Harris 

County 
State of Texas     
 

CRIMINAL COMPLAINT

Case No.

Filed at: Office of Texas Attorney General Ken Paxton

Date filed: 17 January 2022

Filed by: Jack E. Boteler

538 Surf Oaks Drive
Seabrook, TX 77586

I, Jack E. Boteler, a citizen of Seabrook, Harris County, Texas and resident of same together
with all interested parties and subscribed citizens and residents of the United States of
America who received any Emergency Use Authorization investigational injection of
genetic biologic material (mRNA or adenoviral DNA) coding for the Wuhan spike protein
known to be the pathogenic structure of SARS-CoV-2 designed to provoke the human body
to produce antibodies for Covid 19, commonly referred to as the “Covid 19 vaccines,” along
with all persons living with, near or adjacent to any such person or persons in this county
or State (hereinafter the “Complainants”).

V.

Any and all officers and/or directors of the U.S. Department of Health and Human Services
(“HHS”) and affiliates: Food and Drug Administration (“FDA”), National Institutes of Health
(“NIH”), National Institute of Allergy and Infectious Diseases (“NIAID”), Centers for Disease
Control and Prevention (“CDC”), Center for Medicare and Medicaid Services (CMS), all of the
aforementioned hereinafter referred to as “establishment officials”; Dr. Ralph Baric and the
Board of Regents at the University of North Carolina Chappell Hill; Director General Tedros
Adhanom Ghebreyesus of the World Health Organization (“WHO”); Dr. Anthony Fauci; Dr.
Francis Collins; Dr. Rick Bright; Dr. Janet Woodcock, Dr. Peter Daszak; Mr. William Gates Junior;
Mr. Theodore (“Ted”) Turner; Mr. Eli Broad; Mr. George Soros; Dr. Deborah Birx; Mr. Richard A.
Rothschild; any Director or Officer of Moderna Inc.; any Director or Officer of Pfizer, Inc.; any
Director or Officer of Johnson & Johnson Services, Inc.; any Director or Officer of Astra Zeneca
Plc.; any Director or Officer of the Pirbright Institute; any Director or Officer of Johns Hopkins
Bloomberg School of Public Health; any Director or Officer of the World Economic Forum; any
Director or Officer of the Bill & Melinda Gates Foundation; any Director or Officer of the World
Bank; any Director or Officer of the International Monetary Fund (“IMF”); and any other person,
governmental, or non-governmental organization, incorporated or not, including U.S. and
international media outlets that / who knowingly aided and abetted the denial or restriction of
access to therapeutic treatments for the Sars-CoV-2 virus and / or promoted or distributed
Emergency Use Authorization (EUA) experimental gene therapy injections commonly referred
to as “Covid 19 Vaccines” (collectively, the “Defendants”)
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CRIMINAL COMPLAINT
 JURISDICTION & STATUTORY AUTHORITY
 THEORY OF THE CASE
 FACTUAL ALLEGATIONS – VIRUS ORIGINS
 FACTUAL ALLEGATIONS – VACCINE DEVELOPMENT & PROMOTION
 FACTUAL ALLEGATIONS – HOSPITALIZATIONS & CENSORED THERAPEUTICS &
PHYSICIAN PEROGATIVES
 FACTUAL ALLEGATIONS – POST VACCINATION REACTIONS & DEATHS
 IN RELATION TO DEFENDANT VACCINE MANUFACTURERS: THEIR TRIALS,
OFFICERS, DIRECTORS & CONSPIRATORS
 PUBLICLY AVAILABLE OPINIONS of MEDICAL DOCTORS and BIO‐SCIENTISTS
 CONCLUSION

JURISDICTION & STATUTORY AUTHORITY

1. This Criminal Complaint contemplates numerous defendants some of which are

corporate, trusts, affiliations, governmental and non-governmental entities; each such
legal or natural person has minimum contacts in this state and/or county and legal status
or representation to effectuate assertion of jurisdiction of the State of Texas Attorney
General in order to investigate, prosecute and try these defendants pursuant to the legal
authority and jurisdiction(s) below sequenced:

a) At all material times as alleged herein one or more defendants was either
physically present in this jurisdiction, had an “agent” (as defined in 22 U.S. Code
§ 611) resident in this jurisdiction, had a Permanent Establishment (supra) in
this jurisdiction or committed acts for which local minimum contacts standards
for application of jurisdiction are waived by statute, convention, common or
international law.

b) For the preponderance of Crimes alleged and exhibited herein, there is no

Statute of Limitations and state law allows for the assertion of jurisdiction over
the subject matter where reasonable and compelling facts are present, 212 F.3d
885 (5thCir. 2000) et seq.

c) Crimes alleged herein provide minimum contacts for equivalent state and
federal crimes pursuant to 18 U.S.C. § 3235 & supplemental jurisdiction under
28 U.S.C. 1367 (1994).

d) Criminal cases, where compelling state interests are at issue, provide

state, sovereign or local jurisdiction. See Holt v. Hobbs, 574 U.S. 352
(2015).
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e) This complaint is brought pursuant to 50 U.S.C. § 2441 et seq. under the

Universal Jurisdiction provisions, which allow “any State” or instrumentality
thereof to prosecute Crimes Against Humanity;

f) Jurisdiction and venue are also proper under 18 USC §175 et Seq. in relation to
Prohibitions with Respect to Biological Weapons;
g) Universal jurisdiction (State, County, City and Federal) is provided by 18 USC §
1091(e) in relation to Genocide;

h) Universal and local jurisdiction is provided by Articles 3, 4 & 5 of the Convention

on the Non-Applicability of Statutory Limitations to War Crimes and Crimes
Against Humanity per 18 USC § 2441 et seq.
i) Universal and local jurisdiction is provided by the Convention on the
Prevention and Punishment of the Crime of Genocide as further codified
under 18 USC § 1091 irrespective of limitations imposed by 18 USCS §
3282];
j) Local Jurisdiction is provided by Texas State statute in relation to Homicide (all
forms, degrees and levels of intent);

k) Local Jurisdiction is provided by Texas State statute in relation to Attempted

Homicide (any degree or similarly named crime in state statutes);
l) Local Jurisdiction is provided by Texas State statute in relation to Criminal
Assault (any degree or similarly named crime in the State statutes);
m) Local Jurisdiction is provided by Texas State statute in relation to Fraud in
Connection with Major Disaster or Emergency Benefits (any degree or
similarly named crime in the State statutes);

n) Probable Cause exists based on the facts, affidavits and exhibits presented
herein to believe that one or more crimes was committed by one or more actors
in this locality and therefore subjects all other Defendants to local jurisdiction
by virtue of the Felony Murder Rule. (MODEL PENAL CODE note 3, § 210.2 at
31 n.74.)

o) Reasonable Suspicion exists, based on the facts, affidavits and exhibits

presented herein to believe that one or more crimes were committed by parties,
actors and persons within this jurisdiction to initiate an investigation into the
allegations recited herein.

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THEORY OF THE CASE

2. This Complaint alleges murder and crimes against humanity arising from a collection
of facts, observations, expert opinions, media reports and eye-witness testimony. It will
show that Defendants planned and executed, jointly and/or severely, the development
and release of a bio warfare toxin, referred to herein as either “SARS-CoV-2” or “Covid
19” and/or as the ‘Spike Protein’ component with the dual objectives of: 1) global
depopulation, and 2) population control leading to a one-world government by
inducing panic, economic hardship, terror, death and injury to global populations.

By employing psychological warfare mechanisms, including but not limited to media

reports, public policy, coercion, deceit, mandates, bribes, travel restrictions,
employment restrictions, free speech restrictions and liberty restrictions, this
complaint will also show that Defendants seek to induce the global population into
receiving a pre-planned experimental gene therapy commonly referred to as “Covid 19
Vaccines” in furtherance of their aforementioned objectives.

The data, evidence, testimony, articles and interviews provided herein amount to a
small fraction of demonstrable / evidentiary material, including but not necessarily
limited to: effectiveness, side effects, drugs, hearings, false attributions, vaccine
ingredients, lawsuits (past and pending), immunity, and liability.

FACTUAL ALLEGATIONS – VIRUS ORIGINS

3. The sequence of dates and times may not follow a linear path in the presentation of the
FACTS as stated hereinafter, because events contributing to the crimes enumerated
herein are vast, international in scope and occurred over the course of many years
involving numerous defendants, criminal actors, conspirators and collaborators.

