Update Dec 17th: Given the controversy surrounding the claims below, so that all perspectives are referenced, please find a rebuttal here. The essence of the rebuttal is that the excess deaths claimed are a function of 28 days (in the case of the c19 vax, because it is comprised of two shots) being compared with 14 days (for the influenza vax comprised of a single shot). However, the following scomment also published on the above linked page is worth considering imo:
Sometimes what looks simple is deceptively simple, or simply deceptive. The obvious big question is: Why are the deaths following both doses a function of the number of days following vaccination? If there is no causal relationship of vaccination to the deaths, then the deaths should not occur as a very obvious and consistent temporal function in relation to the vaccination event. If they are just background deaths, causally unrelated to the vaccination, they should occur tightly and randomly distributed around 7.14% per day (100% divided by 14 days) for each of the 14 days following vaccination. For some reason that is pretty glaringly not what shows up in the data. (source)
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This post is about America's Frontline Doctors (AFLDs) lawsuit filed on the 19th July 2021, which seeks an injunction to bring an end to the emergency use authorizations (EUAs) for the three main vaxes, in respect of the 'scenarios' listed/quoted below (from the conclusion section of the lawsuit). The lawsuit also contains details about the whistleblower evidence (given under penalty of perjury) that 45,000 individuals have died within three days of receiving the vax (see the 'quote 7' section below).
Note: To get straight to the section dealing with the whistleblower evidence re the 45,000 dead within 3 days of receiving the vax, please jump to 'quote 7' below by clicking here -- though please note that the lawsuit document consists of many additional and important arguements as to why the injuction preventing the ongoing EUAs should be granted.
Let us begin at the end of the document on page 65 as it most clearly sets out what is being sought in the injunction:
Conclusion:
Accordingly, and for all of the foregoing reasons, Plaintiffs move under Rule 65, Fed.R.Civ.P., for a preliminary injunction against Defendants enjoining them from continuing to authorize the emergency use of the so-called “Pfizer-BioNTech COVID-19 Vaccine,” “Moderna COVID-19 Vaccine” and the “Johnson & Johnson (Janssen) COVID-19 Vaccine” pursuant to their respective EUAs, and from granting full FDA approval of the Vaccines:
(i) for the under-18 age category;
(ii) for those, regardless of age, who have been infected with SARS-CoV-2 prior to vaccination; and
(iii) until such time as the Defendants have complied with their obligation to create and maintain the requisite “conditions of authorization” under Section 546 of the Food, Drugs and Cosmetics Act, 21 U.S.C. § 360bbb–Case 2:21-cv-00702-CLM Document 15 Filed 07/19/21 Page 65 of 67-66-3(e), thereby enabling Vaccine candidates to give truly voluntary, informed consent
Point (ii) above is particularly noteworthy, as it refers to a clearly defined category of individuals not typically identified/discussed as being at high risk from COVID-19 vaccination - however according to the evidence cited in the lawsuit, it seems a particularly vital factor for medical professionals to ascertain about an individual via blood tests (and by default, before a vaccine is even offered).
The following is an overview of the main points made in the lawsuit, and thus also shows it's structure and logic. Almost all the points made in the lawsuit are accompanied by references and/or study citations. Quotes where referred to, can be found below the overview (and are typically hyperlinked). In addition, the full lawsuit is embedded below here, or it can be downloaded from here (right click then, save as target).
To note, I have written a few brief additional comments about the lawsuit below the content/structure/logic section.
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Contents and structure of the lawsuit (apologies for not consistently including page number references):
-The pandemic is based on a declaration of emergency (which itself is legally untenable given official stats).
--Survivability in those who contract the virus is greater then 99.8% (and even higher in the young).
-Death certificate legal 'guidelines' have been changed so as to 'recommend' entering CV19 as a cause of death on death certs, without proper checks/postmortems being carried out (i.e. CV19 can just be probable/assumed). [Essentially such death certificate fraud has hugely inflated the 'official' CV19 death numbers.]
-About the use of the PCR test in diagnosing CV19 cases/infections (and which is scientifically unacceptable).
