Case 2:14-cv-04622-AB Document 1 Filed 08/06/14 Page 1 of 17

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

VALLEY FORGE CHRISTIAN COLLEGE OF THE ASSEMBLIES OF GOD Plaintiff, v. SYLVIA MATHEWS BURWELL, in her official capacity as Secretary of the DepaIiment of Health and Human Services; UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES; THOMAS E. PEREZ, in his official capacity as the Secretary of the United States Department of Labor; UNITED STATES DEPARTMENT OF LABOR; JACOB 1. LEW, in his official capacity as Secretary of the United States DepaIiment of the Treasury; and THE UNITED STATES DEPARTMENT OF THE TREASURY, Defendants.

CIVNO.

COMPLAINT

Comes now Plaintiff, Valley Forge Christian College of the Assemblies of God, by and

through its attorneys, and states as follows:

NATURE OF THE ACTION

1. Plaintiff submits this Complaint to seek redress for violations of its sincerely

held religious beliefs by the Defendants and to seek relief from content-based restrictions on free

speech.

2. The Plaintiff challenges regulations issued under the Patient Protection and

Affordable Care Act ("PPACA") that force employers to provide, directly or indirectly,

insurance plans that include potentially life threatening drugs and devices, which harm or

terminate a fertilized humaI1 egg (the "Mandate").

3. Under these regulations, Plaintiff has until October 2014 to either include celiain

drugs, devices, and/or procedures that are potentially life threatening to a fertilized human egg or

