HomeMy WebLinkAbout95-01742
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T. MICHAEL GRUNOON,
Petitioner/owner
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
One PA motor vehicle with' NO.
Vin * 1G4AH19R7FT438196
VS.
CIVIL TERM 1995
COMMONWEALTH OF PENNSYLVANIA,
DEPT. OF TRANSPORTATION
APPBAL or SUSPBNSION or VEHICLB REGISTRATION PRIVILBGB
AND NOW, comes your Petitioner who files this Appeal of the
Suspension of Vehicle Registration Privilege and in support thereof
respectfully represents:
1. Petitioner is the owner of the above-captioned motor
vehicle which has a registration number 3P3724.
2. In September, 1994, your Petitioner was hospitalized in
the cumberland County Nursing Home and was diagnosed with multiple
sclerosis and diabetes.
3. Your Petitioner continues as a patient in the CUmberland
County Nursing Home as of the date of this Petition.
4. In November 1994, your Petitioner's auto insurance policy
for the above-captioned motor vehicle lapsed.
5. On February 23, 1995, your Petitioner's wife, Mary
Grundon, purchased automobile insurance coverage which is
sufficient under the PA Financial ResponSibility Act.
6. By letter dated March 6, 1995, the Department of
Transportation notified Petitioner that the vehicle registration
privilege for the above-captioned vehicle was being suspended for
three months effective April 11, 1995. A copy of that notice is
attached hereto and marked Exhibit "A".
7. Petitioner's wife needs the use of this motor vehicle to
maintain her employment.
8. The suspension of the vehicle registration privilege for
a period of three months is not authorized under S1786 of the
Vehicle Code.
9. The suspension of the vehicle registration privilege is
authorized only until such time as the owner provides the
Department
of
Transportation
with
of
financial
proof
responsibility.
10. Your Petitioner will be providing the Department of
Transportation with proof of financial responsibility prior to
April 11, 1995, and therefore is not subject to the suspension.
11. It is believed and therefore averred that the Department
of Transportation disagrees with Petitioner's interpretation of
S1786 of the vehicle code.
WHEREFORE, your Petitioner prays this Honorable Court will
schedule a hearing to determine the validity of the suspension of
the vehicle registration privilege.
Respectfully submitted,
~&~
R. Mark Thomas, Esquire
54 E. Main street
Mechanicsburg, PA 17055
(717) 697-4650
I.D.# 41301
VBRII'ICATION
This verification is being signed by R. Mark Thomas, Esquire,
attorney for the Petitioner on the basis of information provided to
him by the wife of Petitioner. This Petition must be filed by the
end of business on this date and Petitioner's signature is
unobtainable. The information contained herein is true and correct
to the best of my knowledge, information and belief.
Date: f.l-5/~5
/
~~~
R. Mark Thomas, Esquire
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R. MARK mOMAS
Attorneys et Lew
54 Ellst Mllln Street
Mechllnlcsburl1. Pennsylvllnlll 17055
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T. MICHAEL GRUNDON,
petitioner/Owner
.
.
IN THE COURT OF COMMON PLEAS OF
CUHBERLANDlCOUNTY, PENNSYLVANIA
- 1f"J-
NO.1tr n CIVIL TERM 1995
.
.
.
.
One PA motor vehicle with:
vin . 1G4AH19R7FT438196
VS.
COMMONWEALTH OF PENNSYLVANIA,
DEPT. OF TRANSPORTATION
ORDBR
AND NOW, this
day of
, 1995, after
consideration of the within Appeal, it is hereby ordered that a
hearing on this Appeal is scheduled for the day of
1995, in Court Room No. , cumberland county
courthouse, carlisle, PA.
By the Court,
J.
.
.
-
.
Ml1RREL R. WALTERS, m
R. MARK THOMAS
Attorneys lit LlIw
54 ElIst MlIln Street
Mechllnlcsburg, Pennsylvllnlll 17055
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T. MICHAEL GRUNDON,
Petitioner/Owner
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
One PA motor vehicle with: NO.
Vin . 1G4AH19R7FT438196
CIVIL TERM 1995
VS.
.
.
.
.
."
;~"J ."
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....
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COMMONWEALTH OF PENNSYLVANIA,
DEPT. OF TRANSPORTATION
.
.
1<, '
u,
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APPEAL O~ SUSPBNSION OP VEHICLB RBQISTRlTION PRIV~LB"
r,,-,
)/1' -0
AND NOW, comes your Petitioner who files this.APpeal~f the
..... .( c..o
Suspension of Vehicle Registration Privilege and in support ~ereof
respectfully represents:
1. Petitioner is the owner of the above-captioned motor
vehicle which has a registration number 3P3724.
