HomeMy WebLinkAbout06-4583
ERIC ANDREW JONES,
Appellant
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO.: tJ& -,/5''('3 iNrl jet/A\-
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
v.
: Appeal of Operators License Suspension
APPF.Al. OF OPF.RATOR'S , .TCEN~F. SITSPF.NSTON ANn
t:OMMli',RTCAI. DRTVF.R'S 1.1t:ENSE DTSQ]TAT.nnCATlON
AND NOW, comes the Appellant, Eric Andrew Jones, by and through his attorneys, the
Law Offices of Patrick F. Lauer, Jr., LLC and respectfully avers the following:
1, Appellant resides at 29 Pennway Drive, Carlisle, Cumberland County, Pennsylvania
17013.
2. The underlying violations that are alleged for this suspension and disqualification
occurred in Cumberland County,
3. The Appellant received a notice dated August 6, 2006, that as a result of his July 5,
2006 conviction of violating S 3736 of the Vehicle Code, Reckless Driving on April 6, 2006,
that his driving privilege is suspended for a period of six (6) months, effective September 10,
2006 at 12:01 a.m, A copy of the Notice is attached as Exhibit "A."
4, The Appellant received a notice dated August 7, 2006, that as a result of his July 5,
2006 conviction of violating S 3745 of the Pennsylvania Statutes, Leaving Scene of Accident
on April 6,2006, that his commercial driving privilege is disqualified for a period of one (1)
year, effective September 11, 2006 at 12:01 a.m, A copy of the Notice is attached as Exhibit
liB."
~1
5. The Appellant filed a Summary Criminal Conviction Appeal in Cumberland County
Court on July 21, 2006 regarding his convictions on July 5, 2006.
6. The Appellant submits that there has not been a final disposition of his appeal and that he
would be unduly prejudiced if the suspension and disqualification were to be imposed at this time.
7. There was insufficient evidence to convict the Appellant
8, The Appellantdenies he committed the offenses.
WHEREFORE, your Appellant respectfully requests your Honorable Court to schedule an
evidentiary hearing on the matter and to reverse the Department's Order to suspend and disqualifY
his Pennsylvania operating privileges.
Respectfully submitted,
Patrick F. Lauer, Jr., Esquire
Law Offices of Patrick F, Lauer r" LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 46430 Tel. (717) 763-1800
Date: August 8, 2006
ERIC ANDREW JONES,
Appellant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO.: 0 b - tf5'r3 C),lIt +<<~
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF lRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
v.
~
: 1\.ppeal of Operators License Suspension
A TTORNRV VF.Rn?J(, A TTON
I, Patrick F, Lauer, Jr" Esquire, undersigned counsel for Appellant, Eric Andrew Jones,
hereby verifies and states that:
1. I am the attorney for Appellant; Eric Andrew Jones;
2. I am authorized to make this verification on my client's behalf;
3, The facts set forth in the foregoing Appeal are known to me and not necessarily to my
client;
4. The facts set forth in the foregoing Appeal are true and correct to the best of my
knowledge, information and belief; and
5. I am aware that false statements herein are made subject to the penalties of 18 Pa. C.S,
4904, relating to unsworn falsification to authorities,
Respectfully submitted,
Patrick F, Lauer, Jr" Es . e
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 46430 Tel. (717) 763-1800
Date: August 8, 2006
ERIC ANDREW JONES,
AppeJlant
v,
: IN TIIE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
(j ~ - L.j~'?3 ('.lIt fu....
: NO,:
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
: Appeal of Operators License Suspension
CF.RTTI?lCATF. OF SF.RVICE
I hereby certify that I served a copy of the foregoing Appeal upon opposing counsel by
depositing a copy of the same in the United States Mail, Camp Hill, Pennsylvania, through first
class mail, certified, return receipt requested, postage paid and addressed as follows: .
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg, PA 17104
Date: August 8, 2006
Respectfully submitted, .
Patrick F, Lauer, J ., Esq . e
Law Offices of Patrick F. Lauer, Ir" LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 46430 Tel. (717) 763-1800
, .
