PETITION OF by tLGoNhJ

VIEWS: 13 PAGES: 5

									              IN THE CIRCUIT COURT FOR           COUNTY, MARYLAND

PETITION OF              :

     :

FOR JUDICIAL REVIEW OF THE                   :
DECISION OF THE MOTOR VEHICLE
ADMINISTRATION                               :
6601 Ritchie Highway, N.E.                       Civil Action No.
Glen Burnie, Maryland 21062                  :

IN THE CASE OF    :
Office of Administrative Hearings
Soundex:            :
Case No.:

                     PETITION FOR JUDICIAL REVIEW

     COMES NOW the Petitioner, , by and through his attorneys,

GOLDSTEIN   &   STAMM,       P.A.,   and   pursuant   to   Annotated   Code   of

Maryland, Transportation Article, §§ 12-209, 16-205.1 (j), Maryland

Rule 7-201, et. seq., and State Government Article, § 10-201, et.

seq., states as follows:

     1.     That the Petitioner is requesting judicial review of the

decision of the Office of Administrative Hearings on ,               2004 where

the Petitioner's driver's license/privilege was              for .

     2.     That the Petitioner was a party to the agency proceeding.
    WHEREFORE, the Petitioner requests this Court reverse or

modify the decision of the Office of Administrative Hearings.

                              GOLDSTEIN & STAMM, P.A.



                              By:
                              LEONARD R. STAMM
                              Capital Office Park
                              6301 Ivy Lane, Suite 504
                              Greenbelt, Maryland 20770
                              301-345-0122
                                 LAW OFFICES
                         GOLDSTEIN & STAMM, P.A.
                               CAPITAL OFFICE PARK

                             6301 IVY LANE, SUITE 504

                         GREENBELT, MARYLAND 20770


                                  (301) 345-0122
                                FAX (301) 441-4652
ALAN J. GOLDSTEIN           EMAIL LSTAMM@LSTAMM.COM
  (1942-1991)               HTTP://WWW.LSTAMM.COM
LEONARD R. STAMM
   ---------
MD & DC BAR                        , 2004


Alice Brown, Chief
Administrative Adjudication Division
Motor Vehicle Administration
6601 Ritchie Highway
Glen Burnie, Maryland 21062

Re:
Soundex:

Dear Ms. Brown:

     I am writing you pursuant to Maryland Annotated Code,
Transportation Article §§ 12-209(c) and 16-205.1 (m), and COMAR,
Department of Transportation Regulations, § 11.11.03.12, to request
a stay of enforcement of the administrative law judge’s suspension
of my client’s license for a period of , issued on , 2004.

     Enclosed please find a copy of the Petition for Judicial
Review that I filed with the Circuit Court for County today.

     For the reasons set forth below, my client will be irreparably
injured without the issuance of a stay, and the issuance of a stay
is not contrary to public safety:

        We believe the appeal is meritorious because ..........My
        client is a salesman for a pharmaceutical company and
        needs his license in the course of his employment. This
        is his first alleged refusal and drinking driving
        incident.    Additionally, he has been evaluated by
        ............., in ..........., Maryland, as a .....
        drinker and has enrolled in their .... week ......
        course.
                            2
    Thank you for your immediate attention to this matter.

                             Very truly yours,



                             LEONARD R. STAMM
LRS:kao
Enclosure

								
To top