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HomeMy WebLinkAbout95-04469 LARRY LYNN SHAULIS : IN TI IE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 95-4469 CIVIL TERM COMMONWEALT" OF PENNSYLVANIA: DEPARTMENT OF TRANSI'ORTA nON BUREAU OF DRIVER LICENSING : CIVIL ACTION - LA W ORDER OF COURT AND NOW this M't/Jy of Murch, 1997, a continuance Is grunted, indefinlte,in the above referenced mailer. Currently, this mUlier Is scheduled to be heurd on Murch 21, 1997 at 10:00 a.m. In Courtroom Number I of the Cumberland County Court of Common Pleas. Lastly. the Petitioner, Larry Lynn Shaulis, shall notify the I'ennsylvanla Department ofTransportatlon Bureau of Drivers License. Immediately upon receipt of any notification that his petition for appeal now pending before the Pennsylvania Supreme Court has been ruled upon, At that time, the pending license suspension hearing shall be rescheduled, UY TilE COURT. ec: Larry Lynn Shaulis Arthur Oils, Esquire George Kabusk, Esquire, I)epartment of Transportation ~..." ,...~.(..c 3J.:.l~( ~'1,' "\.\. \. ." '."! \ I ~, :. . I y " Iii i." I .- ,... of., ' - PAUL BRADFORD ORR """"""11 alIAU! 78 Wc.II'"",f,,,1 St",c1 Carll.I.., I' ^ 171113 Teleph"n. (717) 258.8558 T.I.f.. (717) 243.0061 Morch I R, 1997 The Honorable Harold E. Sheely, Presldelll Judge Cumberland County Courthouse I Courthouse Square Carlisle. PA 17013 RE: Larry Lynn Shaulis v, Commonweallh of Pennsylvania, el 01 No: 9S-4469 Civil Term Dear President Judge Sheely: Please be advised, that I now represent Larry Lynn Shaulis In the above captioned mailer. Furthermore,lhls shall confirm a conversation belween myself and George Kabusk. Esquire, allorney for the Pennsylvania Department of TransportAtion, Bureau of Driver Licensing, whereby on Tuesday, March 18, 1997 II was agreed upon between the parties that a continuance request by Larry Lynn Shaulis would nol be opposed by the Commonweallh due to his pendlna Petillon for Appeal filed with the Pennsylvania Supreme Court's Prothonotary's office In December of 1996. Lastly, II was agreed upon belween the parties thatlmmedlalely upon nollficatlon by the Pennsylvania Supreme Court thallhe pelltion for appeal has either been denied or granled, such notice shall be given to all panics, "~R~ ..~~~ ""~ 7f~'t;pm~ro- my ,- PAUL BRADFORD ORR, ESQUIRE PBO:ss Enclosure cc: Larry Lynn Shaulis Arthur Oils, Esquire George Kabusk, Esquire HAW~ 0 ~~ I V~R~ j> '3~ /q. q 1 p. i\1. . (7\ '/. cr. ' ~~-'~ ((~-'tr~1 ATTORNEYS AT LAW EXECUTIVE HOUSE SUITE II 101 SOUTH SECOND STREET HARRISBURG, PENNSYLVANIA 17101 PHONE: (7171233.1743 ARTHUR K, OILS JOSEPH J, DIXON DIANE M. RUPICH December 4, 1996 The Honorable Harold E. Sheely President Judge of Cumberland County Cumberland County Court HOUBe One Court House Square Carlisle, PA 17013 RE: Larry Lynn Shau Department of Tran N Dear Judge Sheely: Pursuant to the Order of Court datod October 1 B, 1995 in the - above captioned matter, enclosed U !! ~ 91 the .!.!!I!lll, this ia to notify your Honorable Court that the Appeal to the Superior Court filed on behalf of Larry Lynn Shaulis has been denied aa of November lB, 1996. However, I appeared with Mr. Shaulis before The Honorable Kevin A. Hess on Tuesday, December 3, 1996 and at that time', Judge Hess permitted Mr. Shaulis ten (10) days in which to file a Petition for Allowance of Appeal to the Pennsylvania Supreme Court. As of this date, Mr. Shaulis has retrieved hiB file from my office and has indicated that he will be seeking counsel elsewhere to pursue the Petition for Allowance of Appeal to the Pennsylvania supreme Court. letter to Attorney George Kabusk, Pennsylvania, Department of aware of the outcome of the Appeal I am sending a copy of thiB of the commonwealth of Transportation, so that he is to the Superior Court. Thank you for your cooperation and assistance in this matter. AKDlkjrn Ene. ce: George Kabusk, Esquiro Larry Lynn Shaulis ,""."'''