REQUEST FOR STAY OF ENFORCEMENT PENDING REVIEW

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/court has jurisdiction to stay enforcement under [rule/statute].
• For Pennsylvania matters, cite 2 Pa.C.S. 504 or Pa.R.A.P. 1781 (supersedeas from Commonwealth Court).

3. STANDARD FOR STAY

• Applicable standard (see Pa.R.A.P. 1781): (1) likelihood of success on the merits; (2) petitioner will suffer irreparable harm if stay is denied; (3) grant of stay will not substantially harm other parties; (4) grant of stay will not adversely affect the 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.