Note : The "Case Number" Format is Type-Year-Number, Ex: AR-02-000123

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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA

CIVIL DIVISION
COVER SHEET

Plaintiff(s) CIVIL DIVISION

Allegheny County Sportsmen's
League, et al. Case Number :

GD - 94 - 001499
Type of pleading :
Concise Statement of Matters
Complained of on Appeal

Code and Classification :

Filed on behalf of
Allegheny County Sportsmen's
League
Vs
Defendant(s)
City of Pittsburgh (Name of the filing party)

✔ Counsel of Record
Individual, If Pro Se

Name, Address and Telephone Number :

Joshua Prince, Esq.
Civil Rights Defense Firm,
P.C.
646 Lenape Road
Bechtelsville, PA 19505
888-202-9297

Attorney's State ID : 306521

Attorney's Firm ID :

GD-94-001499
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[cover]
Joshua Prince, Esquire
Attorney Id. 306521
Civil Rights Defense Firm, P.C.
646 Lenape Road
Bechtelsville, PA 19505
888-202-9297 ext 81114
610-400-8439
Joshua@CivilRightsDefenseFirm.com

Attorney for Plaintiffs

IN THE COURT OF COMMON PLEAS OF ALLEGHNEY COUNTY
PENNSYLVANIA – CIVIL DIVISION

ALLEGHENY COUNTY SPORTSMEN’S :

LEAGUE, et al., :
Plaintiffs :
v. : CIVIL ACTION NO. GD-94-1499
:
CITY OF PITTSBURGH, :
Defendant. :

Plaintiff’s Concise Statement of

Matters Complained of on Appeal

Plaintiff Allegheny County Sportsmen’s League, by and through their counsel,

respectfully files the following concise statement of matters complained of on appeal in

the above-captioned matter, pursuant to the Court’s Order of December 10, 2019:

1. Whether the Court abused its discretion, committed error of law, or violated

constitutional rights of Allegheny County Sportsmen’s League by holding that

Plaintiff’s Petition for Contempt was moot, and thereafter dismissing the Petition,

due to the Court’s October 29, 2019 Opinion and Order in GD-19-5330, when,

inter alia,

a. During the May 20, 2019 status conference in Chambers, the undersigned

specifically requested that this matter be considered before GD-19-5308

and GD-19-5330, due to it being the first filed and challenging all three of
 the Ordinances in total, and the Court declared that it would consider all

three cases at the same time and not hold any decision rendered in either

of the other cases to moot or otherwise against this matter;

b. The decisions rendered in GD-19-5308 and GD-19-5330 only address the

unlawful nature of the City’s Ordinances and do not address whether the

City of Pittsburgh violated the underlying Settlement Agreement, entered

into on February 27, 1995, or this Court’s Order of February 27, 1995,

approving the Settlement Agreement; and, when

c. Allegheny County Sportsmen’s League is entitled to have its rights

determined and declared, pursuant to the Settlement Agreement and Court

Order of February 27, 2019, for which no decision has been rendered, and

thereafter, a determination on its right to attorney fees and costs for

requiring compliance with the Settlement Agreement and Court Order.

Dated: December 11, 2019 Respectfully Submitted,

Joshua Prince, Esq.

Attorney Id. No. 306521
Civil Rights Defense Firm, P.C.
646 Lenape Rd
Bechtelsville, PA 19505
888-202-9297
610-400-8439 (fax)
Attorney for Plaintiff

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 CERTIFICATE OF COMPLIANCE

I certify that this filing complies with the provisions of the Public Access Policy

of the Unified Judicial System of Pennsylvania: Case Records of the Appellate and Trial

Courts that require filing confidential information and documents differently than non-

confidential information and documents.

________________________
Joshua Prince, Esquire

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 CERTIFICATE OF SERVICE

I hereby certify that a copy of Plaintiff’s Concise Statement of Matters

Complained of on Appeal is being provided as set-forth below on December 11, 2019 to:

(via US Mail)
Judge Joseph James
Allegheny County Court of Common Pleas
708 City-County Building
414 Grant Street
Pittsburgh, PA 15219

(via email)
Yvonne Hilton, Esq.
Department of Law
313 City-County Building
Pittsburgh, PA 15219-2453
yvonne.hilton@pittsburghpa.gov
etirschwell@everytown.org
wtaylor@everytown.org
john.doherty@pittsburghpa.gov
wendy.kobee@pittsburghpa.gov
KIverson@carlsonlynch.com

________________________
Joshua Prince, Esquire

Dated: December 11, 2019