4. Dr. Anthony Fauci was appointed Director of the NIAID in 1984. In 1986 Fauci took the
first steps toward creating human dependency on vaccines by lobbying for legislation
to relieve big pharma of liability through what became the ‘Emergency Use
Authorization’.

https://www.bitchute.com/video/IWWRK0fYk5SU/

5. In 1994 David Rockefeller opined on the need to end self-rule government.

https://www.lewrockwell.com/2017/03/no_author/david-rockefellers-chilling-
speech-bilderberg/

6. Addressing the U.N. General Assembly three years later, in 1994 David Rockefeller
implored his audience of the imperative of world population control.

https://www.lewrockwell.com/2017/03/no_author/david-rockefellers-chilling-
speech-bilderberg/

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7. In 1998 Dr. Fauci funded research at the University of North Carolina Chappell Hill
(UNC) following Dr. Ralph Baric’s clone of the Corona Virus and amplifying the
pathogenic “Spike’ Protein. In 1999 the Coronavirus was engineered as a bioweapon,
paid for by Fauci through NIAID. It was later patented by UNC as the Sars Corona Virus
in 2002, a full year before anyone ever heard the name, Sars.

https://www.bitchute.com/video/IWWRK0fYk5SU/ ;

https://principia-scientific.com/covid-pandemic-was-planned-in-2015-by-gang-of-
rico-conspirators/ ;

https://www.bitchute.com/video/IWWRK0fYk5SU/

8. In or about May 2010, the Rockefeller Foundation and Global Business Network
published Scenarios for the Future of Technology and International Development, which
outlines a scenario whereby World powers utilize a global pandemic, naturally
occurring or man-made, that presents an opportunity to technocratically control
humanity and reduce the size of the global population. See: LOCK STEP Scenario,
Narratives, A world of tighter top‐down government control and more authoritarian
leadership, with limited innovation and growing citizen pushback (page 18). Said
publication provided the framework and methodology for the planning and
preparation of a planned bio warfare attack on the global population now affecting
every person in every country and in every location on the planet, thus proving motive
or the mens rea element for the crimes alleged herein.

https://principia-scientific.com/2010-rockefellers-operation-lockstep-predicted-
2020-lockdown/

https://www.centerforhealthsecurity.org/news/center-news/2017/2017-10-
23_spars-scenario.html

9. Though framed in less sinister terms, in a meeting convened by Bill Gates on or about
1 March 2013, persons including but not limited to: Dr. Anthony Fauci, Mr. Eli Broad,
Mr. Theodore (Ted) Turner, Mr. Warren Buffet, Ms. Oprah Winfrey, Mr. George Soros,
Mr. William Gates Jr., and other Defendants met in New York for the purpose of
planning mass reduction of the World’s population, as evidenced in part by the
presence of Dr. Fauci, the only non-billionaire believed there present.

https://www.wsj.com/articles/BL-WHB-1322;

https://www.telegraph.co.uk/finance/newsbysector/banksandfinance/5363613/Op
rah-Winfreys-charity-challenge.html;

https://www.thetimes.co.uk/article/billionaire-club-in-bid-to-curb-overpopulation-
d2fl22qhl02;

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https://fort-russ.com/2020/04/bill-gates-and-the-depopulation-agenda-rfk-jr-calls-
for-an-investigation/

10. On or about 17 February 2017, Defendant Gates predicted a world-wide pandemic at
the 53 Munich Security Conference stating, “Bioterrorism has become feasible enough
that a genetic engineer could use computers to create a synthetic airborne pathogen
capable of wiping out a fraction of the world’s population quickly. The next epidemic
could originate on the computer screen of a terrorist intent on using genetic
engineering to create a synthetic version of the smallpox virus, or a super contagious
and deadly strain of the flu. [emphasis added]”.

https://www.huffpost.com/entry/bill-gates-warns-that-a-devastating-pandemic-is-
right-around-the-corner_n_58a889a7e4b045cd34c22c71

11. On or about 9 November 2015 Defendant Baric published A SARS-like Cluster of

Circulating Bat Coronaviruses Shows Potential for Human Emergence, which was the
result of his research to create such a virulent disease with manufactured “gain-of-
function” in order to increase transmissibility. Said report was directed and sent to
Defendant Fauci, stating in part: “Having established that the SHC014 spike has the
ability to mediate infection of human cells and cause disease in mice, we next
synthesized a full-length SHC014-CoV infectious clone based on the approach used for
SARS-CoV.”

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4797993/

12. On or about 9 November 2015, in the same scientific paper titled A SARS-like Cluster
of Circulating Bat Coronaviruses Shows Potential for Human Emergence, Defendant
Baric states: “to examine the emergence potential (that is, the potential to infect
humans) of circulating bat CoVs, we built a chimeric virus encoding a novel, zoonotic
CoV spike protein . . . Using this approach, we characterized CoV infection mediated by
the SHC014 spike protein in primary human airway cells and in vivo and conclude these
results confirm that the DIV vaccine would not be protective against infection with
SHC014 and could possibly augment disease in the aged‐vaccinated group.”
[Emphasis added].

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4797993/

13. Between January 2014 and December 2020, Defendant Fauci, along with other named
and unnamed Defendants through their instrumentalities, including but not limited to
the National Institutes of Health, EcoHealth Alliance and the Department of Health and
Human Services, provided samples of bio warfare agents and funding to the Wuhan
level 4 biolab for the purpose of continuing “gain-of-function” research. Though Fauci
told congress under oath that the purpose was not gain-of-function, evidence would
later prove he lied.

https://www.thesun.co.uk/news/15069561/fauci-admits-us-sent-600k-wuhan-lab-
covid/;
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https://www.theepochtimes.com/mkt_breakingnews/newly-released-documents-
detail-us-funded-coronavirus-research-at-wuhan-institute-of-virology-
report_3984829.html?utm_source=News&utm_medium=email&utm_campaign=break
ing-2021-09-07-
1&mktids=aa419e5baa3f48d215373eefc5a526fa&est=pdeO%2FPtXLKf8aKkmrE00G
WRUpopYL3T84p9ndaAtbRQxTO19jsi4paTQ2OGr

https://www.theepochtimes.com/mkt_breakingnews/newly-released-documents-
detail-us-funded-coronavirus-research-at-wuhan-institute-of-virology-
report_3984829.html?utm_source=News&utm_medium=email&utm_campaign=break
ing-2021-09-07-
1&mktids=aa419e5baa3f48d215373eefc5a526fa&est=pdeO%2FPtXLKf8aKkmrE00G
WRUpopYL3T84p9ndaAtbRQxTO19jsi4paTQ2OGr

https://www.msn.com/en-us/health/medical/nih-admits-to-funding-gain-of-
function-research-in-wuhan-says-ecohealth-violated-reporting-requirements/ar-
AAPNb5m?ocid=winp-
sf&fbclid=IwAR3t8oZQ2kxjx5ci2GThHu9TVI5XGbn34HicVzX8Mwl6tS9qtqCzomfZbM
0

14. In 2014 Dr. Anthony Fauci sent a letter to UNC acknowledging that its research was
“gain-of-function”, again a point about which he would later lie in Congressional
testimony. DOD documents discovered in a “Top Secret Shared Drive” likewise prove
Fauci’s knowledge of and support for gain-of-function research.

https://www.bitchute.com/video/IWWRK0fYk5SU/;

https://www.msn.com/en-us/news/politics/nih-admits-fauci-lied-about-funding-
wuhan-gain-of-function-experiments/ar-AAPLZIe ;

https://www.projectveritas.com/news/military-documents-about-gain-of-function-
contradict-fauci-testimony-under/

15. In 2015, Defendant Gates stated, “that an infectious disease pandemic posed a greater
threat to the world than nuclear war;” and that “If anything kills over 10 millionpeople
over the next few decades, it’s most likely to be a highly infectious virus rather than a
war — not missiles, but microbes.”

https://www.rev.com/blog/transcripts/bill-gates-ted-talk-transcript-from-2015-
warns-of-pandemics-epidemics ;

https://pubchem.ncbi.nlm.nih.gov/patent/US-7776521-B1#section=Inventor

16. In 2015, Dr. Peter Daszak, then CEO of EcoHealth Alliance, in an address to the National
Academy of Science, spoke on the need to promote a major pandemic, saying that “until
an infectious disease crisis is very real, present, and at an emergency threshold it is often
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Harris County 
State of Texas     
ignored. To sustain the funding base beyond the crisis, he said, we need to increase public
understanding of the need for MCM’s such as a pan‐influenza or pan‐coronavirus vaccine.
A key driver is the media, and the economics follows the hype. We need to use that hype
to our advantage to get to the real issues. Investors will respond if they see profit at the
end of the process”.

https://principia-scientific.com/covid-pandemic-was-planned-in-2015-by-gang-of-
rico-conspirators/