--PCR Ct cycle count manipulation, given it has been stated by the CDC that anything over 35 cycles is 'essentially worthless' - yet PCR tests are commonly carried out with cycle counts (Ct) of 40-45. The impact of increasing cycle counts is exponential, not linear, in terms of the 'amplification' effect upon the test sample, so even a few extra cycles represents a huge increase in test sensitivity (see this post for more about this subject). Labs have to legally set the Ct value to what the individual PCR test manufacturer directs it to be - yet these vary enormously from brand to brand. Please see this very insightful table below, which lists the differing PCR cycle counts (Ct) for the various manufacturers/brands (from page 6 of the lawsuit). [I've been wondering (speculatively) if this is how the cycle count is being managed/manipulated, i.e. labs are directed to use a particular brand of PCR test at any one time - rather than labs being directed directly what cycle count to use.]
-Introduction of the concept of asymptotic spread of infection as a major plank of the 'pandemic' (and which is scientifically untenable and not evidenced in studies).
-Ongoing renewal of state of emergency not in line with laws/constitution.
--For a renewal of a state of emergency, it has to be fact that there is a serious or life threatening disease or condition endangering the population - yet this has never been shown to be a fact, beneath all the propaganda).
-Points regarding the maintenance of the vax emergency use authorizations (EUA).
--EUAs can only be legally maintained if a vax is effective AND that there are no other viable alternatives.
---The absolute risk reduction of CV19 vaxes is only a mere 0.7-1.1%. The use of relative risk reduction figures close to 100% is not scientifically acceptable and is instead highly manipulative propaganda.
---A point about the vax only being shown in peer reviewed studies, to reduce symptoms (and not transmission or prevent infection). Therefore what is the purpose/need of such a vax if most claimed infections are asymptomatic?
-More about the dubious science of the 'asymptotic virus spreading' concept. The concept is based just on theoretical modeling and not supported in real life studies.
-How correct vaccine development takes 10-15 years. The four phases of trials and how they should proceed is described along with the reasons it is vital such lengthy periods are observed.
--Mentions how two of the vax brands appear to have been designed in just two days (and that the virus sequencing they are supposedly based on, was posted on the internet by China in the first days of the 'pandemic' and was not cross-checked/verified by any party subsequently.
-Summary of spike protein risks. A very significant section and worth reading in full, starting page 11.
-About the VEARS system (vaccine adverse event reporting system) and how it is meant as early warning system of injury and death being caused by a vax. It is currently flashing red.
-Concerns about reproductive health (see note below about the 82% figure mentioned).
--Spike protein risks to ovaries.
--Autoimmune risks to placenta.
--Vascular disease/ blood clots.
-Concerns about autoimmune disease development if spike protein binds to long lived proteins.
-Concerns about the breaching of the blood brain barrier which the spike protein is known to do. No other vax is known to breach the blood brain barrier in a comparable way.
--Neurological and brain damage - indicated by VEARS reports.
-Effect on the young.
-An official warning has recently had to be given about myocarditus (inflammation of the heart muscle) and pericarditis (inflammation of the lining of the outside of the heart).
-Risks of Antibody Dependent Enhancement (ADE) - also known as Pathogenic Priming (where a vaxed being, later suffers a cytokine storm when infected in the wild with the virus).
--Comparison with what happened with the Dengue virus vaccine.
--The ADE that happened with SARS-CoV-1 (animals in early phase trials died when later exposed to live virus).
--Yet full and proper animal trials have not been carried out for the SARS-CoV-2 vaxes [There was no time to waste.]
-About the risk of more virulent viruses forming because of universal vaccination [during a so-called pandemic].
-The serious issue of the blood stocks/supply now becoming contaminated with spike protein.
-The profoundly serious matter as to how the spike protein itself produces disease - even without the virus. The trillions of cells in an individual's body are being recruited/instructed to produce a toxic spike protein!
-Vaccine EUAs only legally maintainable if no alternative available.
--See 'quote 1' about ivermectin below (from page 22).
