APPLICATION FOR STAY OF AGENCY ENFORCEMENT

Filing Overview

• Applicant: [NAME/ENTITY], Contact: [ADDRESS/EMAIL/PHONE]
• Agency action: [ORDER/NOTICE], Date: [DATE], Docket/Ref: [ID]
• Parallel proceedings: [ADMIN APPEAL/JUDICIAL REVIEW pending?]

Requested Relief

Stay enforcement of the [ORDER/NOTICE] pending [administrative appeal/judicial review] under [CITE AGENCY RULE / PENNSYLVANIA ADMINISTRATIVE AGENCY LAW (2 Pa.C.S. 504)].

Proposed Order (summary)

• Stay effective upon filing/court grant until final disposition of [appeal/review].
• Maintain status quo; no penalties/collection during stay.

Argument (outline)

1) Likelihood of success / substantial questions: [Key legal/factual grounds].
2) Irreparable harm: [Non-compensable harms, business closure risk, reputational harm, safety, etc.].
3) Balance of equities: [Compare harms to applicant vs. agency/public].
4) Public interest: [Compliance pathway, safety, continuity of service, consumer protection].

Evidence (attach as exhibits)

• Agency order/notice and record excerpts.
• Declarations on harm and compliance steps.
• Financial/operational impact evidence.

Practice Notes

• Under 2 Pa.C.S. 504, the filing of a petition for review does not automatically stay the agency action.
• A supersedeas (stay) may be sought from the Commonwealth Court.