17. In 2016 UNC announced that the Sars Coronavirus was poised for human immersion,
referencing the Wuhon Viral Institute.

https://www.bitchute.com/video/IWWRK0fYk5SU/

18. On or about 17 January 2017, Defendant Fauci met with and warned the newly elected
President Trump, “There is no question that there will be a challenge to the coming
administration in the arena of infectious diseases,” further stating, “The thing we’re
extraordinarily confident about is that we are going to see this in the next few years.”

https://www.huffpost.com/entry/fauci-warned-of-trump-pandemic-
2017_n_5e8a0548c5b6e7d76c65c8a4

19. In February 2017, just two to three weeks after his inauguration, Dr. Fauci foretold of
President Trump having to deal with a major, global pandemic during his first term in
office.

https://www.youtube.com/watch?v=puqaaeLnEww

20. On or about 23 March 2019, Defendant WHO declared and published its first “Situation
Report” thereby triggering the claim against a $500,000,000 Pandemic Insurance
Financing Bond issued by Defendant World Bank for the purpose of ratifying the
pandemic declaration and payment of funds to other named and unnamed Defendants,
including payments made or recovered pursuant to Covid 19 PCR test kits patented and
previously sold or financed in 2015 and 2018 respectively, one to five years prior to
the renaming of SARS-COV-2’s official designation as Covid 19.

https://foreignaffairsintelligencecouncil.files.wordpress.com/2021/02/rothschilds-
patented-covid-19-biometric-tests-in-2015.-and-2017.pdf ;

(original link deleted)
https://wits.worldbank.org/trade/comtrade/en/country/ALL/year/2018/tradeflow/
Imports/partner/WLD/nomen/h5/product/382 ;

https://www.who.int/emergencies/diseases/novel-coronavirus-2019/donate

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21. On or about 18 October 2019, associates of the named and unnamed Defendants caused
the release of the manufactured SARS-COV-2 Coronavirus in Wuhan, China at the 7th
CISM Military World Games, intentionally or with such wanton disregard for human
life that homicidal intent is inferred through the knowledge and malice aforethought of
the implications and ramifications on global health and world populations by means of
the enhanced transmissibility and virulent, harmful, deadly and contagious features of
the bioweapon later named officially by Defendants as the “Covid 19 Virus”.

https://www.news.com.au/world/coronavirus/leaked-chinese-document-reveals-a-
sinister-plan-to-unleash-coronaviruses/news-
story/53674e8108ad5a655e07e990daa85465

22. In or about January 2020, named and unnamed Defendants together with their
conspirators and collaborators caused the Covid 19 Virus to be transmitted into the
United States with knowledge and malice aforethought for the purpose of creating and
declaring a Global Pandemic as defined by the World Health Organization pursuant to
the International Health Regulations 2005 as amended and pursuant tothe provisions
of Global Preparedness Report of 2019.

https://www.who.int/ihr/9789241596664/en/ ;

https://www.foxnews.com/media/chinese-virologist-government-intentionally-
coronavirus

23. On or about March 11, 2020, Defendants Dr. Fauci and NIH were made aware of the
fabricated nature of the Covid 19 Virus when Virologist Adam Gaertner sent an email
containing the exact manufacturing process by which the Covid 19 was created,
including components designed to impair or obstruct normal immunological response.
The mechanism by which the Virus was created (“cookbook”) was available to
Defendants Fauci and NIH for investigation and analysis at the very beginning of the
intentional outbreak in the United States; yet Defendants along with their co-
conspirators maintained the narrative that the Virus was naturally occurring until June
of 2021. It was Defendants Fauci, NIH, Baric, Collins, Daszak and others that funded,
collaborated and disguised the Virus in an effort to ensure their stated goals and
warning to President Trump; “The thing we’re extraordinarilyconfident about is that
we are going to see this in the next few years”.

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4797993/ ;

https://www.huffpost.com/entry/fauci-warned-of-trump-pandemic-
2017_n_5e8a0548c5b6e7d76c65c8a4

24. Newly released emails show that Drs. Anthony Fauci and Francis Collins pressured a
group of scientists to abandon their intention to publish a report refuting the premise
of a naturally occurring virus, raising instead the possibility that it was “genetically
manipulated” and likely leaked from the Wuhon Laboratory.

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https://thefederalist.com/2022/01/13/fauci-collins-pressured-scientists-to-
abandon-paper-on-covid-origins-and-potential-wuhan-lab-leak/

https://www.youtube.com/watch?v=sD0i_YxPATc

25. Other evidence of attempted cover up include testimony by former Chinese Scientist
Dr. Li-Meg Yan, emails released through FOIA efforts exposing government efforts to
hide conversations between scientists, and the disclosure of emails that show Fauci and
other health officials sought to promote the natural origin theory despite having
evidence and internal expert opinions that pointed to the possibility of a leak from the
Wuhan lab.

https://www.foxnews.com/world/chinese-virologist-coronavirus-cover-up-flee-
hong-kong-whistleblower

https://www.dailymail.co.uk/news/article-10052689/Government-condemned-
refusing-release-details-key-email-conversations-Covid-
origins.html?fbclid=IwAR3An7M1Fqrm1oMhcMtblhbUP0KmTAdi-
CrtjuJELJud5p_OA7J1tExWMI0

https://www.theepochtimes.com/mkt_morningbrief/fauci-was-told-privately-by-
key-scientists-that-natural-origin-was-highly-unlikely-newly-unredacted-emails-
confirm_4207003.html?utm_source=Morningbrief&utm_medium=email&utm_campai
gn=mb-2022-01-
12&mktids=d1e62fbaafc1a1101bd7071f31bb0874&est=Zgo%2FQaWCqYHhhafSXyJ
MmRzJbZU0NpbOhlU1bRkJj14ZO%2Fpla3QM5%2FE3vW3m

26. In  or  about  December  2021,  referencing  books  by  Drs.  Pam  Popper  and  Peter  Breggin,  Dr.  Peter 
McCullough, in an interview with Joe Rogan, claims the existence of proof that the entire pandemic 
was  planned,  coordinated  and  perpetrated  on  the  people  to  induce  the  people  to  accept  the 
experimental vaccines. 
 
https://www.redvoicemedia.com/2021/12/theres-proof-the-pandemic-was-coordinated-
planned-effort-for-mass-vaccination-dr-mccullough-video/ 
 
 
FACTUAL ALLEGATIONS – VACCINE DEVELOPMENT & PROMOTION

27. On or about October 24, 2021, Bayer Pharmaceuticals CEO Stefan Oelrich, in a
presentation at the World Health Summit in Berlin, Germany, shared with international
“experts” from academia, politics, and the private sector that the novel mRNA COVID
vaccines are actually “cell and gene therapy” that would have otherwise been rejected
by the public if not for a “pandemic” and favorable marketing.

https://www.lifesitenews.com/news/bayer-executive-mrna-shots-are-gene-therapy-
marketed-as-vaccines-to-gain-public-trust/

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28. On or about September 18, 2019, the WHO published a “Worldwide Exercise in the
Release of Respiratory Pathogens”, to facilitate a worldwide acceptance of a vaccine.

https://www.bitchute.com/video/IWWRK0fYk5SU/

29. On or about September 19, 2019, then President Donald Trump signed an Executive
Order laying out a pathway for the “Warp Speed” development of a vaccine. Dr. Fauci
would later tell congress on or about December 4, 2019, that the President’s E.O. gave
him authorization to make the mRNA vaccine.

https://www.bitchute.com/video/IWWRK0fYk5SU/ ;

30. In or about October 2019, Defendants Gates, Fauci, Brix, the NIH, CDC and WHO,
together with associated conspirators planned, orchestrated and conducted Event 201
whereby they practiced their global and industry-wide response to their criminal
enterprise.

https://www.centerforhealthsecurity.org/event201/about

31. On or about September 2015, Defendants Richard A. Rothschild & the Pirbright
Institute developed and patented the “Covid 19” Polymerase Chain Reaction (“PCR”)
test kit, four and a half years before the discovery of the Novel Corona Virus SARS 2,
later renamed “Covid 19” in March of 2020.

https://foreignaffairsintelligencecouncil.files.wordpress.com/2021/02/rothschilds-
patented-covid-19-biometric-tests-in-2015.-and-2017.pdf ;

http://stateofthenation.co/?p=7130 ;

https://raypeatforum.com/community/threads/cdc-lowers-pcr-ct-count-and-
diagnostic-guidelines-only-for-the-vaccinated.40549/

32. In or about January 2018, the World Bank, together with its affiliated financing
subsidiaries and associated entities, including the International Monetary Fund
(“IMF”), financed the purchase of Covid 19 Polymerase Chain Reaction (“PCR”) Test kits
for more than 50 countries world-wide. Said kits were specifically for the purpose of
diagnosing Covid 19, which was a disease that did not exist in 2018 and the Novel
Corona Virus SARS 2 was not named as “Covid 19” until March of 2020; yet the World
Bank not only financed the acquisitions of the tests but referenced them as being used
to detect “Covid 19”, a heretofore undefined disease.