-Whereas the legal EUA conditions are that the following four disclosures must be made to the vax recipient without coercion - such legally mandated information is (seemingly purposefully) not being provided (see page 23):
--(i) that the Vaccines are only authorized for emergency use and not FDA approved, (ii) the significant known and potential risks of the Vaccines, (iii) available alternatives to the Vaccines, (iv) the option to accept or refuse the Vaccines [without sanction or punishment].
-Distortion of the meaning of immunity (see quote 2 from the lawsuit below).
-Legal implications of the use of mRNA gene therapy technology, rather than traditional vax technology (see quote 2 from the lawsuit below).
-Matters stemming from the unprecedented promotion of the vaxes - and the censorship of all criticism/discussion, etc.
--Points about propaganda and generation of fear.
---Has led to the situation described in quote 3 from the lawsuit below.
--Please see the fascinating table reproduced below/here, comparing the psychologically coercive techniques used in war - to what the earth's population has been subject to since early 2020.
-Legal issues arising from the lack of proper information being provided to vaccine recipients (see 'quote 4' below, from pages 32/33).
-Issues with VEARS and other comparable systems.
-Serious concerns regarding the vaccination of under 18 year olds.
--Risk of harm to children might be 1:50 (see quote 5 below).
-Hazards arising in those who have previously had a cv19 infection - see quote 6 below (from pages 39-40).
-Jane Doe whistleblower testimony regarding 45,000+ deaths within 3 days of the vax (see quote 7 below from page 41 for relevant text).
-A detailed legal discussion about the merits of the case (and other aspects of compensation) and why the court should grant the injunction.
-An important quote from a case to do with Flint River poisoning, given the cases claimed similarity - see quote 8 below (from page 58).
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My comments:
Imo, this is an extremely well structured and comprehensive lawsuit. The only main point which I consider was not included (under the section to do with populations being subjected to propaganda and fear) is the criticism as to how a positive PCR result is being considered 'a case' (thereby implying an infection). Such is an axiom of the medical fraud which is taking place, imo. Also, the recent observation that the 'vaccines' appear to contain significant amounts of graphene oxide probably came too late to be included, albeit is a very important discovery for sure - particularly as it might be the factor which is causing the magnetism phenomena being reported. [The magnetism phenomena wasn't listed in the lawsuit, though probably because there isn't a suitable study available yet suitable for referencing in such an important lawsuit.]
One exceptionally important statement (referenced above), is in regard to young people, where there are indications that the risk of injury might be as high as 1 in every 50 individuals. The reason for this is said to be that the immune response mounted (by the body) against the spike protein (which cells are instructed to produce), can be up to 20 times greater in the young. Please see the quote 5 here from the lawsuit in regard to this concern.
There is one other statement under the reproductive section (page 12) which I feel might have been better qualified. Where in the lawsuit it states (on page 12):
There are now a very high number of pregnancy losses in VAERS. A study recently published in the New England Journal of Medicine, “Preliminary Findings of mRNA COVID-19 Vaccine Safety in Pregnant Persons,” exposes that pregnant women receiving Vaccines during their first or second trimesters suffer an 82% spontaneous abortion rate, killing 4 out of 5 unborn babies.
It needs to be explained how the 82% is arrived at, given the study abstract states:
Among 3958 participants enrolled in the v-safe pregnancy registry, 827 had a completed pregnancy, of which 115 (13.9%) resulted in a pregnancy loss and 712 (86.1%) resulted in a live birth (mostly among participants with vaccination in the third trimester).
However, the criticism of the methodology used (and which the study abstract statement above is based on) is as follows:
...miscarriage generally only occurs in the first or second trimester while a stillbirth is a loss after the 20th week of pregnancy (here) and, therefore, the rate of miscarriage should only be calculated using figures of the women who had a vaccine in the first or second trimester and not the third.(source)
By excluding the 700 (of 827 completed pregnancies) who had the vaccine in the last trimester, the 127 remaining becomes the denominator and the rate equates to 81.9%.
Given so far it has not been a widely referenced category of individuals with whom especial care needs to be taken with the vax, I feel the highlighting of the potential danger the category comprising: "those, regardless of age, who have been infected with SARS-CoV-2 prior to vaccination" (quoted from lawsuit conclusion above) is very relevant, and the evidence supporting such prudence supplied, is convincing. For more insight, see quote 6 below (from pages 39-40)
Re the 20 or so last pages of the lawsuit, dealing with the merits of the case in terms of law and legal precedent - these were generally beyond my understanding, and so I am not able to comment of this part. Though 'quote 7' was used as a summary of certain points and is certainly a powerful statement and worth reading.
