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Home My WebLink About05-4855 COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING APPELLEE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. p~5 No. DC; .J-lCNIL TERM IGOR JURINOVIC APPELLANT NOTICE OF APPEAL OF LICENSE SUSPENSION L Appellant, Igor Jurinovic, is an adult individual who currently resides at 826 w. North Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Appellee, Commonwealth of Pennsylvania, Department of Transportation, Bureau of Drivers' Licensing, is a Commonwealth agency with offices in Harrisburg, Dauphin County Pennsylvania. 3. The appellant was cited on April 28, 2005, Cumberland County, for allegedly cOmmitting violations of the Vehicle Code. 4. On August 9, 2005, Appellant was convicted of 75 Pa. C.S. ~1543(a) Driving While Operating Privilege Suspended or Revoked. 5. By letter dated August 18, 2005, Appellee notified Appellant that his operating privileges would be suspended for a period of one (1) year effective August 18, 2005. A true and correct copy of said letter is attached as Exhibit A. 6. On August 18, 2005, Appellant rued an Appeal of his conviction of August 9, 2005, to the Court of Common Pleas of Cumberland County. A copy of the Notice of Appeal is attached as Exhibit B. 7. It is believed, and therefore averred, that this Court's decision whether to grant or deny this appeal will be predicated on the result of the Summary Trial yet to be scheduled before a Judge of the Court of Common Pleas of Cumberland County. WHEREFORE, your appellant respectfully requests this Honorable Court to set a hearing and deny the Commonwealth's request that his license be suspended and to reinstate his driving privileges supersedeas while this appeal is pending. Respectfully submitted, Date: ? (' (_ C; 110" ABOM & KUTULAKIS ') \ AZr\ \ ,,\.A Robert]. Daniels, E* Attorney 1.0.# 83376 36 South Hanover St. Carlisle, PA 17013 (717) 249-0900 CERTIFICATE OF SERVICE I, Robert J. Daniels, hereby certify that I served a copy of the within Notice of Appeal upon the Appellee, by mailing a copy of said Notice by hand delivery addressed as follows: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 Dated: "1(",10'1 (-j \~~\\A ~ '* CF-J/-S~-/&I-do~ IN THE COURT OF COMMON PLEAS, COUNTY OF CUMBERLAND O~ Notice of Appeal from Summary Criminal Conviction V Name and Address of Defendant: ~I"lr- J"Y-:'^t!)"~( 1116 G.) . North )'j- {11K"1/,<;lp PA Zip .l71'J/r Name and Address of District Justice: Signature -p~Ullf P. {OAR/'flL I (e>(lvth~",~ SQ C;'vllf"( e r4- Zip Decision of District Justice: 4~'/ 1'1 Date of Decision J::j -0<' Offense(s) Appealed PU r Magisterial District No. 6 J - '2. 0 I Name and mailing address of officer as shown on citation If sentence includes fine and costs, amount of which paid: or complaint (Javd ,.) ;:J{O L"l1./'1!>(11 pA-O"2 t02()O rF;....-~J 1Ao<I_ V'I sO )"1 ra~/'5/~ PA 17Dj~ ?~ Type or amount of bail fumished to District Justice, if any: District Justice Docket No. Name and Address of Attorney: (signature) (print name) Citation No. ML g f 71-S"- t (address) r~ ~~ Zip Atty.r.'&.# .. ." Phone: ',j NOTICE TO DEFENDANT: You will be notified of court hearing date by the District Attorney. \.: -........ .J If your appeal is from a motor vehicle conviction that will result in your driver's license ~ng suspended, you may have the Clerk of Courts certify the Bureau of Driver Licensing copy of the appeal for your use in requesting a delay in that suspension. ,;) "'0,:' f hereby certify that an appeal had been filed in the above captioned matter. A TRUE COpy FROM RECORD in Testimony \\'118reof, I here unto set my hand and t ~f said ' . rt atCarlisle, PA. This day of I. 2~ 1f2-^-- urtsClerk C\S1Ii~.