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UNITED STATES DISTRICT COURTFOR THE DISTRICT OF XXJOHN SMITH #1, JOHN SMITH #2,*JANE SMITH #1, JANE SMITH #2*c/o Attorney XX.*XXXst*XX City**and**OTHER SIMILARLY SITUATED*INDIVIDUALS**Plaintiffs,**Civil Action No. 03-_______vs.**PRESIDENT BARACK OBAMA*The White House*20500 Washington, D.C.**and*DAVID NABARRO*UNITED NATIONS*760 United Nations Plaza,
*New York, NY 10017**and*DR. MARGARET CHAN*WORLD HEALTH ORGANISATION*Avenue Appia 20*1211 Geneva 27, Switzerland**and*KATHLEEN SIBELIUS*SECRETARY OF HEALTH AND*HUMAN SERVICES*200 Independence Avenue, S.W.*Washington, D.C. 20201,**and*JANET NAPOLITANO*DEPARTMENT OF HOMELAND SECURITY*1000 Defense Pentagon*Washington, D.C. 20301**and*DR. MARGARET HAMBURG*COMMISSIONER*FOOD AND DRUG ADMINISTRATION*5600 Fishers Lane*Rockville, Maryland 20857-0001,**
COMPLAINTA.
Plaintiffs, known as AA, BB and CC, #1 through #X, bringthis action on behalf of themselves and all other similarlysituated individuals, against the Defendants President BarackObama, President of the United States, David Nabarro, UNSystem Coordinator for Influenza, Margaret Chan, Director-General of World Health Organisation, Kathleen Sibelius,Secretary of Department of Health and Human Services (HHS),Secretary Janet Napolitano, the Department of HomelandSecurity, and Dr. Margaret Hamburg, newly confirmedCommissioner, Food and Drug Administration, seeking temporaryand permanent injunctive relief from the government, UN’s,WHO’s, DHS's and HHS’s swine flu and other pandemic fluvaccination or other medication programs, as well as adeclaratory judgment that those provisions of The Model StateEmergency Health Powers Act, the National Emergency Act,NATIONAL SECURITY PRESIDENTIAL DIRECTIVE/NSPD 51 and HOMELANDSECURITY PRESIDENTIAL DIRECTIVE/HSPD-20, InternationalPartnership on Avian and Pandemic Influenza, or any otherpresidential waiver or directive or international law or actthat abolishes or modifies the primacy of the US Preamble,Constitution and Bill of Rights, and restricts the civicrights assigned to citizens thereby, including militarypersonnel, to refuse a vaccination, classified as a bioweaponby the government’s own definition, and is being administeredto United States federal employees is in violation of federallaw. Plaintiffs seek this relief pursuant to theAdministrative Procedures Act, 5 U.S.C. § 551, et seq., theFederal Declaratory Judgment Act, 28 U.S.C. § 2201 and the AllWrits Act, 28 U.S.C. § 1651.PARTIES1. Plaintiffs are citizens of the United States of America,and have been instructed to submit to untested “swine flu” andother similar pandemic vaccines including “bird flu”, whichare classified by the US government as bioweapons, withouttheir consent pursuant to the Model State Emergency HealthPowers Act, National Emergency Act, NATIONAL SECURITYPRESIDENTIAL DIRECTIVE/NSPD 51 and HOMELAND SECURITYPRESIDENTIAL DIRECTIVE/HSPD-20, and the InternationalPartnership on Avian and Pandemic Influenza. Similarlysituated individuals including everyone whose currentresidence is the United States of America, who have beenordered, or will imminently be ordered, to take thevaccinations, classified by the US government as bioweapons,in the event of a pandemic level 6 being declared by the World
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