Table showing the different Ct values for different test brands:
Observational studies in Delhi and Mexico City show dramatic reductions in COVID-19 case and death counts following the mass distribution of Ivermectin. These results align with those of a study in Argentina, in which 800 healthcare professionals received Ivermectin, while another 400 did not. Of the 800, not a single person contracted COVID-19, while more than half of the control group did contract it. Dr. Pierre Kory, a lung specialist who has treated more COVID-19 patients than most doctors, representing a group of some of the most highly published physicians in the world, with over 2,000 peer reviewed publications among them, testified before the U.S. Senate in December 2020.14 He testified that based on 9 months of review of scientific data from 30 studies, Ivermectin obliterates transmission of the SARS-CoV2 virus and is a powerful prophylactic (if you take it, you will not contract COVID-19). Four large randomized controlled trials totaling over 1500 patients demonstrate that Ivermectin is safe and effective as a prophylaxis. In early outpatient treatment, three randomized controlled trials and multiple observational studies show that Ivermectin reduces the need for hospitalization and death in statistically significant numbers. In inpatient treatment, four randomized controlled trials show that Ivermectin prevents death in a statistically significant, large magnitude. Ivermectin won the Nobel Prize in Medicine in 2015 for its impacts on global health.15
Inexplicably, the Defendants never formed or assigned a task force to research and review existing alternatives for preventing and treating COVID-19. Instead, the Defendants and others set about censoring both concerns about the Vaccines, and information about safe and effective alternatives
Perhaps the first step in understanding the potential risks of the Vaccines is to understand exactly what they are, and what they are not. The CDC defines a “vaccine” as: “A product that stimulates a person’s immune system to produce immunity to a specific disease, protecting the person from that disease. Vaccines are usually administered through needle injections, but can also be administered by mouth or sprayed into the nose.”16 The CDC defines “immunity” as: “Protection from an infectious disease. If you are immune to a disease, you can be exposed to it without becoming infected.”17
However, the “Pfizer-BioNTech COVID-19 Vaccine” and the “Moderna COVID-19 Vaccine” do not meet the CDC’s own definitions. They do not stimulate the body to produce immunity from a disease. They are a synthetic fragment of nucleic acid embedded in a fat carrier that is introduced into human cells, not for the purpose of inducing immunity from infection with the SARS-CoV-2 virus, and not to block further transmission of the virus, but in order to lessen the symptoms of COVID-19. No published, peer-reviewed studies prove that the “PfizerBioNTech COVID-19 Vaccine” and the “Moderna COVID-19 Vaccine” confer immunity or stop transmission.
Further, the “Pfizer-BioNTech COVID-19 Vaccine” and the “Moderna COVID-19 Vaccine” are not “vaccines” within the common, lay understanding of the public. Since vaccines were first discovered in 1796 by Dr. Edward Jenner, who used cowpox to inoculate humans against smallpox, and called the process “vaccination” (from the Latin term vaca for cow), the public has had an entrenched understanding that a vaccine is a microorganism, either alive but weakened, or dead, that is introduced into the human body in order to trigger the production of antibodies that confer immunity from the targeted disease, and also prevent its transmission to others.
The public are accustomed to these traditional vaccines and understand them. The public are fundamentally uninformed about the gene therapy technology behind the “Pfizer-BioNTech COVID-19 Vaccine” and the “Moderna COVID-19 Vaccine.” Referring to the “mRNA technology” in its Vaccine, Moderna admits the “novel and unprecedented nature of this new class of medicines” in its Securities and Exchange Commission filings.18 Further, it admits that the FDA classes its Vaccine as a form of “gene therapy.” No dead or attenuated virus is used in the “Pfizer-BioNTech COVID-19 Vaccine” and the “Moderna COVID-19 Vaccine.” Rather, instructions, via a piece of lab-created genetic code (the mRNA) are injected into your body that tell your body how to make a certain “spike protein” that is purportedly (my emphasis) useful in attacking the SARS-CoV-2 virus.