~L.. ,... -., . to N.../ , -.-:--' . . ~ -. ~ LARRY LYNN SHAULIS, Appellant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 95-4469 Civil Term VB. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee OaDIR or COOR'I' It/f.. day of Ge, rl Rt'L. Arthur K. DUs, and with acquie.cence in eald reque.t by the counsel for the Commonwealth of penn.ylvania, Department of Tran.portation, George Kabu.k, E.quire, it is hereby Ordered that the hearing scheduled for october 18, 1995 at 9100 a.m. concerning the Appeal from Su.pen.ioD of Motor Vehicle Operating PrivUeges is hereby continued, the purpose of the continuance 1& to await the Appellant' e criminal appeal before the Superior Court for the Middle Di.trict of Penn.ylvania. Arthur K. Dila, Eaquire, counael for the Appellant, is hereby Ordered to notify this Court and counsel for the Commonwealth of Pennsylvania, Department of Transportation within m d..~IL P J/..u~' , / Il J , forty-eight (48) hour. aft.r the date of learning the outcome of the superior court App..l, .0 that if necelSary, the APpeal matter b.for. thi. court can be dlcidld. In accordance with thi. court'. Order dated Auguet 25, 1995, the Itay .hall continue. BY THE COURT I Ordered that a hearing ahall be held the ~ day of (J,.:f.kli1- in the Courtroom No. ~ of the cumberland county Court , 1995, LARRY LYNN SHAULIS, Appellant vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . ') No. 7f 4 ~((1 (I( Ll'l t '... (It n'- COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee AND NOW, this ORDER OF COURT a.ljl/.,day of Qv.....~t upon presentation and consideration of the within Appeal From Suspension of Motor Vehicle Operating Privileges, it is hereby on w,JAJ,-,tlAY , 1995 at 'f;OtJ -1...M. , House, One Court Houae Square, Carlisle, Pennsylvania. It is further Ordered that the Attorney for the Appellant shall serve a certified copy of this Order of Court and Appeal upon the Appellee. All proceedings to stay in the meanwhile. BY THE COURT I j 1 . Ue) I/]?- I" i'.II - t.,- ~_ .J <'- ...;\. - ,. .~~ ~ Sr II' F ? ll, Ii, j ~J (.. ~ -'1.!) I ~'J. tt~ J. . c..ov.V'~ot~ r~ LARRY LYNN SHAULIS, Appellant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee APPEAL FROM SUSPBNSION OF MOTOR VBHICLB OPBRATING PRIVILBGBS AND NOW, thiSof/ day of Au~ust, 1995, comes the Appellant, Larry Lynn Shaulis, by his Attorney, Arthur K. DUs, Esquire, and respectfully requests the following: 1. Your Appellant, Larry Lynn ShauliS, is an adult individual, who currently resides at 431 Old State Road, Gardners, cumberland County, Pennsylvania, 17324. 2. The Appellee is the commonwealth of pennsylvania, Department of Transportation, Bureau of Driver Licenaing, with its office located at Room 103, Transportation and Safety Building, Harrisburg, Pennsylvania, 17120. 3. Attached hereto and marked Exhibit "A" is a copy of an official notification L~om the Appellee informing your Appellant of his suspension of his motor vehicle operating privllegea for a period of six months as a result of a violation of section 13A30 of the Pennsylvania Motor Vehicle Code, Delivery of Controlled Substance. 