(original link deleted)

https://wits.worldbank.org/trade/comtrade/en/country/ALL/year/2018/tradeflow/
Imports/partner/WLD/nomen/h5/product/382

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33. On or about 24 December 2020, Defendants WHO, CDC, NIH, among others,
fraudulently and intentionally caused governments, ministries, hospitals and global
health services to mandate the use of ineffective face masks and utilize and incorporate
the use of knowingly ineffective PCR tests among the global population for the purpose
of inciting fear, terror and coercion among the complainants. In fact,the inventor of the
PCR test stated, “Anyone can test positive for practically anything with a PCR
test, if you run it long enough”.

https://stephenlendman.org/2021/04/pcr-tests-dont-work-and-risk-
harm/;

https://www.cdc.gov/media/releases/2020/s1224-CDC-to-require-
negative-test.html

34. In or about October 2020, three of the world’s top-tiered Epidemiologists: Drs. Martin
Kulldorff, Professor of Medicine Harvard University and a biostatistician at Brigham
and Women’s Hospital; Sunetra Gupta, Professor of Theoretical Epidemiology Oxford
University; and Jay Bhattacharya, Professor of Medicine Stanford University, along with
forty-three initial co-signers (and as of this compliant now just under one million)
imploring establishment officials to focus their approach on those at greatest risk,
exposing in the process the societal consequences of a mass approach. Emails since
released in a Congressional House staff report show that both Dr. Anthony Fauci and
former NIH Director, Francis Collins, conspired to discredit the Barrington Declaration
and disparage its authors by pushing for a fresh round of lockdowns.

www.gbdeclaration.org

https://www.theepochtimes.com/new-emails-reveal-evidence-of-government-
efforts-to-suppress-free-
speech_4171310.html?utm_source=News&utm_campaign=breaking-2021-12-22-
1&utm_medium=email&est=NADAxH1Z25TmdFef444ksyIimQBNauqsNULV%2ByJW
5iWpkMDD9zlvPgDQXDUc

FACTUAL ALLEGATIONS – HOSPITALIZATIONS & CENSORED THERAPEUTICS & PHYSICIAN
PEROGATIVES

35. In or about September 2021, an international group of about 3,000 physicians and
scientists signed a declaration Friday accusing COVID-19 policy makers of “crimes
against humanity” for preventing the use of life saving treatments on their patients.

https://humanevents.com/2021/09/27/3000-doctors-scientists-accuse-covid-policy-makers-of-
crimes-against-humanity/

36. A ‘Frontline Physician’ explains that between the financial inducements of the “CARES
Act” and Patient Rights waivers granted by the Center for Medicare and Medicaid
Services (CMS).
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https://www.facebook.com/watch/?v=815270466322332&aggr_v_ids%5b0%5d=81527046
6322332&aggr_v_ids%5b1%5d=270284701862862

https://en.wikipedia.org/wiki/CARES_Act#:~:text=The%20Coronavirus%20Aid%2C%20Rel
ief%2C%20and%20Economic%20Security%20Act%2C,of%20the%20COVID-
19%20pandemic%20in%20the%20United%20States.

37. In or about December 2021, Dr. Vladimir Zelenko, New York Physician who treated
President Donald Trump. Brazil’s Jair Bolsonaro and Israel’s Benjamin Netanyahu,
explains how early Covid treatments were sabotaged in 2020 by former BARDA Director
Dr. Rick Bright collaborating with Dr. Janet Woodcock, current Director of the FDA, in
contravention to the Executive Order issued in 2020 by then President Donald Trump
to make Hydroxychloroquine universally available.
 
https://www.redvoicemedia.com/video/2021/12/dr‐zelenko‐exposes‐how‐early‐covid‐treatments‐ 
were‐sabotaged‐by‐dr‐rick‐bright‐killing‐masses/?utm_source=daily‐email&utm_medium=email 
 
38. In or about June 2020 the Association of American Physicians and Surgeons (AAPS) sued the FDA to  
end its arbitrary restrictions on Hydroxychloroquine. 
  
https://aapsonline.org/hcqsuit/
 

 
39. In or about March 2021, Dr. Peter McCullough, in testimony before the Texas Senate,
explained how the denial of therapeutic drug treatments resulted in the hospitalizations
and subsequent deaths of thousands of people.

https://www.youtube.com/watch?v=QAHi3lX3oGM    

40. In or about July 2020 a group of American physicians on the steps of the U.S. Capitol held
a press conference to address the censorship of therapeutic drugs for the treatment of
the Covid virus.
 
https://www.breitbart.com/politics/2020/07/28/watch‐live‐silenced‐frontline‐doctors‐hold‐capitol‐
 

hill‐press‐conference‐to‐challenge‐big‐tech/?fbclid=IwAR3JsFMDemrPWXpXtnmyvB5DxRzhjBGqpob_  

 
idRLYOaYawicfbR‐27ffKXI  

41. In and around the dates of September 2020 to May, 2021, named and unnamed
Defendants, including but not limited to the CDC, WHO, NIH, fraudulently coerced,
mandated, tricked and conducted a criminal scheme to increase the fear and terror
among the global population by economically rewarding hospitals, physicians,
governments, ministries and health service providers with pecuniary rewards up toUS
$400,000 per case for diagnosing substantially all sickness, morbidity and fatalities as
being caused by Covid 19.

https://www.cdc.gov/coronavirus/2019-ncov/travelers/testing-international-air-
travelers.html;
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State of Texas     

https://www.ahcancal.org/Survey-Regulatory-Legal/Emergency-
Preparedness/Documents/COVID19/Testing-Requirements-FAQs.pdf

42. On or about 22 August 2005, Defendant Fauci and Defendant NIH declared
Hydroxychloroquine (HCQ) a ‘wonder drug’ for the treatment of SARS-COV-1 and MERS,
stating in The Virology Journal (Defendant NIH’s publication) that “Chloroquine is a
potent inhibitor of SARS Coronavirus spread.” Yet, on or about July 30, 2020, Defendant
Fauci testified to Congress that Hydroxychloroquine has “no therapeutic effect” on
Covid 19.

https://news.yahoo.com/fauci-shoots-down-flawed-hydroxychloroquine-
183931215.html

43. On or about 20 January 2021, Defendants Fauci and NIH publicly dismissed and
subverted the use of Ivermectin, a known and generic antiviral medication that clinically
demonstrated a significant reduction in Covid 19 viruses within a 48-hour period.
Congressional testimony by Dr. Pierre Kory in December 2020 reported a substantial
success rate using Ivermectin as both a prophylactic and cure after conducting a review
of dozens of peer reviewed trials, studies and publications.

www.bitchute.com/video/YnSppbsgDBYS/

https://www.medsearchuk.com/controversy-flares-over-ivermectin-for-covid-19-
controversy-flares-over-ivermectin-for-covid-19/ ;

https://www.thegatewaypundit.com/2021/06/smoking-gun-fauci-lied-millions-
died-fauci-informed-hydroxychloroquine-worked-lied-public-instead-despite-
science-fauciemails/

44. On or about January 31, 2020, Defendants Fauci, Collins, Farrar and Daszak conspired
to and did conduct a fraudulent clinical trial, in response to positive reports about the
benefits of HCQ, wherein they overdosed patients with Hydroxychloroquine for the
purpose of creating a published report discounting the drug’s efficacy and labeling it
dangerous and deadly; said conspiratorial conduct, including the publishing of
fraudulent results in several peer-reviewed scientific journals, including The Lancet and
Nature, is now revealed in their own notes, emails and documents pursuant to a
Freedom of Information Act request by and published by Buzzfeed. See also disclosure
of same by Dr. Vladimir Zelenko.

https://www.childrenshealthdefense.org/defender/fauci-emails-top-public-health-
officials-lies-covid-origin-treatments/ ;

https://www.redvoicemedia.com/video/2021/12/dr-zelenko-exposes-how-early-
covid-treatments-were-sabotaged-by-dr-rick-bright-killing-
masses/?utm_source=daily-email&utm_medium=email
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State of Texas     

(link since deleted)

https://www.msn.com/en-us/health/medical/fda-denies-henry-ford-s-request-for-
hydroxychloroquine-approval/ar-BB17VGtg