By referring to the “Pfizer-BioNTech COVID-19 Vaccine” and the “Moderna COVID19 Vaccine” as “vaccines,” and by allowing others to do the same, the Defendants knowingly seduce and mislead the public, short-circuit independent, critical evaluation and decision-making by the consumers of these products, and vitiate their informed consent to this novel technology which is being deployed in the unsuspecting human population for the first time in history.
The combined effect of (i) the suppression and censorship of information regarding the risks of the Vaccines, (ii) the failure to inform the public regarding the novel and experimental nature of the mRNA Vaccines, (iii) the suppression and censorship of information regarding alternative treatments, (iv) the failure to inform and properly educate the public that the Vaccines are not in fact “approved” by the FDA, (v) the failure to inform and properly educate the public that the DHHS Secretary has not determined that the Vaccines are “safe and effective” and on the contrary has merely determined that “it is reasonable to believe” that the Vaccines “may be effective” and that the benefits outweigh the risks, (vi) the sustained psychological manipulation of the public through official fear-based messaging regarding COVID-19, draconian countermeasures and a system of rewards and penalties, is to remove any possibility that Vaccine recipients are giving voluntary informed consent to the Vaccines. They have no real option to accept or refuse the Vaccines. They are unwitting, unwilling participants in a large scale, ongoing non-consensual human experiment.23
VAERS was established in 1986 in order to facilitate public access to information regarding adverse events potentially caused by vaccines. This system is inadequate to the present circumstances, for the following reasons:
• neither healthcare professionals nor Vaccine recipients are being informed by the Defendants, and conditions do not exist ensuring that others will inform them, that the DHHS Secretary “has authorized the emergency use of the [Vaccines]” since they are not being informed of the true meaning of the EUAs, specifically, that the Secretary has not determined that the Vaccines are “safe and effective” (notwithstanding the President’s widely publicized statements to the contrary, which are amplified daily by countless other governmental and private sector statements that the Vaccines are “safe and effective”), and that instead the DHHS Secretary has only determined that he has “reason to believe” that the Vaccines “may be effective” in treating or preventing SARS-CoV-2 and COVID-19, based on trials of the Vaccines that are not being conducted like any previous trials and are compressed, overlapping, incomplete and in many instances conducted by the Vaccine manufacturers themselves;
• neither healthcare professionals nor Vaccine recipients are being informed by the Defendants, and conditions do not exist ensuring that others will inform them, of “the significant known and potential [ ] risks” of the Vaccines, since there is a coordinated campaign funded with $1 billion to extol the virtues of the Vaccines, and a simultaneous effort to censor information about the inefficacy of the Vaccines in preventing or treating SARS-CoV-2 and COVID-19, Vaccine risks, and injuries and deaths caused by the Vaccine;
• Vaccine recipients are not being informed by the Defendants, who have a financial stake in the intellectual property underlying at least one Vaccine, and who have other financial conflicts of interest, and conditions do not exist ensuring that others will inform them, that there are alternatives to the Vaccines and of their benefits;
• Vaccine recipients are not being informed by the Defendants, and conditions do not exist ensuring that others will inform them, of their “option to accept or refuse” the Vaccines, since they have been saturated with unjustified fearmessaging regarding SARS-CoV-2 and COVID-19, psychologically manipulated, and coerced by a system of rewards and penalties that render the “option to [ ] refuse” meaningless; and
• Appropriate conditions do not exist for “the monitoring and reporting of adverse events” since only a fraction (as low as 1%) of adverse events are reported to VAERS by physicians fearing liability, and the Defendants have established a parallel reporting system for COVID-19 that is not accessible by Plaintiffs or the rest of the public.