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Mail Date: AUGUST 06, 2006
ERIC ANDREW JONES
2'1 PENNWAV DR
CARLISLE PA 17013
WID t 062116105675853 002
PROCESSING DATE 07/30/2006
DRIVER LICENSE t 27757311
DATE OF BIRTH 07/26/1'178
Dear MR. JONES:
This\is an O~~icia1 Notice of the Suspension of your Driving
Privilege as authorized by Section 1532B of the PennsYlvania
Vehicle Code. As a result of your 07/05/2006 conviction of
violating Section 3736 of the Vehicle Code RECKLESS DRIVING
on 04/06/2006:
. Your driving privilege is SUSPENDED ~or a period of 6
MONTH(S) ef~ective 09/10/2006 at 12:01 a.m.
Before PennDOT can restore your driving privilege, YOU must
follow the instructions in this letter for COMPLYING WITH
THIS SUSPENSION, PAYING THE RESTORATION FEE and PROVIDING
PROOF OF INSURANCE. You should ~ollow ALL instructions very
care~ully. Even i~ you have served all the time on the
suspension/revocation, we cannot restore your driving
privilege until all the requirements are satis~ied.
COMPLYING WITH THIS SUSPENSION
You must return all current Pennsylvania driver's licenses.
learner's permits, temporary driver's licenses (camera
cards> in your possession on or before 09/10/2006. You may
surrender these items before. 09/10/2006. for earlier
credit; however. YOU may not drive after these items are
surrendered.
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 for a cost
of $10.00. You must present two (2) forms of proper
identification (e.g., birth certificate, valid U.S.
passport, marri,ge certificate, etc.> in order to obtain
your photo identification card.
You will not receive credit toward serving any suspension
until we receive your 1icense(s). Complete the following
steps to acknowledge this suspension.
> '
062116105675853
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
insurance 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.
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 06, 2006, 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 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. You
must return all current Pennsylvania driver license products
to PennDOT by 09/10/2006.
Sincerely,
tJ,.e~
Janet L. Dolan, 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 (8:00
IN STATE
OUT-OF-STATE
TDD IN STATE
TDD OUT-OF-STATE
AM TO 6:00 PM)
1-800-932-4600
717-412-5300
1-800-228-0676
717-412-5380
. .
062116105675853
1. Return all current PennsYlvania driver's licenses,
learner's permits and/or camera cards to, PennDOT. If
YOU do not have any of these items, send a sworn
notarized letter stating YOU are aware of the suspension
of your driving privilege. You must specify in your
letter why YOU are unable to return your driver's
license. Remember: You may not retain your driver's
license for identification purposes. Please send these
items to:
Pennsylvania Department of Transportation
Bureau of Driver Licensing
P.O. Box 68693
Harrisburg, PA 17106-8693
2. Upon receipt, review and acceptance of your Pennsylvania
driver's licensees), learner's permit(s), and/or a sworn
notarized letter, PennDOT will send YOU a receipt
confirming the date that credit began. If YOU do not
receive a receipt from us within 3 weeks, please contact
our office. Otherwise, YOU will not be given credit
toward serving this suspension. PennDOT phone numbers
are listed at the end of this letter.
3. If YOU do not return all current driver license
products, we must refer this matter to the PennsYlvania
State Police for prosecution under SECTION 1571<a) (4)
of the PennsYlvania Vehicle Code.
PAYING THE RESTORATION FEE
You must pay a restoration fee to PennDOT to be restored
from a suspension/revocation of your driving privilege. To
pay your restoration fee, complete the following steps:
1. Return the enclosed Application for Restoration. The
amount due is listed on the application.
2. Write your driver's license number (listed on the first
page) on the check or money order to ensure proper
credit.
3. Follow the payment and mailing instructions on the back
of the application.
,
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Harrisburg. PA 17123
AUGUST 07. 2006
ERIC ANDREW JONES
2'1 PENNWAV DR
CARLISLE PA 17013
WID' Ob212?3&07'12&bb 001
PROCESSING DATE 0?/31/200b
DRIVER LICENSE' 2??57311
DATE OF BIRTH 0?/2b/l'1?&
Dear Motorist:
This is an Official Notice of Disqualification of your com-
mercial driving privilege as authorized by Section 1611A of
the Pennsylvania Vehicle Code as a result of your pre-
adjudication, conviction. administrative adjudication. or
refusal in PennsYlvania.
Your driving record reflects one of the above adjudications
on 07/05/2006 of 3745. of the PennsYlvania Statutes. LEAVING
SCENE OF ACCIDENT on 04/06/2006.
Your commercial driving privilege is disqualified for a pe-
riod of 1 YEARCS) effective 09/11/2006 at 12:01 A.M.