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anange for or facilitate coverage with its insurance carrier, third pmiy administrator or any other third pmiy to provide the same drugs, devices and procedures, thereby transferring its legal and moral authority. This is contrary to Plaintiffs sincerely held religious beliefs.
4. The Plaintiff, Valley Forge Christian College of the Assemblies of God ("Valley Forge Christian College"), is a Christian college located in Chester County, Pennsylvmlia. Valley Forge Christian College's religious beliefs forbid it from pmiicipating in, providing access to, paying for or designating others to pay for celiain drugs, devices or procedures, which harm or terminate a feliilized human egg.
5. Because of this sincerely held religious belief, Valley Forge Christiml College carmot comply with the government's Mandate. Moreover, Valley Forge Christian College cmmot participate in the so-called "Religious Accommodation," which would cause it to facilitate, pmiicipate and assist in actions resulting in the provision of potentially life threatening drugs and devices, which harm or terminate a feliilized human egg.
6. Valley Forge Christian College faces significant fines and/or the loss of its insurance coverage for the exercise of its sincerely held religious beliefs.
JURISDICTION AND VENUE 7. The COUli has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 and § 1361. This action arises under the Constitution and laws of the United States. This Court has jurisdiction to render declaratory and injunctive relief under 28 U.S.C. §§ 2201 mId 2202, and 42 U.S.C. § 2000bb-1. 8. Venue lies in this district pursuant to 28 U.S.c. § 1391(e). A substantial part of the events or omissions giving rise to the claim occurred in this district, and Plaintiff resides in this district.
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IDENTIFICATION OF PARTIES 9. Plaintiff Valley Forge Christian College is a Christian college founded in 1939 by the Assemblies of God. The College Mission Statement declares its purpose "to prepare individuals for a life of service and leadership in the church and in the world." 10. Defendant Sylvia Mathews Burwell is the Secretary of the United States Depatiment of Health and Human Services. Secretmy Burwell is an official of the United States. She is sued in her official capacity. 11. Defendant the United States Depatiment of Health and Human Services ("HHS") is a depatiment and agency of the United States. 12. Defendatlt Thomas E. Perez is the Secretary of the United States Department of Labor. Secretmy Perez is atl official of the United States. He is sued in his official capacity. 13. Defendant the United States Depatiment of Labor ("Labor") is a depatiment and agency of the United States. 14. Defendant Jacob J. Lew is the Secretary of the United States Department of the Treasury. Secretary Lew is an official of the United States. He is sued in his official capacity. 15. Defendatlt the United States Department of the Treasury ("Treasury") is a depatiment and agency of the United States. 16. All Defendants are hereafter collectively referred to here as "the Departments" or "the Government."
VALLEY FORGE CHRISTIAN COLLEGE'S SINCERELY HELD RELIGIOUS BELIEFS 17. Valley Forge Christian College has been affiliated with the Assemblies of God religious denomination since its founding in 1939.
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18. The Bylaws of Valley Forge Christian College require the College to be "bound to the Statement of Fundamental Truths of the General Council of the Assemblies of God" and its endorsement by the Alliance for Assemblies of God Higher Education.
19. The Valley Forge Christian College's Board of Trustees is composed of 51 members, all of whom are members of the Assemblies of God and 25 of whom must be credentialed ministers of the Assemblies of God.
20. Six regional and two ethnic districts of the Assemblies of God are responsible for the nomination of24 members of the Board of Trustees. Valley Forge Christian College requires the administration, the faculty, and professional staff to adhere to the Statement of Fundamental Truths of the Assemblies of God. Valley Forge Christian College requires all of its staff, administration, faculty and students to adhere to a lifestyle covenant.
21. Valley Forge Christian College has no religious objection to providing coverage for contraceptive drugs and devices which truly-and only-prevent conception and do not interfere with the continued survival of a human embryo.
22. It is, however, Valley Forge Christian College's sincerely held religious belief that it is forbidden, under religious principles and teachings, from providing, facilitating, counseling to use, or assisting in the provision of any drugs or services that interfere with the survival of a human embryo, except to save the life of a mother.
23. At a meeting held April 9-10, 2014, the Board of Trustees of Valley Forge Christian College passed a resolution declaring its opposition to the HHS Mandate because some of the drugs and/or devices required by it may interfere with the survival of a human embryo. That resolution is attached hereto as Exhibit A.
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24. That resolution, in pali, stated that" ... the Assemblies of God has a sincerely held religious belief vigorously opposed to abOliion, abOliion-related legislation and medical procedures as documented in (1) A position paper adopted at the General Presbytery in Session August 9-11,2010 'Sanctity of HUmall Life: AbOliion and Reproductive Issues', and (2) The February 27, 2012 statement issued in opposition to the Obalna Health Insurance Plan by Dr. George Wood, General Superintendent of the Assemblies of God."
25. In that SaIne resolution, the Board of Trustees of Valley Forge Christian College stated, "The Board of Trustees affirms its sincerely held religious belief in opposition to abortion and abOliion-related drugs and procedures."
26. Valley Forge Christian College not only opposes the direct provision of potentially life threatening drugs alld devices, which harm or terminate a feliilized human egg and services, on religious grounds, but it also opposes being associated with, paliicipating indirectly with, or transferring any legal or moral authority by which a third party might enable the provision of such services to the employees of Valley Forge Christian College.
27. Valley Forge Clu·istian College considers it contrary to the tenets of the Christian religion as held by the Assemblies of God denomination - to directly or indirectly provide potentially life threatening drugs and/or devices that may harm or terminate a developing humall embryo after conception.