Professor Hervé Seligmann, an infectious disease expert and biomedical researcher with over 100 peer-reviewed international publications, of the University of Aix-Marseille, has scrutinized the official COVID-19 statistics and figures of Israel, which has vaccinated 63% of its population, and fully vaccinated 57% of its population. Professor Seligmann sees no benefit in vaccinating those under 18, and significant risk of harm:
"There are several theories about why the risk of death is so low in the young including that the density of the ACE2 receptors that the virus uses to gain entry into cells is lower in the tissue of immature animals and this is expected to be true also in humans. However, the vaccines induce the cells of the recipient to manufacture trillions of spike proteins with the pathology described above.
Because immune responses in the young and healthy are more vigorous than those in the old, paradoxically, the vaccines may thereby induce, in the very people least in need of assistance, strong immune responses, including those which can damage their own cells and tissues as well as by stimulating blood coagulation. Experts predict that vaccination will greatly increase the very low COVID-19 risks experienced by the younger population … vaccination-associated mortality risks are expected at least 20 times greater below age 20 compared to the very low COVID19-associated risks for this age group.33"
CDC data indicates that children under 18 have a 99.998% COVID-19 recovery rate with no treatment. This contrasts with over 45,000 deaths (see below) and hundreds of thousands of adverse events reported following injection with the Vaccines. The risk of harm to children may be as high as 50 to 1. Thus, children under 18 are at no statistically significant risk of harm from SARS-CoV-2 and COVID-19. Administering Vaccines to this age group knowingly and intentionally exposes them to unnecessary and unacceptable risks.
Not only is a Vaccine unnecessary in this subpopulation, it is more likely to cause harm. Scientists have observed vaccine-driven disease enhancement in the previously infected. The FDA admits that many people receiving a Vaccine either are or were previously infected with SARS-CoV-2, or have or previously had COVID-19.41 Upon injection with the Vaccines, this population has reported serious medical harm, including death.42 There is an immediately higher death rate worldwide upon receiving a Vaccine, generally attributed to persons having recently been infected with COVID-19. A person who previously had SARS-CoV-2, and then receives a Vaccine, mounts an antibody response to the Vaccine that is between 10 and 20 times stronger than the response of a previously uninfected person. The antibody response is far too strong and overwhelms the Vaccine subject. Medical studies show severe Vaccine side effects in persons previously infected with COVID-19.43 A study published in the New England Journal of Medicine noted antibody titers 10-45 times higher in those with preexisting COVID-19 immunity after the first Vaccine injection, with 89% of those seropositive reporting adverse side-effects.44 This substantial risk is suppressed in mainstream national news. Groups of scientists are demanding improved pre-assessment due to “Vaccine-driven disease enhancement” in the previously infected, a subpopulation which has been excluded from clinical trials. The failure to protect a subpopulation at higher risk, such as this one, is unprecedented. Injecting this subpopulation with the Vaccines, without prescreening, threatens them with immediate, potentially life-threatening harm.
Plaintiffs’ expert Dr. Richard Urso is a fully licensed, board certified, practicing medical doctor (see Declaration of Dr. Richard Urso at Exhibit C). Dr. Urso has treated over 300,000 patients in his career, including over 450 COVID-19 recovered patients. In his professional medical opinion:
"COVID recovered patients are at extremely high risk to a vaccine. They retain an antigenic fingerprint of natural infection in their tissues. They have all the requisite components of immune memory. Vaccination may activate a hyperimmune response leading to a significant tissue injury and possibly death. I have read the Complaint and Motion for Preliminary Injunction in the above captioned matter, specifically the allegations related to the dangers to members of the population who have already had Covid-19. I agree with the allegations contained in the Complaint and Motion for Preliminary Injunction."
Pre-screening can be accomplished in the traditional way by (1) obtaining relevant personal and family medical history including prior COVID-19 symptoms and test results, (2) obtaining antibody and T-Detect testing from indeterminate persons, (3) obtaining rapid PCR screening testing on all persons (using at least the standard cycle thresholds set forth infra). If the prescreening results are positive, the Vaccine candidate must be excluded. The documented risks of indiscriminately injecting this subpopulation with the experimental Vaccines far outweigh the purported benefits.
