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Home Court filings Children's Health Defense, Inc. v. Rutgers — U.S. District Court, D.N.J. Notice of Motion for TRO — Children's Health Defense v. Rutgers

Court filing

Notice of Motion for TRO — Children's Health Defense v. Rutgers

Summary

A Notice of Motion for Temporary Restraining Order pursuant to Fed. R. Civ. P. 65, Document 10, filed 08/30/21 in Children's Health Defense, Inc., et al. v. Rutgers, The State University of New Jersey, et al., Case No. 3:21-cv-15333 (ZNQ-TJB), in the United States District Court for the District of New Jersey. It states that Plaintiffs Children's Health Defense, Inc. and Adriana Pinto will apply for emergency relief under 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 terms of Rutgers University Policy Section 10.3.14 on COVID-19 vaccination requirements and exemptions. A certification of service lists a legal memorandum, declarations and a proposed order. It is dated August 30, 2021 and signed s/ Julio C. Gomez.

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Filed August 30, 2021 in Childrens Health Defense v. Rutgers; one of 35 filings from this case.

Record facts

Filed2021-08-30

Cite this document

“Notice of Motion for TRO — Children's Health Defense v. Rutgers.” Original at archive.org, No. 3:21-cv-15333-ZNQ-TJB, Doc. 10, filed 2021-08-30. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/childrens-health-defense-v-rutgers/2021-08-30-motion-tro-notice/, SHA-256 fe6298f3d817ad8092d90382a5690475ce83fc85383edee7e55ab65f927b0e7d.

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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

 
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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

 
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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

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Our copy
gov.uscourts.njd.480171.10.0.pdf
Original
archive.org
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