HomeMy WebLinkAbout94-04104
Appellant
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
<14 - <II o'~
NO, CIVIL TERM
VS.
COMMONWFALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
AND NOW, this
ORDER
~i'day of July, 1994, upon presentation and
consideration of the attached, verified petition, it is ordered
that a hearing be held on the 71".1 day of ffi-Z~A . , 1994,
,
9: ~c) -
at o'clock~,m, in Courtroom No. ~, of the
Cumberland County courthouse, carlisle, Pennsylvania.
Appellant shall forthwith serve a copy of this Order and her
Petition on Appellae by certified mail, return receipt requested.
The registration suspension is hereby stayed pending further
Order of court, fo"t o"I'1""{ l..d so lo\,,~.l~ ~PfC({)I)t~ '''Sl.lJzhC~
~.." U 7",.. h? fo be ~'"l rCo'''' s.1at J 6r ,., ~ ,'(e d ""'~ I't...,,', OS ,..; it f4.c.l
~ By ~e Court, ,
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Appellant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
q'l-'f/()Lf
NO. CIVIL TERM
TOMMI LYNCH,
VS.
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
PETITION FOR APPEAL AND SUPERSEDEAS
The appellant, by counsel, Philip C, Briganti of Legal
services, Inc" respectfully represents as follows:
1. The appellant is Tommi Lynch, an adult individual
residing at 236 North Baltimore Avenue, Apartment B, Ht. Holly
springs, Pennsylvania 17065,
2, The appellee is the Commonwealth of Pennsylvania,
Department of Transportation, Bureau of Driver Licensing
(hereafter "Penn Dot"), whose offices are located in the
Transportation and Safety Building, Room 103, HarriSburg,
Pennsylvania 17123,
3. By a Notice dated June 27, 1994, Penn Dot informed the
appellant that her registration was being suspended as of August
2, 1994, for a three-month period, because of an alleged lapse in
the insurance coverage for her vehicle, A true copy of the
Notice is attached hereto as Exhibit "A,"
4. Penn Dot's proposed suspension of the appellant's
registration is contrary to law and unsupported by evidence, in
that, inter ~:
a, A three-month suspension was not authorized by the
controlling statute, 75 P,S. S17B6(d), at the time the
appellant's insurance coverage was terminated,
(e) Property owned
Cash :._.._.._._.__.__.......__._.._..U~~
Check i ng Account :.... ..___.________...19,J_QQ__.. ______
Sav i n9s Account:. p$l1QQ,9.9_______._.
Certificates of Deposit: N/A....___._____
Real Estate (including home): NI!!.__ .___...
Motor veh i c 1 e: Make pontll;\g Year
Cost__9H_t._______ Amount owed
Stocks; bonds: $.on.' ~_.b9.n(tli__$,2Q_QtQQ_____
Other: __.__.___ _____________________0._ _
(f) Debts and obligations
Mortgage: u..u__ ____ m__ 9____.u
Rent: _____.__H1!D._..':'__I1Q.J:!lnLPAi..d
Loans :_ . _____ _ u ___u___ ___ __.____._______p
Monthly Expenses:G.r9_~!lriQ'Il____1')9_L~Qy.!lred by food stamos
S80, 00: .QM._IQ.Lc!ir_ $40_,0_Q_;___IU_~~r i c S30, 00: _Ie 1 eDn2nL..
12.2.....0.0.;, L jte j n.~_u.r:_!m~!LlJ_Q ,.QQ;_.I,!,._Qfl.l1J.!L.t2.~,..QJ2;___.
MJ ece 1. 1 aneOlJ6~Xpen8!!1S $~Q,_oo_;_CJ_otJ1 in.9._$~Q&~
(g) Persons dependent upon you for support
(Wife) (Husband) Name: _ u___.NltL___u__.
Children, if any:
Name: ___$!lthj..Yn~b __ __ _.__ Age :_____ ..l_t1_~_
4. I understand that I have a continuing obligation to
inform the court of improvement in my financial circumstances
whiCh would permit me to pay the costs incurred herein.
.., .....
....'.
TOMMI LYNCH,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 94-4104 CIVIL TERM
Appellant
VS.
COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF TRANSPORTATION,
BUREAU OF DRIVER LICENSING,
Appellee
PETITION TO WITHDRAW APPEAL
COMES NOW the appellant, Tommi Lynch, by counsel, Philip C,
Briganti, Legal Services, Inc., and respectfully petitions this
Court as follows:
1. On July 22, 1994, Appellant filed an appeal from a
decision by Appellee to suspend her vehicle registration for a
three-month period, because of an alleged lapse in the insurance
coverage for her vehicle,
2, On July 25, 1994, this Court issued an Order scheduling
a hearing on this matter for October 7, 1994 at 9:30 a.m,
3, Subsequently, the issues raised in Appellant's Petition
for Appeal and supersedeas have been resolved, rendering further
proceedings unnecessary,
WHEREFORE, Appellant respectfully requests that she be
permitted to withdraw her appeal, and that the hearing sche.duled
for October 7, 1994, at 9:30 a.m., be cancelled.
Respectfully submitted,
7j,,/thr
/ / / / J
j//. <0 ( ~__,. At-
Philip e, Brigan~
Attorney for Appellant
LEGAL SERVICES, INC,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400