COMMONWEALTH OF PENNSYLVANIA BEFORE THE STATE BOARD OF EDUCATION INRE: APPLICATION OF ERIE COUNTY. : Docket No. 2019-001 SEEKING TO ESTABLISH A COMMUNITY COLLEGE ANSWER TO PETITION TO INTERVENE OF CHARLES A. BENNETT Pursuant to 1 Pa. Code § 35.35, the County of Erie (“County”), by and through its undersigned counsel, files the within answer to the request to intervene filed in the format of an email by Charles A. Bennett. In support hereof, the County avers as follows: 1, Mr, Bennett's filing does not comply with the requirements of 1 Pa. Code § 35.29 insofar as it does not clearly and concisely set forth any facts from which this Board can determine any right or interest that Mr, Bennett may have to support a request to intervene. 2. Inorder to be eligible to intervene, Mr. Bennett must claim a right to intervene or an interest of such nature that intervention is necessary or appropriate to the administration of the statute under which the proceeding is brought. See 1 Pa. Code § 35.28(a), 3. Mr. Bennett has made no such claim, and consequently cannot be deemed eligible to intervene in this matter under I Pa. Code § 35.28(a). ws19546u1WHEREFORE, Erie County respectfully requests that this Board deny Charles A. Bennett’s request to intervene in this matter. Dated: January 3, 2020 ~ PQST & SCHELL, Ps a Respectfully submitted, tz, Esqt ID No. 21589 Michael W. Winfield, Esquire ID No. 72680 17 North Second Street, 12" Floor Harrisburg, PA 17101 (AD) 731-1970COMMONWEALTH OF PENNSYLVANIA, STATE BOARD OF EDUCATION INRE: APPLICATION OF ERIE COUNTY + Docket No. 2019-001 SEEKING TO ESTABLISH A COMMUNITY COLLEGE CERTIFICATE 0} CE VI Thereby certify that I have this date caused a true and correct copy of the foregoing document to be served upon the following as indicated below: Via First Class U.S. Mail, Postage Prep: ‘Thomas P. Howell, Esquire Deputy General Counsel Governor's Office of General Counsel ‘Commonwealth of Pennsylvania 333 Market Street, 17th Floor Harrisburg, PA 17101 Via Email Only: Professor Charles A. Bennett Bennett@gannon, Dated: January 3, 2020 POST & SCHELL, P.C. 17 North Second Street, 12" Floor Harrisburg, PA 17101 Telephone: (717) 612-6024 Facsimile: (717) 720-5393 MWinfield@PostSchell.com Attorneys for County of Eri