THE ACCOMMODATION 28. On June 28, 2013, Defendants issued a final rule (the "Mandate"), which ignores the objections repeatedly raised by religious organizations and continues to co-opt objecting religious employers into the government's scheme of expanding free access to potentially life threatening drugs and devices, which harm or terminate a feliilized hUmall egg.
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78 Fed. Reg. 39870. 29. Under the Mandate, the discretionary "religious employers" exemption, which is
still implemented via footnote on the Health Resources and Services Administration ("HRSA") website, Ex. C, remains limited to formal churches and religious orders "organized and operate[d]" as nonprofit entities and "referred to in section 6033(a)(3)(A)(i) or (iii) ofthe [Internal Revenue] Code." 78 Fed. Reg. at 39874.
30. All other religious organizations, including Valley Forge Christian College, are excluded from the exemption.
31. The Mandate creates a separate "accommodation" for certain non-exempt religious organizations. 78 Fed. Reg. at 39874.
32. An organization is eligible for the accommodation ifit (1) "[o]pposes providing coverage for some or all of the contraceptive services required"; (2) "is organized and operates as a nonprofit entity"; (3) "holds itself out as a religious organization"; and (4) "self-certifies that it satisfies the first three criteria." 78 Fed. Reg. at 39874.
33. The self-certification must be executed "prior to the begilming of the first plan year to which an accommodation is to apply." 78 Fed. Reg. at 39875.
34. The Final Rule extends the current safe harbor through the end of2013. 78 Fed. Reg. at 39889; see also HHS Center for Consumer Information and Insurance Oversight, Guidance on the Temporary Enforcement Safe Harbor for Celiain Employers (June 28, 2013) (extending the safe harbor to the first plan year that begins on or after January 1,2014).
35. Thus, an eligible organization would need to execute the self-certification prior to its first plan year that begins on or after January 1, 2014, and deliver it to the organization's
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insurer or, if the organization has a self-insured plan, to the plan's third party administrator. 78 Fed. Reg. at 39875.
36. By the terms of the accommodation, Valley Forge Christian College would be required to execute the self-celiification and deliver it to its insurers and plan administrators before July 1,2014.
37. By delivering its self-certification to its insurers and third-party administrators, Valley Forge Christian College would trigger its obligations to "provide payments for contraceptive services," including potentially life threatening drugs and devices that may harm or terminate a fertilized human egg like Plan B (the "day after pill") and Ella (the "week after pill"). 78 Fed. Reg. at 39876 (insurers) see also id. at 39879 (third patiy administrators).
38. In the case of its self-insured plan, Valley Forge Christian College's selfceliification acts as a designation of the third patiy administrator(s) as plan administrator and claims administrator for plan, which includes potentially life tlu"eatening drugs and devices, which harm or terminate a fertilized human egg, benefits pursuatlt to section 3(16) of ERISA. 78 Fed. Reg. at 39879.
39. Because Valley Forge Christiatl College has a sincerely-held religious objection against directly providing celiain potentially life tlu"eatening drugs atld devices that may harm or terminate a feliilized hUmatl egg, and because Valley Forge Christian College believes it would be wrong to transfer its legal and moral authority to a third patiy that would provide the smne potentially life threatening drugs and devices, it can neither comply with the HHS Mandate, nor engage in the Accommodation. Therefore, it faces and is subject to a $100.00 per day per beneficiary fine, which will cause a severe economic consequence to Valley Forge Christian College.
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CLAIMS FOR RELIEF COUNT I
Violation of the Religious Freedom Restoration Act - Substantial Burden 40. Valley Forge Christian College incorporates by reference all preceding paragraphs. 41. Valley Forge Christian College's sincerely held religious beliefs prohibit it from providing, or transferring to another, its legal and moral authority for facilitating health insurance that would facilitate access to potentially life threatening drugs and devices, which harm or tenninate a fertilized human egg, or to related education and counseling, which promote the use of such drugs or devices. 42. The Mandate and Defendants' threatened enforcement of the Mandate violate Valley Forge Christian College's rights secured to it by the Religious Freedom Restoration Act, § 2000bb-1 et seq. The language of the applicable section of the Religious Freedom Restoration Act (RFRA) is as follows: (b) Exception: Government may substantially burden a person's exercise ofreligion only ifit demonstrates that application of the burden to the person(1) is in fmiherance of a compelling governmental interest; and (2) is the least restrictive means of furthering that compelling govenunental interest 42 U.S. Code § 2000bb-1 43. The Mandate creates government-imposed coercive pressure on Valley Forge Christian College to change or violate its religious beliefs. 44. The Mandate restricts Valley Forge Christian College's religious exercise. 45. The Mandate exposes Valley Forge Christian College to substantial fines for its religious exercise.
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46. The Mandate exposes Valley Forge Clu"istian College to substantial competitive disadvantages, in that it will no longer be permitted to offer health insurance.
47. The Mandate imposes a substantial burden on Valley Forge Clu"istian College's religious exercise.
48. The Mandate fmihers no compelling govermnental interest. 49. The Mandate is not narrowly tailored to any compelling govermnental interest. 50. The Mandate is not the least restrictive means of fmihering Defendants' stated interests. 51. Because the "accommodation" provided by the Mandate is not narrowly tailored and is not the least restrictive means available, it violates the terms of the exception granted by the Religious Freedom Restoration Act, 42 U.S.C. § 2000bb-1 et seq. 52. Absent injunctive and declaratory relief against the Mandate, Valley Forge Clu"istian College will continue to be harmed.
COUNT II Violation of the First Amendment to the United States Constitution
