45K DEATH COUNT FROM COVID SHOT LAWSUIT
I. INTRODUCTION
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,”1 “Moderna COVID-19 Vaccine”2 and the “Johnson &
Johnson (Janssen) COVID-19 Vaccine”3 (collectively, the “Vaccines”) pursuant to their respective EUAs, and from granting full Food and Drug Administration (“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–
3(e), thereby enabling Vaccine candidates to give truly voluntary, informed consent
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