Xn 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 privi-
lege. Failure to comply with this notice shall result in
this Bureau referring this matter to the Pennsylvania State
Police for prosecution under SECTION 1571Ca)(4) of the Ve-
hicle Code.
Although the law mandates that your driving privilege is
under disqualification even if YOU do not surrender your
license. Credit will not begin until all current driver's
license productCs), the DL16LC Form. or a letter acknowl-
edging your sanction is received in this Bureau.
WHEN THE DEPARTMENT RECEIVES YOUR LICENSE OR ACKNOWLEDGE-
MENT. 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
SANCTI ON.
.
,
062127380792866
The above mentioned sanction is in addition to any pre-
viously issued sanction(s).
You have the right to appeal the Department's action to the
Court of Common Pleas (Civil Division) within 30 days of the
mail date (AUGUST 07, 2006) of this notice. You must still
send in your license before the effective date of disquali-
fication unless yOU appear in person before a JUdge and re-
ceive an order permitting you to continue to drive. PLEASE
NOTE that this Civil Appeal is in addition to any appeal yOU
have to file from the criminal conviction.
AFTER THE APPEAL HAS BEEN FILED IN THE COUNTY COURT, A
TIME-STAMPED CERTIFIED COPY OF THE APPEAL MUST BE SENT BY
CERTIFIED MAIL TO:
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
OFFICE OF CHIEF COUNSEL
THIRD FLOOR, RIVERFRONT OFFICE CENTER
HARRISBURG, PA. 17104
Sincerely,
i;),.e~
Janet l. Dolan, 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 (8:00
IN STATE
OUT~OF-STATE
TDD IN STATE
TDD OUT-OF-STATE
AM TO 6:00 PM)
1-800-932-4600
717-412-5300
1-800-228-0676
717-412-5380
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ERIC ANDREW JONES,
Appellant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
/) ,.l/,t3
NO.:
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
: Appeal of Operators License Suspension
EX P A RTF REQJJE~T )fOR ~TTPER~F.n1i'.A~ OF
ONE YEAR COMMF.RTr\I\T. DRIVER'S l,T("'tEN~F.<n"SQITAT.TF'CATTON
AND NOW, comes the Appellant, Eric Andrew Jones, by and through his attorneys, the
Law Offices of Patrick F. Lauer, Jr., LLC and respectfully avers the following:
1. Appellant resides at 29 Pennway Drive, Carlisle, Cumberland County, Pennsylvania
17013.
2, Appellant was convicted of summary offense, 75 S 3745 on July 5, 2006 by Magisterial
District Judge Vivian Cohick.
3, Appellant makes this request pursuant to 75 S 1550(b)(2).
4, Appellant respectfully requests a supersedeas until the conclusion of the hearing
regarding appellants appeal of the suspension and disqualification.
5, Appellant filed his appeal of the suspension and disqualification with the Court of
Common Pleas of Cumberland County on August 9, 2006,
6. A hearing is scheduled on the Appellant's appeal of the conviction on October 24, 2006
at 3:00 p.m. before the Honorable J. Wesley Oler, Jr.
7, Appellant received notice of disqualification from PennDot date August 7, 2006, A
copy of the Notice is attached as Exhibit "A."
~
8, Appellant avers that this disqualification is based solely upon his summary conviction.
9. Appellant avers that his summary conviction will be overturned upon appeal at the
October 24, 2006 appeal hearing.
10. If the conviction is upheld the Commonwealth will not be prejudiced by the supersedeas
being granted.
WHEREFORE, your Appellant respectfully requests your Honorable Court to grant the
request for supersedeas of his commercial driver's license disqualification.
Date: August 8, 2006
Patrick F. Lauer, If" Esquire
Law Offices of Patrick F, Lauer, Ir" LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 46430 Tel. (717) 763-1800
ERIC ANDREW JONES,
Appellant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO,:
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING, : Appeal of Operators License Suspension
Appellee
A TTORNF.V VF.RWlC' A TTON
I, Patrick F. Lauer, Jr., Esquire, undersigned counsel for Appellant, Eric Andrew Jones,
hereby verifies and states that:
1. I am the attorney for Appellant, Eric Andrew Jones;
2. I am authorized to make this verification on my client's behalf;
3. The facts set forth in the foregoing Appeal are known to me and not necessarily to my
client;
4. The facts set forth in the foregoing Appeal are true and correct to the best of my knowledge,
information and belief; and
5. I am aware that false statements herein are made subject to the penalties of IS Pa. C.S.
4904, relating to unsworn falsification to authorities.