45. In or about March 2020, Dr. Rick Bright, former Director of the Biomedical Advance
Research and Development Authority (BARDA), in a conspiracy with Dr. Janet
Woodcock, current Director of the FDA, sought to thwart an Executive Order issued by
then President Donald Trump to make HCQ universally available by designating it as an
“Emergency Use Authorization” (EUA) treatment available only to hospitalized patients.

https://www.redvoicemedia.com/video/2021/12/dr-zelenko-exposes-how-early-
covid-treatments-were-sabotaged-by-dr-rick-bright-killing-
masses/?utm_source=daily-email&utm_medium=email

46. On November 19, 2020, testifying before the Senate Homeland Security Committee
Hearing on COVID‐19 Outpatient Treatment, Dr. Peter McCullough (Epidemiologist,
Cardiologist and Professor of Medicine at Texas A&M University, who opines frequently
as an expert on the useof antiviral medications for the treatment of Covid 19 infections
and prevention) described in detail the success of the antiviral medications, clinical
studies and treatment protocols that were saving lives at the time. Dr. McCullough
also provided statistical data in his testimony to the US senate that 50% of the
American lives lost could have been saved with early treatment (4-6 drugs in
combination). On March 10, 2021, Dr. McCullough testified in the Texas Senate that 85%
of the lives lost could have been saved since “we had evolved better treatment
programs.” The current estimate is 85% of lives lost could have been saved, according
to Dr. McCullough.

https://www.authorea.com/users/414448/articles/522499-sars-cov-2-mass-
vaccination-urgent-questions-on-vaccine-safety-that-demand-answers-from-
international-health-agencies-regulatory-authorities-governments-and-vaccine-
developers

https://www.theepochtimes.com/dr-mccollough-says-outpatient-treatments-for-
covid-19-have-been-
suppressed_4189353.html?utm_source=News&utm_campaign=breaking-2022-01-
03-
3&utm_medium=email&est=wtsFuGXW3lJTnP3Flc6%2FaVqfraBrKTCsD0gbjRLHWzS
5aSoBYgBCYKN%2FyTyd

47. The aforementioned testimony patently contradicted the subversive messaging and
publications Defendants Fauci, Daszak, Collins and Farrar orchestrated withtheir co-
conspirators. Effectively, no policy change resulted even after a redaction by said
publications as it relates to the conduct of the Defendants aforementioned; and, the
FDA persisted in its banning of the emergency use of HCQ as a treatment
alternative.

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https://ratical.org/PandemicParallaxView/DrMcCulloughC19OutpatientTreatmnt.ht
ml;

https://www.nejm.org/doi/full/10.1056/NEJMoa2012410

48. On or about September 2021, an international group of about 3,000 physicians and
scientists signed a declaration Friday accusing COVID-19 policy-makers of “crimes
against humanity” for preventing the use of life saving treatments on their patients.

https://humanevents.com/2021/09/27/3000‐doctors‐scientists‐accuse‐covid‐policy‐makers‐of‐crimes 
against‐humanity/ 

49. On or about September 28, 021, Ontario Physician Dr. Patrick Phillips, speaks out about
authorities shutting down his practice for violating Covid protocol.

https://brightlightnews.com/full‐interview‐dr‐patrick‐phillips‐the‐war‐against‐medical‐tyranny/ 

50. In or about December 2021, Dr. Peter McCullough questions why governments and
public health officials around the world have put little to no emphasis on outpatient
treatments in their efforts to fight the COVID-19 virus, instead promoting a massive
effort on vaccines.

https://www.theepochtimes.com/dr-mccollough-says-outpatient-treatments-for-covid-19-
have-been-suppressed_4189353.html?utm_source=News&utm_campaign=breaking-2022-01-
03-
3&utm_medium=email&est=wtsFuGXW3lJTnP3Flc6%2FaVqfraBrKTCsD0gbjRLHWzS5aSoBYg
BCYKN%2FyTyd

FACTUAL ALLEGATIONS – POST VACCINATION REACTIONS AND DEATHS

51. As of May 28, 2021, the Vaccine Adverse Reaction Reporting System details in excess of
5,100 fatalities and more than 294,000 Serious Adverse Events (“SAE”) and serious
injuries resulting from all four mRNA vaccines produced by the Defendant
Manufacturers. It is worth noting that the VAERS system collects only a fraction of the
actual injuries or fatalities, in this instance by an estimated 4 to 5 times according to Dr.
Peter McCullough.

https://cleverjourneys.com/2021/05/31/serious-adverse-events-after-covid-
vaccines-soar-for-12-17-year-olds/ ;

https://www.openvaers.com/covid-data ;

https://childrenshealthdefense.org/defender/vaers-data-deaths-reported-following-
covid- vaccines/?utm_source=salsa&eType=EmailBlastContent&eId=d7469d69-4a7b-
4b6b-9134-

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https://www.redvoicemedia.com/2021/12/shocking-vaers-data-jab-injuries-deaths-
nears-1-million-underreported-4-5x-dr-peter-mccullough-video/?utm_source=daily-
email&utm_medium=email

52. In or about June 2021, CDC VAERS data reports a spike > 5,000 mRNA vaccine deaths;
the Swine Fly Vaccine was pulled at a reported 26 deaths.
https://coronanews123.wordpress.com/2021/06/12/possible‐related‐mrna‐injection‐deaths‐spike‐
over‐5800‐swine‐flu‐vax‐was‐shut‐down‐after‐25‐deaths/ 

53. In or about February 2021, CDC data revealed that the Covid Vaccines are about 18K%
more deadly than Flu Vaccines.

https://greatmountainpublishing.com/2021/02/17/cdc‐data‐reveals‐that‐the‐covid‐19‐vaccines‐
are‐18000‐more‐deadly‐than‐the‐flu‐vaccines/

54. On or about August 25, 2021, it was reported that the CDC counts people who died
within 14 days of an injection as “Unvaccinated”.

https://newsrescue.com/trust‐science‐cdc‐counts‐people‐who‐died‐within‐14‐days‐of‐jab‐as‐
unvaccinated/ 
 
55. The CDC quietly updated its 2019 Covid death numbers, admitting that only 6% of all the 153,504
deaths recorded were actually a result of the Covid Virus.

https://www.cdc.gov/nchs/nvss/vsrr/covid_weekly/index.htm?fbclid=IwAR2-
muRM3tB3uBdbTrmKwH1NdaBx6PpZo2kxot

56. In or about October 2021, U.S. Senator Ron Johnson revealed that about 63% of U.K.
deaths from the Delta Variant were fully vaccinated.

https://www.thegatewaypundit.com/2021/10/boom-sen-ron-johnson-drops-truth-
bomb-senate-floor-63-uk-delta-deaths-last-7

57. In or about September 2021, a group of German pathologists and scientists presented
findings from a first-ever comprehensive, independent set of autopsies of people who
had died unexpectedly within 2 weeks of the COVID vaccine injections. One pathologist
calculated that, for a certain broad age group, takers of the injections were 15 times
more likely to die from the injections than from COVID.
https://coronanews123.wordpress.com/2021/12/24/first-systematic-vaccine-death-
autopsies-show-immune-systems-attacking-own-organs/

https://pathologie-konferenz.de/en/

58. According to Osteopathic Physician, Dr. Joseph Mercola, the risks of serious reactions
and death are far greater in children than the Covid Virus, itself.

https://www.theepochtimes.com/more-children-die-from-the-covid-shot-than-from-
covid_4215381.html
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59. By about July 2021, the CDC’s Vaccine Adverse Effects Reporting System VAERS) showed that
reported injuries had already surpassed 400K.

https://www.theburningplatform.com/2021/07/03/latest‐cdc‐vaers‐data‐show‐reported‐injuries‐ 
surpass‐400000‐following‐covid‐vaccines/ 
 
60. As of January 2, 2022, the VAERS weekly “Red Box” Report VAERS reached the
unprecedented milestone of 1,000,227 injuries following coronavirus vaccines. In the 31-
year history of VAERS, there are 9,248 reports of fatalities following all other vaccines.
Since the start of the coronavirus vaccine campaign there have been 21,002 reports of
death following coronavirus vaccines. It is noted, too, that after approximately 26 reported
deaths the Swine Flu Vaccine was stopped.

https://openvaers.com/component/acym/archive/42-the-openvaers-red-box-
report?userid=41119-4pYaAeC5R0wuoB&tmpl=penVAERS

61. In or about December 2021, Dr. Peter McCullough shares that VAERS under reports for COVID
Vaccines by a factor of 4 to 5 times, even though a former Harvard study showed an accuracy
rate as low as 1%.
 
