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Home My WebLink About06-0671 GOLDBERG KATZMAN, P.C. Royce L. Morris - #64310 320 Market Street Post Office Box 1268 Harrisburg, Pennsylvania 17108-1268 (717) 234-4161 DOUGLAS E. WILLIAMS, JR. vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0 G . (. 7/ &.J .7':...... COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION APPEAL OF MOTOR VEHICLE LICENSE SUSPENSION AND NOW, this 1st day of February, 2006, comes Douglas E. Williams, Jr., by and through his attorney Royce L. Morris and Goldberg Katzman, P.C. and files an appeal to the Commonwealth's Notice of License Suspension and avers as follows: 1. The above-captioned Appellant currently holds a valid Pennsylvania driver's license. The license number of 23330587. 2. On or about January 4, 2006, Mr. Williams received a Notice of a License Suspension to begin and be effective December 19, 2006. See Notice of License Suspension attached hereto, made a part hereof and marked as Exhibit "A". 3. Mr. Williams was notified that the suspension resulted from a conviction which occurred on December 19, 2005, for a violation of Section 3802Al of the Pennsylvania Vehicle Code. 4. It is believed and therefore averred that the suspension is not proper and that the Appellant should maintain a valid license. WHEREFORE, Mr. Williams respectfully requests this Honorable Court order the Commonwealth of Pennsylvania Department of Transportation to restore Mr. Williams' driving privileges and rescind their Notice of Suspension dated January 4, 2006 or, in the alternative, order a hearing in the above-captioned matter. Respectfully submitted, GOLDBERG KATZMAN, P.C. By,! ;1)"0 /01~2~ j Roycl L~rris, Esquire Atfurney J.D. #64310 Date: C2/01 !C{o 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorney for Douglas E. Williams, Jr. i\lU(uO r x" I 0; 1 A COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Mail Date: JANUARY 04. 2006 DOUGLAS E WILLIAMS JR 1911 FRANKLIN AVE WID t 053626122819829 001 PROCESSING DATE 12/28/2005 DRIVER LICENSE t 23330587 DATE OF BIRTH 11/22/1969 HARRISBURG PA 17109 LICENSE IN BUREAU Dear MR. WILLIAMS: This is an Official Notice of the Suspension of your Driving Privilege as authorized by Section 3804E21 of the Pennsylvania Vehicle Code. As a result of your 12/19/2005 conviction of violating Section 3B02A1 of the Vehicle Code DUI GENERAL IMPAIRMENT on 02/20/2005: . Your driving privilege is SUSPENDED fo~ a pe~iod of 1 YEAR(Sl effective 12/19/2006 at 12:01 a.m. This suspension is in addition to any other suspensions al- ready on your record. PROVIDING PROOF OF INSURANCE Within the last 30 days of your suspension/revocation, we will send you a letter asking that you provide proof of in- surance at that time. This letter will list acceptable documents and what will be needed if yoU do not own a vehicle registered in Pennsylvania. IMPORTANT: Please make sure that PennDOT is notified if you move from your current address. You may notify PennDOT of your address change by calling any of the phone numbers listed at the end of this letter. 053626122819829 APPEAL You have the right to appeal this action to the Court of Common Pleas (Civil Division) within 30 days of the mail date, JANUARY 04, 2006, of this letter. If you file an ap- peal 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 certi- fied 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, .bff.~ 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 CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy ofthe foregoing document upon the person(s) and in the manner indicated below. The manner of service satisfies the requirements of the Pa.R.Crim.P. 575: Service by first class mail addressed as follows: George Kabusk, Esquire Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 GOLDBERG KATZMAN, P.C. -, // j'7/7 By: '// '--- .{v r t/_____________ Royce L,ftofris, Esquire 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Date: 02/DI(cf..p 130836.1 ~ I;t '" '"). ~'<) '-l" f--''') ~ '\J: .-.? ,- -.'..) 'l. ";--.' .., \..J' ,j-\ , --c:) ~ "~:, c,~ ......:,> ., ,--,' ..,., f";"\ CJ \ N \.0 ;'.} t"<1 (3 () -..-1. :yl rl1 .:.'7 ,.11 .\ '::>, 'J .< , < rEB 0 8 2005 ^ ~ Ii! \ GOLDBERG KATZMAN, P.C. Royce L. Morris - #64310 Attorneys for Defendant 320 Market Street Post Office Box 1268 Harrisburg, Pennsylvania 17108-1268 (717) 234-4161 DOUGLAS E. WILLIAMS, JR. VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, ~EJ:'lNSYLV ANIA : ;100(" - {,?I ('" I :NO. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION ORDER AND NOW, this latI day of !tJ4/.J/l/l')' , 2006, upon consideration of the within Appeal of Motor Vehicle License Suspension, it is hereby ORDERED AND DECREED that the Commonwealth of Pennsylvania Department of Transportation is ordered to rescind its Notice of License Suspension. In the alternative, it is hereby ORDERED AND DECREED that a hearing on the license suspension is scheduled for the ;({P--t/ day of Ulol.h~-1 > ,2006 at 3 ',{b o'clock f.m. -&1 (!IZ -II '-I. BY THE COURT: Distribution: Royce L. Morris, Esquire George Kabusk, Esquire, A Department of Transportation, Office of Chief Counsel j"lu oCp ('(}---ftv1~k 'M:' j /i J. '() ,~, J_, ',:;'i 01 llJ3 ;3DJl ;jJ GOLDBERG KATZMAN, p.e. Royce L. Morris - #64310 320 Market Street Post Office Box 1268 Harrisburg, Pennsylvania 17108-1268 (717) 234-4161 DOUGLAS E. WILLIAMS, JR. : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PA VB. : NO. 2006-671 Civil COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: AND NOW this 6th day of July, 2006, comes Douglas E. Williams, Jr., by and through his counsel Royce L. Morris, Esquire and Goldberg Katzman, PC, who files the following Praecipe to Withdraw the Appeal of Motor Vehicle License Suspension previously filed in this matter. Respectfully submitted, GOLDBERG KATZMAN, PC i) flA-----:--- orris, Esquire A ey J.D. #64310 320 Market Street P.O. Box 1268 Harrisburg, P A 17108-1268 (717) 234-4161 Attorney for Douglas E. Williams, Jr. By Date: 1{7J. 136274.1 e<p -, CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document upon the person(s) and in the manner indicated below. The manner of service satisfies the requirements of the Pa.R.Crim.P. 575: Service via U.S. regular mail, addressed as follows: George Kabusk, Esquire Pennsylvania Department of Transportation Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104-2516 GOLDBERG KATZMAN, P.C. By ~ Date: 1 NJi" o~ e . orris, Esquire J.D. #64310 32 arket Street P.O. Box 1268 Harrisburg, PAl 71 08-1268 (717) 234-4161 Attorney for Douglas Williams, Jr. ~.~. :::! ;.i""l H-:-1 ,- ~ '\ . ,. (~~J .l'~ c,