OFFICE OF INSPECTOR GENERAL

UNITED STATES DEPARTMENT OF HEALTH AND HUMAN SERVICES

THE DEMOCRATIC COALITION, )

SCOTT DWORKIN and )
J. WHITFIELD LARRABEE, )
COMPLAINANTS )
)
V. )
)
DONALD J. TRUMP, THE CENTERS FOR )
DISEASE CONTROL and The DEPARTMENT )
OF HEALTH AND HUMAN SERVICES, )
DEFENDANTS )
)
)
)

COMPLAINT

1. This complaint concerns steps taken by Donald Trump (“Trump”) to intentionally

prevent, slow, delay, hamper and obstruct testing for coronavirus (SARS-CoV-2) in the
United States during the present pandemic that have increased the number of deaths
caused by COVID-19.

2. Coronavirus testing delays have caused the United States to have the highest number of
COVID-19 cases and deaths of any country in the world. Presently over 2.36 million
Americans have been infected and over 122,000 Americans have died of COVID-19.
Intentionally delaying testing during this pandemic is mass murder, a criminal conspiracy
against the United States, violates the RICO Act and violates other state and federal laws.

3. The complaint concerns the Department of Health and Human Services (“HHS”) because
The Centers For Disease Control (“CDC”), an agency within the HHS, is responsible for
coordinating coronavirus testing in the United States. Trump’s statements suggest that
individuals at CDC may be involved in assisting Trump to slow coronavirus testing,
commit mass murder, conspiracy, wire fraud and other crimes.

4. On August 20, 2020 at a rally in Tulsa, Oklahoma, President Trump stated, in reference to
testing for coronavirus:

We've tested now 25 million people. It's probably 20 million

people more than anybody else. Germany's done a lot, South
Korea's done a lot. They call me, they say the job you're doing –
here's the bad part, when you test of – when you do testing to that
extent, you're going to find more people, you're going to find more
cases. So, I said to my people slow the testing down, please.
They test and they test. [emphasis supplied].
5. When later asked about this statement, a White House spokesperson suggested Trump
was joking.

6. On June 23, 2020, Trump disputed the claim that he was joking. "I don't kid," Mr Trump
told reporters as he left the White House for a trip to Arizona, again calling COVID-19
testing a "double-edged sword."

7. Trump’s tweet on June 23, 2020 suggests he prefers less testing.

8. Because of Trump’s public statements, it is necessary for the Inspector General to

investigate and determine whether Trump has directed or influenced any officials within
CDC or HHS to intentionally prevent, slow, delay, hamper and obstruct testing for
SARS-CoV-2.

9. If the Inspector General obtains information that any persons working for CDC or HHS
have aided, abetted, assisted or conspired with Trump or any other individuals to prevent,
slow, delay, hamper and obstruct testing for SARS-CoV-2, the Inspector General should
immediately issue a report exposing this to Congress and the American people. The
Inspector General should also refer the matter to the United States Department of Justice
so that the responsible individuals can be prosecuted for murder and for other crimes
against the American people.

10. Intentionally preventing, slowing, delaying, hampering and obstructing testing for
SARS-CoV-2 also violates statutes, rules, regulations, guidelines and laws governing
HHS and CDC.

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 WHEREFORE, the complainants respectfully request the Office of the Inspector General
to fully investigate the violations alleged in this Complaint and to institute appropriate civil and
criminal proceedings.

DATED: June 23, 2020

Respectfully submitted,
The Democratic Coalition,
Scott Dworkin,
by their attorney,

J. Whitfield Larrabee
891 Centre Street, Suite 200
Jamaica Plain, MA 02130
jw.larrabee@verizon.net
(857) 999-9894
BBO # 553499

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