Free Exercise Clause Intentional Discrimination 53" Valley Forge Christian College incorporates by reference all preceding paragraphs. 54. Valley Forge Clu"istian College's sincerely held religious beliefs prohibit it from providing, or transferring to another its legal and moral authority for facilitating health insurance that would facilitate access to potentially life tlu"eatening drugs and devices, which harm or terminate a feliilized human egg, and/or to related education and counseling.
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55. The Mandate and Defendants' threatened enforcement of the Mandate therefore violate Valley Forge Christian College's rights secured to it by the Free Exercise Clause of the First Amendment of the United States Constitution.
56. Absent injunctive and declaratory relief against the Mandate, Valley Forge Christian College will continue to be harmed.
COUNT III Violation of the First Amendment to the United States Constitution
Free Exercise Clause Discrimination Among Religions 57. Valley Forge Christian College incorporates by reference all preceding paragraphs. 58. The Free Exercise Clause and Establishment Clause of the First Amendment mandate the equal treatment of all religious faiths and institutions without discrimination or preference. 59. This guarantee of equal treatment protects organizations as well as individuals. 60. Because the Mandate provides a narrow exemption for "religious employers" but not for other religious organizations, it discriminates among religions on the basis of religious views or religious status. 61. The Mandate and Defendants' threatened enforcement of it thus violate Valley Forge Christian College's rights secured to it by the Free Exercise Clause of the First Amendment of the United States Constitution. 62. Absent injunctive and declaratory relief against the Mandate, Valley Forge Christian College will continue to be harmed.
COUNT IV Violation of the First Amendment to the United States Constitution
Establishment Clause
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Selective BurdenlDenominational Preference (Larson v. Valente) 63. Valley Forge Christian College incorporates by reference all preceding paragraphs. 64. By design, Defendants imposed the Mandate on some religious organizations but not on others, resulting in a selective burden on Valley Forge Christian College. 65. The Mandate and Defendants' threatened enforcement of the Mandate therefore violate Valley Forge Christian College's rights secured to it by the Establishment Clause of the First Amendment to the United States Constitution. 66. Absent injunctive and declaratory relief against the Mandate, Valley Forge Christian College will continue to be hmmed.
COUNT V Interference in Matters of Internal Religious Governance
Free Exercise Clause and Establishment Clause 67. Valley Forge Christian College incorporates by reference all preceding paragraphs. 68. The Free Exercise Clause and the Establishment Clause protect the freedom of religious organizations to decide for themselves, free from state interference, matters of internal governm1ce as well as those of faith and doctrine. 69. Under the Free Exercise Clause m1d the Establishment Clause, the Government may not interfere with a religious organization's internal decisions concerning the organization's religious structure, doctrine, or leadership. 70. Valley Forge Christian College made an internal decision, based on the doctrine set forth by Assemblies of God, that it opposes potentially life threatening drugs and devices, which harm or terminate a feliilized human egg, which is based on its religious beliefs.
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71. The Mandate therefore directly interferes with Valley Forge Christian College's faith and mission because it interferes with its ability to make internal decisions concerning its doctrine.
72. Because of this interference, the Mandate violates the Establishment Clause and the Free Exercise of the First Amendment and Valley Forge Christian College is entitled to relief.
COUNT VI Violation of the First and Fifth Amendments of the United States Constitution
Establishment Clause and Due Process 73. Valley Forge Christian College incorporates by reference all preceding paragraphs. 74. The First Amendment provides that "Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof." 75. The Free Exercise Clause of the First Amendment prohibits the Government from substantially burdening an entity's exercise of religion. 76. The Free Exercise Clause protects organizations from Government-imposed burdens on religious exercise. 77. The Due Process Clause of the Fifth Amendment mandates the equal treatment of all religious faiths and institutions without discrimination or preference. 78. The Mandate and the "accommodation" require Plaintiff to provide, facilitate, or initiate the provision of services that are directly contrary to its religious beliefs respecting the sanctity and dignity of human life and prohibiting being associated with the provision of potentially life threatening drugs and devices, which harm or terminate a fertilized human egg.
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79. The Mandate and the "accommodation" are not neutral laws of general applicability because they exempt substantial categories of employers, solely for secular reasons, while not exempting employers for religious reasons, and the exemptions are so substantial as to render any differing treatment for religious employers suspect and discriminatory.
80. The Mandate and the "accommodation" are subject to strict scrutiny.
81. The Government has no compelling interest to require Plaintiff to comply with the Mandate or the "accommodation."
82. The Mandate and the "accommodation" are not narrowly tailored to further a compelling government interest.
83. By enacting the Mandate and the "accommodation," the Govermnent has, therefore, burdened Plaintiffs religious exercise in violation of the Free Exercise Clause of the First Amendment, and Plaintiff is entitled to relief.
PRAYER FOR RELIEF WHEREFORE, the Plaintiff respectfully requests that the COUli: a. Declare that Defendant's enforcement of the Mandate against the Plaintiff violates the First and Fifth Amendments to the United States Constitution; b. Declare that Defendant's enforcement of the Mandate against the Plaintiff violates the Religious Freedom Restoration Act; c. Issue temporary and permanent injunctions prohibiting enforcement of the Mandate against Plaintiff or any other regulation or law which requires Plaintiff to provide,
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directly or indirectly, potentially life threatening drugs and devices, which harm or terminate a

