Opinion
NO. 7 JD 15
12-21-2016
Samuel C. Stretton, Esquire Attorney for Respondent/Appellant, Thomasine Tynes 301 South High Street P.O. Box 3231 West Chester, PA 19381 (610) 696-4243 Attorney I.D. #18491
MOTION OF THE RESPONDENT , THOMASINE TYNES, TO STAY THE REMOVAL ORDER OF DECEMBER 16, 2016 AND TO ALLOW MEDICAL BENEFITS TO CONTINUE PENDING THE APPEAL
The Respondent, Thomasine Tynes, by and through her counsel, Samuel C. Stretton, Esquire, respectfully requests this Honorable Court stay the removal Order dated December 16, 2016 and allow medical benefits to continue pending the appeal for the following reasons:
1. On December 16, 2016, the Court of Judicial Discipline, by Order removed Thomasine Tynes.
2. Mr. Stretton has filed an appeal to the Pennsylvania Supreme Court on the sanction issue.
3. Thomasine Tynes was receiving her pension and was still receiving her medical benefits.
4. Since Mr. Stretton has filed an appeal, he asks that the operation of the Order removing Thomasine Tynes be stayed pending the appeal. Thomasine Tynes is asking that the Order be stayed so she can continue to receive her pension pending the resolution and her medical benefits.
WHEREFORE, Samuel C. Stretton, Esquire, respectfully requests the Court of Judicial Discipline stay the December 16, 2016 Order pending the appeal so Thomasine Tyne can continue to receive her pension and medical benefits for the reasons above stated.
Respectfully submitted,
/s/_________
Samuel C. Stretton, Esquire
Attorney for Respondent/Appellant,
Thomasine Tynes
301 South High Street
P.O. Box 3231
West Chester, PA 19381
(610) 696-4243
Attorney I.D. #18491
SUPREME COURT DOCKET #:
CERTIFICATE OF SERVICE
I hereby certify I am this date serving a copy of the foregoing Motion to Stay of the Respondent, Thomasine Tynes, in the captioned matter upon the following persons in the manner indicated below.
Service by First Class Mail addressed as follows:
1. James P. Kleman, Jr., Esquire
Deputy Counsel
Judicial Conduct Board
Pennsylvania Judicial Center
601 Commonwealth Ave., Suite 3500
P.O. Box 62525
Harrisburg, PA 17106
2. Honorable Thomasine Tynes
12/21/16River Park House Condominiums
Unit 1905
3600 Conshohocken Avenue
Philadelphia, PA 19131
Date
Respectfully submitted,
/s/_________
Samuel C. Stretton, Esquire
Attorney for Respondent/Appellant,
Thomasine Tynes
301 S. High St., P.O. Box 3231
West Chester, PA 19381-3231
(610) 696-4243
Attorney I.D. No. 18491