. Respectfully, ~C-l~ '^^'~ Richard C. Reh, MD J1.-- Date: July 1, 2005 COMMQNWEALrH OF PENNSYLVANIA DEPARTMENT OF TRANSPORT ATlON BUREAU OF ORNER LICeNSING HARRISBURG. PENNSYl..VANIA 17123 CERTIFICATION STATEMENT ..:"~ @ In compliance with your request. r hereby certify that r have caused a search to be made of the files of the Department of Transportation, and herewith is a true record in the name of: ROSEMARY M SCHALL, 10 HEATHER DRIVE, 8, CARLISLE, PA 17013 OPERATOR NO: 18713867 DATE OF BIRTH: 01f5/195~1 CLASS OF LICENSE: TITLE NO.: PURPOSE OF REQUEST: Legal (R=INSURANCE. C=CREDIT. E=EMPLOYMENT. L=LEGAL. M=OTHER) DATE SECTION VlOlATlON ACTION TAKEN BY DEPARTMENT! VIOLATION OFFICIAL NOTICE OF SUSPENSION ( RECAll) DATED,~ MAilED 04/29/05 EFFECTIVE 06/3/05 UNTil SATISFACTORY EVIDENCE IS PRESENTED AS TO PROOF OF COMPETENCY DUE TO MEDICAL CONDITION - . APPEAL TAKEN - NOT RESTORED - NO ORDER OF SUPERSEDEAS SIGNED BY THE JUDGE In com Iiance with your request, I hereby certify that I have caused a search to be made of the files of the D rtmentofTransportation, and herewtth is a true record in the name of p the subject listed above. <E.J:c.a ~. DRIVER LICENSING DATE: July 1, 2005 Infcrmation requested by: ADC COMMONWEALTH OF PENNSYLVANIA ss: I hereby certify that Rebecca L. Bickley, DIrector of the Bureau of Driver licensing of the Pennsylvania DI~partment of Transportation, is the legal custodian of the Driver License records of the Pennsylvania Department of Transportation. As the Director of the aforesaid Bureau, she has legal custody of the original or microfilm records which are reproduced in the attached certification. IN TESTIMONY WHEREOF, J HAVE HEREUNTO SET MY HAND AND SEAL OF THIS DEPARTMENT THE DAY AND YEAR AFORESAID SEAL ~1J.~;t~~ SECRETARY OF TRANSPORTATION Jt) P1WE 1 PENNSYLVANIA DEPARTMENT OF T~~SPORTATION BUREAU OF DRIVER LICENI~ING CERTIFIED DRIVING HISTORY JON 28 2005 DRIVER: ROSEMARY M SCHALL 10 HEATHER DR CARLISLE, PA 17013 DRIVllR LICENSE NO DATE OF BIRTH SEX RECORD TYPE 14944145 JUL 14 1921 FEMALE REG LICENSE DRIVER LICENSE (DL) COWilERCIAL DRIVER LICENSE (CDL) - - ~ - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - LICENSE CLASS : LICENSE ISSUE DATE: LICENSE EXPIRES MED RESTRICTIONS LEARNER PERMITS : LICENSE STATUS C MAY OB 2002 JUL 15 2006 1 CDL LICENSE CLASS CDL L,ICENSE ISSUED : CDL LICENSE EXPIRES: CDL ENDORSEMENTS NONE CDL RESTRICTIONS NONE CDL LEARNER PERMITS: CDL LICENSE STATUS : RECALLED SB ENDORSEMENT PRO:BATIONARY LICENSE (PL) RECALLED - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - PL LICENSE CLASS PL LICENSE ORIG ISS: PL LICENSE ISSUED PL LICENSE EXPIRES : PL LICENSE STATUS OCCUP1~TIONAL LIMITED LICENSE (OLL) - - - - - - - - - - - - - - - - - - - - - - - - - - - . - - - - - OLL LICENSE CLASS OLL LICENSE ISSUED : OLL LICENSE EXPIRES: OLL LICENSE STATUS : *** CONTINUED *** PAGE 2 . CERTIFIED DRIVING HISTORY - JON 28 2005 - LICENSE NUMBER 14944145 CONTINUED ~ - ~ - - ~ - _ - ~ _ _ _ _ M _ M _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ REPORT OF VIOLATIONS AND DEPARTMENTAL ACTIONS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NO VIOLATIONS OR DEPARTMENTAL ACTIONS DURING THIS REPORTING PERIOD - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - REPORT OF MEDICALS AND DEPARTMEN'I'AL ACTIONS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ACTION: ACTION: MEDICAL EXAM ORDERED RECALL-GENL MEDICAL EFFECTIVE JON 03 2005 GEN MED RECALL OFFICIAL NOTICE MAILED APR 29 2005 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - REPORT