Plaintiffs’ expert Jane Doe45 is a computer programmer with subject matter expertise in the healthcare data analytics field, and access to Medicare and Medicaid data maintained by the Centers for Medicare and Medicaid Services (CMS) (see Declaration of Jane Doe at Exhibit D). Over the last 20 years, she has developed over 100 distinct healthcare fraud detection algorithms for use in the public and private sectors. In her expert opinion, VAERS under-reports deaths caused by the Vaccines by a conservative factor of at least 5. As of July 9, 2021, VAERS reported 9,048 deaths associated with the Vaccines. Jane Doe queried data from CMS medical claims, and has determined that the number of deaths occurring with 3 days of injection with the Vaccines exceeds those reported by VAERS by a factor of at least 5, indicating that the true number of deaths caused by the Vaccines is at least 45,000 [emphasis in original]. She notes that in the 1976 Swine Flu vaccine campaign (in which 25% of the U.S. population at that time, 55 million Americans, were vaccinated), the Swine Flu vaccine was deemed dangerous and unsafe, and removed from the market, even though the vaccine resulted in only 53 deaths. The gross and willful under-reporting of Vaccine-caused deaths, which is substantiated by Jane Doe’s Declaration, and also by other independent data points considered as part of Plaintiffs’ due diligence, is profoundly important on a number of levels. This evidence increases the likelihood of Plaintiffs’ success on the merits by: (1) making it impossible (a) that the DHHS Secretary can reasonably conclude, as required by § 360bbb–3(c)(2)(B), that “the known and potential benefits of [the Vaccines] outweigh the known and potential risks of [the Vaccines]”, (b) that the DHHS Secretary has succeeded in creating conditions, as required by § 360bbb–3(e)(1)(A)(i)(II) and (ii)(II), that ensure that healthcare professionals and Vaccine candidates are informed of the “significant known and potential [ ] risks” of the Vaccines, and (c) that the DHHS Secretary has succeeded in creating conditions, as required by § 360bbb–3(e)(1)(A)(iii), for the monitoring and reporting of adverse events; and (2) sealing Plaintiffs’ argument that the FDA’s “citizen petition” process (discussed infra in section III(1)) is “inadequate and not efficacious” and that its pursuit by Plaintiffs would have been a “futile gesture” by showing Defendants’ bad faith. The evidence makes it irrefutable that Plaintiffs and others in the public will suffer irreparable injury (discussed infra in section III(2)) if this Motion is denied. Finally, the evidence tilts the balance of hardships and public interest (discussed infra in Section III(3) decisively in favor of Plaintiffs.
Associated foot note 45: Plaintiffs’ expert Jane Doe is a whistleblower who fears for her personal safety and that of her family, and reprisal, including termination and exclusion from her chosen profession for the duration of her working life, for disclosing the evidence contained in her Declaration at Ex. D. Plaintiffs will present the Court with a motion for an appropriately tailored protective order seeking to preserve the confidentiality of Jane Doe’s identity. In the meantime, Defendants are not prejudiced, since they can respond to the substance of Jane Doe’s Declaration and challenge her expert qualification without knowing her true identity. Plaintiffs’ counsel have in their possession a copy of this same Declaration of Jane Doe, signed by the witness in her actual name.
The Court admonished:
"[K]nowing the Flint River water was unsafe for public use, distributing it without taking steps to counter its problems, and assuring the public in the meantime that it was safe “is conduct that would alert a reasonable person to the likelihood of liability.” [ ] [T]aking affirmative steps to systematically contaminate a community through its public water supply with deliberate indifference is a government invasion of the highest magnitude. Any reasonable official should have known that doing so constitutes conscience-shocking conduct prohibited by the substantive due process clause. These “actions violate the heartland of the constitutional guarantee” to the right of bodily integrity…"
The language of this decision ought to send a chill through each of the individually named Defendants, for their conduct — albeit distributing dangerous experimental Vaccines, rather than contaminated water — is effectively a mirror image. This is indisputably so with respect to the under-18 age category, and those previously infected with SARS-CoV-2. Since SARS-CoV-2 / COVID-19 present no statistically significant threat to these subpopulations, the Vaccines can have no therapeutic benefits for them. At the same time, the experimental Vaccines, which have known, dangerous side effects and in some cases are even fatal, expose them to unnecessary and dangerous risks.
The full lawsuit document filed 19th July 2021:
