Court filing
Notice of Motion for TRO — Children's Health Defense v. Rutgers
Filed August 30, 2021 in Childrens Health Defense v. Rutgers; one of 33 filings from this case.
Record facts
| Filed | 2021-08-30 |
|---|
No. 3:21-cv-15333-ZNQ-TJB · Doc. 10 · 2021-08-30 · Docket on CourtListener
Full text
Julio C. Gomez, Esq. GOMEZ LLC ATTORNEY AT LAW 1451 Cooper Road Scotch Plains, NJ 07076 Tel 908.789.1080 Fax 908.789.1081 Attorney for Plaintiffs UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY CHILDREN’S HEALTH DEFENSE, INC., PETER CORDI, RAELYNNE MILLER, KAYLA MATEO, ADRIANA PINTO, JAKE BOTHE, AND DOES 1- 13, Case No. 3:21-cv-15333 (ZNQ-TJB) Plaintiffs, NOTICE OF MOTION FOR TEMPORARY -against- RESTRAINING ORDER PURSUANT TO RUTGERS, THE STATE UNIVERSITY OF NEW JERSEY, BOARD OF GOVERNORS, RUTGERS SCHOOL OF BIOMEDICAL AND HEALTH SCIENCES, CHANCELLOR BRIAN L. STROM, PRESIDENT JONATHAN HOLLOWAY, in their official capacities. FED. R. CIV. P. 65 Defendants PLEASE TAKE NOTICE that on Monday, August 30, 2021, or thereafter and as soon as this Court will allow, Plaintiffs Children’s Health Defense, Inc. and Adriana Pinto, through their undersigned attorney, shall Case 3:21-cv-15333-ZNQ-TJB Document 10 Filed 08/30/21 Page 1 of 3 PageID: 117 2 make application to this Court for emergency relief pursuant to Fed. R. Civ. P. 65 and L. Civ. R. 65.1, seeking a temporary restraining order and/or preliminary injunction requiring Defendants to comply with the express terms of their own policy, Rutgers University Policy Section 10.3.14 concerning mandatory requirements and exemptions for COVID-19 vaccination. Copies of Plaintiffs’ moving papers shall have been served on opposing counsel contemporaneously with this notice and with Plaintiffs’ application to the Court. Dated: August 30, 2021 GOMEZ LLC ATTORNEY AT LAW By: s/ Julio C. Gomez Julio C. Gomez, Esq. 1451 Cooper Road Scotch Plains, NJ 07076 Tel 908.789.1080 Fax 908.789.1081 jgomez@gomezllc.com Attorney for Plaintiffs Case 3:21-cv-15333-ZNQ-TJB Document 10 Filed 08/30/21 Page 2 of 3 PageID: 118 3 CERTIFICATION OF SERVICE I hereby certify that on this same date, I electronically filed the foregoing Notice of Motion For Temporary Restraining Order Pursuant to Fed. R. Civ. P. 65 and L. Civ. R. 65.1, a Legal Memorandum in support of the motion, Declarations of Counsel and Plaintiff Adriana Pinto with supporting exhibits, and a Proposed form of Order on behalf of Plaintiffs Childrens’ Health Defense, Inc. and Adriana Pinto with the Clerk of the Court using the CM/ECF system, which shall forward a true copy of same to all counsel and parties participating therein for this matter. I also certify that on this same date, I served all of the foregoing to the following attorney for Defendants via e-mail: Steve Nolan, Esq. (snolan@ogc.rutgers.edu) Associate Vice President and Deputy General Counsel Office of the Senior Vice President and General Counsel Rutgers, The State University of New Jersey 335 George Street – Suite 2160 New Brunswick, NJ 08901 Tel:848-932-7697 Dated: August 30, 2021 GOMEZ LLC ATTORNEY AT LAW By: s/ Julio C. Gomez Julio C. Gomez, Esq. Case 3:21-cv-15333-ZNQ-TJB Document 10 Filed 08/30/21 Page 3 of 3 PageID: 119
File and source
- File
- gov.uscourts.njd.480171.10.0.pdf
- Size
- 170,144 bytes
- SHA-256
- fe6298f3d817ad8092d90382a5690475ce83fc85383edee7e55ab65f927b0e7d
- Our copy
- gov.uscourts.njd.480171.10.0.pdf
- Original
- archive.org