IN THE DISTRICT COURT IN AND FOR TULSA COUNTY, STATE OF OKLAHOMA DONALD BAKERxxxxxxxxxxxxxx, PLAINTIFF ) ) VS ) ) STATE OF OKLAHOMA ) Ex rel
. DEPARTMENT OF ) PULBIC SAFETY, ) DEFENDANT ) Case No.
PETITION FOR HEARING OF DRIVER’S LICENSE SUSPENSION COMES NOW, Plaintiff, Donald Bakerxxxxxxxxxxx, and petitions this Court to0 conduct a hearing on suspension and in support of his Petition, alleges the following: 1. Plaintiff was stopped while driving his car on November 6, 2004 by Tulsa Police Department Officer M.A. Moorexxxxx, and was subsequently tested by breathalcohol analysis for alcohol concentration. 2. Plaintiff tested over .10, at which time Plaintiff’s license was taken by the officer, and Plaintiff was issued a Notice of Revocation of Driver’s License and a temporary license, which is effective for thirty (30) days, after which time Plaintiff’s license was to be revoked for six (6) months, pursuant to 47 O.S., sec. 754. 3. Plaintiff subsequently applied for an Administrative Hearing with the
Department of Public Safety, at which time Plaintiff’s driving privileges or Plaintiff’s Revocation was stayed pending the outcome of the Administrative Hearing. 4. The Administrative Hearing was held on December 18, 2004xxxxxxx, at which time the Hearing Officer sustained the Order of the Commissioner of Public
Safety, and the Plaintiff’s driving privileges were ordered revoked for a period of 180 days, beginning January 14, 2005. 5. This is Plaintiff’s first alcohol related offense. 6. Plaintiff is employed by the National Guard and has to travel to different locations and will sufferer extreme and unusual hardship unless the revocation of his driving license is modified to allow him to drive during the revocation period. WHEREFORE, premises considered, Plaintiff prays this Court to strike the suspension of his driver’s license..
__________________________ Bruce Edge, OBA# 18697 717 S. Houston, Suite 500 Tulsa, OK 74127 (918) 582-6333 Attorney for Plaintiff