fertilized human egg;

d. Issue temporary and permanent injunctions prohibiting Plaintiffs health

insurance carrier from providing an insurance plan that includes potentially life threatening drugs

and devices, which harm or terminate a fertilized human egg;

e. Issue temporary and permanent injunctions prohibiting enforcement of the

Mandate against Plaintiff or any other regulation or law which prohibits Plaintiff from exercising

its First Amendment rights to believe, teach or counsel its opposition to the

use of potentially life threatening drugs and devices, which harm or terminate a fertilized human

egg;

f.

Award Plaintiff the costs ofthis action and reasonable attorney's fees; and

g. Award such other and further relief as it deems equitable and just.

Respectfully submitted,

IJjid/',~ MAZArVID & HOEFFEL

BY

'tV

/JAMES W. MAZ:A, ESQUIRE

( Attofley LD. No. 363(5/

YA, DAVID & HOEFFEL P.O. Box 369 507 Salfordville Road Lederach, PA 19450 Phone: (215) 256-0007 Fax: (215) 256-0008 jmaza@mdhlawyers.com
It Date t2JJ/Y U/ /

Jeffrey C. Mateer* Texas State Bar No. 13185320
Jeremiah G. Dys * West Virginia State Bar No. 9998
Justin E. Butterfield* Texas State Bar No. 24062642
LIBERTY INSTITUTE 2001 W. Plano Parkway, Suite 1600 Plano, Texas 75075 (972) 941-4444
*Will seek admission pro hac vice
Attorneys for Valley Forge 14 Christian College ofthe
Assemblies ofGod

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E HI IT

Case 2:14-cv-04622-AB Document 1 Filed 08/06/14 Page 16 of 17
Valley Forge Christian College Board of Trustees April 9-10, 2014
RESOLUTION 10 AUTHORIZATION TO OPPOSE THE HHS MANDATE
WHEREAS, Valley Forge Christian College has been intricately linked to the Assemblies of God since its founding in 1939; and
WHEREAS, The Bylaws of Valley Forge Clllistian College (Bylaws) require its endorsement by the Alliance for Assemblies of God Higher Education (Alliance); and
WHEREAS, The Bylaws require that the college be "bound to the Statement of Fundamental Truths of the General Council ofthe Assemblies of God;" and
WHEREAS, Membership of the Board of Trustees is comprised of fifty-two (52) members, twenty-six (26) of whom must be credentialed ministers with the Assemblies of God, with additional members also possessing credentials as Assemblies of God ministers; and
WHEREAS, The 6 regional and 2 ethnic Districts of the Northeast are responsible to nominate twentyfour members for membership on the Board of Trustees; and
WHEREAS, The Bylaws require the Administration, faculty, and professional staff to adhere to the Statement of Fundamental Truths of the Assemblies of God; and
WHEREAS, The college mission statement, "to prepare individuals for a life of service and leadership in the church and in the world," affirms its commitment to participate in the Great Commission by providing qualified ministers and other leaders for service and leadership; and
WHEREAS, the Assemblies of God has a sincerely held religious belief vigorously opposed to abortion, abortion-related legislation and medical procedures as documented in: (1) a position paper adopted at the General Presbytery in session August 9-11, 2010, "Sanctity of Human Life: Abortion and Reproductive Issues;" and, (2) the February 27,2012 statement issued in opposition to the Obama Health Insurance Plan by Dr. George Wood, General Superintendent of the Assemblies of God; and
WHEREAS, The Board of Trustees affirms its sincerely held religious belief in opposition to abortion and abortion-related drugs and procedures; therefore be it
RESOLVED, That the Board of Trustees empower the Executive Committee to take all steps necessary to lift the imposition of the HHS Mandate against our religious liberties; be it further
RESOLVED, That the college Administration send a letter to Aetna, its health care provider, requesting that Aetna disallow abortion-related drugs and procedures as part of the college's health plan; be it further
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RESOLVED, That if Aetna replies that it is not possible to comply with the request based on the HHS Mandate, copies of the original request and Aetna's rejection be sent to the appropriate US Congresspersons aleliing them of our coneem and Aetna's response; be it fmiher RESOLVED, That the Board of Trustees authorize the Administration to engage the Liberty Institute as co-counsel with Maza and David to pursue an injunction against enforcement of the HHS Mandate; be it further RESOLVED, That the Board of Trustees appoint a Task Force to advise and assist the Executive Committee and the Administration in the pursuit of this matter.
Submitted by the College Administration
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 Case 2:14-cv-04622-AB Document 9 Filed 10/20/14 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