https://www.redvoicemedia.com/2021/12/shocking‐vaers‐data‐jab‐injuries‐deaths‐nears‐1‐million‐ 
  underreported‐4‐5x‐dr‐peter‐mccullough‐video/?utm_source=daily‐email&utm_medium=email 

62. In or about September 2021, a HHS ER physician discloses in an undercover video that the
government does not want to disclose either the content or the side effects of the vaccines.

https://www.projectveritas.com/news/federal‐govt‐whistleblower‐goes‐public‐with‐secret‐recordings‐
government/ 

63. In or about August 2021, Covid vaccine maker Moderna received 300,000 reports of side
effects over a three-month period following the launch of its vaccine, according to an
internal report from a company that helps Moderna manage the reports. That figure is far
higher than the number of side effect reports about Moderna’s vaccine publicly available in
the federal system that tracks such adverse events.

https://alexberenson.substack.com/p/some‐actual‐news  

64. As of January 2022, VAERS Injury and death reports eclipsed one million.

https://www.redvoicemedia.com/2022/01/vaers‐reports‐jab‐injuries‐deaths‐pass‐
1000000‐safe‐effective‐narrative‐in‐shambles 
 

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IN RELATION TO DEFENDANT VACCINE MANUFACTURERS: THEIR TRIALS, OFFICERS,
DIRECTORS & CONSPIRATORS

65. In or about spring 2021, doctors testified before a Texas Senate Committee that Phase
II Trials were abandoned once it was determined that most, if not all, test animals were
dying after receiving the vaccine and later exposed to the natural virus.

https://authentictexan.com/doctor‐covid‐vaccine‐dangers‐texas/?fbclid=IwAR0o0Cnwt5GbGkEOFPt 
8bafw5rqdvYDNX7CvEJR_ugrsSmQLkxcOfR5ypsQ 

66. In or about November 2021, a federal district judge rejects DOD claim that the Pfizer
EUA and Comirnaty Vaccines are the same.

https://childrenshealthdefense.org/defender/judge-allen-winsor-pfizer-eua-comirnaty-
vaccines-interchangeable/

67. In or about August 2021, Dr. Robert Malone explains precisely how the Pfizer EUA and BioNTech
Comirnaty Vaccines are NOT the same, contrary to efforts of HHS to claim “FDA Approval”
essentially applicable to the EUA.

https://www.thethinkingconservative.com/dr-malone-sounds-alarm-on-liability-coverage-of-
pfizer-vaccine/

68. Multiple reports show that Pfizer has taken a number of liberties with its trials in
violation of the rigid guidelines each trial is required to follow:

https://www.bmj.com/content/375/bmj.n2635

https://ifunny.co/picture/dr-benjamin-benulis-dr-benjaminbenulis-today-the-fda-
announced-they-Vbbj6Z7s8

https://globalcovidsummit.org/news/pharmacological‐scientist‐hong‐reviews‐whistleblower‐claims‐on‐
the‐pfizer‐covid‐vaccine 
 
https://t.me/angiefarellamd/152 

69. Dr. Byrum Bridle, Immunologist at Quelph University, discovers that Pfizer had withheld
disclosure of its Biodistribution Study until forced to share it with Japanese officials who
insisted on seeing it.

https://video.foxnews.com/v/6266459580001#sp=show-clips

70. On or about October 2016, Defendant National Institutes of Health, together with other
interested parties, filed for US Patent WO/2018/081318 to create an injectable
compound to cause the recipient to produce prefusion coronavirus Spike proteins. This
injectable is known as the “Moderna Covid 19 Vaccine”. A recently disclosed 2015,
heretofore ‘Confidential’ Agreement between the NIAID and Moderna, show that the
two jointly owned the vaccine when at the same time sharing the dataset with UNC’s Dr.
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Ralph Baric.

https://www.huffpost.com/entry/fauci-warned-of-trump-pandemic-
2017_n_5e8a0548c5b6e7d76c65c8a4

https://www.facebook.com/messenger_media/?thread_id=100000487501154&attac
hment_id=946698959307298&message_id=mid.%24cAABa830dDwuDmXPbjl9aC6Sj
cEzq

71. Said Moderna Covid 19 Vaccine contains SM-102 (also Luciferase), which is a known
poison fatal to humans and animals as disclosed in Moderna’s Food and Drug
Administration’s published ingredients list. See (list of ingredients and toxicity report
for SM-102):

https://www.fda.gov/media/144638/download

72. In 2015 appeared a heretofore confidential agreement between the NIAID and Moderna
proving joint ownership of the Coronavirus mRNA vaccine, the same vaccine that the
NIAID, it’s parent HHS, and its co-affiliates the CDC and FDA have been aggressively
promoting to the public.

https://www.facebook.com/messenger_media/?thread_id=100000163206094&attac
hment_id=611712543414486&message_id=mid.%24cAABa80qhcaeEE_Um7194q_hZ
rAoV

73. In or about January 2022 it was discovered by physician and Senator Roger Marshall, R
-KY, that Dr. Anthony Fauci had been deceitful in his public financial disclosures.

https://www.foxnews.com/politics/fauci-financial-disclosure-senator-publishes-accuses-biden-
advisor-misleading

74. Moderna and Pfizer mRNA Covid 19 Vaccines are designed to cause the human
recipients to mass produce Corona Virus Spike Proteins through messenger RNA
stimulus; such Spike Proteins are known to cause acute cardiovascular disease,
inflammation and / or blood clotting.

https://www.salk.edu/news-release/the-novel-coronavirus-spike-protein-plays-
additional-key-role-in-illness/

https://www.theepochtimes.com/nearly-800-reports-of-heart-inflammation-after-
covid-19-vaccination-in-
us_3853032.html?utm_source=News&utm_medium=email&utm_campaign=breaking-
2021-06-10-
2&est=%2BTD6%2FBVIpHak5N1LZ8rHTNKrO7l8aQilGowarvHQ2nmnffCC2slU4Xms
pqy1

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75. Animal testing conducted with the Moderna Covid 19 mRNA Vaccine was undertaken in
2012, which included a “Challenge” study whereby inoculated animals were exposed to
the SARS-Cov-2 virus (later called “Covid 19”) and in eachand every instance, the test
animals developed Pulmonary Immunopathology causing a 100% fatality rate. The
conclusions of various scientific journals opine that the deaths of the test animals were
not caused directly by the vaccine; rather they were caused by the test subject’s immune
response of Spike Protein creation from the changes made to the animals’ immune
system by virtue of the messenger RNA in the Vaccine. See:

https://varjager.wordpress.com/2021/01/30/dr-lee-merritt-in-animal-studies-
after-being-injected-with-mrna-technology-all-animals-died-upon-reinfection/

http://www.uphs.upenn.edu/cep/COVID/mRNA%20vaccine%20review%20final.pdf;

https://www.lewrockwell.com/2021/04/no_author/dr-lee-merritt-in-animal-
studies-after-being-injected-with-mrna-technology-all-animals-died-upon-
reinfection/

76. Thirteen (13) people died in the Moderna human clinical trials as a result of the said
enhanced autoimmune response, which is beyond the industry standard threshold of
continued development for marketable use. See

https://principia-scientific.com/13-people-died-during-modernas-covid-vaccine-
trial/

77. All of the Vaccines produced by the Defendant manufacturers (Johnson & Johnson,
Moderna, Pfizer and Astra Zeneca) caused the same immunopathological response in
their animal challenge tests conducted years in advance of the Emergency Use
Authorization and all experienced up to a 100% fatality rate in their challenge studies.
Furthermore, the science was so dispositive that on or about January 25, 2021, Pfizer’s
former Chief Science Officer (Dr. Michael Yeadon) warned
“Governments are lying because they are going to kill you and your family.” See:

https://www.cdc.gov/vaccines/covid-19/info-by-product/pfizer/reactogenicity.html

78. All of the Defendant manufacturers knew, or should have known, that their Vaccines
caused this immunopathological response and were warned by the FDA against
conducting human trials. See:

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7162764/

79. On or about April 20, 2012, the Federation of Registration Agencies (DOI) publisheda
report that analyzed all of the mRNA vaccines at the time and arrived at the conclusion
that each such injection presents a near certainty that all SARS Coronavirus vaccinations
lead to Pulmonary Immunopathology upon challenge of the user; meaning that the
inoculated person or animal will die when exposed to the virus or (relative thereto)
being vaccinated against. This peer-reviewed, common conclusion of scientists
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responsible for registration of vaccines arrived at this conclusion more than 8 years in
advance of the release, distribution and sale of the Covid Vaccines.

https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0035421

80. At all material times Defendants Fauci, Birx, Gates, Tedros, Baric, Daszak and others
were acting in their official capacities and had the authority to represent the interestof
and contractually bind the institutions or entities by whom they were employed or
compensated.

81. At all material times, Defendants Fauci, Rothschild, Gates, Baric, Daszak, NIH, CDC, WHO
and other named and unnamed Defendants had economic interests in the intellectual
property rights of the Covid 19 Virus or the various Covid 19 Vaccines or both and
conspired to economically benefit from the exploitation of these bio- weapons.

https://www.niaid.nih.gov/research/anthony-s-fauci-md ;

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2866602/ ;

https://fort-russ.com/2020/04/breaking-kennedy-exposes-dr-faucis-role-in-
creating-highly-infectious-mutant-strain-of-coronavirus/

PUBLICLY AVAILABLE OPINIONS of MEDICAL DOCTORS and BIO‐SCIENTISTS

82. Medical Doctors and scientists in the biological health and treatment of human beings
attest to:

a) the fatality rate of the SARS-COV-2, also known as COVID-19, virus (hereinafter
“Virus”) is .0046% across combined age groups under age 70 in the United
States:

https://www.cdc.gov/coronavirus/2019-ncov/index.html

b) the case fatality rate was purposefully inflated by Defendants World Health
Organization, Centers for Disease Control and Prevention, The National
Institutes of Health or any other governmental or non-governmental agency or
entity acting with authority to make such a declaration:

https://www.cnsnews.com/article/washington/melanie-arter/cdc-director-i-
think-youre-correct-about-inflated-covid-death

c) there are widely available and extremely effective therapeutic medicines,

inclusive of hydroxychloroquine and ivermectin, that both prevent and treat
said Virus:

https://pubmed.ncbi.nlm.nih.gov/32283237/
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d) Defendants named herein caused people, entities, organizations and health care
services to avoid the use, prescription and delivery of said therapeutic
medicines to patients and the public at large and caused the therapeutic
medicines to be unavailable to infected individuals and the public, resulting in
large numbers of unnecessary injuries and deaths in those that were infected
with the Virus:

https://noqreport.com/2021/05/31/dr-pierre-kory-exposed-whos-
suppression-of-ivermectin-youtube-keeps-deleting-this-video/

e) credible evidence exists to support a conclusion that interested parties and

stakeholders disregarded scientific data and alternative, efficient therapies to
coerce people and entities to require COVID-19 injectables as a condition of
employment, entry to properties, purchase of goods and services and admission
to gatherings:

https://stateofthenation.co/?p=64361

f) the Defendant manufactures of the four “COVID-19 Vaccines” identified herein,

have attempted and failed to create a messenger RNA styled vaccine that is
suitable for sale or distribution due to safety concerns, fatalities and morbidities
experiencedduring both animal and human trials despite more than 10 years of
testing:

https://edition.cnn.com/2020/09/01/health/eua-coronavirus-vaccine-
history/index.html

g) the Defendants, manufacturers and other participants, were warned in multiple

scientific and media papers that mRNA designed to increase spike protein
production is and was hazardous to the users’ autoimmune systems:

https://principia-scientific.com/halt-covid-vaccine-prominent-scientist-tells-
cdc/

h) the mRNA and adenoviral injections all code for the original spike protein that
was the product of Gain of Function (hereinafter “GOF”) research in Wuhan,
China:

https://childrenshealthdefense.org/defender/covid-vaccine-spike-protein-
travels-from-injection-site-organ-damage/

i) this laboratory engineered spike protein component created in Wuhan, China is

intentionally caused to be produced in humans via the subject COVID-19
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injections. Furthermore, said spike protein was intentionally modified at the
furin cleavage site of the protein, making the spike protein elicited to be
produced in the body by the COVID-19 injections far more dangerous and
infectious to the human body than the original spike protein created in Wuhan,
China:

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7859469/

j) the spike protein elicited to be produced by injection of the purported COVID-19

“vaccines” has intentionally placed sequences of RNA that code for known
epitopes of the HIV virus:

https://www.thegatewaypundit.com/2021/06/caught-top-official-thanks-dr-
fauci-email-april-2020-insisting-covid-19-naturally-occurring- men-knew-lie/);

k) once administered to humans, all COVID-19 injections cause the human body to
produce the modified Wuhan spike protein product of Gain of Function (“GOF”)
research in an uncontrolled fashion for as long as two weeks with no regulation
mechanism for 1) the concentration of spike protein, 2) the tissues or locations
in the body where it is created, 3) its distribution in the body, and 4) the duration
of itsability to be produced in the body:

https://www.pnas.org/content/117/41/25254

l) this Wuhan spike protein product of GOF research directly causes damage to
blood vessels and major organs, including the lungs, heart, brain, kidneys and
liver and directly promotes the development of blood clots in critical organs
resulting inpermanent disability and death in some cases:

https://drmalcolmkendrick.org/2021/06/03/covid19-the-spike-protein-and-
blood-clotting/

m) the United States mass vaccination program is investigational. Defendants,

either knowingly or with a duty to know and with a reckless disregard for
human life, committed egregious malfeasance that has resulted in harm to at
least hundredsof thousands and death to at least many thousands of people, in
failing to establish an external unbiased clinical event adjudication committee,
data safety monitoring committee, or human ethics committee. As a result, there
is no mechanism for risk mitigation in the investigational program (critical
event committee, data safety monitoring board, human ethics committee) and
this has contributed to causing the aforementioned injuries and deaths.
Remarkably, 46% of the deaths that have occurred following the injections have
taken place on days 1, 2 or 3 post injection:

https://www.wsj.com/articles/people-harmed-by-coronavirus-vaccines-will-
have-little-recourse-11602432000

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n) furthermore, in an act of egregious malfeasance, Defendants recommended
administration of the experimental injections in large patient groups that were
excluded from the registrational trials on the basis of either anticipated lack of
benefit or excessive harm, resulting in severe harm and/or death to at least
many thousands of people in these groups that were administered the
injections. These groups include: COVID-recovered, suspected COVID-
recovered, those with positive serologies, pregnant women, and childbearing
women who could not assure contraception. In fact, Defendants knowingly
administered the COVID-19 injections to individuals with durable natural
immunity due to prior infection with COVID-19, despite many known studies
spanning decades and demonstrating that these individuals were more
susceptible to serious injury from the injections:

https://www.thelancet.com/journals/langas/article/PIIS2468-
1253(21)00008-X/fulltext

o) intentional disregard of the results of the animal challenge studies which

resulted in up to 100% fatality rates, was egregious conduct under the norms of
the medical communities’ policies, procedures, ethical, licensing and other
mandates which govern such conduct:

https://foreignaffairsintelligencecouncil.files.wordpress.com/2021/02/horrific
-latent-deaths-predicted-among-the-elderly-by-genetics-professor-after-
immunization-with-rna-vaccines.pdf

p) Defendant Manufacturers knew or should have known their Emergency Use

Authorization would result in mass fatalities of the Users:

https://www.lifesitenews.com/news/vaccine-researcher-admits-big-mistake-
says-spike-protein-is-dangerous-toxin

q) Defendants threatened medical doctors who prescribed widely available, safe

and effective therapeutic medicines in furtherance of coercing the public to take
the COVID-19 injections:

https://www.reuters.com/article/us-health-coronavirus-usa-hydroxychloroq-
idUSKBN23B340

r) Defendants defrauded and coerced the public by knowingly failing to disclose

scientific study results and facts as well as knowingly disseminating fraudulent
information to the public:

http://amsterdamnews.com/news/2020/dec/24/why-black-people-cannot-
trust-pfizer-vaccine/

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s) Defendants failed to provide notice of risks and the right of informed consent to
the public (per Nuremberg Code):

https://pubmed.ncbi.nlm.nih.gov/33113270/

t) sufficient evidence exists to support a determination that: 1) a bioweapon in the

form of a spike protein created in Wuhan, China through GOF research was
releasedinto the civilian population; 2) for the purpose of or intent to cause a
demand for COVID-19 injections; 3) irrespective of or with intent to diminish,
disregard or subvert known and efficient, existing therapies; 4) with the intent
to cause harm or without regard to the consequences of harm that was known
or foreseeable to the users; 5) for purposes of injuring, harming, controlling or
killing the users; 6) while Defendant stakeholders enjoy and/or enjoyed
monetary or other economic, academic or political rewards.

https://thetruthaboutvaccines.com/stop-damage-mrna-vaccines/

CONCLUSION

The overwhelming sum of information presented herein, much of it incontrovertible,
offers more than sufficient probable cause to believe that one or more of the named
Defendants has committed the offenses alleged in this Criminal Complaint, specifically
mass murder through the commission of crimes against humanity. This complaint alleges
that some or all of the Defendants did knowingly, intentionally, with malice aforethought
and/or with reckless disregard for human life, some also in criminal conspiracy and others
of willful ignorance, engaged in acts that:

A) planned, coordinated, colluded and collaborated among two or more named and
unnamed Defendants to design a criminal enterprise, taking steps in furtherancethereof
for the purpose of:

1) creating the Covid 19 Virus as a Bio warfare weapon;

2) enhancing the efficacy of the virus to further infect, contaminate and transmit
among the global population for the purpose of killing human beings;

B) orchestrated and implemented fraudulent acts, statements, public service

announcements (PSA), publications, mandates and lockdowns in order to:

1) induce fear in and amongst an unsuspecting public, thus compelling compliance

therewith, including the public’s unwitting willingness to accept an injectable
bioweapon / gene-therapy veiled as a vaccine;

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2) diminish the knowledge, use and efficacy of existing therapeutic medicines for
the purpose of limiting perceived treatments to the “vaccines” and / or the
high-risk drug, Remsdesivir;

3) coerce, intimidate or force medical providers into compliance with non-

legislated regulations, thus limiting their treatment options for infected
patients, the consequences of which would often lead to hospitalization and
often death.

C) pre-planned the use and distribution of fraudulent, non-efficacious PCR tests for the
purpose of creating false positive results, false narratives, false pretenses and false
conditions about infection in order to terrorize, incite fear, intimidation and coercion in
the general population in support of their sales, marketing and distribution of deadly
Covid 19 Vaccines;

D) conceived, created, manufactured, sold and distributed deadly Covid 19 Vaccines forthe
purpose of stimulating a well-known and established hyper or enhanced immune
response in the victims and users of the experimental gene therapy injectables;

E) falsified data and reports in scientific and news media publications regarding thesafety
and efficacy of the Covid 19 Vaccines for the purpose of hiding the deadly effects of the
injectables;

F) conspired with and among the many named and unnamed Defendants to use theafore-
stated manipulation, tactics and coercion in furtherance of their economic benefit and
genocidal pursuits;

G) engaged in, conspired, coordinated and executed on this criminal homicidal enterprise
for their pecuniary, economic, academic and / or political benefit as a plan to infect,
inoculate and kill not less than 70% of the global population;

In particular, the evidenced elements of the crimes alleged herein are as follows:

A. CRIMES AGAINST HUMANITY (18 USC § 2441(d)(1)(c)):

i) The act of a person who subjects, or conspires or attempts to subject, one ormore
persons within his custody or physical control to biological experiments without a
legitimate medical or dental purpose and in so doingendangers the body or health
of such person or persons.

B. PROHIBITIONS WITH RESPECT TO BIOLOGICAL WEAPONS (18 USC §175(a))

ii) Whoever knowingly develops, produces, stockpiles, transfers, acquires, retains,

or possesses any biological agent, toxin, or delivery system for use asa weapon, or
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knowingly assists a foreign state or any organization to do so, or attempts,
threatens, or conspires to do the same, shall be fined under this title or imprisoned
for life or any term of years, or both. There is extraterritorial Federal jurisdiction
over an offense under this section committed by or against a national of the United
States.

iii) Whoever knowingly possesses any biological agent, toxin, or delivery systemof
a type or in a quantity that, under the circumstances, is not reasonably justified by
a prophylactic, protective, bona fide research, or other peaceful purpose, shall be
fined under this title, imprisoned not more than 10 years, or both. In this subsection,
the terms “biological agent” and “toxin” do notencompass any biological agent or toxin that
is in its naturally occurring environment, if the biological agent or toxin has not been
cultivated, collected, or otherwise extracted from its natural source.

C. GENOCIDE

iv) Whoever, whether in time of peace or in time of war and with the specific intent to
destroy, in whole or in substantial part, a national, ethnic, racial, or religious
group as such—

(1) kills members of that group;

(2) causes serious bodily injury to members of that group;
(3) causes the permanent impairment of the mental faculties of members of
the group through drugs, torture, or similar techniques;
(4) subjects the group to conditions of life that are intended to cause the
physical destruction of the group in whole or in part;
(5) imposes measures intended to prevent births within the group; or
(6) transfers by force children of the group to another group;
(7) shall be punished as provided in subsection (b).

D. WAR CRIMES AND CRIMES AGAINST HUMANITY (18 USC § 2442)

v) Whoever knowingly—
(1) recruits, enlists, or conscripts a person to serve while such person is
under15 years of age in an armed force or group; or
(2) uses a person under 15 years of age to participate actively in hostilities;

E. MURDER (18 U.S. Code § 1111(a))

vi) Murder is the unlawful killing of a human being with malice aforethought. Every
murder perpetrated by poison, lying in wait, or any other kind of willful, deliberate,
malicious, and premeditated killing; or committed in the perpetration of, or attempt
to perpetrate, any arson, escape, murder, kidnapping, treason, espionage, sabotage,
aggravated sexual abuse or sexual abuse, child abuse, burglary, or robbery; or
perpetrated as part of a pattern or practice of assault or torture against a child or
children; or perpetrated from a premeditated design unlawfully and maliciously to
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effect the death of any human being other than him who is killed, is murder in the
first degree.

F. ATTEMPTED MURDER (18 U.S. Code § 1113)

vii) Except as provided in section 113 of this title, whoever, within the special
maritime and territorial jurisdiction of the United States, attempts to commit
murder or manslaughter, shall, for an attempt to commit murder be imprisoned
notmore than twenty years or fined under this title, or both, and for an attempt
to commit manslaughter be imprisoned not more than seven years or fined
under thistitle, or both.

viii)CONSPIRACY TO MURDER (18 U.S. Code § 1117)

ix) If two or more persons conspire to violate section 1111, 1114, 1116, or 1119 ofthis
title, and one or more of such persons do any overt act to effect the object of the
conspiracy, each shall be punished by imprisonment for any term of years or for life.

H. ASSAULT WITHIN MARITIME AND TERRITORIAL JURISDICTION (18 U.S. Code §

113)

x) Whoever, within the special maritime and territorial jurisdiction of the United
States, is guilty of an assault shall be punished as follows:

(1) Assault with intent to commit murder or a violation of section 2241 or 2242, by a fine
under this title, imprisonment for not more than 20 years, or both.
(2) Assault with intent to commit any felony, except murder or a violation of section
2241 or 2242, by a fine under this title or imprisonment for not more than ten years,
or both.
(3) Assault with a dangerous weapon, with intent to do bodily harm, by a fine under this
title or imprisonment for not more than ten years, or both.
(4) Assault by striking, beating, or wounding, by a fine under this title or imprisonment
for not more than 1 year, or both.
(5) Simple assault, by a fine under this title or imprisonment for not more than six
months, or both, or if the victim of the assault is an individual who has not attained
the age of 16 years, by fine under this title or imprisonment for not more than 1 year,
or both.
(6) Assault resulting in serious bodily injury, by a fine under this title or imprisonment for
not more than ten years, or both.
(7) Assault resulting in substantial bodily injury to a spouse or intimate partner, a dating
partner, or an individual who has not attained the age of 16 years, by a fine under this
title or imprisonment for not more than 5 years, or both
(8) Assault of a spouse, intimate partner, or dating partner by strangling, suffocating, or
attempting to strangle or suffocate, by a fine under this title, imprisonment for not
more than 10 years, or both.

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I. FRAUD IN CONNECTION WITH MAJOR DISASTER OR EMERGENCY BENEFITS (18
U.S. Code § 1040)

x) Whoever, in a circumstance described in subsection (b) of this section,knowingly—

(1) falsifies, conceals, or covers up by any trick, scheme, or device any material fact; or
makes any materially false, fictitious, or fraudulent statement or representation, or
(2) makes or uses any false writing or document knowing the same to contain any
materially false, fictitious, or fraudulent statement or representation, in any matter
involving any benefit authorized, transported, transmitted, transferred, disbursed, or
paid in connection with a major disaster declaration under section 401 of the Robert T.
Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5170) or an emergency
declaration under section 501 of the Robert T. Stafford Disaster Relief and Emergency
Assistance Act (42 U.S.C. 5191), or in connection with any procurement of property or services
related to any emergency or major disaster declaration as a prime contractor with the United
States or as a subcontractor or supplier on a contract in which there is a prime contract with
the United States, shall be fined under this title, imprisoned not morethan 30 years, or both.

I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge and belief.

________________________ (signature)
Jack E. Boteler, Complainant, citizen and resident of Harris County in the State of Texas

Subscribed and sworn to before me at_______ _________(place), on this

day of , 2022

(Notary Public)

Signed:

Sealed:

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