Date: August S, 2006
Patrick F. Lauer, Jr" Esquire
Law Offices of Patrick F. Lauer, Jr., LLC
210S Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID#46430 Tel.(717)763-1S00
ERIC ANDREW JONES,
Appellant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO,;
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING, : Appeal of Operators License Suspension
Appellee
CF,RTTFlCATF, OF SF,RVlCF.
I hereby certifY that I served a copy of the Ex parte Request for Supersedeas of One Year
Commercial Driver's License Disqualification upon opposing .counsel by depositing a copy of the
same in the United States Mail, Camp Hill, Pennsylvania, through first class mail, certified, return
receipt requested, postage paid and addressed as follows:
Pennsylvania Department of Transportation
Office of Chief Counsel
Third Floor, Riverfront Office Center
Harrisburg,PA 17104
Respectful1y submitted,
~ JiL-
Patnck F, Lauer, Jr., Esquire
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID#46430 Tel.(717)763-1800
Date: August 8, 2006
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF TRANSPORTATION
Bureau of Driver Licensing
Harrisburg, PA 17123
AUGUST 07, 2006
ERIC ANDREW JONES
29 PENNWAY DR
CARLISLE PA17013
WID' 062127380792866 001
PROCESSING DATE 07/31/2006
DRIVER LICENSE' 27757311
DATE OF BIRTH 07/26/1978
Dear Motorist:
This is an Official Notice of Disqualification of your com-
mercial driving privilege as authorized by Section 1611A of
the Pennsylvania Vehicle Code as a result of your pre-
adjudication, conviction, adl1linistrative adjudication, or
refusal in PennsYlvania.
Yqur driving record reflects one of the above adjudications
on 07/05/2006 of 3745, of the Pennsylvania Statutes, LEAVING
SCENE OF ACCtDENT on 04/06/2006.
Your commercial driving privilege is disqualified for a Pe-
riod of 1 YEAR(S) effective 09/11/2006 at 12:01 A.M.
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 e1'1'ective 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 privi-
lege. 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) of the Ve-
hicle Code.
Although the law mandates that your driving privilege is
under disqualification 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 acknowl-
edging your sanction is received in this Bureau.
WHEN THE DEPARTMENT RECEIVES YOUR LICENSE OR ACKNOWLEDGE-
MENT, WE WILL SEND YOU A RECEIPT. IF YOU DO NOT RECEIVE THIS
RECEIPT WITHIN 15 DAYS CONTACT THE DEPARTMENT IMMEDIATELY.
OJHERWISE, YOU WILL NOT BE GIVEN CREDIT TOWARD SERVING THIS
SANCTI ON.
~. . It '
062127380792866
The above mentioned sanction is in addition to any pre-
viously issued sanction(s).
You have the right to appeal the Department's action to the
Court of Common Pleas (Civil Division) within 30 days of the
mail date (AUGUST 07, 2006) of this notice. You must still
send in your license before the effective date of disquali-
fication unless you appear in person before a JUdge and re-
ceive an order permitting yoU to continue to drive. PLEASE
NOTE that this Civil Appeal is in addition to anY appeal YOU
have to file from the criminal conviction.
AFTER THE APPEAL HAS BEEN FILED IN THE COUNTY COURT, A
TIME-STAMPED CERTIFIED COPY OF THE APPEAL MUST BE SENT BY
CERTIFIED MAIL TO:
PENNSYLVANIA DEPARTMENT OF TRANSPORTATION
OFFICE OF CHIEF COUNSEL
THIRD FLOOR, RIVERFRONT OFFICE CENTER
HARRISBURG, PA. 17104
SincerelY,
D,.e~
Janet L. Dolan, Director
Bureau of Driver Licensing
SEND FEE/LICENSE/DL-16LC/To.
