ite OFFIC PROTHOS 2019 JUN 17 AN 8: 08 COUNTY NA A. Michael Pratt (PA 44973) James E. Ellison (PA 81372) ‘Amy C. Foerster (PA 77986) Harrisburg School District Justin G. Weber (PA 89266) Office of Solicitor PEPPER HAMILTON LLP 1601 State Street Suite 200, 100 Market Street Harrisburg, Pennsylvania 17104 P.O. Box 1181 Harrisburg, PA 17108-1181 Attorney for the Harrisburg School District DAUPHI PI 717.255.1155 717.238.0575 (Fax) ‘prattam@pepperlaw.com focrstex@pepperlaw.com weberin@pepperlaw.com Joe H. Tucker, Jr., Esquire (PA 56617) ‘Tucker Law Group 1801 Market Street Suite 2500 Philadelphia, PA 19103 215.875.0609 jtucker@ulgettomeys.com Attorneys for the Commonwealth of Pennsylvania IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA INRE: APPOINTMENT OF A : CIVIL DIVISION RECEIVER FOR THE HARRISBURG: SCHOOL DISTRICT + No. 2019-CV-3960-MD. ‘STIPULATION .CTS. AND NOW, Pedro A. Rivera, Secretary of Education for the Commonwealth of Pennsylvania (“Secretary”) and the Harrisburg School District (“District”), by and through their soneundersigned counsel, hereby agree and adopt this Joint Stipulation of Facts and Authentication of Documents. 1. On December 12, 2012, then-Pennsylvania Secretary of Education, Ronald J. Tomalis, issued « Declaration of Financial Recovery Status declaring the District in ‘Moderate Financial Recovery Status as set forth in Section 621-A of the Pennsylvania Schoo! Code, 24 P.S, §6-621-A. 2, Ate and correct copy of the 2012 Declaration is attached to the Sceretary's Petition for Appointment of a Receiver (“Petition) as Exhibit 1, and constitutes a genuine and authentic copy of the same, 3. Then-Secretary Tomalis appointed Geno G. Veno to serve as the District’ Chief Recovery Officer (the “CRO”) by letter deted December 12, 2012. 4. A true and correct copy of the Veno appointment letter is attached to the Petition as Exhibit 2, and constitutes a genuine and authentic copy of the same. 5. Dr. Audrey Utley was eppointed as CRO of the District on July 6, 2015, 6. A true and correct copy of the Utley appointment letter is attached to the Petition as Exhibit 6, and constitutes a genuine and authentic copy of the same, 7. Dr. Janet Samuels was appointed CRO of the District on October 18, 2018. 8. Atrucand comect copy of Dr. Samuels” appointment letters atached to the Petition as Exhibit 10, and constitutes a genuine and authentic copy of the same. 9% The Secretary filed the Petition on June 3, 2019, in accordance with ‘Section 671-A of the Public School Code of 1949, 24 Pa, §6-671-A. 10. The District filed a Response to the Petition on June 12, 2019. soonest11, The Department of Education, with the assistance of Data Recognition ‘Corporation, reports PSSA and Keystone Exam data at the school level, as set forth on the Department of Education's publicly-accessible website at https://www. education.pa.gov/Data- 1d-Stutistics/PSS/ wult.aspx and https://www.education.pa.gov/Data-and- istics/Pa ne. ults.os 12. The percentage of the District's students scoring Proficient or Advanced on the Grade 3 Math PSSA for 2017-2018 was 16.5%, 13. The percentage of the District's students scoring Proficient or Advanced ‘on the Grade 3 ELA PSSA for 2017-2018 was 20.1%. 14. The percentage of the District's students scoring Proficient or Advanced ‘on the Grade 4 Math PSSA for 2017-2018 was 7.8%, 15. The percentage of the District's students scoring Proficient or Advanced on the Grade 4 ELA PSSA for 2017-2018 was 18.3%. 16, The percentage of the District's students scoring Proficient or Advanced ‘on the Grade 5 Math PSSA for 2017-2018 was 12.0%, 17. The percentage of the District's students scoring Proficient or Advanced ‘on the Grade 5 ELA PSSA for 2017-2018 was 19.3%. 18, The percentage of the District’s students scoring Proficient or Advanced ‘on the Grade 6 Math PSSA for 2017-2018 was 8.7%. 19, The percentage of the District’s students scoring Proficient or Advanced on the Grade 6 ELA PSSA for 2017-2018 was 21.9%. 20. The percentage of the District’s students scoring Proficient or Advanced on the Grade 7 Math PSSA for 2017-2018 was 7.3%. sone