Professional Documents
Culture Documents
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No.
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Plaintiff,
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vs.
SYLVIA MATHEWS BURWELL, in her
official capacity as U.S. Secretary of
Health and Human Services; Marilyn
Tavenner, as Administrator of the Centers
for Medicare & Medicaid Services; and
Cara M. Christ, as Director of the Arizona
Department of Health Services,
Defendant.
TO DEFENDANTS AND THEIR COUNSEL:
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Cochise Regional Hospital (CRH), in the courtroom of an Article III Judge of this
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Court as yet to be determined, will and hereby do apply pursuant to Rule 65 of the
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Federal Rules of Civil Procedure and Local Rule 65-1 for a temporary restraining order
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and order to show cause why a preliminary injunction should not be issued against
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Sylvia Mathews Burwell, in her official capacity as U.S. Secretary of Health and
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Human Services; Marilyn Tavenner, as Administrator of the Centers for Medicare &
Medicaid Services; and Cara M. Christ, M.D., as Director of the Arizona Department of
Health Services.
This motion is made on the grounds that (1) Plaintiff is likely to succeed on the
agreement is invalid for various violations of the Fifth and Fourteenth Amendments of
the United States Constitution; (2) Plaintiff will suffer immediate and irreparable harm
unless the decision is enjoined; (3) the balance of hardships tips in favor of Plaintiff;
and (4) the public interest supports the issuance of a temporary restraining order and
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Guterman, M.D.; and on such argument and evidence as may be presented at the
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hearing.
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Notice of this motion has been given to counsel for Defendant by Thomas
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Murphy and William Sowders on July 15, 2015 via telephone and on July 16, 2015 via
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email. Notice of the hearing date will be given to Defendant when that date is set.
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Delivery of this application and all supporting papers to Defendant will be made on
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July 16, 2015 by e-mail immediately upon the signing of this application.
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