Harrisburg Answer to DCED Receivership Vacation Request

8/13/2019 Harrisburg Answer to DCED Receivership Vacation Request

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C.ALAN WALKER, in his capacity as

Secretary for the Department of

Community and Economic Development,

ANSWER TO

APPLICATION TO VACATE

RECEIVERSHIP AND OTHER RELATED MATTERS

undersigned counsel, to answer and otherwise respond to the State's request to vacateo

receivership, transfer certain authority and responsibilities to a Coordinator and otherwise


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options, a statutorily-impaired tax base, an as yet unresolved labor contractl

and a

I In January 2014, the City's firefighters, in their capacity as members of the IAFF union, rejected

proposed modifications to their Collective Bargaining Agreement. The City and union have engaged in

subsequent ongoing discussions to identify and close the gap on remaining differences.


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I '7( ~.By: lid~'v/

Neil A. Grover:0Acting City Solicitor

City of Harrisburg

Law Bureau

lO North Second St., Suite 402

Harrisburg, PAl 710 1

Telephone: 717-255-3065Fax: 717-255-3056

Email: [email protected]
mailto:[email protected]:[email protected]


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~ E r J :P a P e /1fu S { \ MayorCity of Harrisburg, Pennsylvania


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C. ALAN WALKER, in his capacity as

Secretary for the Department of

Community and Economic Development,

The undersigned hereby certifies that on this 4th

day of February, 2014,

contemporaneously with filing with the Court, I served a true and correct copy of the

foregoing ANSWER TO APPLICATION TO VACATE RECEIVERSHIP AND OTHER RELATED

via confirmed electronic mail transmission as well as via first class mail, postage prepaid upon

the individuals identified on Exhibit A hereto at the addresses indicated

// v(?

By:Nkd! ' ,/:- _-_..

Neil A. Grover, PA~3142

Acting City SoliC>itcl-

City of Harrisburg

Law Bureau

10 North Second St., Suite 402

Harrisburg, PAl 710 1

Telephone: 717-255-3065

Fax: 717-255-3056

Email: [email protected]
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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E X HIB I T A

Jarad W. Handelman Jeffrey G. Weil

First Executive Deputy General Council Cozen O'Connor

333 Market Street, 17th

Floor 1900 Market StreetHarrisburg, PA 17101 Philadelphia, PA 19103

(717)783-6563 {215 )665-5582

[email protected] (Attorneys for c. Alan Walker, DCEDSecretary)

Brain Allen Kint Neal David Colton

Cozen O'Connor Cozen O'Connor

1900 Market Street 1900 Market Street

Philadelphia, PA 19103 Philadelphia, PA 19103

(215)665-4686 (215)665-2060

(Attorneys for c.Alan Walker, DCEDSecretary) (Attorneys for c. Alan Walker, DCEDSecretary)

Eric Louis Scherling Scott. T Wyland

Cozen O'Connor Salzmann Hughes PC

1900 Market Street 105 N. Front Street, Suite 205

Philadelphia, PA 19103 Harrisburg, PA 17101

(215)665-2042 (717)249-6333

(Attorneys for C. Alan Walker, DCEDSecretary) (Attorneys for certain Suburban Municipalities)

Stephen Aaron Miller Markian Roman Slobodian

Cozen O'Connor Law Offices of Markian R. Slobodian

1900 Market Street 801 N.2nd

Street

Philadelphia, PA 19103 Harrisburg, PA 17102-3213

(215}665-2000 {717}232-5180

(Attorneys for c. Alan Walker, DCEDSecretary) (Attorneys for Ambac Assurance Corporation)

Edward Lee Stinnett, II Ronald L.Finck

Salzmann Hughes PC Mette, Evans& Woodside354 Alexander Spring Rd Ste 1 3401 N Front PO Box 5950

Carlisle, PA 17015 Harrisburg, PA 17110

(717}249-6333 {717}232-5000

(Attorneys for certain Suburban Municipalities) (Attorneys for County of Dauphin)

Mark Joachim Paul M Hummer

Arent Fox LLP Saul Ewing LLP

1050 Connecticut Ave., NW Centre Square West

Washington, DC 20036 1500 Market Street, 38th

Floor

(202)8576018 Philadelphia, PA 19102-2186

(Attorneys for Ambac Assurance Corporation) {215}972-7777

(Attorneys for Assured Guaranty Municipal Corp.)

Charles B. Zwally James S.Gkonos

Mette, Evans & Woodside Saul Ewing LLP

3401 N Front Street Centre Square West

PO Box 5950 1500 Market Street, 38th Floor

. Harrisburg, PA 17110 Philadelphia, PA 19102-2186

(717}232-5000 {215}972-8667

(Attorneys for County of Dauphin) (Attorneys for Assured Guaranty Municipal Corp.)
mailto:[email protected]:[email protected]


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Matthew M Haar Joseph Krolikowski

Saul Ewing LLP McKenna Long & Aldridge LLP

Centre Square West 303 Peachtree Street, Suite 5300

1500 Market Street, 38th Floor Atlanta, Georgia 30308

Philadelphia, PA 19102-2186 Phone: (404)527-4000

(215)972-7777 Fax: (404)527-4198

(Attorneys for Assured Guaranty Municipal Corp.) (Attorneys for Williams B Lynch in his official

capacity as Receiver for City of Harrisburg)

Christopher R Sullivan Thurbert Baker

Deputy General Counsel McKenna Long & Aldridge LLP

Office of General Counsel 303 Peachtree Street, Suite 5300

333 Market Street, 17th Floor Atlanta, Georgia 30308

Harrisburg, PA 17101 Phone: (404)527-4000

Phone: (717)787-9342 Fax: (404)527-4198

Fax: (717)787-1788 (Attorneys for Williams B Lynch in his official

(Attorneys for Williams B Lynch in his official capacity as Receiver for City of Harrisburg)capacity as Receiver for City of Harrisburg)

B.Summer Chandler Gregory Brow

McKenna Long & Aldridge LLP McKenna Long & Aldridge LLP

303 Peachtree Street, Suite 5300 303 Peachtree Street, Suite 5300

Atlanta, Georgia 30308 Atlanta, Georgia 30308

Phone: (404)527-4000 Phone: (404)527-4000

Fax:(404)527-4198 Fax: (404)527-4198

(Attorneys for Williams B Lynchin his official (Attorneys for Williams B Lynch in his official

capacity as Receiver for City of Harrisburg) capacity as Receiver for City of Harrisburg)

Mark Kaufman

McKenna Long & Aldridge LLP

303 Peachtree Street, Suite 5300Atlanta, Georgia 30308

Phone: (404)527-4000

Fax: (404)527-4198

(Attorneys for Williams B Lynch in his official

capacity as Receiver for City of Harrisburg)

Documents

Harrisburg Answer to DCED Receivership Vacation Request