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Home My WebLink About02-2381RICHARD ZEFF 691 St. Johns Road Camp Hill, PA 17011 Driver's License No. 27-037-173 V. ~ COMMONWEALTH OF PENNSYLVANIA: DEPARTMENT OF TRANSPORTATION : 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C1VIL APPEAL - LAW APPEAL FROM LICENSE SUSPENSION PETITION FOR APPEAL FROM SUSPENSION OF DRIVING PRIVILEGES AND NOW comes Richard Zef£, by his attorneys, Caldwell & Kearns, and presents the following Petition for Appeal from Suspension o£ her Driving Privileges. 1. Petitioner is an adult individual residing at 691 St. Johns Drive, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Your Petitioner is licensed as a motor vehicle operator by the Commonwealth of Pennsylvania, Department of Transportation, License No.27-037-173. 3. By official notice, dated April 26, 2002, your Petitioner received notification from the Commonwealth of Pennsylvania, Department of Transportation, that his driving privileges were suspended for sixty (60) days effective May 31, 2002. 4. This suspension arose out of a guilty plea on April 18, 2002 for violating 75 P.S.§3345. 5. The Petitioner has withdrawn his guilty plea and a summary trial is scheduled for June 18, 2002, before Magisterial District No. 09-02-01. 6. The Petitioner requests this Honorable Court to stay the suspension imposed by PennDOT pending disposition of the underlying citation. WHEREFORE, your Petitioner prays this Honorable Court to schedule a hearing on this appeal from the suspension of his driving license privileges and order that the suspension imposed by PennDOT is stayed pending the outcome of underlying case. Respectfully submitted, CALDWELL & KEARNS Dated: 02-307/39558 ~.~~Marsico, Esquire Attott1%y I.D. No. 69804 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Petitioner, Richard Zeff ATTORNEY VERIFICATION I, Douglas K. Marsico, Esquire, on behalf of Richard Zeff, verify that the statements made in the foregoing 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 tmsworu falsification to authorities. ~D. ~_. Marh'~,o, Esquire ~t~y for Petitioner, Richard Zeff CERTIFICATE OF SERVICE AND NOW, this ¢7~ day of May, 2002, I hereby certify that I have served the foregoing Petition for Appeal from Suspension of Driving Privileges on the following by depositing a true and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, certified, return-receipt requested, addressed to: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Office of Chief Counsel Third Floor, Riverfront Office Center Harrisburg, PA 17104 CALDWELL & KEARNS By: I~rn Crider, Paralegal to Douglas K. Marsico, Esquire 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 RICHARD ZEFF 691 St. Johns Road Camp Hill, PA 17011 Driver's License No. 27-037-173 V. COMMONWEALTH OF PENNSYLVANIA: DEPARTMENT OF TRANSPORTATION : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C1VIL APPEAL - LAW APPEAL FROM LICENSE SUSPENSION ORDER AND NOW, this &'~ay of May, 2002, upon presentation of the attached Petition and upon the Motion of Douglas K. Marsico, Esquire, attorney for the Petitioner, a hearing de novo is granted to determine whether the action of the Department of Transportation in suspending the driver's license of Petitioner should be set aside. Moreover, it is hereby ORDERED and DECREED that no suspension shall occur until a heating has been held and this Court makes a final determination of the Petition contained herein. Hearing in the within matter is scheduled for at ~,/~_~ o'clock in Courtroom No. ~ Courthouse Square, Carlisle, Pennsylvania. ~0~, 2002, , Cumberland County Courthouse, One AMY MENGES, Plaintiff, V. JONATHAN C. MENGES, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-3281 CIVIL ACTION - Divorce PROOF OF SERVICE The undersigned makes the following return of service: the Divorce Complaint was served upon Jonathan C. Menges, the Defendant, on July 12, 2002 at 915 Old Mountain Road, Dillsburg, York County, Pennsylvania. The signed acceptance of service is attached hereto as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and remm of service are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsfication to authorities. Respectfully submitted, Dated: ROBINSON & GERALDO By: ~...~ Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front SWeet P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the Pack of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. ~ by (P/eeee Print Cleariy) B. Date of Delivery X [] Add...... D. Isdeliveryaddm",:~sdiffemntfrern~l? []Yes If YES, enter delivery address below: E] No 3. Service Type ~Certified Mail [] Express Mail [] Registered '~ Return Receipt for Merchandlae [] Insured Mail [] C.O.D. 4. Restricted Delivery? irExtra Fee) DYes 7001 1940 0004 1686 7444 PS Form 3811, July 1 999 Dorneatic P~tu~t P~c~ot 102595-99-M-1789 RICHARD ZEFF : 691 St. Johns Road : Camp Hill, PA 17011 : Driver's License No. 27-037-173 : : v. : NO.02-2381 COMMONWEALTH OF PENNSYLVANIA: DEPARTMENT OF TRANSPORTATION : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL APPEAL - LAW APPEAL FROM LICENSE SUSPENSION PRAECIPE TO WITHDRAW APPEAL TO THE PROTHONOTARY: Please withdraw and discontinue the Appeal from License Suspension in the above- captioned matter. Dated: Respectfully submitted, CALDWELL & KEARNS ~-'~/~as K. Marsico, Esquire t~Attomey I.D. No. 69804 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Petitioner, Richard Zeff CERTIFICATE OF SERVICE AND NOW, this ./c~/j~ day of September, 2002, I hereby certify that I have served the foregoing document on the following by depositing a tree and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: George Kabusk, Esquire Office of Chief Counsel COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION 1101 South Front Street Harrisburg, PA 17104 02-307/45752 CALDWELL & KEARNS RICHARD ZEFF, : Appellant : : V. : : COMMONWEALTH OF PENNSYLVANIA : DEPARTMENT OF TRANSPORTATION,: Appellee : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-2381 CIVIL TERM APPEAL FROM LICENSE SUSPENSION IN RE: APPEAL WITHDRAWN ORDER OF COURT AND NOW, this 23rd day of September, 2002, the Department having rescinded its action in suspending the operating privileges of Appellant, Richard Zeff, thereby rendering the appeal moot, it shall be deemed to have been withdrawn. By the Edward E. Guido, J. ,~eorge Kabusk, Esquire Attorney for Appellee -~Douglas K. Marsico, Esquire Attorney for Appellant srs