REQUEST FOR STAY OF ENFORCEMENT PENDING REVIEW

TABLE OF CONTENTS

1. Preliminary Statement
2. Procedural Posture
3. Standard for Stay
4. Argument (Stay Factors)
5. Bond/Conditions (if applicable)
6. Relief Requested
7. Signature

1. PRELIMINARY STATEMENT

• Petitioner requests a stay of the Agency’s [Decision/Order] dated [DATE] pending [reconsideration/appeal] to prevent irreparable harm.

2. PROCEDURAL POSTURE

• Petition/appeal filed on [DATE] under [citation]; agency has jurisdiction to stay enforcement under [rule/statute].

3. STANDARD FOR STAY

• Applicable standard: [cite agency rule/case law] (likelihood of success, irreparable harm, balance of harms, public interest).

4. ARGUMENT (STAY FACTORS)

• Likelihood of success: [Summarize key merits points].
• Irreparable harm: [Describe imminent harms not compensable by money—license suspension, business shutdown, reputational harm].
• Balance of harms: [Explain harms to Petitioner outweigh any harm to agency/others].
• Public interest: [Explain alignment with public interest/safety/fairness].

5. BOND/CONDITIONS (IF APPLICABLE)

• Petitioner is [willing/unwilling] to post bond or comply with conditions: [Describe proposed conditions].

6. RELIEF REQUESTED

• Enter an order staying enforcement of the [Decision/Order] pending final disposition of the [reconsideration/appeal].

7. SIGNATURE

• Signature block for Petitioner or counsel.