4. Your Appellant, Larry Lynn Shaulis, was found guilty by a jury of the charge of delivery of controlled substance I however, post-sentencing Motions were timely filed on his behalf and are currently pending before Your Honorable Court, the Court of Common pleas of cumberland county. 5. The Appellant's Appeal is not frivolous and consists of valid appeal issues. 6. Your Appellant has an absolute right to file his Appeal. 7. Until the Appellant has exhausted all of his rights to appeal, it is averred that a suapension of his motor vehicle operating privileges would result in an injustice upon him. WHEREFORE, Your Appellant respectfully requesta Your Honorable Court to grant his Appeal from Suspension of Motor Vehicle Operating privileges, and to Order that said suapension ohall not become effective until your Appellant has exhausted all of his appeal rights. submitted, BY: rt 1 South Second Street Harrisburg, PA 17101 (717) 232-9724 J.D. No. 07056 -2- COHHONWEALTH OF PENNSYLVANIA DEPARTHENT OF TRANSPORTATION Bur.au of Driv.r Lic.nsing Harrisburg, PA 17125 JULV 26, 1995 ---. .--- ---- LARRY LVNN SHAULIS ~31 OLD STATE RD 'S11~a~330D~3'D 001 0711'/1"5 HjI~3nD 01f/U/1'5j1 GARDNERS PA H3~~ Dur Hotorht I A. a r..ult of ~our conviction an D6/27/1995 of violating S.ct1on llAID of the V.h1cl. Cad., DELIVERV OF CTRL SUI an 01/Dl/1994. ~our driving pr1vileg. 1. being SUSPENDED far a p.riod of 6 HONTH(S) a. .andat.d b~ Sact10n 1552C of thl Ve- hich Cad.. In ord.r to caapllf with thh sanction lfOU ar. required to r.turn anlf curr.nt dr1v.r's lic.ns.. 1.arner's per.it and/or t.aporar~ dr1v.r's l1c.ns. (ca.era card) in ~our pa.....ion no lat.r than the .ff.ctiv. date list.d. If lfOU cannot ca.- pl~ with the requir...nts stat.d abav., lfOU Ire requ1r.d to .ub.it a DL16LC Far. or a l.tter acknowl.dg1ng the sanction of lfour driving priv1l.g.. Fa1lur. to coapllf with this no- tic. shall r..ult in this Bur.au r.f.rring this .atter to the P.nnllflvania Stlt. Polic. for pro3.cution und.r SECTION 1571(1)(4) of the V.h1cl. Cad.. Although the law IIIlndat.s that lfour Ilrlving privU.ge 11 UlI- d.r susp.ns1on .v.n if lfOU do not surr.nd.r lfour HClnl., credit wlll not b.gin unt 11 all curr.nt driv.r' s l1c.n.. product(s), the DL16LC Forlll, or a l.tt.r acknowl.dging lfour sanction is r.c.iv.d in this Bur.au. WHEN THE DEPARTHENT RECEIVES YOUR LICENSE OR ACKNOWLEDGEHENT, WE WILL SEND YOU A RECEIPT. IF YOU DO NOT RECEIVE THIS RECEIPT WITHIN 15 DAVS CONTACT THE DEPARTHENT IHHEDIATELV. OTHERWISE, YOU WILL NOT BE GIVEN CREDIT TOWARD SERVING THIS SANCTION. Effective Date of suspension I 08/30/1995, 121Dl a.lII. Pl.ase se. the enclosed application for restoration f.. in- forlllation. Exhibit "A" 951848455002590 -.-- You have the right to appeal the Department's action to the Court of COMMon Pleas (Civil Division) within 3D da~s of the mail date (JULY 26. 1995) of this notice. PLEASE NOTE that this Civil Appeal is in addition to an~ appeal ~ou have to file from the criminal conviction. You must follow the in- structions listed below according to ~our individual situ- ationl 1. PENNSVLVANIA RESIDENT - If ~ou are a resident of Penns~lvania. ~ou must file an appeal with the Court of Com~ mon Pha. in the Count~ of ~our residence. Sending a cop~ of the eppeal which ~ou filed with the Court. to the Depart- ment. will postpone the Depart.ent's action pending a fina~ deci.ion b~ the