imported post
Here is Meleanie's amended complaint according to Rich Banks of PAOpenCarry.org:
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IN THE COURT OF COMMON PLEAS LEBANON COUNTY,
PENNSYLVANIA CIVIL DIVISION
Meleanie Hain, :
Appellant :
:
:
V. : No. 2008-02149
:
Michael J. DeLeo :
Sheriff of Lebanon County :
Amended Appeal of Revocation of License Issued pursuant to Pa.C.S.A. §6109
And now comes the appellant above-named, by and through her Counsel, Worth, Magee and Fisher, P.C. and files this Amended Appeal from the Decision of the Sheriff of Lebanon County to revoke the License previously issued by the Sheriff to the Appellant pursuant to §6109 of the Pennsylvania Uniform Firearms Act (“UFA”) and, in support thereof, states the following:
1. The Appellant herein is Meleanie Hain, who at all relevant times, resided in Lebanon County, Pennsylvania.
2. The Appellee is Michael J. DeLeo, Sheriff of Lebanon County, with a mailing address at Room 3, Municipal Building, 400 S. 8th Street, Lebanon, PA 17042-6794.
2. In February 2007, upon application of the Appellant, the Sheriff of
Lebanon County, after conducting the investigation set forth in §6109(d) of the UFA, issued to the Appellant a License to Carry a Concealed Firearm;
3. Thereafter, by letter dated September 17, 2008, the Sheriff purported to revoke that license. A true and correct copy of the revocation notice is attached hereto as Exhibit “A”;
4. The aforesaid revocation of the license is improper and unlawful for the following reasons:
a. The Appellant does not fall into any of the specifically enumerated categories of individuals who have lost their eligibility for the license;
b. The Appellant herein, since the issuance of the license, has not committed any act which would authorize or justify the revocation of the license;
c. Neither prior to the initial issuance of the license, nor at anytime thereafter, did the Appellant possess a character or reputation such that she would be likely to act in a dangerous manner to public safety;
d. There is no other good cause for the revocation of a license;
e. The action of the Sheriff in revoking the license is a violation of 18 Pa..C.S. §6120.