VALLEY FORGE CHRlSTIAN COLLEGE
OF TIIE ASSEMBLIES OF GOD
Plaintiff,
v.
SYLVIA M. BURWELL, et al.}
Defendants.

"
CIVNO. 2:14-cv-4622-AB

STIPULATION OF VOLUNTARY DISMISSAL PURSUANT TO FED. R. elY. P. 41(a)(1)(A)(ii)

The parties, through their tmdersigned counsel of record, hereby stipulate to the voluntary dismissal of the above-captiOliedmatter as to all Defendants with prejudice.

BY: b:.-~· ~
BENJAMIN L. BERWICK, ESQUIRE
MA Bar No. 679207
Attomey for Defendants

1

 
 Case: 2:14-cv-4622 As of: 11/19/2014 02:16 PM EST 1 of 3
CLOSED,STANDARD
United States District Court Eastern District of Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 2:14−cv−04622−AB

VALLEY FORGE CHRISTIAN COLLEGE OF THE ASSEMBLIES OF GOD v. BURWELL et al Assigned to: HONORABLE ANITA B. BRODY Cause: 42:2000bb Religious Freedom Restoration Act of 1993
Plaintiff

Date Filed: 08/06/2014 Date Terminated: 10/21/2014 Jury Demand: None Nature of Suit: 440 Civil Rights: Other Jurisdiction: U.S. Government Defendant

VALLEY FORGE CHRISTIAN COLLEGE OF THE ASSEMBLIES OF GOD

represented by JAMES W. MAZA MAZA &DAVID 507 SALFORDVILLE RD POBOX 369 LEDERACH, PA 19450 215−256−0007 Email: jmaza@mcdlawfirm.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant SYLVIA MATHEWS BURWELL IN HER OFFICIAL CAPACITY AS SECRETARY OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES
Defendant UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES
Defendant THOMAS E. PEREZ IN HIS OFFICIAL CAPACITY AS SECRETARY OF THE UNITED STATES

represented by BENJAMIN LEON BERWICK U.S. DEPT OF JUSTICE CIVIL DIV FEDERAL PROGRAMS BRANCH 20 MASSACHUSETTS AVE NW ROOM 7306 WASHINGTON, DC 20530 202−305−8573 Email: Benjamin.L.Berwick@usdoj.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
JOEL M. SWEET U.S. ATTORNEY'S OFFICE 615 CHESTNUT STREET SUITE 1250 PHILADELPHIA, PA 19106 215−861−8581 Fax: 215−861−8618 Email: joel.sweet@usdoj.gov ATTORNEY TO BE NOTICED
represented by BENJAMIN LEON BERWICK (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
JOEL M. SWEET (See above for address) ATTORNEY TO BE NOTICED
represented by BENJAMIN LEON BERWICK (See above for address) LEAD ATTORNEY

Case: 2:14-cv-4622 As of: 11/19/2014 02:16 PM EST 2 of 3

DEPARTMENT OF LABOR

ATTORNEY TO BE NOTICED

JOEL M. SWEET (See above for address) ATTORNEY TO BE NOTICED

Defendant
UNITED STATES DEPARTMENT OF LABOR

represented by BENJAMIN LEON BERWICK (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

JOEL M. SWEET (See above for address) ATTORNEY TO BE NOTICED

Defendant
JACOB J. LEW IN HIS OFFICIAL CAPACITY AS SECRETARY OF THE UNITED STATES DEPARTMENT OF THE TREASURY

represented by BENJAMIN LEON BERWICK (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

