FRONTLINE DOCTORS EXPOSE UNLAWFUL EUA
Read the full Complaint below. Here is the Introduction
Case 2:21-cv-00702-CLM Document 32-1 Filed 11/04/21 Page 1 of 66
“This challenge will establish that, illegally and in bad faith, the following are true:
▪ The COVID vaccine mandates are unlawful and unconstitutional. Further, Plaintiffs
assert that the declaration of an emergency, issuance of an EUA, current branding of
the COVID-19 vaccines, and mandate of vaccines authorized under said EUA cannot
be supported under the following circumstances which will be demonstrated at trial:
• Over 99.8% of all those infected with COVID survive with the number being far higher
in a vast majority of the population. Even the highest risk population has approximately
a 95% recovery rate which is substantially higher than many other diseases we have
lived with for centuries with no emergency measures taken. (Hence no emergency
▪ Merriam Webster defines an emergency as: an unexpected and usually dangerous
situation that calls for immediate action.1
It is undisputed that COVID-19 will remain
with us forever and thus this is not an emergency. If we allow emergency measures
indefinitely we are constructively amending the Constitution and rewriting legislation
through the use of the emergency declaration.
▪ Those who survive COVID-19 or it’s variants (“COVID”) obtain robust and durable
natural immunity. The natural immunity so obtained is superior to COVID vaccineinduced immunity.
▪ Adequate alternative treatments exist.
▪ The COVID vaccines are ineffective against the Delta strain of COVID, which the
Center for Disease Control (“CDC”) states is the dominant (>99%) strain spreading
throughout the United States.
▪ The CDC Director has acknowledged that the COVID vaccines do not prevent infection
or transmission of COVID: “[W]hat the vaccines can’t do anymore is prevent
transmission.”2 The CDC has also acknowledged that the vaccinated and unvaccinated
are equally likely to spread the virus.
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