Court if the applal wa. filed within the re-O quired 50 da~s. Howevar. i f ~our privUege to operate a commercial Motor vehicle ha. been DISqUALIFIED, a signed .upersedeas b~ the judge must acco.pan~ ~our appeal. I. NON-RI.IDINT - If ~ou are not a resident of Penns~lvania, ~ou Must fill an appeal with the Court of COMMon Pleas in the Penns~lvania Count~ where the violation occurred. Slnding a cop~ of the appeal which ~ou fUed with the Court. to the DepartMent. will postpone the Department's action plnding a final dlclsion b~ the Court if thl appeal was filed within the required 3D da~s. THI APPEAL MUST IE SINT IY CERTIFIID MAIL TOI PINNSYLVANIA DEPARTMENT OF TRANSPORTATION OFFICE OF CHIEF COUNSEL ROOM lOS, TRANSPORTATION. SAFETY BUILDING HARRISBURG, PA. 17120 Sincerel~. ..-; ~ ~ ",. ~....,-;::i' I Douglas K. Tobin. Director Bureau of Driver Licensing Dated, August 21, 1995 VUIPICA'l'ION I v.rify that the .tat.ment. made in this Appeal from suspension of Motor Vehicle Operating Privilegeare true and correct. I undentand that fal.e .tat.ment. herein are made .ubject to the penal tie. of 18 Pa. C.B.A. SOD4, relating to un.worn falaitication to authoritie.. LARRY LYNN SHAULIS, Appellant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 95-4469 Civil Term vs. COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF TRANSPORTATION, BUREAU OF DRIVER LICENSING, Appellee ORDER OF COURT AND NOW, rfl this r ~ day of , 1995, upon c!) <.. r" ,.l;._L.---. a telephonic conference request by counsel for the Appellant, Arthur K. Dila, and with acquiescence in add request by the counsel for the commonwealth of Pennsylvania, Department of Transportation, George Kabusk, Eaquire, it is hereby Ordered that the hearing scheduled for October 18, 1995 at 9:00 a.m. concerning the Appeal from Suspenaion of Motor Vehicle Operating Privileges is hereby continued I the purpose of the continuance is to await the Appellant I s criminal appeal before the Superior Court for the Middle District of Pennsylvania. Arthur K. Oils, Esquire, counsel for the Appellant, is hereby ordered to notify this Court and counsel for the Commonwealth of Pennsylvania, Department of Transportation within .. . forty-eight (481 hours after the date of learning the outcome of the superior Court Appeal, so that if necessary, the Appeal matter before this Court can be decided. In accordance with this court's Order dated August 25, 1995, the stay shall continue. BY THE COURT: 'Jcu~~\ c \k\ !J.J. (11' {IlL .. ,J '.' . ,; , i, 56, HJ 61, r 8/ IJO /6 '1 1(')- .. ( I'/,I ~tlJ //,lA " ~ f ,L ,4.ll" I .l 4 (/ ,A,l (J J<,", c ( . "-;"''-'"v,'' .. -.".... . I ,."." -,.,.. ','.'"', " " . COMMONWEALTH OF PENNS\'LV ANIA DEPARTMENT OF TRANSPORT A TION OFFICE OF CIIIEF COUNSEL VEIIICLE.. TRAFFtC LAW D1VIStON RtVERFRONT OFFICE CENTER 1101 SOUTIl FRONT STREET IlARRtSBURG, PENNSVLVANIA 1710+2516 (71717.7.2130 FAXI (7171705-1122 Februlry n, 1997 The Honorable Harold E, Sheely President Judge Cumberland County Counhouse I Counhouse Square Carlisle, PA 17013-3387 REI Commw. of Pa" DOT, DDL v, Larry Lynn Sbaulls, Cumberland County Case 4469.1995, CIvil Dear Judge Shecly: I refcr you 10 the above menlioned license suspension appeal. Pursuant to the Order of Coun daled October 18, 1995, the above mentioned case was continued pending the outcome of the motorist's appeal to the SuperiorCoun and Mr, Oils was to notify the Court of the outcome of the Superior coun sppeal, so Ihatlfnecessory, the Appeal before this