2. In September, 1994, your Petitioner was hospitalized in
the Cumberland County Nursing Home and was diagnosed with multiple
sclerosis and diabetes.
3. Your Petitioner continues as a patient in the Cumberland
County Nursing Home as of the date of this petition.
4. In November 1994, your Petitioner's auto insurance policy
for the above-captioned motor vehicle lapsed.
5. On February 23, 1995, your Petitioner's wife, Mary
Grundon, purchased automobile insurance coverage which is
sufficient under the PA Financial Responsibility Act.
6. By letter dated March 6, 1995, the Department of
Transportation notified Petitioner that the vehicle registration
privilege for the above-captioned vehicle was being suspended for
three months effective April 11, 1995. A copy of that notice is
attached hereto and marked Exhibit "A".
7. Petitioner's wife needs the use of this motor vehicle to
maintain her employment.
8. The suspension of the vehicle registration privilege for
a period of three months is not authorized under li1786 of the
Vehicle Code.
9. The suspension of the vehicle registration privilege is
authorized only until such time as the owner provides the
Department
of
Transportation
with
proof
of
financial
responsibility.
10. Your petitioner will be providing the Department of
Transportation with proof of financial responsibility prior to
April 11, 1995, and therefore is not subject to the suspension.
,
11. It is believed and therefore averred that the Department
of Transportation disagrees with Petitioner's interpretation of
li1786 of the vehicle code.
WHEREFORE, your Petitioner prays this Honorable Court will
schedule a hearing to determine the validity of the suspension of
the vehicle registration privilege.
Respectfully submitted,
~~M;,~~
R. Mark Thomas, Esquire
54 E. Main street
Mechanicsburg, PA 17055
(717) 697-4650
I.D.II 41301
T. MICHAEL GRUNDON,
Petitioner/Owner
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
One PA motor vehicle with. NO.
Vin . 1G4AH19R7FT438196
CIVIL TERM 1995
VS.
" '7,
~
-"
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COMMONWEALTH OF PENNSYLVANIA,
DEPT. OF TRANSPORTATION
(...0.';
.I:-
APPEAL OP SUSPENSION OP VEHICLE REGISTRATION PRIV~LEGB:
>,. ~
AND NOW, comes your Petitioner who files this App~al~ the
--';..- c.a
c.n
suspension of Vehicle Registration Privilege and in support thereof
respectfully represents:
1. Petitioner is the owner of the above-captioned motor
vehicle which has a registration number 3P3724.
2. In September, 1994, your Petitioner was hospitalized in
the Cumberland County Nursing Home and was diagnosed with multiple
sclerosis and diabetes.
3. Your Petitioner continues as a patient in the Cumberland
County Nursing Home as of the date of this Petition.
4. In November 1994, your Petitioner's auto insurance policy
for the above-captioned motor vehicle lapsed.
5. On February 23, 1995, your Petitioner's wife, Mary
Grundon, purchased automobile insurance coverage which is
sufficient under the PA Financial Responsibility Act.
6. By letter dated March 6, 1995, the Department of
Transportation notified petitioner that the vehicle registration
privilege for the above-captioned vehicle was being suspended for
three months effective April 11, 1995. A copy of that notice is
attached hereto and marked Exhibit "A".
7. Petitioner's wife needs the use of this motor vehicle to
maintain her employment.
8. The suspension of the vehicle registration privilege for
a period of three months is not authorized under !il786 of the
Vehicle Code.
9. The suspension of the vehicle registration privilege is
authorized only until such time as the owner provides the
Department
of
Transportation
with
proof
of
financial
responsibility.
10. Your Petitioner will be providing the Department of
Transportation with proof of financial responsibility prior to
April 11, 1995, and therefore is not subject to the suspension.
,
11. It is believed and therefore averred that the Department
of Transportation disagrees with Petitioner's interpretation of
11786 of the vehicle code.
WHEREFORE, your Petitioner prays this Honorable Court will
schedule a hearing to determine the validity of the suspension of
the vehicle registration privilege.
Respectfully submitted,
;~&~~
R. Mark Thomas, Esquire
54 E. Main street
Mechanicsburg, PA 17055
(717) 697-4650
I. 0.11 41301
VERIFICATION
This verification is being signed by R. Mark Thomas, Esquire,
attorney for the Petitioner on the basis of information provided to
him by the wife of Petitioner. This Petition must be filed by the
end of business on this date and Petitioner's signature is
unobtainable. The information contained herein is true and correct
to the best of my knowledge, information and belief.