OF ACCIDENTS AND DEPARTMENT1!.!. ACTIONS - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - NO ACCIDENTS DURING THIS REPORTING PERIOD *** END OF RECORD *** PAGE 3 CERTIFIED DRIVING HISTORY - JON 28 2005 - LICENSE NUMBER 14944145 CONTINUED IN COMPLIANCE WITH YOUR REQUEST, I HEREBY CERTIFY THAT I HAVE CAUSED A SEARCH TO BE MADE OF THE E'ILES OF THE DEPART- MENT OF TRANSPORTATION, AND HAVE SET FORTH ABOVE AN ACCURATE SUMMARY OF ALL RECORDS IN THE NAME OF THE PERSON INDICATED. SINCERELY, ~~,~ SEAL DIRECTOR, BUREAU OF DRIVER LICENSING FOR SECRETARY OF TRANSPORTATION COMMONWEALTH OF PENNSYLVANIA SS: DATE:JON 28 2005 I HEREBY CERTIFY THAT REBECCA L. BICKLEY, DIRECTOR OF THE BUREAU OF DRIVER LICENSING, OF THE PENNSYLVANIA DEPARTMENT OF TRANSPORTATION IS THE LEGAL CUSTODIAN OF THE DRIVER LICENSING RECORDS OF THE DEPARTMENT OF TRANSPORTATION. AS THE DIRECTOR OF THE AFORESAID BUREAU, SHE: HAS LEGAL CUSTODY OF THE ORIGINAL OR MICROFILM RECORDS WHICH ARE THE SUBJECT OF THE ABOVE CERTIFICATION. IN TESTIMONY WHEREOF, I HAVE HEREUNTO SET MY HAND AND SEAL OF THIS DEPARTMENT THE DAY AND YEAR AFORESAID. SINCERELY, @~/J.~ SECRETARY OF TRANSPORTATIO~1 SEAL ROSEMARY SCHALL, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2005.-2772 COMMONWEALTH OF PENNSYLVANIA, : DEPARTMENT OF TRANSPORTATION, BUREAU OF DRNER LICENSING, RESPONDENT LICENSE RECALL APPEAL VERIFICATION I verifY that the statements made in the Motion to Dismiss are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. ~ ,~/" ~~Sk .. Assistant Counsel Department of Transportation Riverfront Office Center 1101 South Front Street Harrisburg, P A 17104- 2S 16 (717) 787-2830 DATE: September 23,2005 ROSEMARY SCHALL, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. No. 2005-2772 COMMONWEALTH OF PENNSYLV ANlA, : DEPARTMENT OF TRANSPORTATION, BUREAU OF DRNER LICENSING, RESPONDENT LICENSE RECALL APPEAL CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the Motion to Dismiss2 upon the person, and in the manner, indicated below, which satisfies the requirements of the Pennsylvania Rules of Civil Procedure: By first class mail, prepaid, addressed to: Richard R. Gan, Esquire 17 W. South Street Carlisle, Pennsylvania 17103 ~!1:t"l~/( Assistant Counsel Department of Transportation Riverfront Office Center 1101 South Front Street Harrisburg, P A 17104-2516 (717) 787 -2830 DATE: September 23,2005 o i-; ,..., <'.::::::l ~.::;::" CJ-' o ..,., :r.! P.l~ -nl~i1 -nC: OL ~i~i$ '. ") ::) ~ ..... :::<; U' r-q -c' f'o' <.0> ,,J (."1 (t-) ROSEMARY SCHALL, PETITIONER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA &- " r- r .-, .. . - -, r ~. ,I ~ ".,,,"" 1'\.:.~1-...:....... ,_.......~ ,~V..I ._J:..J v. No. 2005-2772 r COMMONWEALTH OF PENNSYL VANIA, : DEPARTMENT OF TRANSPORTATION, BUREAU OF DRNER LICENSING, RESPONDENT LICENSE RECALL APPEAL ORDER AND NOW, this 1!---1 day of ;~~ , 2005, upon " consideration of the Department's Motion to Dismiss, this Court finds that the petitioner has failed to proceed to meet her burden of proof and accordingly the license suspension appeal is DISMISSED. BYTHECOURT ._ J. ---.- D!S-TRIBUTION: Aeorge H. Kabusk, Esquire, PennDOT, Office of Chief Counsel, Riverfront Office Center-3rd Floor, I lor South Front Street, Harrisburg, PAl 7104-2516 Achard R. Gan, Esquire, 17 W. South Street, Carlisle, Pennsylvania 17013 ~ ~,Q5 O~,?-.'l >- ('Y") ff' ..:r ~1:. r;, ::::~ UJ~ 0"" (lC) "- \i::.\" 'ito r- ,.' oee N wo..., EEUJ (.\~ -r W F= c,/) , u.. u-> ::.:) = 0 = 0 ,..... .1