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PETITION FOR TEMPORARY RESTRAINING ORDER
Plaintiffs bring before the Court today a request for a Temporary Restraining Order (“TRO”) against the U.S. Department of Health and
Human Services (DHHS), and the relevant subagencies and personnel including but not limited to the Food and Drug Administration (FDA), Centers for Disease Control and Prevention (CDC), National Institutes of Health (NIH), the DHHS Secretary, the DHHS Assistant Secretary for Preparedness and Response, and the DHHS Vaccines and Related Biological Products Advisory Committee, seeking temporary injunctive relief against any existing or further authorization for use in children under the age of 16, of any of the COVID-19 “vaccines”1 that have been approved under the Emergency Use Authorization (“EUA”) provided in 21 U.S. Code § 360bbb–3. In this Motion, Plaintiffs ask only that the status quo be maintained – that the EUAs not permit the use of COVID-19 vaccines in children under the age of 16, and that no further expansion of the EUAs to children under the age of 16 be granted prior to the resolution of these issues at trial. Such relief would protect the lives and safety of millions of children in the American public for whom serious illness and mortality from COVID-19 represent a zero percent (0%) risk statistically, but who face substantial risks from these experimental injections.