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Home My WebLink About94-01911 , ~ J -j ~ c ,- (... 8 .'\ , \, \ \ ~I J-=- JI ! i I ~I .",.. CJ") - (":::), V> /"-.j Iv) ~ ~\ ""', lr; >-,.. ,r. ;r ': I~I ~~ - ., u:.i:' .. ~. ('",....: .'~ ....17.;" ::r: <>- en o-i N -:~ . ~ - ~ 1-(\ I'" ~ Co ~ '-- \r, '\ ~ ~ ~ ',) , '-q- c. "'~ \'-0 \ '0 '--..) ~ -~... . ~l .~.. -:r - ..I" ::: , ':11__; t- 2:.... :> 0(.) ct:: ... "= "".' ~< .... UI IS::; o-:l>< lJ"U1 Z~ O~ ~lJ" o . U>< E-< ~Z O::J o E-<U r:<: ::JC OZ U< o-:l ~r:<: :I:~ E-<lJ:l ::t Z::JO ....UZ , ....0 ~~ >< ~ o-:lE-< UI ><r:<: iii~ U10 I-< ffilJ,,+J U~ QJ U1t:: ....lJ" . t:: lJ,,~~ o-:llJ" ~O < ~'... r:<: O+J ~E-<O 0:<' Z.... 0 C. ~O ....+J ~ Ul .... r:<: QJ :I:OQJ ZUI lJ:llJ" E-< r:<: OZ 0 o-:lE-< ....~ C <Z E-<lJ" ~~ ....U1 . E-<::J o-:l > ~U1 Or:<: lJ" ~ ~~ ~ O~ UC a: w Z Cl ~ 0 <{ ~ ~ .. lil ~ I ~ ~ ~ 0 II. S Z ~ .; a; ~ <{ :l III W !II ~ " a; " a; U " ~ Z " X <{ ::i! . . WE DO HEREBV CERTIFY THA' THE WITHIN IS A TRUE AND COR- RECT COPY Of THE ORIQINAl 'lltD IN THIS ACTIo)N Bv ~ .. AnOANEV . 'A_".("j_'I.I<; :g..n'ilT.lMivldtillDlIY;1lit .. wI"nCH AI'~O"'1l '0 '"1 ::~~'IIIIf~'" JIGI DAY' UO" ""'1C.f ....Mt(W \lfII '" .I\JO()"'...., 1014> It "'lIMD.&OAItfST YOU .,. --~-- -iri(jiUit-,,-- MANCKE AND WAGNER ;; , '. ~ GARY L, DOBRINOFF, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No,Q4- /q/I ~(J~ , , : , , V, . , , , COMMONWEALTH OF PENNSYLVANIA, : DEPARTMENT OF TRANSPORTATION, : Respondent , , ORDBR OP COURT 18'0., AND NOW, this day of April, 1994, upon consideration of the within Petition, it is hereby Ordered and Decreed that a hearing be held on the ~ day of \..('nCk.d- ' 1994, at J,.50 p.tn o'clock in courtroom ~ , Cumberland County Courthouse, Carlisle, Pennsylvania. Notice of said hearing shall be given to the Department of the date of said hearing by J, Transportation by petitioner'S counsel at ays prior to / ft. ~.. 18 /I ,. lH '9~ : ,l l i(;"HOt !If nt, ':'..;1I01l0iA~Y CUIHiUL,\//O Cf.'L'Hl'Y r-[~l/l~I,dl/'4 . , GARY L, DOBRINOFF, Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA , , , , , . C i vii T~JtYl V, : NO. q4- /1/1 , , COMMONWEALTH OF PENNSYLVANIA, : DEPARTMENT OF TRANSPORTATION, : Respondent , , PETITION POR LICENSE SUSPENSION APPEAL AND NOW, this li'~ day of April, 1994, comes Petitioner Gary L, Dobrinoff, by and through his attorneys, Mancke, Wagner, Hershey & Tully, who respectfully represent: 1, Gary L. Dobrinoff is an adult individual residing at 3819 Lamp Post Lane, Camp Hill, Cumberland County, Pennsylvania, 2, Petitioner has received a notice of indefinite suspension, a copy of which notice is a~tached hereto and made a part hereof as Exhibit "A". 3, Said indefinite suspension is improper, illegal and unjust and is not in conformity with the Motor Vehicle Code, 4. Your petitioner's record does not reflect six or more points and any request for a special examination was improper, 5, Your petitioner has complied with the requirements of taking the test and, in fact, passed the special examination, even though under the law he was not required to do so, 6, There were periods of time when attempts were made for examinations and the number given on the Department of . . Transportation literature was busy, making it impossible for anyone to schedule appointments, 7, When your petitioner contacted the Department of Transportation, they indicated that there would be no problem with him taking the test and they, in fact, scheduled the test, at