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FAEGRE DRINKER BIDDLE & REATH, LLP
Jeffrey S. Jacobson
Andrew B. Joseph
Kristen N. Roshto
600 Campus Drive
Florham Park, New Jersey 07932
(973) 549-7000
(973) 360-9831 (fax)
Jeffrey.Jacobson@faegredrinker.com
Andrew.Joseph@faegredrinker.com
Kristen.Roshto@faegredrinker.com
Attorneys for Rutgers, The State University of New Jersey, et al.
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEW JERSEY
CHILDREN'S HEALTH DEFENSE, INC., Civil Action No. 3:21-cv-15333-ZNQ-TJB
PETER CORDI, RAELYNNE MILLER,
KAYLA MATEO, ADRIANA PINTO, JAKE
BOTHE, AND DOES 1-13,
Civil Action
(Document Filed Electronically)
Plaintiffs, STIPULATION AND PROPOSED
ORDER
v.
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,
Defendants.
It is hereby stipulated and agreed by and between the attorneys for Plaintiffs Children's
Health Defense, Inc., Peter Cordi, Raelynne Miller, Kayla Mateo, Adriana Pinto, Jake Bothe, and
Does 1-13 ("Plaintiffs"), and Defendants Rutgers, The State University of New Jersey, Board of
Governors, Rutgers, School of Biomedical and Health Sciences, Chancellor Brian L. Strom, and
President Jonathan Holloway ("Defendants") that Plaintiffs will file an amended complaint by
October 19, 2021.
The parties also propose the following briefing schedule for Defendants' anticipated
motion to dismiss the amended complaint:
1. Defendants will file the motion to dismiss by November 19, 2021;
2. Plaintiffs will oppose the motion to dismiss by December 31, 2021;
3. Defendants will reply to Plaintiffs' opposition by January 14, 2022.
Separately, Defendants anticipate filing a motion requiring any and all "Doe" plaintiffs to
comply with Fed. R. Civ. P. 10(a) (i.e., to sue in their real names). That motion is unaffected by
this stipulation and will briefed in the regular course.
GOMEZ LLC ATTORNEY AT LAW FAEGRE DRINKER BIDDLE & REATH,
LLP
By: /s/ [signature] By: /s/ Jeffrey S. Jacobson
Julio C. Gomez Jeffrey S. Jacobson
Dated: October 6, 2021 Dated: October 6, 2021
SO ORDERED this ____ day of ____, 2021.
Hon.
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