In the 54-page petition, HSP seeks an order requiring the three entities "to comply with their duties to implement the decision by the Pennsylvania Gaming Control Board to locate a Category 2 gaming facility" on HSP's site. It notes that the PGCB has sole jurisdiction in this matter, a condition that has been reiterated in Rendell previous court decisions and by Gov. Ed. The PGCB awarded the two licenses designated for Philadelphia to SugarHouse and Foxwoods.

HSP charges that "the City Council has continued to refuse to implement the gaming board's decision by failing to designate the approved zoning…and has defied the decision of the (PCBG), as upheld by this court." It notes that the City Council "has thrown roadblocks in the orderly development" of gaming in the city and "intentionally delayed" the necessary approvals and permits.

In the application for summary relief, HSP calls for an expedited briefing schedule on its petition for review and asks the court to appoint a master with jurisdiction over the matter. It also calls for a writ of mandamus, which is a court mandate, or an injunction that would require the planning commission to enact bills covering the necessary approvals and permits within 10 days of a court order.