IN THE COMMONWEALTH COURT OF In Re: Appointment of a Receiver for the School District for the City of York Appeal of: Nikol Y. Baxter, Nena Gilbert, Margaret and David ES. . Gotwald, HI, Tanisha Harris, Richard Horn, Wayne Lehr, Jr, Sokha Uk, James and Sarah Montgomery, Ornayra Morales, 4.- o??pf?l? . . Horatio Roberson, Otina Rosario, Rachel . ?31 Tyson No. 2276 CD. 201Ar In Re: Appointment of a Receiver for the School District for the City of York so 3? Appeal of: The School District of the City Of York No. 2340 CD. 2014 In Re: Appointment of a Receiver for the School District for the City of York Appeal of: York City Education Assn, and York City Educational . Professionals Assn, PSEAJNEA No. 2352 CD. 2014 MOTION ON CONSENT FOR EXTENSION OF TIME IN WHICH FILE BRIEF Appellant, School District of the City of York (?District?), by undersigned counsel, pursuant to Rule 123 of the Rules of Appellate Procedure, with the consent of all parties, files this Motion on Consent for Extension of Time in Which to File Appellants? Briefs and in support thereof aver as follows: 1. On December 12, 2012, then Secretary of Education, Ronald J. Tomalis, issued a Declaration that the District was in financial recovery status and appointed David G. Meckley (?Mix Meckley?) to serve as Chief Recovery Of?cer for the District.? 2. On December 1, 2014, Carolyn C. Dumaresq, the Acting Secretaryr of Education (?Appellee? or ?Secretary?), ?led a Petition for the Appointment of a Receiver to assume oversight and control with regard to the District?s schools. As required by 24 RS. a hearing was scheduled on the Petition on December 4, 2014. The hearing concluded on December 16, 2014. On December 26, 2014, the Court of Common Pleas for York County entered an Order declaring the District to be in receivership and appointing Mr. Meckley as Receiver. 0n the same day, the District filed an appeal of the trial court?s decision to this Court. 3. On February 12, 2015 this Court entered an order consolidating the . above appeals and provided for Appellants to ?le their briefs on or before March 24, 2015. 4. Recently, the District and Appellee have begun discussions with the intent of resolving this matter in a manner which will be acceptable to all parties. The District and Appellee are optimistic that the discussions will be fruitful. 5. The legal and practical issues entailed in resolution of this matter are complex; therefore, the parties believe it is in the interests of all that their efforts be focused on a resolution of a matter of public import. 6. All parties to this appeal have agreed that it is in the best interests of the litigants and the public for brie?ng on this matter to be delayed until May 29, 2015 in order to permit the parties sufficient time in which to resolve this matter, With the Memorial Day weekend in mind, the parties request that the Appellants briefs be due no later than May 29, 2015, which is more than sixty (60) days. WHEREFORE, the Appellant, the School District of the City of York, with the consent of all parties, respectfully requests that this Court enter an Order declaring that all Appellants? briefs and the reproduced record shall be ?led on May 29, 2015. Respectfully submitted, Date: February 24, 2015 Marc G. Tarlow (ID. #23474) Michael E. Rowan (ID. #85818) Shumaker Williams, RC. 96 3. George Street, Suite 200 York, 17401 848?5134 717? 8486125 (Facsimile) Attorneys for School District of the City of York 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24th day of February, 2015, copies of this Motion on Consent for Extension of Time in Which to File Appellants? Briefs were mailed, first-class, postage prepaid, and sent via electronic mail, which service satis?es the requirements of 121, to: Clyde W. Vedder, Esquire Morris Vedder, LLP 32 N. Duke Street York, 17405 717-843-9815 CWVedder@morriS?veddercom Attorney for Appellee Thomas W. Scott, Esquire Killian Gephart, LLP 218 Pine Street Harrisburg, 17108 717?232-1851 tscott@killiangephart.oom Attorney for York City Education Association and York City Education Support Professionals Association and Sandra Thompson, Esquire 351 East Princess Street York, PA 17405 sthompsonllo@gmail.com Attorney for York NAACP, Nikol Y, Baxter, Nana Gilbert, Margaret and David ES. Gotwald, Tanisha Harris, Richard Horn, Wayne Lehr, Sokha Uk, James and Sarah Montgomery, Omayra Morales, Horatio Roberson, Otina Rosario, Rachel Tyson and by ?rst class mail, postage prepaid to: Kathleen Kane, Attorney General Of?ce of the Attorney General Strawberry Square Harrisburg, 17120 Marc G. #23474) Shumaker Williams, RC. 96 S. George Street, Suite 200 York, 17401 1117- 8485134 717? 8486125 (F aesimile) mtarlow@shumakerwilliams.com Attorney for School District of the City of York IN THE COURT OF In Re: Appointment of a Receiver for the School Distiict for the City of York Appeal of: York NAACP, Nickel Y. Baxter, Nana Gilbert, Margaret and David ES. Gotwald Tanisha Harris, Richard Horn, Wayne Lehr I Sokha Uk, James and Sarah Montgomery, Omaya?a Morales, Horatio Roberson, Otina CASES CONSOLIDATED Rosario, Rachel Tyson No. 2276 CD. 2014, In Re: Appointment of a Receiver for the School District of the City of York Appeal of: The School District of the I City onork No. 2340 CD. 2014 In Re: Appointment of a Receiver for the School District of the City of York Appeal of: York City Education Association, and York City Educational Support . Professionals Association, PSEAJNEA No. 235 2 CD, 2014 ORDER NOW, March 3, 2015, upon consideration of the School District of the City of York?s unopposed application for extension of time to file all appellants? briefs and the reproduced record} the application is granted. All appellants? briefs and the 1'ep1'0duced record shall be ?led on or before May 29, I W?sley Ole??, Se'?ie?? Judge Seemed from the Record MAR 04 2015 And Order Exit