You are on page 1of 6

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
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