UNITED STATES DISTRICT COURTFOR THE DISTRICT OF NEW HAMPSHIREDARTMOUTH-HITCHCOCK CLINIC ANDMARY HITCHCOCK MEMORIAL HOSPITAL,D/B/A DARTMOUTH-HITCHCOCK, ET AL.
CIVIL ACTION No.Plaintiffs,
NICHOLAS A. TOUMPAS, in his officialcapacity as Commissioner of the New HampshireDepartment of Health and Human Services,
Pursuant to Fed. R. Civ. P. 65, Dartmouth-Hitchcock Clinic and Mary Hitchcock Memorial Hospital, d/b/a Dartmouth-Hitchcock; Elliot Health System and its subsidiaries, ElliotHospital of the City of Manchester, Elliot Physician Network, and Elliot Professional ServicesNetwork, Inc.; Catholic Medical Center; Wentworth-Douglass Hospital and its subsidiary,Wentworth-Douglass Physician Corporation; Exeter Hospital, Inc., and its subsidiaries, CorePhysicians, LLC, Exeter Healthcare, Inc., and Rockingham VNA & Hospice; Southern NewHampshire Health System and its subsidiaries, Southern New Hampshire Medical Center andFoundation Medical Partners, Inc.; St. Joseph Hospital of Nashua, N.H.; LRGHealthcare d/b/aLakes Region General Hospital; Cheshire Medical Center; Frisbie Memorial Hospital,(collectively, “Provider Plaintiffs”); and John Doe (“Patient Plaintiff”) (together with ProviderPlaintiffs, “Plaintiffs”), by and through their attorneys, respectfully move this Court for entry of a preliminary injunction. In support of their motion, the Plaintiffs state as follows:
Case 1:11-cv-00358 Document 3 Filed 07/25/11 Page 1 of 6