coun can be decided, See allached Order, Mr, Oils notificd this 1I0norable Coun by leller dated December 4, 1996, that the appeal to the Superior coun has becn denlcd as of November 18, 1996, See ollached teller, I respectfully request thotthis moller be scheduled for hearing. Sincerely, ~ I~C George l~bUSk Assistant Counsel G\lK/gk Enclosures (2) Cc: frank noch, Assistont Cllunsclln Chorge, Driver Licensing Sectilln Anhur K, Ulls, Esquire, Eseclltlvc \Io11se, Suite #1,101 South Second Strecl, Harrisburg. Po. 17101 . fI)~ ct .so~, ATTORNEYS AT LAW EXECUTlIIE HOUSE SUITE II 101 SOUTH SECOND STREET HARRISBURG, PENNSYLIIANIA mOl PHONE: (717123,..741 ARTHUR K, OILS JOSEPH J, DIXON DIANE M, RUPICH December 4, 1996 The Honorable Harold E. Sheely President Judge of Cumberland County Cumberland County Court. House One Court House Square Carlisle, PA 17013 REI Larry Lynn Shaulia v. Commonwealth of Pennsylvania, Department of Transportation, Bureau of Driver Licensing No. 95-4469 Civil Term Dear Judge Sheely I Pursuant to the Order of Court dated october 18, 1995 in the above captioned matter, enclosed is a copy of the same, this is to notify your Honorable Court that the Appeal to the Superior Court filed on behalf of Larry Lynn Shaulis haa been denied as of November 18, 1996. However, I appeared with Hr. Shaulis before The Honorable Kevin A. Heaa on Tuesday, December 3, 1996 and at that time, Judge Heas permitted Hr. shauUa ten (101 days in which to file a Petition for Allowance of Appeal to the Pennsylvania supreme Court. As of thia date, Mr. Shaulia has retrieved his file from my office and has indicated that he will be aeeking counsel elsewhere to pursue the Petition for Allowance of Appeal to the Pennaylvania Supreme Court. I am sending a copy of this of the Commonwealth of Transportation, ao that he is to the Superior Court. Thank you for your cooperation and aaaistance in thia matter. letter to Attorney George Kabuskl Pennsylvania, Department ot aware of the outcome of the Appeal 0IIltWftII"""" r11...,'nw!..... DI.rYlel1l qI '~Il~"",r.llloJ" RI'.Cit:tllh' AKDlkjm Enc. /' eCI George Kabuak, EaquireVl Larry Lynn Shaulia /-...,~.\ " II .\! \.CI \~:J J /,~~ 0 9 1996 . ~'11l1hC L" '~.:tItd I;u..'.... ....-.....~---- ....111 , .' ~ -, - LARRY LYNN SHAULIS, Appellant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. gS-446g Civil Term VI, COMMONWEALTH or PENNSYLVANIA, DEPARTMENT or TRANSPORTATION, BUREAU or DRIVER LICENSING, Appellee OJDD or COUIl'l' thil IK't. day of (}(1 a ()..VI.- Arthur K. DUI, and with acqulelcence in ..id requelt by the coun..l for the COlUlonweelth of Penneylvania, Department of TranlportaUon, aeorge Kabulk, Ilquire, it il hereby Ordered that the hearin9 Icheduled for October 18, 1US at glOO a,lII. concernin9 the Appeal froa SUlpenlioD of Motor Vehicle Operating PrivUeves i. hereby continued, the purpo.e of the conUnuance i. to await the Appellant'. crl.inal appeal before the Superior Court for the Middle Dletrict of Penn.ylvania. Arthur ~. Dile, E.quire, coun.el for the Appellant, i. hereby Ordered to notify thl. court and coun..l for the Commonwealth of Penneylvania, Department of Traneportation within ~v- ~~'~..'" "'---... - --- ,~, ,'~ ~-.;"Qf ,~" ""'C,'f"" !,It" ,II~'. , \I't ;, OfC 0 9 1996 ~::' !'tltlt l" . ,. ....... ,....,."..".. .... - -.. .,.,. Corty-.ight (48) hour. aft.r the dlte of l.uning the outcom. of the Superior Court Appell, .0 thlt 11 n.c...uy, the Appeal matt.1' b.fore thi. court oln be d.oid.d. In accord.nce with thi. Court I. Order d.ted Augullt 25, 1995, th. .tay .hall continue. I' THI COURTI m JtL.u.11... . f:' J /..u ~. / "J ~ '_'-,. -.