JOEL M. SWEET (See above for address) ATTORNEY TO BE NOTICED

Defendant
THE UNITED STATES DEPARTMENT OF THE TREASURY

represented by BENJAMIN LEON BERWICK (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

JOEL M. SWEET (See above for address) ATTORNEY TO BE NOTICED

Date Filed 08/06/2014
08/06/2014
08/06/2014 08/06/2014

# Docket Text
1 COMPLAINT against SYLVIA MATHEWS BURWELL, JACOB J. LEW, THOMAS E. PEREZ, THE UNITED STATES DEPARTMENT OF THE TREASURY, UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES, UNITED STATES DEPARTMENT OF LABOR ( Filing fee $ 400 receipt number 105608.), filed by VALLEY FORGE CHRISTIAN COLLEGE OF THE ASSEMBLIES OF GOD. (Attachments: # 1 Civil Cover Sheet)(mima, ) (Entered: 08/06/2014)
Summons Issued as to SYLVIA MATHEWS BURWELL, JACOB J. LEW, THOMAS E. PEREZ, THE UNITED STATES DEPARTMENT OF THE TREASURY, UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES, UNITED STATES DEPARTMENT OF LABOR. One Forwarded To: AUSA, Seven Given To: Counsel on August 8, 2014 (mima, ) (Entered: 08/06/2014)
2 NOTICE of Appearance by JOEL M. SWEET on behalf of SYLVIA MATHEWS BURWELL, JACOB J. LEW, THOMAS E. PEREZ, THE UNITED STATES DEPARTMENT OF THE TREASURY, UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES, UNITED STATES DEPARTMENT OF LABOR with Certificate of Service(SWEET, JOEL) (Entered: 08/06/2014)
3 Acceptance of Service by U.S. Attorney Re: accepted summons and complaint on behalf of the United States Attorney (only). (kk, ) (Entered: 08/06/2014)

Case: 2:14-cv-4622 As of: 11/19/2014 02:16 PM EST 3 of 3

08/13/2014
08/21/2014 08/29/2014 09/18/2014 10/01/2014
10/20/2014 10/21/2014

4 NOTICE of Appearance by BENJAMIN LEON BERWICK on behalf of SYLVIA MATHEWS BURWELL, JACOB J. LEW, THOMAS E. PEREZ, THE UNITED STATES DEPARTMENT OF THE TREASURY, UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES, UNITED STATES DEPARTMENT OF LABOR with Certificate of Service(BERWICK, BENJAMIN) (Entered: 08/13/2014)
5 NOTICE of Hearing:A RULE 16 CONFERENCE WILL BE HELD ON 9/23/2014 AT 02:00 PM IN JUDGE CHAMBERS, ROOM 7613 ON THE 7TH FLOOR, BEFORE HONORABLE ANITA B. BRODY.8/21/2014 ENTERED AND COPIES SENT VIA ECF.(mo, ) (Entered: 08/21/2014)
6 Disclosure Statement Form pursuant to FRCP 7.1 by VALLEY FORGE CHRISTIAN COLLEGE OF THE ASSEMBLIES OF GOD.(MAZA, JAMES) (Entered: 08/29/2014)
7 Discovery Plan by VALLEY FORGE CHRISTIAN COLLEGE OF THE ASSEMBLIES OF GOD.(MAZA, JAMES) (Entered: 09/18/2014)
8 ORDER... that DEFENDANTS' DEADLINE TO RESPOND TO THE COMPLAINT IS EXTENDED BY 14 DAYS. DEFENDANTS SHALL RESPOND TO THE COMPLAINT ON OR BEFORE OCTOBER 20, 2014.. SIGNED BY HONORABLE ANITA B. BRODY ON 9/30/14. 10/1/14 ENTERED AND COPIES VIA ECF.(mo, ) (Entered: 10/01/2014)
9 STIPULATION of Dismissal Voluntary by VALLEY FORGE CHRISTIAN COLLEGE OF THE ASSEMBLIES OF GOD. (MAZA, JAMES) (Entered: 10/20/2014)
10 Minute Entry for proceedings held before HONORABLE ANITA B. BRODY: Pretrial Conference held on 9/23/2014 (ems) (Entered: 10/21/2014)