Date: f/-5"hS-
/
K~/~~
R. Mark Thomas, Esquire
TITLE HUHBER 37484998
PLATE HUHBER 3P37Z4
VIH . IG4Altl9R7FT438196
OFFICIAL
NOTICE
PROCESSED 95-059
HAIL DATE, HAR 06 1-995
T tlICHAEL
i!1l3 CLARK
LEHOVNE
GRUNDON
STREET
PA 17043
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"OU StenE ;;:c:::rr:.... nl!~utcn:c T' I'f!cvibifpp.!:CF ....F PJt'\H~j.~~, p....nttOl"TL~:~r.nuFR'NQ THF npF.ftlTTnN OF THE
DESCRIbED "OTOR VEHICLE. Tilts I~F.o.iiA#~~ HAS REQUEST~D';AS A RESIIlT D~ 'J~I~iBU~EAU BUNO NOTIFIED BV
AlLSTAlE INSUR CD /,)IIAT TilE IHSURANCE PO~*~V COVERIIID THE VEHICl~,~AS TER"INATED ON 11/16/94.
EITIIER NO RESPDuse HAS REC.IVE~Cp~ THE INfDR"ATIDII YDU:l'RDVIDED INDICATED A LApsE IN CDVERAGE HHICH HAS NDT
PERHITTED UNDER SECTIDII 170~ Oi'\i'~E VEIIIClE CDDE. AS'A:':~ESUl T, TNE VEHICLE )IEDI~tRATIDN PRIVIlEOE HIll BE
SUSPENDED fOR TIlREE "DHTHS iffE~#V" Wll/95 AT l~iOnilt, AS AUTHORIZED~(~EC.iIDH 1786 IDJ Df THE VEIIICLE
CODE AHD VOU WIll IE REQUIRiDT~R~tyRH VOUR CURREJrt'Ri:DI~JRATION PLATEAH.Ji.~~~Ji~ ADDITIONAllY, CREDIT TOWARD
SUVINO THE SUSPEHSIOU WIll ~~filE~I~.UNTIl TilE REDISTli~i'l~H,.PlATE IS RE~EiVE~."ii THIS BUREAU. YOU WIll BE
REQUIRED TO PAV A RESTDRATIDHfE~"iH,,'r"E A"OUNT,Oi':'.so,iio{TDqIlE DEPARtrfE'It)ii ACCORDANCE WITH SECTION 1960 Df
THE VEIIIClE CDDE. PLEASE SEE r~~~~5~~~E\ ~~t~~f~t#e~;r~~~~~M~tN^lj~~!~~W~N fEE IUfDR"ATIDN.
ADDRESS ANV CDRRESPOIIDENCE DR SU8"I~St~N.Of DOCUHElrtS/CREDENTIALS LI~TEDABOVE TO' DEPART"ENT Of TRANSPDRTATION
BUREAU OF "OTOR VEHICLES, fJNANCIAlRE~r~~IBIlITV SECTION, P.O. ~~X:~~674j HARRISBURO, PA. 17106-B674
" ,"":;::';:::' ','.' '
VOU HAVE TilE RIOIIT TO APrEAl TNIS SUSPEtiSIiltiTD,T~E,5D~~T,.,~f,~DHljiitipi.EAS Of THE COUNTV Of VOUR RESIDENCE
WITHIN THIRTY 1511 DAVS Of THE DATE Of TillS NDTICE,.SEilliiilo'A'-corv TD THIll DEPART"ENT OF A TIHElV, fILED
APPEAL WIll STAY THE DEPARTHENT'S ACTIDN PENDING A flNAl DECISIDII D'/ TilE CDURT. THE CDPV IIUST BE SENT BV
CE~TlfIED HAIL TO. DEPART"ENT Of TRAIISPDRTATION, RDD" IDS, HARRISBURO, PA. 17125.
BV DRDER Df
~GitfuR ~ Wf}e;
BUH~AU ur.lluru" Vtll'~Lt..
DEPARTIIEIIT Df TRANSPORTATIDN
ENCLOSURE, RESTORATION fEE PAV"ENT APPlICATIDN
INfDR"ATIDII C7.00 A" TD 6.50 P"I
PITTSBURGH AREA 412-565-5670
PHILADELPHIA AREA 215-69B-BI00
IIAR~ISBURO AREA 717-7B7-5150
TDll fREE BDD-'32-Q600
TDD BDD-22B-D676
EXHIBIT
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