-'n,.,-.,'&','''''-' LARRY LYNN SHAULIS 1 IN THB CDURT OF CDMMON PLIAS OF 1 CUHBBRLAND COUNTY, PBNNSYLVAHIA V. 1 1 CONMONWBALTH OF PBNNSYLVAHIA, 1 ND. 95-4469 CIVIL TBRM DIPARTMlNT OF TRANSPORTATION, 1 BURIAU OF DRIVlR LICBNSING 1 1 CIVIL ACTION - LAW ORDBR OF COURT AND NOW, thi. 20th day of FBBRUARY, 1997, a hearing i. .cheduled in the above captioned ca.e for Friday, March 21, 1997, at 10100 a.m. in Courtroom' 1. By the Court, \ -. LI.,IJ l~ B ld I. heely, P.J. Larry L. Shauli. 431 Old State Rd. Gardner., Pa. 17324 Arthur Dil., I.quire Georg. Xabu.k, I.quire D.partment of Tran.portation add ~~..A. .;./.;a.1/'I'I, ,~.f'. ,. i"r: r- ',. (~.. ~ . t, co;.. J.) ~s;, ' )~ ~!';': ';~ u.. \~ ~r "",. I, j'(n '" N I ~_.: I. ,'.... t:et: ~~ iim r 'In. t;.. ,.. a LJ C1I q)~ r( ~~, ATTORNEYS AT LAW EllECUTIVE HOUSE SUITE .1 101 SOUTH SECOND STREET HARRISBURG, PENNSYLVANIA 17101 PHONE: t717l 21,..741 ARTHUR K, OILS JOSEPH J, DillON DIANE M, RUPICH February 24, 1997 The Honorable Harold E. Sheely President Judge Cumberland County Court House One Court House Square Carlisle, PA 17013 RE: Commonwealth of Pennsylvania, Dept. of Transportation v. ;, Larry Lynn ShauUa No. 4469 - 1995 Appeal from License suspension Dear Judge Sheely: In reply to Attorney George II. Kabusk's letter to you dated February 12, 1997 in the above captioned matter, pursuant to his enclosures, I am no longer representing Larry Lynn Shaulis. It is respectfully requested that when the hearing is scheduled, that notice be directed to Larry Lynn Shaulis at his addreas of: 431 old State Road, Gardnera, Pennsylvania, 17324. Thank you for your cooperation i~ this matter. AKD:kjm cc: George H. Kabusk, Esquire 'L I' . ~', .... . ( '. ',__~'-"h',,,,-~_~,, ._ . ,,__...~_,,",..~~1e.~,.;,.lltIt#-,,';~~~~~'dl'!t"~ife!~~,-,_,=-,,<,_ fl)J cf ~ /- llSAG fGrU&......, AnllRNEYS AT L/IW EXECUTIVE HOUSE SUITlII 101 SOUTH SECQljQ STREET HARIIISlUIIO, PkNNSYlVANIA 11101 Office of Chief Counsel Commonwealth of Pennoylvania Department of Transportation Room 103 Transportation and Safety Building Harrisburg, PA 17120 .--"._",.",.,.-..._-~~..-~_..- ",~~.~=-.."",,,,,,....,._.,.,.,-..___._..--.....___''''U.'''_ ~ . I , \ I i t . I :~ , COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSI'ORTATION BUREAU OF DRIVERS LICENSING Appellee : IN TIll! COURT OF COMMON I'LEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. LARRY LYNN SHAULIS, NO, 95-4469 CIVIL Appellant : AI'I'EAL FROM DRIVERS LICENSE : SUSI'ENSION I'RAECIP"~ TO WITIIDRAW PREVIOUSLY ......ED APPEAL AND, this 23rd day of January 1998, the above Pethioner, LARRY LYNN SHAULIS, by and through his allorncy, Paul Bradford Orr, Esquire. respectfully request the Court to whhdraw his prcvlously tilcd appeal in the above rcferenced mallcr, This is due to the fact that the Jletltion for Allocator tiling In thc Pennsylvania Supremc Court on hchalf of Appellant has hccn dcnied and by agrccment hctwccn Gcorge Kabusk. Esquire. of the Pennsylvania Dcpartment of Transportation and Pcthloncr's allorney, Paul Bradford Orr. Esquire. Ihatthere are no further outslanding issucs for appeal. DATE: January 27, 1998 1'1Iul BradlilTd Or . Esquirc Allorncy fur LlIrry Lynn Shllulis 78 Wcst I'llInfrct Strect ClIrllsle,I'A 17013 (7 \7) 258-8558 Suprcme Court II> No, 71786 cc: Gcorgc Kllbusk, Esquirc LlIrry Shllulls