Department of Transportation
Bureau of Driver Licensing
P.O. Box 68693
Harrisburg, PA 11106-8693
INFORMATION (8.00
IN STATE
OUT-OF-STATE
TOO IN STATE
TDD OUT-OF-STATE
AH TO 6.00 PH)
1-800-932-4600
117-412-5300
1-800-228-0616
117-412-5380
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4
ERIC ANDREW JONES,
Appellant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
COMMONWEALTH OF
PENNSYLVANIA,
DEPARTMENT OF
lRANSPORTATION,
BUREAU OF DRIVER
LICENSING,
Appellee
NO. 06-4583 CIVIL TERM
ORDER OF COURT
AND NOW, this 14th day of August, 2006, upon consideration of Appellant's
Appeal of Operator's License Suspension and Commercial Driver's License
Disqualification, and of Appellant's Ex Parte Request for Supersedeas of One Year
Commercial Driver's License Disqualification, a hearing is scheduled for Wednesday,
November 22,2006, at 1:30 p.m" in Courtroom No, 1, Cumberland County Courthouse,
Carlisle, Pennsylvania.
A SUPERSEDEAS is granted until such time that this Court resolves this appeal.
BY THE COURT,
Patrick F. Lauer, Ir" Esq,
2108 Market Street
Camp Hill, PA 17011
Attorney for Appellant
esley Oler,
g--((P-c>' ~ ~
Jt15^
VINV^1",sNN3d
"Nf'1('(i iT ".r'~ .icIPiJ'n"
1'\..1. 11""., ',),' ,'" ,....,~' V
8 I : II WV 91 50nDOZ
Ai:lV10NOH.LC,"8d 3111 :10
381.::l:IQ-Cl311:1
George Kabusk, Esq.
Office of Chief Counsel
Pennsylvania Department
of Transportation
Third Floor, Riverfront
Office Center
1101 South Front Street
Harrisburg, PA 17104-2516
Attorney for Appellee
:rc
<j-tG,-oCt?
..
ERIC ANDREW JONES,
Appellant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LA W
COMMONWEALTH OF
PENNSYL VANIA,
DEPARTMENT OF
TRANSPORTA TION,
BUREAU OF DRIVER
LICENSING,
Appellee
NO. 06-4583 CIVIL TERM
APPELLANT'S APPEAL OF OPERATOR'S LICENSE SUSPENSION
AND COMMERCIAL DRIVER'S LICENSE DISQUALIFICATION,
AND OF APPELLANT'S EX PARTE REQUEST FOR SUPERSEDEAS
OF ONE YEAR COMMERCIAL DRIVER'S LICENSE DISQUALIFICATION
ORDER OF COURT
AND NOW, this 21st day of November, 2006, upon agreement of counsel, the
hearing previously scheduled in the above matter for November 22, 2006, is rescheduled
to Monday, March 5, 2007, at 11:30 a.m., in Courtroom No.1, Cumberland County
Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
Patrick F. Lauer, Jr., Esq.
2108 Market Street
Camp Hill, PA 17011
Attorney for Appellant
l. II : II
ZZ i.ON 9002
I 'b"'d)";\ ,. ';i :'!I1' .Jf~)
^ v.....\,-'J.,.....Jll .....HJ .J\,
:j~}:! ,!c: '{FJlJ.:J
"
George Kabusk, Esq.
Office of Chief Counsel
Pennsylvania Department
of Transportation
Third Floor, Riverfront
Office Center
1101 South Front Street
Harrisburg, PA 17104-2516
Attorney for Appellee
:rc
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--T--
ERIC ANDREW JONES,
Appellant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.: 06 - 4583
COMMONWEALTH OF PENNSYLVANIA,:
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING, : Appeal of Operators License Suspension
Appellee
PRAECIPE TO WITHDRAW
APPELLANT'S APPEAL OF OPERATOR'S LICENSE SUSPENSION
TO THE PROTHONOTARY:
Kindly withdraw the Appellant's Appeal of Operator's License Suspension filed on August
9, 2006.
The License Suspension Appeal hearing scheduled for Monday, March 5, 2007 at 11:30
a.m. in the Cumberland County Courthouse before the Honorable J. Wesley Oler, Jr. is no longer
necessary.
Respectfully submitted,
Date:
~J ~z,IQ
\
Pa . L uer, Jr., Esquire
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 46430 Tel. (717) 763-1800
Distribution:
-PA Department of Transportation, Office of Chief Counsel, George Kabusk, Esq.,
Third Floor, Riverfront Office Center, Harrisburg, P A 17104
-Patrick F. Lauer, Jr., Esq., 2108 Market St., Camp Hill, PA 17011
-Eric Jones, c/o Cumberland County Prison
-Honorable J. Wesley Oler, Jr., Cumberland County Courthouse
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