DR. SUSAN M. KEGERISE, Plaintiff CIVIL ACTION No. 1:14-CV-00747-WWC V. SUSQUEHANNA TOWNSHIP SCHOOL DISTRICT, CAROL L. KARL, JESSE RAWLS, SR., and MARK Y. SUSSMAN, JURY TRIAL DEMANDED Defendants DEFENDANTS' MOTION TO LIFT STAY OF PROCEEDINGS AND NOW, come the Defendants, Susquehanna Township School District, Carol L. Karl, Jesse Rawls, Sr., and Mark Y. Sussman, by and through their attorneys, Latsha Davis & McKenna, P.C. and file the within Motion to Lift the Stay of Proceedings stating as follows; On April 17, 2014, Plaintiff commenced this action by filing a Complaint. 476486V1 1 Case 1:14-cv-00747-WWC Document 15 Filed 09/05/14 Page 1 of 5 On May 13, 2014, Plaintiff filed an Amended Complaint. 2. On July 5, 2014, Defendants filed a Motion to Dismiss Plaintiffs 3. Amended Complaint pursuant to F.R.C.P. 12(b)(6). 4. After the filing of Defendants' Motion to Dismiss, the parties agreed to attempt to mediate this dispute. 5. Accordingly, the parties desired to stay all proceedings on this docket, including the requirement that Defendants file their Brief in Support of Their Motion to Dismiss. On July 29, 2014 Defendants filed a Motion to Stay the Proceedings 6. on this docket. On July 30, 2014 Defendants' Motion to Stay was granted and the 7. supporting Order was issued. g On August 18, 2014 Plaintiff and Defendants participated in a mediation in an unsuccessful attempt to resolve the claims set forth in Plaintiffs Amended Complaint. Accordingly, the parties now desire that the stay on the docket be lifted and that the Court issue a scheduling order setting forth appropriate case deadlines. 10. The undersigned counsel for Defendants certifies that he contacted Plaintiffs counsel and that Plaintiffs counsel concurs in this Motion. 476486v1 2 Case 1:14-cv-00747-WWC Document 15 Filed 09/05/14 Page 2 of 5 WHEREFORE, Defendants, Susquehanna Township School District, Carol L. Karl, Jesse Rawls, Sr., and Mark Y. Sussman, respectfully request that this Honorable Court enter an Order lifting the stay of the proceedings in this matter. 476486v1 3 Case 1:14-cv-00747-WWC Document 15 Filed 09/05/14 Page 3 of 5 Respectfully submitted. LATSHA DAVIS & McKENNA, P.C. Dated; September 5,2014 By: /S/ Carles ha Green Halkias Glenn R. Davis AttyLD. No. 31040 gdavis@ldvlaw.com Andrew P. Dollman AttyLD. No. 209466 adollman@ldvlaw.com Carlesha Green Halkias Atty. I.D.No. 200751 chalkias@ldvlaw.com 1700 Bent Creek Boulevard, Suite 140 Mechanicsburg, PA 17050 (717) 620-2424 fax: (717) 620-2444 Attorneys for Defendants 476486v1 4 Case 1:14-cv-00747-WWC Document 15 Filed 09/05/14 Page 4 of 5 CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing Defendants' Motion to Lift Stay of Proceedings was served via electronic filing upon the following: Jason P. Kutulakis, Esquire Abom & Kutulakis, LX.P- 2 West High Street Carlisle, PA 17013 Attorney for Plaintiff Dated: September 5, 2014 /S/Carlesha Green Halkias Carlesha Green Halkias 476486v1 5 Case 1:14-cv-00747-WWC Document 15 Filed 09/05/14 Page 5 of 5 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA DR. SUSAN M. KEGERISE, Plaintiff CIVIL ACTION No. 1:14-CV-00747-WWC V. SUSQUEHANNA TOWNSHIP SCHOOL DISTRICT, CAROL L. KARL, JESSE RAWLS, SR., and MARKY. SUSSMAN, JURY TRIAL DEMANDED Defendants ORDER AND NOW, this day of 2014, upon consideration of Defendants' Motion to Lift the Stay of Proceedings, said Motion is GRANTED. It is ORDERED that the Stay is lifted. Defendants will file their Brief in Support of Motion to Dismiss within five (5) days if the date of this Order. BY THE COURT: 476466v2 Case 1:14-cv-00747-WWC Document 15-1 Filed 09/05/14 Page 1 of 1
Tickler: Unenforceable Contracts, Statute of Frauds G.R. No. L-5447 March 1, 1910 PAUL REISS, ET AL., Plaintiffs-Plaintiffs, JOSE M. MEMIJE, Defendant-Defendant