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HomeMy WebLinkAbout95-04843 , . \i\WIfM"opI me' 4111.~1 . . COMMONWEALTH OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 85- ',r V :'J CIVIL TERM APPEAL FROM SUSPENSION VI. DAVID P. WAGNER, Defendlnt/Petltloner ~ AND now this _( ~ . , 1995, upon consideration day 01 of the foregoing Petition for Appeal from the Orde of the Director of the Bureau of Driver Ucenslng, Department of Transportation, suspending temporary privileges of David P. Wagner, and on the Motion of Carol J. Undsay, Esquire, attorney for David P. Wagner, a hearing Is granted de novo to determine whether the Petitioner Is subject to suspension of his operating privileges. This Appeal shall act as a supersedeas of the suspension. 11<-- (\, / . . ) A hearing set for the (J 7 day of l,tfo Iuv, 1995, In Court Room No. ~ '1 at the Cumberland County Court House in Carlisle, Pennsylvania at I tJ.. P?J o'clock A~.M. By the Court, S~)1 ~~ O~ b J. , ,'0:\.......'..,.. Ole, 4111."-01 ., , . VI. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 85- 'If'l,) CIVIL TERM COMMONWEALTH OF PENNSYLVANIA DAVID P. WAGNER, Defendant/Petitioner APPEAL FROM SUSPENSION NOW comes David P. Wagner, by and through his counsel, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C., and petitions this Honorable Court as follows: 1. Petitioner resides at 350 Carlisle Road, Newville, Cumberland County, Pennsylvania. 2. Petitioner Is duly licensed driver of motor vehicles with an Operator's License No. 19326426. 3. On August 8, 1995, the Director of the Bureau of Driver Licensing suspended Petitioner's operating privileges effective September 12, 1995 under authority of Section 1547 of the Vehicle Code. 4. The said Order Is Illegal, arbitrary, unreasonable and an abusive discretion In contrary to law In that the Petitioner did not give a valid refusal to chemical testing. WHEREFORE, Petitioner prays this Honorable Court to allow this Appeal, and to hold a hearing de novo to determine whether Petitioner Is subject to suspension of operating privileges, . . .11\......'..,.. ru., 4111."-01 and that upon conclusion thereof, the Order of the Director of Driver Licensing be vacated, and the Appeal sustained. FLOWER, MOROENTHAL FLOWER. LINDSAY, P.C. Attorn'VI for Dlf.ndlnt/p.tltlonlr By: Ia'ifg €~r~~dSaY, Esquire ID I 44693 11 East High Street Carlisle, PA 17013 (717) 243.5513 Date: 1/lI/tj~ 2 . , . o:\......"..pl Rio' 4111."-01 COMMONWEALTH OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 85. 'I r'l J CIVIL TERM VI. DAVID P. WAGNER, Defendant/Petitioner APPEAL FROM SUSPENSION ~ AND now, this II day Of"~J/r'17I.H~, 1995, I, Carol J. Lindsay, Esquire, of the law firm of FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys, hereby certify that I served the within Petition for Appeal from the Order of the Director of the Bureau of Driver Licensing, Suspending Operating Privileges this day by depositing same In the United States Mall, First Class, Postage Prepaid, In Carlisle, Pennsylvania, addressed to: Douglas K. Tobin, Director Bureau of Driver Licensing Commonwealth of Pennsylvania Department of Transportation Harrisburg, PA 17123 FLOWER, MORGENTHAL FLOWER. LINDSAY Attorn'YI for O.f.ndant/p.tltloner By: arol J. Lindsay, Esquire -ID I 44693 11 East High Street Carlisle, PA 17013 (717) 243.5513 ..J ~ ~ J ~ ~ ',. .,. ~ c ., 'n' .p. It lR e IR '" ~'... "'.- I"':!~ t,.It'l.,I:O-Z ~:r.f,:.t" ~...:,?C ..... 't__1":. " ~~ ! " .'~ " ~ "....,' I,.. 'I. ',~ or ;~.r'.'!.~ ;,,1 I'. :. II.,...) '" - - Jl OCT Z i Ij 04 PH '95 I .\1\'1 . I -+