LEGAL CASE

In August 2021 I filed a suit in Federal court challenging the constitutionality of the University of California's vaccine mandate on behalf of Covid-recovered individuals, whose natural immunity is equal to (indeed, superior to) vaccine-mediated immunity. Forcing those with natural immunity to be vaccinated introduces unnecessary risks without commensurate benefits--either to individuals or the population as a whole--and violates their rights guaranteed under the equal protection clause of the Constitution's 14th Amendment. Expert witness legal briefs include, among others, a declaration from several highly distinguished UC School of Medicine faculty members from infectious disease, microbiology/immunology, cardiology, endocrinology, pediatrics, OB/Gyn, and psychiatry.

Links to the legal briefs submitted in this case are available below.

LEGAL CASE

P - PLAINTIFF'S COMPLAINT

P - MOTION FOR PRELIMINARY INJUNCTION

P - PLAINTIFF'S DECLARATION

P - DECLARATION UC MEDICAL FACULTY

P - DECLARATION DR. MCCULLOUGH

D - MOL IN OPP TO PI

D - DEF OBJECTION TO PLAINTIFF'S DECLS

D - PROPOSED ORDER

D - CROTTY DECL

D - REINGOLD DECL

D - BYINGTON DECL

D - BOLDEN-ALBADA DECL

D - DE SAINT MAURICE DECL

D - DRAKE DECL

D - KUWAHARA DECL

P - MAIN REPLY TO OPPOSITION

P - PLAINTIFF'S REPLY DEC

P - UC FACULTY REPLY DEC

P - MCCULLOUGH REPLY DEC

P - RISCH REPLY DEC

FDA - FOIA REQUEST PFIZER DATA