&oUrAlliant's Copy YELLOW - District Justice PINK. DistrictAttorney (;umOerlalidt:DUntv CLERK OF COURT ;!J...?"",j rOd GOLD - Defendant COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bu~eau of D~ive~ Licensing Mail Date: AUGUST 18, 2005 IGOR JURINOVIC 826 W NORTH ST CARLISLE PA 17013 WID. 052239283769322 001 PROCESSING DATE 08/11/2005 DRIVER LICENSE' 26777681 DATE OF BIRTH 03/23/1984 LICENSE IN BUREAU Dea~ MR. JURINOVIC: This is an Official Notice of the Suspension of YOU~ D~iving P~ivilege as autho~ized by Section 1543 of the PennsYlvania Vehicle Code. As a ~esult of YOU~ 08/09/2005 conviction of violating Section 1543A of the Vehicle Code DRIVING WHILE SUSP/REVOKE on 04/28/2005: . You~ d~iving P~ivilege is SUSPENDED fo!" a pe!"iod of 1 YEARCS) effective 08/18/2005 at 12:01 a.m. This suspension is in addition to any othe~ suspensions al- ~eady on YOU~ ~eco~d. PROVIDING PROOF OF INSURANCE Wi thin the last 30 days of YOU~ suspension/~evocation. we will send YOU a lette~ asking that yOU P~ovide P~oof of in- sU~ance at that time. This lette~ will list acceptable documents and what will be needed if YOU do not own a vehicle ~egiste~ed in PennsYlvania. IMPORTANT: Please make sU~e that PennDOT is notified if YOU move f~om YOU~ cU~~ent add~ess. You may notify PennDOT of YOU~ add~ess change by calling any of the phone numbe~s listed at the end of this lette~. ~ Hfi led . . 052239283769322 - APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division> within 30 days of the mail date, AUGUST 18, 2005, of this letter. I~ YOU ~ile an appeal in the County Court, the Court will give yOU a time-stamped certi~ied copy o~ the appeal. In order for Your appeal to be valid, You must send this time-stamped certified copy of the apPeal by certified mail to: PennsYlvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 Remember, this is an OFFICIAL NOTICE OF SUSPENSION. Sincerely, j;jre~ Janet L. Dolan, Acting Director Bureau of Driver Licensing SEND FEE/LICENSE/DL-16LC/TO: Department of TransPortation Bureau of Driver Licensing P.O. Box 68693 Harrisburg, PA 17106-8693 INFORMATION (7:00 IN STATE OUT-OF-STATE TDD IN STATE TDD OUT-OF-STATE AM TO 9:00 PM> 1-800-932-4600 717-391-6190 1-800-228-0676 717-391-6191 p ~ y 1 ~ Crt --- ~ () ~ a.v ffJ ""> w & Vi S ;:~ (T"' 7-. "7' t{; C~ ~ "1:;',"-- ~::'.- ~~-~ )>C..:. Z --\ -<. ....> 0 ~ -n ~ ~:n @ r-' r11 Fn -0 t::":j w'J'1 - ;:.) J- --+-. ....0 '::'-4(1. ""-.J -r: ~11 ~ e]B ~ en,. ~'- i" - S - 2J5 :- '-< -l , ! COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING APPELLEE .:)RECEIVEDSfP 2020055 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 4p55 v. No. DS - CIVIL TERM IGOR JURINOVIC APPELLANT ORDER ~ ~ AND NOW, this II. day of , 2005, upon consideration of the Appellant's Notice of Appeal, a hearing is set for the ~/1:"'y of ~1~20or: at I. . to ~ Courtroom # ~umberland County Courthouse. AND NOW, Appellee is hereby ordered to reinstate Ap e ~bertJ. Daniels, Esquire 36 S. Hanover Street Carlisle, P A 17013 ~ennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, P A 17104-2516 J ) , \/tl\ !1i.,\"'! /,~~~ .,j!\~ 3C.1 ,UNnc(, i'-L'(~:\PllflJ 60 :S ~ld LZ d3S SOUl . "I/In'I'-' ,,",' ',1 ::1'Hl. ::10 Aa ....\'VI'J..L\JO'" 001' 38I:HO-a:JlI:l COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA APPELLEE V. No. CIVIL TERM Doc+:..et IJo.: 05 - 4855 IGOR JURINOVIC APPELLANT PRAECIPE TO WITHDRAW Respectfully submitted, TO THE PROTHONOTARY OF SAID COURT: Kindly withdraw the LICENSE SUSPENSION APPEAL in the above- captioned action with prejudice. A License Suspension Appeal Hearing is scheduled to occur on November 21, 2005. ADOM & KUTULAKlS, LLP DATE: NOVEl\ffiER 18, 2005 ~~,~ Robert J. Daniels, Attorney ID# 83376 36 S. Hanover Street Carlisle, P A 17013 (717) 249-0900 CERTIFICATE OF SERVICE I, Robert J. Daniels, Esquire, hereby certify that I served a copy of the within Praecipe to Withdraw upon the Appellee, by mailing a copy of said Notice First Class u.s. Mail at the following: Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 Dated: ~\G Robert J. Daniels, ~ e ~ <' (.- .-> c:~ '.;....-:J c..r1 l~~ ..---' {~ -- 0;; y"\- ::~) (~'? (...../ --- .------