which time he took the test and the Department of Transportation further indicated that there would be no suspension imposed, WHEREFORE, your petitioner prays Your Honorable Court to hold a hearing to determine the validity of the suspension outlined in Exhibit "A", Respectfully submitted, MANCKE, WAGNER, HERSHEY & TULLY By Joh B, Mancke, Esqu re Atto ney I,D, No. 07212 2233 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Petitioner , VERIFICATION I verify that the statements made in the foregoing document are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa,C,S, section 4904, relating to unsworn falsification to authorities, Dated: )~~ CAMP HILL PA 17011 940809223546210 DOL 03/21/1994 12679661 12/25/1945 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION Bureau of Driver Licensing Harrisburg, PA 17123 MARCH 28, 1994 GARV L DOBRINOFF 3819 LAMP POST LANE Dear 110torist 1 An indefinite suspension will be imposed under Section 1538 of the Vehicle Code, on the effective date listed below, as a result of your failure to conlply with the required Special Examination. In order tc cor.lply with this sanction you are required to return any current driver's license, learner's permit and/or temporary driver I s license (camera card) in your possession no later than the effective date listed below, Failure to comply with this notice shall result in this Bureau referring thi:; maHcr to tho P'lnnsylvania State Police for prosecution under Section 1571<a)(4) of the Vehicle Code. If you cannot comply with the requirements stated above, you must contact the Bureau (See information below) for furthl!r directions on how to receive credit towards your sanction. When the department receives your license or acknowledgement, it will send you a receipt, If you do not receive this receipt within 15 days contact the department immediatelY. Otherwise, you may not be given credit toward serving this sanction, Effective Date of Suspension 1 05/02/1994, 12101 a,m, Please see the enclosed application for restoration fee information. Exhibit "A" - , 940809223546210 You have the right to appeal to the Court of Common Pleas of the county of your residence within 30 days of the mail date (MARCH 28, 1994) of this notice, Sending a copy to this department of a timelY, filed appeal will stay the department's action pending a final decision by the court, The ~opy must be sent by certified mail tOI Room 103 Transportation and Safety Building Harrisburg, PA 17120 Sincerely, ...-. _? I"/v ~ -r;::r , - Douglas K. Tobin, Director Bureau of Driver Licensing SEND FEE/LICENSE/DL-16LC/TOI Department of Transportation Bureau of Driver Licensing P,O, Box 68693 Harrisburg, PA 17106-8693 INFORMATION (7100 AM TO 6130 PM) Pittsburgh Area - 412-565-5670 Philadelphia Area - 215-698-8100 Harrisburg Area - 717-787-3130 Toll Free 1- 800-932-4600 ~~ - , GARY L, DOBRINOFF, Petitioner : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA , , V, : NO, 94-1911 Civil Term , , COMMONWEALTH OF PENNSYLVANIA, : DEPARTMENT OF TRANSPORTATION, : Respondent , , PRABCIPB TO THE PROTHONOTARY: Please withdraw the above-captioned appeal, Respectfully SUbmitted, MANCKE, WAGNER, HERSHEY & TULLY By " , B, Mancke, Esqu re rney I.D. No. 07212 223 North Front Street Harrisburg, PA 17110 (717) 234-7051 Attorneys for Gary Dobrinoff -::r en - :z: -=s ,.. II> ~~ "'- .t_~ .- .....f -:;,"- - U:.r.l:.'., ::6,",,~1 ...~r")... .- ~ ... ...r: "_-. '..~. i '.... ".. _ :~u '~;~ t...~ ...., a: ... ""'"